Document mp8jz3jrED1MXERdjBq5Y5ROO

i r+ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 2 7711 Mr. John R. Lawrence Technical Director The Society of the Plastics Industry, Inc. 355 Lexington Avenue New York, Hew York" 10017 Dear John: ____ At our meeting with you and other members of SPI on September 9, 1976, we agreed that, if individual companies submitted additional data to us on their research and development facilities, we would reevaluate the emission limit for these facilities included in the vinyl chloride standard. Following the meeting we received letters from B. F. Goodrich Chemical f.ninpanv- Air Products and Chemicals, and General Tire and Rubber company. ' The primary argument presented by SPI at the September 9 meeting against the 10 ppm limit is that separate control systems for research and development facilities are not cost-effective. The basis of the vinyl chloride standard is best control technology, not cost-effectiveness. In defining best control technology, we did exclude technology for which the costs were "grossly disproportionate" to the emission reduction achieved. By this we meant ridiculous costs which were not affordable by the industry and which would result in widespread plant closure. We also decided not to require incineration of the emissions from the oxychlorination process due to the energy expenditures that would be involved. It is emphasized that this decision was based on energy considerations rather than monetary considerations; we believe that incineration of these emissions is affordable by the industry. It should also be pointed out that the standard recommended by B. F. Goodrich is even less stringent than the standard recommended by SPI. B. F. Goodrich states that it could not meet SPI's proposed limit of 0.05 Ib/lb vinyl chloride charged unless the limit were expressed as a 30-day running average. B. F, Goodrich-also suggested that the 0.05 lb/lb limit be applied only to reactors, strippers, monomer recovery GENC 011H4 2 systems and miscellaneous vessels rather than to the entire research and development facility, ihis would also be a less stringent limit that the one proposed by SPI. Furthermore, in your letter dated September 13, 1976, it was stated that some members of SPI prefer the 10 ppm limit and request that the standard not be changed. In summary, we have carefully evaluated the information contained in these three letters and your letter of September 13, 1976, and have_ decided not to revise the 10 ppm emission limit specified_for research vTn7TTMc^TorTcTe"^,r^7T^arH"^s"^aTG^"^T^~ best control technology that is both available to and affordable by the industry. All data available to us indicate that the control technology required by the standard is both available and affordable, and a revision in the standard is not justified. I appreciate the cooperation shown by you and the members of the industry in supplying us with information so that we could more fully evaluate this subject. Sincerely yours. cc: John Barr W. C. Holbrook- ^/Robert Laundrie Stfiwd By Don P GrMwIn Don R. Goodwin Director Emission Standards and Engineering Division GENC 01U15