Document VG8Gwbq13ob8BErdEDvk0k4Qj

JOSEPH E KELLER JEROME H. HECKMAN CHARLES M MEEHAN william h borohesani, jr. ROBERT R TIERNAN WAYNE V BLACK david l hill MARTIN w BERC0V1CI JOHN S. ELDRED JOSEPH E HADLEY, JR. Carole c Harris MICHAEL F. MORHONE LARRY S. SOLOMON JOHN B. DUBECX CHRISTINE A. MEAGHER SHIRLEY S FUJIMOTO LAWRENCE P. HALPRIN DEBORAH SHIJK TRINXZR C.DOUGLASJARRETT LAW OFFICES Keller ajtd Heckman 1150 ITt* STREET, X. w SUITE lOOO October 25, 1979 TELEPHONE 302 457*UOO CABLE ADDRESS "EELMAIT WRITER'S DIRECT DIAL NUMBER (202) 457-1116 Mr. R. N. Wheeler, Jr. Union Carbide Corporation P. 0. Box 8004 S. Charleston, W. Virginia 25303 Dear Mr. Wheeler: Following up on our telephone conversations and John Lawrence's August 7, 1979 letter to Mr. S. M. Weiss of Cali fornia's South Coast Air Quality Management District (SCAQMD), we are enclosing herewith several copies of the survey results concerning residual vinyl chloride monomer levels in PVC sus pension resins for you to give to Mr. Weiss. As we understand it, Mr. Weiss asked SPI representatives for information about residual vinyl chloride monomer (RVCM) levels in connection with the development of SCAQMD Rule 1005.1, Standards for Vinyl Chloride. Mr. Lawrence, Technical Director of The Society of the Plastics Industry, Inc. (SPI) and SPI's staff representative to the PVC Safety Group, then wrote to Mr. Weiss on August 7, 1979 to inform him that, at that time, such information was not available but that a survey would be conducted to obtain these data for him. Accordingly, we were commissioned to conduct such a sur vey. As you are aware, the U. S. Environmental Protection Agency (EPA) has enacted a National Emissions Standard for Vinyl Chloride. 40 C.F.R. 61.60 et seq. (1976). Section 61.64 of that Standard which governs emissions from all PVC plants limits RVCM in PVC resin following the stripper to: UCC 033006 Mr. R. N. Wheeler, Jr. October 25, 1979 Page Two Keller and Heckman (i) 2,000 ppm for polyvinyl chloride dispersion resins, excluding latex resins; (ii) 400 ppm for all other polyvinyl chloride resins, including latex resins, averaged separately for each type of resin....40 C.F.R. 861.64(e) (1) (i) and (ii)(1976). Since this federal EPA Standard also requires that records of RVCM levels at this point in the process must be maintained (40 C.F.R. 561.70(c)(2)(1976)), this was the obvious choice for the point to which we would direct our survey. The survey, a copy of which accompanied Mr. Lawrence's letter to Mr. Weiss, was distributed to all members of The Society's PVC Safety Group. The membership of this Group re presents approximately 93% of domestic PVC resin production. We received survey responses representing nearly all companies and plant locations manufacturing PVC suspension resins. The data submitted are compiled in the attached report of the sur vey results. The only question in the survey not answered in the report concerns the time when furture expectations are fore casted to be met. Although the range of tiroes reported was from "no change expected" to "end of 1981," the "future" col umn could not be uniformly characterized because the responses were very mixed and fell randomly into two groups, viz. (1) by the end of the first half of 1980, and (2) by the end of 1981. We hope that both you and Mr. Weiss will find the at tached survey results to be informative and the foregoing de scription of why and how they were collected sufficient for your purposes. As always, however, should you have any addi tional questions, comments or suggestions with regard to any aspect of this matter, please do not hesitate to let us know. Cordially yours. Enclosure cc: Mr. John R. Lawrence i // Joseph E. Hadley, Jr. UCC 038001