Document B8XQ906NGQg7nR70wYjzgJNjL

JOSEPH E. KELLER JEROME H. HECKMAN CHARLES M-MEEHAN WILLIAM H. BOROHESANI, JR. ROBERT R, TIERNAN WAYNE V. BLACK DAVID L, HILL MARTIN W, BERCOVICI PETER M- NEMKOV JOSEPH E HADLEY, JR. CAROLE C- HARRIS PETER THOMAS SMITH MICHAEL F MORRONE LARRY S. SOLOMON John b, dubeck CHRISTINE A. MEAGHER SHIRLEY S, FUJIMOTO LAW OFFICES Keller and Heckman 1150 17IF STREET, N.W. SUITE lOOO WASHINGTON, D.C. 20036 December 6, 1977 RECEIVED DEC 8 1977 R. N. WHEELER, JR. TELEPHONE 303 437-1100 CABLE ADDRESS "KKLMAN" writers direct dial number (202) 457-1116 Re: SPI-PVC Safety Group SPI-PVC Manufacturing Technology Committee SPI-PVC Health Committee SPI-PVC Communications Committee SPI-PVC Lawyers Subcommittee Gentlemen: Attached hereto is a letter from Harold Himmelman at Beveridge, Fairbanks & Diamond written to cover the Environmental Protection Agency's Draft Inspection Manual for Vinyl Chloride. Due to the technical nature and bulk of this docu ment, copies are being supplied at this time only to the listed Voting Representatives and members of the Manufac turing Technology Committee. Having received this document only late Monday afternoon, we are sending it out without having an oppor tunity to review it. As always, if before we report to you further about the Manual you have any questions, comments or suggestions with regard to it, please do not hesitate to let us know. Cordially yours. JLs Enclosures cc: (Without copies of Manual) Mr. William H. Bricker Mr. O. P. Thomas Mr. Richard Fleming UCC 103573 HCNftY L. DIAMOND RICHARD M. FAIRBANKS* Ut ALBERT J. BEVERIDGE, HI GARY H.BAISE A JAMES BARNES HAROLD HIMMELMAN CHRISTOPHER H. BUCKLEY, JR. KEVIN M.FOLEY JONATHAN Z.CANNON ANDREW E.MISHKIN Charles a. patrizia SCOTT W, BOWEN law offices Beveridge, Fairbanks & Diamond One Farragut Square South Washington, D. C. 20006 TELEPHONE (202) 938-7200 December 5, 1977 CARL EARDLEY OF COUNSEL CABLE ADDRESS "INDIA*" BY HAND Joseph E. Hadley, Jr. Keller & Heckman Suite 1000 1150 Seventeenth Street, N.W. Washington, D.C. 20036 Dear Joe: I am enclosing herewith the vinyl chloride field in spection manual which EPA's Division on Stationary Source Enforcement has asked me to distribute to the industry. You will recall from my September 29, 1977 letter that the field inspection manual was originally prepared in draft by Research Triangle Institute. The manual, as you know, will be used by EPA inspectors during on-site visits to VCM, PVC and ethylene dichloride plants. In addition to regional EPA offices and Research Tri angle Park, SPI is the only other party to have received a copy of this draft as of this time. The Division of Sta tionary Source Enforcement wants all comments on the draft submitted by January 6, 1978. Currently, the Division plans no hearings on the manual and hopes none will be necessary. However, should there be major areas in need of further dis cussion, there is some possibility that an informal hearing or meeting might be held. EPA hopes to make the field manual final, and to issue it, within two or three months. Although I am sure that the entire manual will be of extreme interest, I should report that SPI has been especially requested to review Chapters 2 and 3. Sincerely yours. HH:cl Enclosure cc: John R. Lawrence Robert Laundrie Harold Himmelman UCC 103574