Document k9KkzvK8bOggDONOeYDdK1pr0

minutes VINYL INSTITUTE MANUFACTURING PRACTICES COMMITTEE Inniebrook Tarpon Springs, Florida Wednesday September 11, 1985 1:00 p.m. Members Present (in whole and in part) W.C. Holbrook, BFGoodrlch, Chairman N. Blackman, Borden C.A. Gellner, CercalaTeed B. Reynolds, PPG &. Oubre, Dow J.T. Barr, Air Products and Chemicals J. Ledvlna, Vista J. V. Kachtlck, Tenneco Polymers H. Waltemats, BFGoodrlch (Guest) K. T. Gottssman, Vinyl Institute M.N. Scbeck, Vinyl Institute ACTION ITEMS AGREED TO: I. Motion msde by Kachtlck, seconded by Blackman, and unanimously approved that The Manufacturing Practices Committee considered the proposed letter to Delaware State Rap. Mack and U.S. Rep. Carper responding to their January 1985 letters to the record on EPA's proposed NESHAPS on vinyl chloride and recommended that no letters be written at this time and that the VI Executive Board be so notified. 2. M. Scbeck to monitor whether vinyl chloride is on the list of acutely haxardous substances being developed by U.S. EPA for use by state and local governments and keep committee apprised. 3. Barr to draft latter and circulate to committee that would be responsive to EPA'a proposed regulations dealing with air emissions prior to biologic treatment or prior to discharge to water treatment facility. 4. VI staff to sand letter asking for requests for VI Safety Award in time so that an award. If given, could be presented at the VI Annual Meeting. 5. Waltemate to determine who did the project dealing with mutual aid response teams relative to vinyl chloride and to send copy of project to VI staff. 6. M. Seheek to send two sets of coamlttee labels to Barr. 7. Barr to draft document on "Do's and Don'ts of VCM Storage" for review by committee. THE SOCIETY OF THE PLASTICS INDUSTRY. INC. 355 Leunpton Avenue . New York. N.Y. 10017 (212)503-0600 BOR 007855 BOR-C07856-00 BFG62060 -2- Discussion of proposed letter to O.S. Rep. Carper and Delaware State Rep. Mack The committee discussed at length eba contents of the propoaed latter aa agreed to In principle by the VI Board et its August 28 meeting. Gottesmas reviewed the background of the development of the letter, including the view* expressed by VT Board member Flaaaser at the VI Technical Comlttee meeting. The conalttee discussed what additional contents may be appropriate should such a latter ba sent (a statement of who the Vinyl Institute la; a review of the meeting with Formosa representatives; hiseory of industry compliance with current standard; Industry's role in providing information leading to the publication of the new proposed standard; an explanation that the proposed rule is not a "reformat" of the existing standard; a review of EPA's study of gasholders and the safety probleeis associated with them) and whether VI member companies could expect to benefit from such a letter. The committee agreed that the ultimate objective of the VI is to have the EPA proposed rule move forward and to assure that the Agency's final rule not require the use of gasholder containment systems. Considering that the record on the proposed rule is officially closed (end considering that their letters ware now several months old), it was decided that nothing was specifically to be gained relative to this objective by responding to Carper's and Mack's letters. Rather, it was suggested that any further contacts made with the EPA reiterate tha VT views on the proposed rule and the desirability of moving the proposal forward. Lastly, the comaittea discussed what the appropriate steps may be should the final rule require gasholder containment systems. Accordingly, a motion was made by Kachtlek, seconded by Blackman, and unanimously approved that the Manufacturing Practices Conelttee considered the proposed letter to Delaware State Rep. Mack and O.S. Rep. Carper responding to their letters to the record on the January 1985 proposed rule on NESHAPS on vinyl chloride and recomaended that no letters he written at this time and that the VI Executive Board be so notified. Discussion of Budget Issues Gottasman reviewed the resources expended to date on the committee's actlvltes related to the EPA proposed rule and legal expenditures made with respect to tha NRDC v. EPA action. Cottesman also noted that at the direction of the Board each of the coimaittaa chairmen has been asked to review the expenditures of their coanittees to determine priorities and anticipated expenditures for the remainder of this fiscal year. EPA Guidance on. Federally Permitted Releases At the request of Ledvlna, the cosnlttee members discussed their interpreta tions of federal permitted releases. Reference was made to e letter distri buted prior to the meeting by Ledvlna prepared'"By Willlur It^Hedeman (Director of the Office of Emergency end Remedial Response, USEFA) responding to a request for clarification of the reporting requirements under the Comprehen sive Environmental Response, Compensation, and Liability Act (CERCLA) as they applied to air emissions from a specific facility. As noted in the letter, EPA "has not yet determined a general policy vlth respect to Federallypermitted or continuous releases. Until a general policy is determined, the Agency will evaluate situations as they arise on e case-by-cese basis..." BOR 007857 ______________________ ________________________________________________LJk BOR-007857-00 BFG62061 u: CroO r") do