Document a1kyEVJ4d1390XpNDywK6vJnX

* j \ a^clT^cxdtcii-or. J%erfticai- J( \ IHC. received INTEROFFICE MEMORANDUM J\PR0 Date 31 March 1975 y^V&ZTML Meeting, Arlington, Va. Apcl CHE LAW DEPT. on 25 March 1975 jo ______ T. L. Carey From J. T. Sarr Valley Forge (Location, Organisation, or Dpartmsnt) Valley Forge (Location, Organisation, or Department) cc: A. R. Adams A. J. Diglio R. Fleming A. K. McMillan J. T. Sebastianell Oones/Prlmeau Kramer/Speed Attached is a copy of the prepared statement by the technical committee of the SPI producers group that was presented 'to EPA and NAPCTAC on March 25th. Also attached is a copy of the agenda for that meeting, a description of the conmittee and its functions, together with a listing of the members. Those members who were present have been marked. The discussion on Vinyl Chloride was completed |on March 25th and not carried over to the 26th. ' i This presentation was prepared by the technical committee in several working sessions in Washington during the previous week, and reviewed by the SPI steering committee on March 20th, and then by the larger group of member company representatives on the 24th of March. The presentation generally was v;ell received and resulted in considerable give-and-take type questioning from the NAPCTAC and EPA representatives. Several points were conceded to the industry and, I believe that we made some progress in getting omitted from the pro posed standard a number of bothersome minor details such1 as connecting relief valve vents, flares, and some of the water regulations. It also appears that the dispersion resin industry will be granted a separate higher residual monomer concentration. \ Another visit is planned to Durham for sometime shortly after the next steering committee meeting which will be held in Washington on April 11th. Each company has been asked to submit its own detailed comments on the entire support document within the next week. The schedule planned by EPA still anticipates declaring Vinyl Chloride a hazardous substance and publishing the proposed standard by June 20th, with a public hearing to follow within 30 - 45 days. attachments (320) AP00027593 THE S IETY OF THE PUASTICi INDUSTRY. INC. 2SO PARK AVENUE NEW YORK. NEW YORK 10017 212/573-9400 March 27, 1975 TO: VCM and PVC PRODUCERS GROUP Gentlemen: This correspondance is intended to provide you with an update on our activities relative to the EPA Standard Support Document and the NATCTAC review of this document at the March 25 meeting. In sequence, here are the activities that have occurred: 1 - EPA provided us with copies of its report on March 6. Copies were made and circulated to all Producer Group companies from the Keller and Heckman offiqe on March 8. 2 - The Technical Subcommittee of the Producer! Group's EPA Conmittee developed a critique of the EPA document and proposed Standard during 4 days of working sessions on March 14, 19, 21 and 24. This resulted in the pre paration of the report entitled "Comments on EPA's Proposed Standard for Vinyl Chloride" (copy attached) that served as the basis of the industry's oral presentation made at the NAPCTAC meeting on March 25. 3 - Simultaneously with the above, activities a special report on dispersion resins was prepared during a work session in Cleveland on March 3 and much activity coordinated through the SPI office. The need for this special report was identified on the occassion of the Technical Subcommittee's visit at the EPA's Engineering Division offices on February 25. This report (copy attached) was finalized and presented to EPA at the NAPCTAC meeting. The Technical Subcommittee's presentation and questioning by NAPCTAC and the EPA staff lasted approximately 3 and 1/2 hours. It was the concensus of our speakers that the industry's presentation was well received. It's our belief that as a result of the presentation - EPA will give additional thought to the proposed standard relative to the following: a) rupture discs on safety valves (A-3). b) flares for emergency vents (A-4). c) control of VC in process water where there is redundancy with other sections of the standard (A-9). AP00027594 2- - jd) control techniques for handling emissions from dilute streams of VC. e) a separate standard applicable to dispersion resins. j f) clarification as to whether the emissions down stream from the stripper of 400 ppm VC has the alternative of controlling dryer exhaust vent to less than 10 ppm. g) control of emissions from the oxychlorination vent. ! The immediate needs relative to continuing our dialogue with EPA as It develops its final standard are as follows: | 1 - Develop an economic analysis relative to the effect of the proposed standard on the Industry. Mr. Harry Connors is heading the task force assigned to this[project. 