Document RaxX97Op5EmGYeGGzZ72Zvn9E

The Vinyl Institute. \ \I IMPORTANT TO: Umion of The Society of The Plastics Industry, Inc. Health Safety & Environment Committee Jan. 9, 1990 RE: Janaury 22, 23 and 24 Meetings The Agenda for the Health, Safety & Environment Committee meeting for Janaury 23, 1990 is attached. As previously notified, this meeting will be at the: Orlando Marriott Hotel 8001 International Drive Orlando, Florida 32819 (407) 351-2420 TWO IMPORTANT CHANGES HAVE BEEN MADE THAT MAY AFFECT YODR CALENDAR. 1. JANUARY 22 - FO 24 Issue A meeting of the FO 24 Task Force has now been scheduled for Monday, Janaury 22, 1990 beginning at 2 p.m. This meeting will also be at the Orlando Marriott. Comments submitted to EPA by member companies on the Land Disposal Restrictions for Third Scheduled Wastes Proposed Rule note substantial problems exist for those of you that classify any wastes as FO 24. The Task Force will discuss the issue and develop a strategy on how to proceed with any joint industry activity, such as a meeting with EPA. If this issue is important to your company, please attend or invite the appropriate person to represent your company at this meeting. Please let me know if you will be attending or sending a representative. 2. JANUARY 24 - Meeting with Contractors Doing Study for Canadian Ministry of the Environment At the suggestion of Jim Lewis and W.C. Holbrook of BFGoodrich, and with the agreement of Committee Chairman Frank Borrelli, a special meeting has been scheduled for Wednesday, January 24, beginning at 9 am and running through noon. Many of you have previously been contacted directly by contractors (O'Connor Associates Environmental and Radian) who are carrying out reviews of comparative VCM Emission levels and emission control technologies for vinyl companies that a seeking construction project approval. The purpose of the review is to develop a "Level 1" analysis of "Lowest Achievable Emission Rate (LAER) and "Best Available Control Technology"(BACT). They have been seeking information on: Wayne Interchange Plaza II 155 Route 46 West* Wayne, NJ 07470 (201) 890-9299 Fax #(201) 890-7029 CTL019263 VCM emission and ambient air standards in various government jurisdictions (including the U.S.) VCM emission levels (from PVC plants) that represent existing plant performance general control or process strategies/methods that are used to achieve plant emission levels Ambient air (or fenceline) VCM levels. W.C. Holbrook and Jim Lewis have asked that you come to this meeting prepared to discuss the above items in detail. Specifically, they have asked that you bring with you two copies of your existing permits to share with the company representatives/ contractors. If you have any questions about this part of the program, please call either W.C. Holbrook at 216/447/7925 or Jim Lewis at 216/447-7979. I will, of course, also be happy to answer any questions. Please let me know if you will be attending this meeting. Meredith N. Scheck Assistant Director CTL019264 agenda $\ "W-- VINYL INSTITUTE HEALTH, SAFETY & ENVIRONMENT COMMITTEE Orlando Marriott 8001 International Drive Orlando, Florida 407/351-2420 Tuesday January 23, 1990 9^ ' I. Opening of Meeting and Self-Introductions II. Approval of Minutes of September 27, 1989 III. Dutch Study on PCDD's PCDF's from the Oxychlorination Process (Will be sent in mail with mail copy of Agenda) Group Group Holbrook IV. F024 Subcommittee Report/Strategy V. Fugitive Emission Follow UP VI. Waste Minimization Task Force VII. SARA 313 Report and Zero Discharge Goal VIII .Activity on East Coast Rail Safety IX. New Jersey Labeling Update Lewis Group Ledvina Scheck & Group Borrelli Group X. Louisiana Water Regulations XI. NESHAPS - inprocess wastewater (40CFR61.65 (b)(9)(i) as it applies to VCM/EDC plants Borrelli Ledvina XII. VI Annual Safety Award and VI Environmental and Safety Recognition Scheck XI11.Enforcement Update Group IX. Request from Occidental - test data on resin/ Group leachates (letter of request being sent under separate cover) XV. New Business XVI Next Meeting CTL019265 BFGoodrich The BFGoodrich Company Geon Vinyl Division 6100 Oak Tree Boulevard Cleveland, Ohio 44131 216-447-6000 December 1. 