Document XzbE6OqJGgaQLoxdeQ2opGOYw

u, JOSEPH E. KELLER JEROME H, HECKMAN CHARLES M. MEEHAN WILLIAM H. SOROHESANI. JR, ROBERT R. TIERNAN MALCOLM 0- MACARTHUR WAYNE V, BLACK OAVIO L. HILL MARTIN W. BERCOVICI JOHN $. ELOREO CAROLE C. HARRIS MICHAEL F. MORRQNE LARRY 5. SOLOMON JOHN B. DUBECK LAW OTTICZS Keller and Heckman USO 17** STREET, N, W. SUITE lOOO CHRISTINE A. MEAGHER SHIRLEY S. FUJIMQTO PETER L. at la CRUZ LAWRENCE P. HALPRIN DEBORAH SHUR TRINKCR C. OOUGLAS JARRCTT EDWARD L. KORWEK ROBERT L. FLESHNER inuiTutu 0 i ru|N WASHINGTON, D. C 20036 (203) 497*1100 RECEIVED St? I 0 133. ft. W. Laundrie September 3, 1982 vc TELECOPIER (202)296-7682 WRITER'S DIRECT DIAL NUMBER (202) 457-me TO: SPI pvc Safety Group SPI PVC Manufacturing Technology Committee Re: EPA Review of the Vinyl Chloride Standard Ladies and Gentlemen: We have received a response from the Environmental Pro tection Agency (EPA) to our letter of July 12, 1982, suggesting several amendments to the vinyl chloride standard. A copy of EPA's letter is enclosed. The letter will be discussed at the Manufacturing Technology Committee's meeting on September 14, 1982. EPA was not receptive to the suggestion that the term "malfunction" be substituted for the term "emergency" in characterizing permissible relief valve discharges. Obviously. this is the most difficult section to negotiate and will need fjar-o-hn-i:ace discussions with EPA. The Agency, however, was interested in a suggestion that discharges of less than 100 pounds be exempted. While the EPA staff has a number of ques tions, it appears that they can be readily answered. As reported previously, EPA agrees that relief valve discharges should be reported on a semi-annual basis. We expect this to be accomplished through the use of section 114 letters to individual firms establishing a semi-annual reporting period. Any subsequent rulemakings would presumably codify this change. EPA characterized the daily analytical compositing of stripping samples as reasonable but was concerned with the specification of an analytical procedure. The Agency asked for suggestions on a recommended procedure. Similarly, the Agency seemed responsive to a suggestion that emission monitoring span GENC 014176 September 3, 1982 Page 2 Keller lnd Heckman checks be conducted on a weekly rather than daily, basis. EPA asked for some justification in terms of the time need for daily span checks and how much reliability would be lost if the frequency of calibration was changed. Finally, EPA appeared willing to make some changes to the general provisions of the hazardous air pollutant regulations. Modification of the general provisions would be responsive to a suggestion by the Group, that the new source regulations be amended to avoid duplicative permitting requirements. After the September 14 jneeiiina of the Manufacturing Technology Committee,)a meeting will probably be arranged with EPA on this matter, fin the interim, if you have any comments or questions, please/feel free to contact us. Cordially yours. fa. Peter L. de la Crua-'' Enclosures ^ & spj: % GENC 014177