Document YrrkMEvGepqngYXxB3DOK3qZk

minutes HEALTH. JOINT MEETING SAFETY & ENVIRONMENT COMMITTEE AND SAFETY SUBCOMMITTEE The Sheraton Music City 777 McGavock Pipe Nashville, Tennessee Wednesday January 25, 10:30 a.m. 1989 Attendees: Frank Borrelli, Georgia Gulf Bruce Brocka, CertainTeed W.C. Holbrook, BFGoodrich Company Jim Kachtick, Occidental Chemical Joe Ledvina, Vista Chemical Gabe Lefebvre, BFGoodrich Company Jack Lippman, Dow Chemical Cris Lunn, Borden Chemicals Bob Oubre, Dow Chemical Irv Power, Occidental Chemical Meredith Scheck, Vinyl Institute Opening of Meeting The meeting convened at 10:30 a.m. with Mr. Holbrook, Committee Chairman, asking for self-introductions. Safety Workshop Mrs. Scheck reviewed the discussions held at the December 15th Executive Board Meeting regarding the Safety Seminar concept. Mr. Lunn distributed a list of discussion items and the tentative outline for a pamphlet/brochure announcing the meeting. Following discus sions, action items agreed to were: A. Location: Wyndham Greenspoint Hotel Date: April 25, 1989 B. Hotel Requirements: Block of Rooms (50-100) Meeting Room Audio Visual (Overhead, video/monitor, slide projector/screen) Lunch 2 Coffee Breaks c- Panel Members: Lunn, Graybill, Lippman, Power and Holbrook to provide names and brief biographical sketch to Scheck by Febru ary 3rd. Power to include paragraph explaining morning presen tation. v -j; :,Je J Jws'cn c; 7he Society of ."e Plastics industry. Inc :-pr^e d 3J3 a j ,\est. Wayne, New Jersey 07470, (201) 890-9299 SL 089423 2- - D. Lippman agreed to moderate afternoon session and to arrange for video presentation in conjunction with the luncheon. E. Budget to be developed by VI to allow for project to be self-funded and supported by registration. F. Assessment sheet to be developed by Lunn/Scheck for development of report to the Board. Hazard Ranking System Mr. Holbrook introduced Mr. Lefebvre of the BFGoodrich Company, noting Mr. Lefebvre's involvement with activities of the Chemical Manufacturers Association on the Hazard Ranking System and related issues. Mr. Lefebvre noted on December 21st that EPA had published in the Federal Register regulations related to the National Contingency Plan and on December 23rd had published the proposed rule on the Hazard Ranking System. He reviewed CMA activity to date on both of these items and noted that the comment period on both items closes February 21st. Mr. Lefebvre noted that he has taken a lead role on the HRS Task Force and Mr. Holbrook reviewed the potential impact of the HRS proposed rule on his and other VI member companies (referencing such items as on site landfills and impoundments). Mr. Lefebvre urged those present to review the proposed rule to determine its impact on each of their facilities. He noted the current involvement on the CMA Task Force of representatives of 2 Vinyl Institute member compa nies (Dow and PPG), and noted his eagerness to have the input and involvement of others. In this regard, Mr. Lefebvre distributed four items he had prepared which Mr. Holbrook asked be appended to the minutes as follows - NCP Issues for Comments; Proposed Rule - NCP, comments being developed by CMA; Draft Comments on Hazard Ranking System; and Hazard Ranking System - Comments Requested by EPA. TCLP Update Mr. Ledvina stated that although he had been earlier informed that the TCLP would be finalized in March, that it now appears as though the date may be June. He commented further that he understood the vinyl chloride level being considered is 200 ppb. Mr. Holbrook commented on the impact of this item on surface impound ments. He noted that it is his understanding that it is in "red border review" by EPA and that publication could be anticipated as early as March. Mr. Holbrook noted that the effective date will be six months after promulgation. The committee had a round table discussion on current activity within member companies on impound ments and ponds. SL 089424 3- - Vinvl Chloride Standard Ms. Scheck noted that amendments to the standard implementing the provisions of settlement agreement in SPIv ERA have not yet been published, but noted that the Agency is required to file a monthly update with the court. SARA Mrs. Scheck distributed additional copies of the chart developed as a result of member company input. Mr. Ledvina offered to provide additional input gleaned from FOI requests and asked that Mrs. Scheck distribute this chart to all committee members. Mr. Holbrook asked for a roundtable discussion on the treatment of relief valve discharges under 61.65 and the definition of "otherwise federally permitted" vis-a-vis SARA's reporting provisions to the NRC. VI Awards Mrs. Scheck noted that forms for the VI Environmental Recognition and Safety Performance Awards along with the nominating ballot for the Annual VI Safety Award were mailed the previous day. Mrs. Scheck noted that the OSHA calculation sheets were the same as in past years and did not reflect discussions at the March 1988 Committee Meeting concerning incorporation of contract maintenance personnel. Mr. Lippman noted the procedures his company follows in dealing with and assigning responsibility for contract employees. Following a lengthy discussion on appropriate amendments to the Safety Award calculation to assure fair and equitable comparisons that would satisfy the varying practices and legal views of VI member companies, it was decided that the issue would be discussed at the Committee's next meeting. ADSTR Mr. Borrelli inquired as to the interest of VI involvement in providing comments on the second 25 draft toxicological profiles released by the Agency For Toxic Substances and Disease Registry and EPA. It was the consensus of the group that companies should provide appropriate input to the CMA (see attached memo on subject). OHEIC Mrs. Scheck inquired whether any member of the Committee wishes to serve as a VI representative to the SPI Occupational Health Environ mental Issues Committee. Members commented that they would be willing to participate on special task forces/projects of OHEIC and suggested that Mrs. Scheck attend the next meeting of the committee and provide some recommendations following that meeting. SL 089425 -4Next Meeting The next meeting is scheduled for May 8th in conjunction with the VI Annual Meeting, unless the Chairman decides that an earlier meeting is necessary. Following the May meeting, it was suggested that tentatively the next meeting would be during the last week of Septem ber . Mav 8th Agenda In summary, it was agreed that the agenda for the May 8th committee meeting would include: 1. Update on measurement of fugitive emissions, with presentations by Vista and Borden. 