1989 Ms. Meredith Scheck The Vinyl Institute Wayne Interchange Plaza 155 Route 46 West Wayne, NJ 07470 II Dear Meredith: It seems appropriate that the attached be sent to the Vinyl Institute Safety, Health and Environmental Committee members prior to our January meeting and this topic be on our meeting agenda. Sincerely THE BFGOODRICH COMPANY Geon Vinyl Division WCH/kp DOC403 Attachment. W. C. Holbrook Director, Environmental Affairs CTL019266 y, \ cISShWDERLO - BELGIUM *0 Cate 06/11/1989 In :ai you did hot receive all pages, please contact Mia or Lieve ' (tel. C13/66.61. Adresaee F.a.o. Pages (incl. this page) W. BORMANS BFGOODRICH / Cleveland 0012164476172 Mr. Lee M. PUCXETT Director of Licensing & International Manufacturing Support 2i Dear Lee, ' R t PCDD's and PCDF's formation in oxychl tination Enclosed, all the information we received about the subject, together with the covering letter. Quote "SOU 14 CATALYTIC OXYCHLORINATION PROCESSES OF ALIPHATIC HYDROCARBONS AS NEW INDUSTRIAL SOURCES OF PCDDs AND PCDFa. E.H.G. Evers*, M. Buring, M. Slie and H. Gpvprs, Laboratory of Environmental and Toxicological Chemistby, University of Amsterdam, Nieuwe Achtergracht 155, 1018 W7 Amsterdam, The Netherlands. j in the last few years extensive sediment I and waste water monitoring studies in the river Rhine area'have been performed with special attention to industrial eourcea of PCDDs and PCDFa. From these studies it was concluded that hitherto not recognized industrial sources contributed significantly to th pollution of the Dutch river delta with these compounds. The PCDD/PCDF isomer patterns and spatial variations of their relative levels indicated vinylchloride momomer (VCM) production as a principal source for PCDDs and especially PCDFs. Analysis of process and waste water, sampled at variduq points in the VCM production process confirmed these indications. The crucial step was found to be the oxychlorination of ethylene to 1,2dichlorocthana catalysed by alumina~CuCla at 250 - 3QQ"C CTL019267 ! Adresaee F.a.o. BFGOOORICH / Cl v land 0012164476172 1 t Hr. Lee H. PUCKETT Director of Licensing .& international Manufacturing Support j At the laboratory the oxychlorination processjand the effect of various reaction parameters (catalyst content and pretreatment, temperature and input gas flows) on the formation of PCDDs, PCDFs and some precursors (polychlorinated biphenyls, -benzenes and -styrenes) was studied. It was established that transition metal halogenides play a key role in the high temperature formation of the ljalogenated dds and DFs and an attempt is made to elucidate thie major formation mechanisms. unquote i PleaBe let us know your comments a.a.a.p. Kind regards, W. BORMANS CTL019268 ECVM, 250 Avenue Louise, Box 122, B 1050 Bruxelles, Belgien . att. Mrs. N. Ru s o 11 o, Oere* ref. Oeres brev if ASSOCIATION OF PlAStICJ WANUFACTUMFI IN IUAOF1 Vor rat. f Ph Oslo 11* 10 PVC discussion - Denmark. In an abstract from Dioxin 89 (Toronto) reference is made (Sou 14) to a paper by Evers, Buring, Olie and Covers from La boratory of .Environmental and Toxicological Chemistry, University of Amsterdam Catalytic Oxychlorination Process of Aliphatic Hydrocarbons aa New Industrial Sources of PCDDs and PCDFa Comments contained in this paper are now used by the Danish Environmental Protection Agency aa yet an argument against the use of PVC. I am sure that our industry has already studied the mentioned paper and that comments to its conclusions have been formulated. To help us in our future discussions with the EPA would you kindly let us have your comments to the enclosed abstract. F, Ring Hansen AT?ME CA.'IMASK co Norsk Hydro Indujfrfens Hu) '.!c!*,tro;i<;* 1 C rx If2f K it navn V CTL019269 Tefefon: 01 11 48 88 Telegrsm: narskhytfro Telex: 15859 Telefax; 01 32 11 90