Document NOnK67awR5QNVRKYO3NQyyyQ

PPG INDUSTRIES, INC. INDUSTRIAL CHEMICAL DIVISION P. 0. BOX 1000 LAKE CHARLES, LA. 70602 February 4, 1985 Meredith N.Scheck The Vinyl Institute 355 Lexington Avenue New York, N.Y. 10017 Dear Ms. Scheck: Attached is my suggested comment to EPA's proposed revision of "ethylene dichloride purification". Please distribute this as appropriate. Respectfully, KSK/bh Kenneth S. Komoroski BR 012169 The proposed definition of Ml & Ct) Purification" is ambiguous and, since "Ethylene Dichlorid it has changed from th existing definition, indicates that different equipment than originally affected may now be subject to regulation. --Itt- particular, the--dwf-iwifcSrm--could aubjeet--crude--and product storage tanks to the emission limitations. The vinyl Institute supplied EPA with data on 10/30/84 which showed that storage tanks presented no significant source of VCM emissions and that costs to control these emissions would be extravagant. In the preamble, EPA stated that the proposed revision was intended only to clarify, but no discussion was made of additional equipment to be affected. Similarly, no mention was made of VCM emissions from additional equipment or the costs to control these emissions. EPA has in no way justified the inclusion of additional equipment by the proposed definition and the Vinyl Institute believes that no further controls are necessary. The existing definition of Ehtylene Dichloride Purification should remain mchanged/L _ & V iVi - Af'j it TertJsaA* ^ cc f l ^ 41> ^ j' AMLh j b{ fraffmt is &PA h j..i0 j CCjUip 04 SlwdLi dab cf. t*- *ruc \Juttj 4a t**** subj<^- ' ^ vLUrprcUv- rJU| nLxL-.A-, aJ suhd-xuA-, BOR 012170