Document km53e5R8vq8a8Qy73n0RYqypV

1 *' mrnm I U1ir4^ INTER-COMPANY AND OFFICE CORRESPONDENCE October 2, 1989 J. C. Ltmn _ OCT 0 3 IS39 M. D. Owens ssuaoL Engineering JCL VINYL INSTITUTE MEETING HIGHLIGHTS HEALTH, SAFETY AND ENVIRONMENTAL COtllTTEE BOSTON, MASS. - SEPTEMBER 27, 1989 1. Peter Oe La Cruz, V.I. Counsel, reviewed the status of the SPI/VI . action against OSHA concerning the 1 PPM 8 hour TWA EDC standard. Cartridge respirators are allowed for compliance with the standard at this time. VI legal action Is awaiting movement In the federal courts. 2. Several companies are having problems disposing of.F024 waste streams. Many companies (Vista, PPG, Dow) classify coice from their furnaces and same other streams as F024. An EPA docmsent has stated that ALL VCM producers In the U.S. generate F024 waste, however, some companies such as BFG and BCP do not classify these waste as F024. A wort group will be set up with all companies participating to review this Issue. 3. Peter Oe La Cruz also circulated his letter of September 14, 1989, discussing the EPA land ban of F024 waste and concerns that waste water Isn't clearly excluded (copy attached). 4. Meredith Schect, VI Assistant Director, commented on the Acute Hazardous Events data base prepared by an EPA contractor. This data base Includes both VCM and PVC fire Incidents. The VI had cowmentad to EPA that Including PVC was not appropriate since PVC Is not toxic. The Information Is still Included In the data base, however, at this EPA is not utilizing It. No VI action Is needed at this time. 5. The Yl made consents to the California Air Resources Board on their draft report on VCM exposure from landfills. No VI action Is needed at this time. 6. The long awaited revisions to the VCM NESHAP standard, which were negotiated by the VI/SPI, have been proposed by EPA In the September 21, 1989 Federal Register. All VI concerns were Incorporated and the VI will go on record as supporting the changes. Changes Included exclusion of crude and product EDC tanks, allowances for flaring of relief valve discharges, and a statanent that relief valve discharges do not result from leaks through the relief valve (copy attached). I! i BOR 009078 CJl o BOR-009078-00 to 8 BFG62056 Vinyl Institute Meeting Highlights Boston, Mass - Septemoer 27, 1989 Page 2 7. The SARA Form R survey mbs tabulated for VI members and Is attached. A comment from Snlntech (PYC producer) stated that the majority of their fugitive emissions come from the water In their gas holder seal area. Jonn Young, Shintech, stated that he has been questioned by the state of Texas as to why their fugitives are so high and others are not. He reconmended that other plants review this source. The VI HSE .conalttee may form a group to share knowledge in the reduction of fugitive emissions. 8. Joe uedvlna, Vista, reported on the TCLP current status. He said that the following waste may be hazardous because of the new TCLP standard. - PYC; PVC Scrap - Burnaole Liquids - Haste Water - Excavated Soils - Recovered Groundwater The standard is expected to be finalized in December, 1989 and become effective in June, 1990. (JCL comments: Leakage of groundwater Into open ditches could make a system hazardous. RCRA permitting would have to begin oy June, 1990 If 3CP isn't out of the ground with possible hazardous streams [PVC pond]). Tne status of the various PYC plants with regard to their settling ponas is as follows: Shintech - Has not found VCM aoove 200 PP8 in their clay lined pono. Do not think they have a problem at tnls time. Vista - Pond is concrete lined ana meets definition of a tank, thus they say oe exempt from this regulation. SFG - Use various clarification methods of separating PVC and now go to aoove ground tanks. (BFS notes that fugitive dusts tnat settle in stormwater drainage areas may be a problem.) Oxycnem - Still stuoylng tne proolera, leaning toward clarification witn aoove ground storage. 9. Legal Action: Oxycnem, Addis, Louisiana recently paid the La. DEO S3,000 for a single 1988 relief valve discnarge. 5CP, Geissar nas recr-'veo a 51,000 penalty u--"ice from OEQ for a single 1968-RV discnarge. BOR 009079 BOR-009079-00 BFG62057 i^% o 0 vinyl Institute Meeting Highlights Boston, Mass. - September 27, 1989 Page 3 10. Waste Minimization Topics: PPG - Charles Parnell reviewed the PPG quality team that was set up to reduce waste water. The team was set up along "Crosby" guldelInes. *BCP - Crls Lunn reviewed the recycle of heavy ends at the Gelsmar site. Stress was placed on recycle of anhydrous HC1 to the original production process and that other streams are routinely recycled wltnln a typical VCM plant system (BFG cemented later that they also recycle at Calvert City [Catoxld unit] and have letters from the agencies that concur with their position!. Vista - Frank Jeanson discussed bagging techniques to provide an accurate measure of fugitive amissions. Dow - Jim Turner discussed Dow's patented high efficiency stripping technology to remove waste water contaminates down Into the low PPB levels. Jim stated that very few stripping systems will allow discharge levels In the low PPB range. Copies of the two papers reviewed by Jim are attached. BFG - Jim Lewis reviewed the BFG program for reducing waste such as druu, bags, pallets, etc. by Installing bulk storage and requiring returnable containers where practical. Official VI minutes will be distributed when received. The next meeting of the VI Health, Safety and Environment Committee will be neld In January, 1990. In addition, the safety subcommittee will also meet in January or February to plan the next safety workshop. JCL/daa cc: A. P. Leonora P. F. Uest J. L. Russ G. T. Hannings R. E. Berg H. J. Accardo U. B- Barton M. Thorsen BOR 009080 BOR-009080-00 BFG62058