2. Review of criteria presently used in computing VI Safety Perfor mance Awards and discussion of appropriate changes to those criteria. 3. Update on labeling. There being no other business, the meeting adjourned at 3:00 p.m* SL 089426 NCP Issues for Comments 51407 51409-10 51413 51415 51415 51415 51416 51418 51418 51419 51419 51420 o Definition of "on-site" for permitting purposes. o Removal limitation implementation. I J06. ^'fSK'sTC/ o Deferral policy/remedial site evaluation pol i cyj sea. *jg (PA/SI). Aim- . -tL/. o Merits of creating a construction completion category for sites on the NPL. ^ o Whether deferra 1 should be extended to state authorities. * (tayt/tC///?) o Whether deferral should be extended to sites where PRPs enter into Federal enforcement agreements for site remediation. o Deferral policy.-, extension to other federal authorities. * yb/f* o The appropriateness of deferring generally to Federal authorities and whether these authorities should be required to meet some or all CERCI<A standards. \ o Comments on two state deferral options deferral based on State petition requesting deferral. 7U r Am*? facr/S-/ deferral based on states certification of its commitment and ability to address the site according to CERCLA standards. TAG grants public notice (public meeting) ' - ATSDR Non NPL listing for deferral sites 7 o Deferral policy - sites regulated by multiple authorities. ** o Deferral of sites with agreements under CERCLA enforcement authorities - 2 options ^ deferral prior to NPL proposal based on agreement to carry out EPA - RD/RA pursuant to consent decree. deferral at time of proposal based on agreement to conduct a RI/FS for that site, with the proposed sited dropped if PRP SL 089427 subsequently agrees to perform RD/RA pursuant^ to consent decree. ^4/17790* Appropriate method for identifying problem sites,] if those sites are not proposed for the NPL because of deferral to CERCLA enforcement agreement. Deferring placement of sites on NPL when other authorities a; available to address contamination at the site and deferring sites when PRPs have signed enforceable CERCLA consent\ orders. Deleting final sites based upon deferral to other authorities/criteria Risk ranges - two in particular current 10~ to.10 alternative 10 to 10" issues related to these or alternative ranges risk Potential advantages and disadvantages of alternative site-specific balancing approaches related to type of criteria considered steps for making statutory findings degree of proposed structure Two alternative approaches are site specific balancing with a costeffectiveness screen sequential decision making approach " Appropriateness and desirability of pursuing on of the following alternative strategies point of departure u site stabilization J06. 36 /'/v r f Aisveau Potential advantages and disadvantages of- the following analytical techniques screening against threshold criteria pairwise comparison ranking alternatives or criteria scoring (measuring alternatives against a consistent scale) weighting alternatives or criteria construction of a multi-attribute model SL 089428 731 51433-5 o Groundwater remediation approach ^ rr HE -v 51436 / o Criteria for ARARs 51439-40^ I o Waiver of ARARs interim remedy equivalent performance fund balancing - specific amount Where ARARs must and TBCs should be attaine Community relations/public comment Community relations during RD/RA phases Interpretation of "restore ground and surfac,e! Jwater quality" and on the merits of alternatives ERA has not adopted. 51454 Whether ten year situations where O&M rule should primary purpose extend to of ground watetj-o---o-y. treatment is to provide drinking water supplies / &/A4- f from water contaminated at the site without J 0*ff restoring it. I 51454 51455 Appropriateness of requiring regions to enter into SMOAs if states request them and have demonstrated capability to take the lead for response action. \ 51456 o Comment on criteria for state lead designation overall expertise legal authorities administrative and contracting capability financial management systems availability of general resources complexity of site availability of site-specific resources workload and expertise past Federal and State actions at the site past State cleanup activity (should other criteria be added?) "$1461 "51468 Subpart H comments consistency with NCP for private party cleanups 1 Should a notice of availability of administrative record or of commencement of public comment } fperiod be published in the Federal Register^ (administrative record for remedial action)" V /fc&sa'' fJ SL 089429 514 6 9 51469 70 51470 o Should public comment be solicite d on activit ies *that have already been completed at the time the record is made available? (administrative record for remova 1 action) o Comment on approaches to developing ,, administrative record for removal actions.* t o Comment on adding documents tourecord after selection of response action, v* / SL 089430