Document kDYYQy18YVZRG1vrR8oO1J6db

JOftCPW l. *Ckb*ft VCHOUC M, rttCOUH cha*l* m. mckham WLU4H M. tOMQHflM). 4. MAkGou* o. M*cA4>rrHWM MVNC V lUUjR KAOTIN . AClieOVfCl JOHN S, CLDCO O0tS C. rttH4*l * i**hot *. soLawdw JOMM I, NMtt A. mCAOCIV SMIlNftST *- PUM04TO h*m re* cvc actca w *ud*ut wDMCvHRANVecIM*WA TWIMRCA (0*4*0 u. AOMWCRc. odt/outa vAAMvrr ACTCA A. SW00C* SHCIWA A> MU-4* *UMlb *- re* Lft H. W(IHC* TmOTHV mown ibftHt MNOCl hCUpCII CUIN A (HTIIN law omces Keller and Heckman U50 17TM STREET. N, W. SUITE lOOO 'WASHINGTON, D. C. 30036 (203) 467*1100 August 31, 1984 i^b-t recex * 99smt (2r0e*)t*(co-I*'tOcO* t CA*b aO0*CM *t!-*** ' WAtTKA OlACCT OlAi. wU*OC* (202) 457-1116 Roy T. Gottesman, Ph.D. The Society of the Plastics Industry, Inc. 355 Lexington Avenue New York, New York 10017 Re: SPA NAPTAC Meeting Dear Roy: On August 30, 1984, the National Air Pollution Control Techniques Advisory Committee (NAPTAC), meeting under the auspices of the Environmental Protection Agency (EPA), reviewed draft revisions to the vinyl chloride standard issued under Section 112 of the Clean Air Act.^This letter lists the `attendees, provides a brief summary of events, and forwards idocuments distributed at the meeting. ^Attendees EPA was represented by: Susan Wyatt Gil Wood Bob Ajax Rob Rosensteel Les Evans Fred Dimmick Mike Dusetzina I Radian Corporation, the EPA contractor on this matter, was represented by Karen Fidler, Jeff Shumaker, and Reese Howie. SL 105093 Roy T. Gotteaman, Ph.D. August 31, 1984 Page 2 Kelt-kr and Heckman NAPTAC members present at this session were: Robert Collom - Georgia EPA Thomas Goodgame - Whirlpool Corporation Linda Greer - Enviromental Defense Fund Roger Randolph - Tulsa City-County Health Department Bruce Stiener - Armco Inc. (EDF) were: Members from the Vinyl Insitute present at the session W.C. Holbrook - B.F. Goodrich Company John Barr - Air Products and Chemicals, Joe Ledvina - Vista Polymers Inc. Nat Blackman - Borden Inc. Bob Oubre - Dow Chemcial Jim Kachtick - Tenneco Polymers, Inc. Inc. Proceedings Vinyl chloride was the last agenda item on the Com mittee's two-day schedule. The morning session dealing with 'Portland Cement was fairly controversial and the vinyl chloride I provisions were not reached until 1:15 p.m. There were relaItively few questions by the Committee and none of the Committee ^-members appeared antagonistic to the proposal. Except for a few questions by Bob Collom of the the Georgia EPA, state enforcement official's did not appear to have any major con cerns. The EDF representative, Linda Greer, did not have any comments or questions on this matter. Only three members of the public commented on the pro posal and these were all Vinyl Institute members. The absence of opposition or criticism to the proposal, except for the Vinyl Institute critique, made this a successful venture since the Institute is supporting this EPA activity. Earlier in the day, copies of the Institute and company comments were provided to the EPA staff for their review. We were informally advised by the EPA staff that the Enforcement Office did not wish to see the proposal go forward. The timing, scope, and intensity of the Enforcement Office's position was not readily discernible. Minutes of the meeting are being prepared and I will forward them to you upon receipt. In the interim, the SL 105094 Roy T. Gottesman, Ph.D. August 31f 1984 Page 3 Ksixtsr and Hscksian following summary of the meeting should give some flavor for the event. Karen Fidler of Radian Corporation reviewed the pro posals for the Committee. A copy of the overhead slides com prising her presentation are enclosed. Among other things, she stated that no new control technologies had been discovered, that enforcement of the standard was relatively straightforward except for the relief valve discharge provisions, and that a review by EPA's Cancer Assessment Group (CAG) indicated that the risk factor posed by vinyl chloride was considered the same as when the standard was promulgated. The proposed numerical limits for pressure relief device