2 - Carry out a thorough analysis of Chapter 2[on Health Hazards of EPA's Support Document. Dr. Ross Adams is heading the task force assigned this project. 3 - Provide production data on dispersion resin manufacturing to support the industry's request that there be an alternate standard for these materials. ' 4 - Provide Mr. Goodwin with any significant additional comments on the Standard Support Document that apply particularly to your own company's situation that were not covered in the Industry's comnents at the NAPCTAC meeting. Mr. Goodwin requested such comments be supplied by April 1 or as soon thereafter as possible. 5 - Continue close contacts with EPA's Engineering Division staff to assist them In whatever way we can to understand the industry's problems. Please make note of the April 11 meeting of the full!VCM and PVC Producers Group as covered in the enclosed Meeting Notices. Sincerely, tlohn R. Lawrence Technical Director cc: R. L. Harding, SPI J. Hadley, Keller and Heckman W. D. Ruckelshaus, Ruckelshaus, Beveridge and Fairbanks Producers Group's EPA Steering Committee AP00027595 AGENDA NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE Crystal Mall Building 2, Room 1112 1921 Jefferson Davis Highway, Arlington, Virginia 22202 March 25 and 26, 1975 March 25 9:00 - 4:30 1:00 - 2:30 VINYL CHLORIDE Regulations **" Economic Impact Environmental Impact Industrial Comments Les Evans Bill Hamilton Susan Wyatt Society of Plastic Industries March 26 9:00 - 10:00 VINYL CHLORIDE (Continued) 10:00 - 4:30 Progress Report - COKE OVEN REGULATIONS i European Technology Drew Trerrtiolm Data Base Reid Iversen Test Results Roy Neulicht Industrial Comments John Brough (AISI) AP00027596 .! I 'l i . -v.: o i :**? f NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE AUTHORITY Established by the Surgeon Ceneral, U.S. Public Health Service, Department of Health, Education, and Welfare, on March 4, 1968, under section 110(d) of the Clean Air Act, aa amended; reestablished by the Administrator, Consumer Protection and Environmental Health Service, pursuant to the Secretary's Reorganization Order dated July 1, 1968; transferred to the U.S, Environmental Protection Agency pursuant to Reorganization Plan No. 3 of 1970; reconstituted by the Administrator on June 8, 1971, pursuant to sections 108(b)(1) and (2), and 117(f) of th Xe*m 'anm'.An, *ae amended; rechartered January 5, 1973, to. Include requirements of section 9(c) of that Federal Advisory Committee Act, P.L. 92-463; revised April 24, 1973, to assign aa adiHrtrmai.-. function; and terminating January 4, 1973, unlcas extension bayond that data la authorized in accordance with section 14 of'the Federal Advleory Committee Act. M `i r x - . Sv . ' ft* ;V:i. s i i . STRUCTURE Consists of the Deputy Assistant Adminiatrator, Office of Air Quality Planning and Standards, or his dealgnaa, at Chairman and 16 members appointed by the Administrator for overlapping terms of one to four years. Met&era are selected from the chemical, engineering, biomedical, and socioeconomic disciplines resident in universities. State end local governments, research institutions, and industry. Members are selected also for their technical expertise and/or interest is tha dareelopment of air pollution control '' techniques. FUNCTIONS Advises the Deputy Assistant Administrator, Office of Air Quality Planning and Standards on the latest available technology and economic feasibility of alternative methods to prevent and control air contamination to be published in air quality control technique! documents. AI90 advises on informational documents regarding air pollution control techniques and testing and monitoring methodology for categories of new sources and air pollutants subject to the provisions of sections 111 and 112 of the Clean Air Act. as amended. In addition, ths Committee, through a subcommittee, periodically revlevs Air Quality Planning and Standards program accomplishment plans and the associated contracts and grants avarded to carry out theas plans. ACCOMPLISHMENTS .The Comnlttee held tvo open meetings during 1973. The average non-member attendance at both meetings was between 30-80. In February, the Committee ^reviewed with EPA ataff technical data upon which new source performance standards for tht fallowing Industries are to be based; kreft pulp mills; coal preparation plants; ferroalloy plants; sta tionary gas turbines; electric arc furnaces; primary aluminum smelters; and phosphate fertilizer