Document g2pjbeppmXMOZxY567qj8MdVe

RiCHAfiO M. Fairbanks, XIX ALBERT J. BEVERIDGE, 1H HENRY L.OlAMONO GARY H. BAISE A.JAMES BARNES MAROLO HIMMtLMAN CHRISTOPHER H. BUCKLEY, JR. KEVIN M. roccr JONATHAN Z.CANNON ANORCW MISHKIN CHARLES A. PATRIZIA SCOTT W BOWEN CATHERINE M.OUNLAP * NOT HGU((R OK O C. BAB o CAW OFFICES Beveridge, Fairbanks & Diamond Onc Farragut Souare South Washington, D. C. 2000 TELEPHONE {202) 636-7800 February 8, 1978 CARL EAROLEY ELLIOTT GOLDSTEIN OF COUNSEL CABLE ADDRESS "in DLaw" BY HAND Joseph E. Hadley, Jr., Esquire Keller & Heckman Suite 1000 1150 Seventeenth Street, N.W. Washington, D.C. 20036 r Dear Joe: As I advised you a few days ago, I have been engaged in preliminary discussions with EPA's Division of Stationary Source Enforcement (DSSE) relative to the Division's plans for enforcement of the national emission standard for vinyl chloride upon the expiration of the two-year waiver period on October 21, 1978. I have recently had an exchange of correspondence with Richard Biondi of DSSE on this matter. Copies are enclosed for circulation to the PVC Safety Group. As I told you when we last spoke,, we are working on a memorandum which will fully set forth the tools available to EPA for enforcing Section 112 standards under the Clean Air Act. Among other things, the memorandum will discuss the important new authority given to EPA by the Clean Air -Act Amendments of 1977, namely. Section 120 relating to assess ment of non-compliance penalties. If you have any questions, please let me know. Sincerely yours. HK : cl Enclosures (2) Harold Himmelman see 5-1841