Document YzkLzLOxjXeR6B51E642k5g0

wO*PM . KCWUCA JCAOMC M HCCXMAM c*AfQlCfl M. NeCMAM WlbUAM H. BOffOMCSANI. J*. B TlCttNAH MALCOLM O HACABTHUB MATMC V. BUCK MABTIN W. BCBCOViCI ,OHN * fibOBBD CAttOLl e. NABB*9 N'CHACl * HOMONC L>BBY 9 I9COMON JOHN . 0UBCC* CMBlftT'NC A. MCAOmCM SM"L(T 9. ^LMIMOTO MCTfR w. c uCAu: wMVACACC B HAbBBlN otaOBAH 9hua r*iH*e* Z 99U9U* ABHCTT (QWAAO C. ROBWC* 9H(IU A, MILLAR ftWflftSLL h rox bSC M. WCIMCA TIMOTHY |MN <LCW( ftlNOCL MCklft* LAW* OFFICES Keller and Heckman 1150 17*" STREET. N. W. SUITE lOOO WASHINGTON, D. C. 20036 (202) 457- UOO April 15, 1983 To: SPI Vinyl Institute SPI Manufacturing Technology Committee Re: EPA Review of the Vinyl Chloride Standard Ladies and Gentlemen: Enclosed is a copy of comments filed with the Environmental Protection Agency (FDA) in response to a letter from the Agency dated February 25, 1983. The comments are in response to a revised report by TRW, Inc. and a draft "Chapter 6" which discusses plant parameters and regulatory alternatives. The comments reflect the work of the Manufacturing Technology Committee and your response to a draft letter previously circulated to the Vinyl Institute. The two enclosures to the comments are not included with this mailing. The first enclosure is a July 12, 1982 letter from The Society of the Plastics Industry, Inc. (SPI) to Don Goodwin at EPA presenting suggested amendments to the vinyl chloride standard. You should have a copy of that letter in your files. The second enclosure to the comments was a paper by B.C. Davis entitled "A Flare Efficiency Study," which was oresented at the AIChE March 1983 meeting in Houston, Texas. The paper, which was brought to our attention by John 3arr, summarizes the EPA study by John Zink Company which measured the efficiency cf flares and found if to be greater than 99+%. If you need copies of either enclosure or have any comments or questions, please feel free to contact us. VVC 000006886 Cordially yours, /^Xu- Peter L. de la Cruz