Document jy4bgDXMdwOXJKkbr21J40qR9

To: John Lawrence From: Paula Dunnigan B. F. GOODRICH 1 of 3 RECEIVED NOV 2 0 1980 CONFIDENTIAL November 7, 1980 SPI/PVC SAFETY GROUP ALTERNATIVES COMMITTEE CONTINGENCY PLAN FOR EPA (CLEAN AIR ACT) PURPOSE: SITUATION: ^ To identify some responses to potential EPA regulatory activity on vinyl chloride. (1) EPA promulgates and enforces regulations addressing chemical substances pursuant to four acts: (a) Clean Air Act (CAA) (b) Clean Water Act (CWA) (c) The Toxic Substances Control Act (TSCA) (d) The Resource Conservation and Recovery Act (RCRA) CLEAN AIR ACT (2) The agency has regulated VCM as a hazardous pollutant pursuant to CAA, Section 112 (NESHAPS) since October 21, 1976. The standard is designed to restrict VCM emis sions to the level attainable through the use of the best control technology available at that time. (3) As one of the settlement provisions of a law suit brought by the Environmental Defense Fund (EDF), the agency agreed to propose more stringent vinyl chloride regulations. These amendments were proposed in 1977 (Vinyl II) but never got beyond public comment. Because of the length of time which has elapsed, these amendments are regarded as out-of-date, and further agency action to finalize these par ticular amendments is deemed unlikely. (4) The agency has contracted with TRW to study the current VCM standard and the status of industry compliance and to recommend whether the standard needs revision. SP1-12278 WHAT IF? TRACKING: i TRIGGERS: CONTINGENCY PLANS: 2 of 3 2- - CONFIDENTIAL (5) Congress will address the task of reauthor izing appropriations for the CAA for FY 1982. Substantive amendments to the act are neither mandated nor precluded by the act. CMA will be putting forth a major effort to gain sup port for its proposed statutory amendments. (1) The agency proposes amending the present VCM standard . (a) Impact - Potentially high (b) Our influence - Medium (2) Congress signals its intent to amend the CAA. (*) Sources (a) Impact - Medium (b) Our influence - Medium Direct agency contacts Contacts with TRW m Contacts with Congress CMA 0 Keller & Heckman (1) TRW report to EPA contains recommendation to revise standard. (2) Congress announces committee hearings on CAA. Trigger (1) A. Alert the PVC Safety Group. B. Evaluate the TRW recommendations. C. Present data on health and safety and on the status of technology to the agency. D. Present modifications to the standard which are advocated by the industry. SP1-12279 3 of 3 CONFIDENTIAL -3- Trigger (2) A. Alert the PVC Safety Group. B. Obtain CMA position papers on CAA revisions. C. Actively support CMA efforts and articulate unique aspects of PVC Safety Group's position. ANTICIPATORY ACTION UNDERWAY: (1) Assessment of health data - Health Com mittee . (2) Assessment of manufacturing technology Manufacturing Technology. (3) Develop PVC industry position on desirable NESHAPS modifications. (4) Develop PVC industry recommendations for revisions in the CAA. t SPl-12280