Document KGaQDzreXeXeVYMVM3m5DZMnr

r and C^&fHICa^\ INC. RE UVED ESCAMBIA PLANT INTEROFFICE MEMORANDUM ,,AN UUj U J. T. BARR To: T. J. Regan Dote: 18 January 1980 From: L. W. Allen Re: Safety and EPA Expenses PVC Plant Copies: R- E- Jones R. E. Gilbert D. E. Hoffman R. L. Duggan 1. The following safety and EPA expenses are listed below for FY79. AREA $M Depreciation Sewer Repairs VCL Monitoring Breathing Air Stripping Column Maint. Thermal Oxydizer Maint. Relief Valve Maint. EPA Fill Water System Maint. Area Lighting Leak Patrol and Mask Repair OSHA Ladders and Platforms Gas Holder Maint. Safety Supplies and Training Environmental Services Effluent Chemicals Other Projects Fuel 238 32 38 5 45 20 ' 19 7 5 40 11 57 5 164 20 22 14 $742M 2. EPA and OSHA regulations have resulted in a loss of production amounting to 5.48MM (1230P) pounds per year. a) Steam Sweep (1230P) 2MM lbs. - N/L 1MM lbs.- - S/L b) Column Boil-Outs (1230P) 700.000 lbs. - N/L 140.000 lbs. - S/L c) General Maint. (1230P) 320.000 lbs. Reflux Cond. 320,000 lbs. Seal Changes 1 MM Misc. Welding Repairs 1.640M AP00025526 I/ T . J. Regan 18 January 1980 Safety and EPA Expenses - Page 2 PVC Plant 3. Steam usage (# Steam/#PVC) of Batch Stripping versus continuous Stripping a) Batch Stripping - 0.788 #Steam/ffPVC b) Continuous Stripping - 0.418 # Steam/#PVC LWA:bg L. W. Allen AP00025527 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 7 1975 1976 1977 1978 1979 .9 4.8 1.5 6.1 2.2 7.6 2.2 8.5 2.8 11.9 1.4 4.1 2.3 1.9 4.3 3.4 2.6 5.3 4.8 6.1 9.7 8.3 10.4 ' 19.5 13.2 8.9 10.4 12.9 18.3 31.5 AP00025528 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 80% 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 New York, New York 10017 (212)573-9400 AP00025529