Document DM84rGQpEdV1xp9VLXqgNnBYn

minutes VINYL INSTITUTE MANUFACTURING PRACTICES COMMITTEE Innisbrook Tarpon Springs, Florida Wednesday September 11, 1985 1:00 p.m. Members Present (in whole and in part) W.C. Holbrook, BFGoodrich, Chairman N. Blackman, Borden C.A. Gellner, CertainTeed B. Reynolds, PPG R. Oubre, Dow J.T. Barr, Air Products and Chemicals J. Ledvlna, Vista J.W. Kachtick, Tenneco Polymers H. Waltemate, BFGoodrich (Guest) R.T. Gottesman, Vinyl Institute M.N. Scheck, Vinyl Institute ACTION ITEMS AGREED TO: I. Motion made by Kachtick, seconded by Blackman, and unanimously approved that The Manufacturing Practices Committee considered the proposed letter to Delaware State Rep. Mack and U.S. Rep. Carper responding to their January 1985 letters to the record on EPA's proposed NESHAPS on vinyl chloride and recommended that no letters be written at this time and that the VI Executive Board be so notified. 2. M. Scheck to monitor whether vinyl chloride is on the list of acutely hazardous substances being developed by U.S. EPA for use by state and local governments and keep committee apprised. 3. Barr to draft letter and circulate to committee that would be responsive to EPA*8 proposed regulations dealing with air emissions prior to biologic treatment or prior to discharge to water treatment facility. 4. VI staff to send letter asking for requests for VI Safety Award in time so that an award, if given, could be presented at the VI Annual Meeting. 5. Waltemate to determine who did the project dealing with mutual aid response teams relative to vinyl chloride and to send copy of project to VI staff. 6. M. Scheck to send two sets of committee labels to Barr. 7. Barr to draft document on "Do's and Don'ts of VCM Storage" for review by committee. THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 355 Lexington Avenue New York, N.Y. 10017 (212) 503-0600 Bor 007856 -2- Discussion of proposed letter to U.S. Rep. Carper and Delaware State Rep. Mack The committee discussed at length the contents of the proposed letter as agreed to in principle by the VI Board at its August 28 meeting. Gottesman reviewed the background of the development of the letter, including the views expressed by VI Board member Flammer at the VI Technical Committee meeting. The committee discussed what additional comments may be appropriate should such a letter be sent (a statement of who the Vinyl Institute is; a review of the meeting with Formosa representatives; history of industry compliance with current standard; industry's role in providing information leading to the publication of the new proposed standard; an explanation that the proposed rule is not a "reformat" of the existing standard; a review of EPA's study of gasholders and the safety problems associated with them) and whether VI member companies could expect to benefit from such a letter. The committee agreed that the ultimate objective of the VI is to have the EPA proposed rule move forward and to assure that the Agency's final rule not require the use of gasholder containment systems. Considering that the record on the proposed rule is officially closed (and considering that their letters were now several months old), it was decided that nothing was specifically to be gained relative to this objective by responding to Carper's and Mack's letters. Rather, it was suggested that any further contacts made with the EPA reiterate the VI views on the proposed rule and the desirability of moving the proposal forward. Lastly, the committee discussed what the appropriate steps may be should the final rule require gasholder containment systems. Accordingly, a motion was made by Kachtlck, seconded by Blackman, and unanimously approved that the Manufacturing Practices Committee considered the proposed letter to Delaware State Rep. Mack and U.S. Rep. Carper responding to their letters to the record on the January 1985 proposed rule on NESHAPS on vinyl chloride and recommended that no letters be written at this time and that the VI Executive Board be so notified. Discussion of Budget Issues Gottesman reviewed the resources expended to date on the committee's actlvltes related to the EPA proposed rule and legal expenditures made with respect to the NRDC v. EPA action. Gottesman also noted that at the direction of the Board each of the committee chairmen has been asked to review the expenditures of their committees to determine priorities and anticipated expenditures for the remainder of this fiscal year. EPA Guidance on. Federally Permitted Releases At the request of Ledvlna, the committee members discussed their interpreta tions of federal permitted releases. Reference was made to a letter distri buted prior to the meeting by Ledvlna prepared~by"JWtXItaiirN7"Hedeman (Director of the Office of Emergency and Remedial Response, USEPA) responding to a request for clarification of the reporting requirements under the Comprehen sive Environmental Response, Compensation, and Liability Act (CERCLA) as they applied to air emissions from a specific facility. As noted in the letter, EPA "has not yet determined a general policy with respect to Federallypermitted or continuous releases. Until a general policy is determined, the Agency will evaluate situations as they arise on a case-by-case basis..." BOR 007857 -3- Discussion of Other Federal Regulations/Legislation Barr reviewed CMA activities related to the issue of air emissions prior to biological treatment or prior to the discharge to water treatment facilities. Comments are due October 15; CMA has officially asked for a 90 day extension of the comment period. The conmittee discussed industry practices regarding collection and steam stripping of EDC streams and also discussed the appropri ateness of VI comments. Barr agreed to draft proposed VI submission which he will circulate to the conmittee members for their review. It was also noted by Barr that the drinking water proposed regulations are now in "red border review" and should be published in the near future. It was decided that the committee will consider the issue and possible VI comments when those proposed regulations are published. Safety Issues The committee discussed the VI Safety Award and its lack of coverage in the industry press. It was decided that VI staff would again canvass the members for nominations for an award in time for final review by the Board at its February meeting. It was agreed that the award should be given only where there has been a demonstrated benefit to the industry and that the award need not necessarily be an annual award. Holbrook led the committee in a discussion of activities that the committee could undertake in the safety arena. The comnlttee reviewed the proposals made to the Board last year and the reasons why the Board had not endorsed those proposals. Waltemate mentioned that a possible benficlal project might be a project on the handling and safety of vinyl storage. The committee discussed whether this would amount to an industry voluntary consensus standard. It was agreed that Barr would draft a paper on the "Do's and Don'ts of VCM Storage" by December 15 and that the committee and VI staff would review the proposed document. Waltemate also mentioned mutual aid response team program that had been created some time ago by unidentlfed source. He stated that he would look into this activity and notify Scheck of details. There being no further business, the meeting was adjourned at 4:00 p.m. Respectfully submitted, JtLLL^CtcCP/^CC<U C Meredith N. Scheck Bor 007858