Document aJEZzGYRaLBg9X3vEYd11p9qR

The Society of the Plastics Industry, Inc. 355 Lexington Avenue New York, New York 10017 (212)5739400 H July 9, 1976 TO: VCM/PVC PRODUCERS GROUP SUBJECT: EPA REGULATIONS ON VINYL CHLORIDE to - *JU R yJ. UUadrte You will recall that in the comments we filed with EPA on February 23, 1976 regarding the proposed standard for vinyl chloride, we asked for certain ex emptions for research and development equipment. Toward the end of June, we learned that the EPA's engineering staff was considering an exemption on re search and development facilities that produced no more than 10,000 pounds of polyvinyl chloride. Since this was an exemption considerably less than what we had asked for, a series of conversations with EPA's engineering staff ensued. These conversations involved certain members of the VCM/PVC Producers Technical Committee and myself. Finally on July 2, 1976 in a telephone conversation with Miss Susan Wyatt of the EPA staff, I was advised that their recommendation to the EPA Technical Committee on July 9, 1976 would call for control of emissions from PVC Research and Devel opment facilities as follows: Test equipment of 50 gallons and below are exempt. Facilities greater than 50 gallons and up to 1,000 gallons need to con form to only sections 61.64a, (except a-2), b, c, and d. Although this may still not be completely satisfactory to all producers, it appears to be a reasonable compromise between what we had originally asked for and what the engineering staff was proposing to recommend. We can not be certain of the exact language of this portion of the regulation until it becomes available to us. It is my understanding that copies may be come available at the time when the regulation is circulated for its Inter agency review. If it is necessary to consider asking for other interpretations to be placed on this exemption, we could consider the best mechanism to influ ence this regulation at that time. Very truly yours JRL:bzp John R. Lawrence Technical Director GEMC 012783