plants including wst process phosphoric acid, superphosphoric acid, diamonlum phosphate, granular triple superphosphate, granular triple superphosphate storage, and run-of-plle triple superphosphate. In May, EPA had new source performance standards . for coal praparatlon plants, kraft pulp mills, phosphate fertilizer plants, and primary aluminum plants and briefed the Committee on the proposed regulations. Standards for stationery gas turbines, ferroalloy plants, and electric arc furnaces vera reviewed in detail with the Committee, including much new data which had recently been collected from the Industry and from EPA source teats. They also reviewed Che Group IIA nev source performance standards for copper, lead and zinc smelters. EPA's final position on new source performance standards for these source* was approved by ths Committee. Regula tions ware reviewed and published by the Comnlttee on (1) National Emission Standards for Hazardous Air Pollutants; (2) The Croup II New Source Performance Standards; and (3) Regulations covering amissions during startup, shutdown, and malfunction for all sources covered under standards of performance for nev stationary sources. ' 16 T AP00027597 March 1975 ENVIRONMENTAL PROTECTION AGENCY NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE Chairman and Executive Secretary Mr. Don R. Goodwin Director, Emission Standards and Engineering Division Office of Air Quality Planning and Standards Environmental Protection Agency Research Triangle Park, North Carolina 27711 (919) 688-8146, extension 271 (Commercial) (919) 668-8271 (FTS) MEMBERS Dr. Lucile F. Adamson Howard University School of Human Ecology 2400 Sixth Street, N.W. Washington, D. C. 20001 Dr. Charles A. Bishop Manager, Chemicals and Chemical Processing Research Laboratory, M. S. #30 United States Steel Corporation 125 Jamison Lane Monroeville, Pennsylvania 15146 Mr. John W. Blanton General Manager, Advanced Technology Programs Department General Electric Company Mail Drop E206 - Jimson Road Evendale, Ohi 45213 Dr. Frank T. Bodurtha Senior Consultant, Environmental Quality E. I. du Pont de Nemours & Company Louviers Building 'Wilmington, Delaware 19898 202-636-7114 (Commercial) Direct Dial FTS: 900-636-7114 FTS: 412-644-3311 Ask: 412-351-3100 (Commercial) extension 2806 FTS: 513-684-2200 Ask: 513-243-3171 (Commercial) Or: 513-243-3172 FTS: 302-571-6011 Ask: 302-366-3184 (Commercial) !1 AP00027598 2 v Mr. Rafael Cruz Perez Vice President, Servicios A,-bier,tales de Puerto Rico, Inc. 304 Fernandez Juncos Avenue P.0. Box 0509 Santurce, Puerto Rico 00910 Call Washington, D. C. FTS Operator: 202-967-1221 Ask: 809-723-9983 Mr. Harold E. Hodges Director, Division of Air Pollution Control Tennessee Department of Public Health C2-212 Cordell Hull Building Nashville, Tennessee 37219 FTS Direct Dial: 615-741-3931 Mr. Harry H. Hovey, Jr. Associate Director, Division of Air Resources New York State Department of Environmental Conservation Albany, Hew York 12207 FTS Direct Dial: 518-457-7230 Mr. Lee E. Jager Chief, Air Pollution Control Division State of Michigan Department of Natural P.esources Stevens T. Mason Building (8th Floor) Lansing, Michigan 48926 FTS: 517-372-1910 Ask": 517-373-7573 Mr. Marcus P,. .McCraven Director cf Environmental Engineering United Illuminating Company 80 Temple Street New Haven, Connecticut 06506 FTS: 203- 432-2111 Ask: 203-777-7981 Dr. William J. Moroz Direct Dial FTS: 814-865-1415 Director, Center for Air Environment Studies 226 Chemical Engineering Building II Pennsylvania State University University Park, Pennsylvania 16802 * Mr. Hugh Mullen I. U. Conversion Systems, Inc. 1515 Walnut Street Philadelphia, Pennsylvania 19103 FTS: 215-597-3311 Ask: 215-545-0700 AP00027599 3 Mr. C. William Simmons Executive Officer, Air Resources Board State of California - Resources Agency 1025 P Street Sacramento, California 95814 Mr. Emmet Spencer Principal Environmental Control Engineer Kaiser Engineers 300 Lakeside Drive Oakland California 94666 Mr. Victor H. Suss,man Director, Stationary Source Environmental Control Office Ford Motor Company Parklane Towers West Suite 628 Post Office Box 54 Dearborn, Michigan 48126 Dr. Ruth F. Weiner Huxley College of Environmental Studies Western Washington State College Bellingham, Washington 98225 Mr. Raymond L. Wiggins 4154 S. Syracuse Street Denver, Colorado 80237 FTS: 916-449-2000 Ask: 916-322-2892 FTS: 415-273-0111 Ask: 415-271-4245 FTS: 313-226-6000 Ask: 313-323-2895 FTS: 20.6-442-0111 Ask: 206-676-3520 FTS Direct Dial: 303-794-0111 Extension 2741 Commercial Number: 303-794-5211 Extension 2741 Home: 303-771-9405 r. AP00027600