emissions were characterized as "consistent with the current standard." Mass-based limits, as opposed to numerical limits, were not chosen because a reli able calculation method had not been identified according to Fidler. After her presentation, Bob Collom of the Georgia PA asked several questions. In response, Susan Wyatt indicated that the reductions intended by the original standard have been achieved. Collom asked about the health impact of the existing standard and the effect of the amendment. Although this was )not well answered by EPA, the staff indicated that the risk had ibeen calculated at 10"^ for pre-standard exposure versus a 10~6 frisk after regulation. Prior to regulation, 11 cancer-asso*-ciated deaths were predicted with less than one predicted afterwards. Another question concerned the impact of changing the reporting period from 10 days to quarterly. Mr. Collom was concerned that this might de-emphasize the need for corrective action. Throughout this presentation and later during the in dustry presentation, his concerns were addressed and he appeared to be satisfied that this would not cause a diminishment of effort. When asked whether the numerical limits were looser or stricter than the current standard, Susan Wyatt indicated that the proposed amendments were "not stricter but the same." Jack Farmer also stated that industry had performed much better over the last several years. Bruce Stiener indicated that he did not-know much about the industry but thought that EPA's limiting the number of per mitted emergency discharges seemed presumptious. Susan Wyatt SI 105095 Roy T. Gottesman, Ph.D. August 31, 1984 Page 4 Kf-t.t.kr axd Heckman partially responded by indicating that there were certain steps that could be taken to minimize such discharges. This con cluded all the questions by the Committee. W.C. Holbrook commented on behalf of the Vinyl Insti tute. A copy of the comments is enclosed. After presenting his comments, Susan Wyatt indicated that several points, such as the definition of "in vinyl chloride service" and the option to destroy samples, could be fixed. There was some discussion concerning leak detection and ethylene dichloride (EDC) storage tanks which were not resolved. Jeff Shumaker of Radian asked if the headspace vapor in the EDC storage tanks had been measured for VCM concentration. W.C. thought this had been done and agreed to send this information and a description of the storage tanks in question. W.C. then presented comments on behalf of B.F. Goodrich which complemented the prior comments on behalf of the Vinyl Institute. Joe Ledvina spoke next. In addition to reinforcing several of the prior comments, he raised the incinerator bypass -and the 24-hour slurry averaging issues. He also recommended f that acts of God be excluded from calculating the number of i pressure relief discharges. John Barr made the last presentation. He mentioned the need to clarify the proposed language to. account for multiple discharges from a single event, the need for a de minimis exemption for discharges of 100 lbs. or less, and problems with the leak detection recommendaLions. There was a fairly extensive interchange between members of the Vinyl Institute and the EPA staff, particularly Fred Dimmick and Bob Ajax, con cerning the leak detection section. Ultimately, Jack Farmer suggested that the Vinyl Institute meet with EPA later to discuss this and other issues. Of the IS or 20 points raised by Institute and company comments, only three or four were discussed at the meeting. It seems highly advisable for the Manufacturing Practices Com mittee to meet with EPA in the near future to discuss EPA's intent and to argue for modification of the draft'prior to its formal proposal by the Agency. An effort should also be made to assess the EPA promulgation schedule and encourage prompt action. SL 105096 Roy T. Gottesman, Ph.D. August 31, 1984 Page 5 Keller and Heckman know. If you have any comments or questions, please let me Cordially yours, Enclosures cc: W.C. Holbrook G. Baise, Esq. c Peter L. de la Cruz SL 105097