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January 12, 1990 BRUCE, Reservations have been^/made for you at the Orlando Marriott for January 22 and 23. Your confirmation number is 8JWW87HQ. I gave them your credit card number so you are now confirmed for late arrival. I also checked with Continental to see if they flew to Orlando. They do have non-stop flights from Houston to Orlando. I DID NOT make your flight reservations because I was under the impression that you may have had some kind of coupon. Let me know if I can help. Janella
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IMPORTANT
A Division of The Society of The Plastics Industry, Inc. TO: Health Safety & Environment Committee
Jan. 9, lyyu
RE: Janaury 22, 23 and 24 Meetings
The Agenda for the Health, Safety & Environment Committee meeting for Janaury 23, 1990 is attached. As previously notified, this meeting will be at the:
Orlando Marriott Hotel 8001 International Drive Orlando, Florida 32819 (407) 351-2420
TWO IMPORTANT CHANGES HAVE BEEN MADE THAT MAY AFFECT YOUR CALENDAR.
1. JANUARY 22 - FO 24 Issue
A meeting of the FO 24 Task Force has now been scheduled for Monday, Janaury 22, 1990 beginning at 2 p.m. This meeting will also be at the Orlando Marriott. Comments submitted to EPA by member companies on the Land Disposal Restrictions for Third Scheduled Wastes Proposed Rule note substantial problems exist for those of you that classify any wastes as FO 24.
The Task Force will discuss the issue and develop a strategy on how to proceed with any joint industry activity, such as a meeting with EPA. If this issue is important to your company, please attend or invite the appropriate person to represent your company at this meeting.
Please let me know if you will be attending or sending a representative.
2. JANUARY 24 - Meeting with Contractors Doing Study for Canadian Ministry of the Environment
At the suggestion of Jim Lewis and W.C. Holbrook of BFGoodrich, and with the agreement of Committee Chairman Frank Borrelli, a special meeting has been scheduled for Wednesday, January 24, beginning at 9 am and running through noon. Many of you have previously been contacted directly by contractors (O'Connor Associates Environmental and Radian) who are carrying out reviews of comparative VCM Emission levels and emission control technologies for vinyl companies that a seeking construction project approval. The purpose of the review is to develop a "Level 1" analysis of "Lowest Achievable Emission
Rate (LAER) and "Best Available Control Technology"(BACT).
They have been seeking information on:
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Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (201) 890-92yy y Fax ft (201) 890-7029
VCM emission and ambient air standards in various government jurisdictions (including the U.S.)
VCM emission levels (from PVC plants) that represent existing plant performance
general control or process strategies/methods that are used to achieve plant emission levels
Ambient air (or fenceline) VCM levels. W.C. Holbrook and Jim Lewis have asked that you come to this meeting prepared to discuss the above items in detail. Specifically, they have asked that you bring with you two copies of your existing permits to share with the company representatives/ contractors. If you have any questions about this part of the program, please call either W.C. Holbrook at 216/447/7925 or Jim Lewis at 216/447-7979. I will, of course, also be happy to answer any questions. Please let me know if you will be attending this meeting.
Meredith N. Scheck Assistant Director
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agenda
VINYL INSTITUTE HEALTH, SAFETY & ENVIRONMENT COMMITTEE
Orlando Marriott 8001 International Drive Orlando, Florida 407/351-2420
Tuesday January 23, 1990 9 am
I. Opening of Meeting and Self-Introductions
Group
II. Approval of Minutes of September 27, 1989
Group
III. Dutch Study on PCDD's PCDF's from the Oxychlorination Process (Will be sent in mail with mail copy of Agenda)
Holbrook
IV. F024 Subcommittee Report/Strategy V. Fugitive Emission Follow UP
Lewis Group
VI. Waste Minimization Task Force
Ledvina
VII. SARA 313 Report and Zero Discharge Goal VIII. Activity on East Coast Rail Safety
Scheck & Group
Borrelli
IX. New Jersey Labeling Update
Group
X. Louisiana Water Regulations
Borrelli
XI. NESHAPS - inprocess wastewater (40CFR61.65 (b)(9)(i) as it applies to VCM/EDC plants
Ledvina
XII. VI Annual Safety Award and VI Environmental and Safety Recognition
Scheck
XIII. Enforcement Update
Group
IX. Request from Occidental - test data on resin/
Group
leachates (letter of request being sent under separate
cover)
XV. New Business
XVI Next Meeting
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The Vinyl Institute, A Division of The Society of the Plastics Industry, *c. Wayne Interchange Plaza II, 155 Route 46 West. Wayne, New Jersey 07470. (201) 890-9299
BFGoodrich
The BFGoodrich Company Geon Vinyl Division
6100 Oak Tree Boulevard Cleveland, Ohio 44131 216-447-6000
December 1, 1989
Ms. Meredith Scheck The Vinyl Institute Wayne Interchange Plaza 155 Route 46 West Wayne, NJ 07470
II
Dear Meredith:
It seems appropriate that the attached be sent to the Vinyl Institute Safety, Health and Environmental Committee members prior to our January meeting and this topic be on our meeting agenda.
Sincerely
THE BFGOODRICH COMPANY Geon Vinyl Division
WCH/kp DOC403
Attachment
W. C. Holbrook Director, Environmental Affairs
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^r^ Yb* From Adresaee F. a . o.
- BELGIUM
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Dat i 06711/1989
In ^a i you did dot receive all pages, please contajct Mia or Liev (tel. (jl3/66.61.12)
: W. BORMANS
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> BFGOODRICH / Clavelanc 0012164476172
< Mr. Lee M. PUCKETT ;
Director of Licensing & Internationalj Manufacturing Support
Pages (incl. this page)
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2
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Dear Lee, ' Re t PCDD's and PCDF's formation in oxychldrination
Enclosed, all the information we received About the subject, together with the covering letter.
Quote
"SOU 14
CATALYTIC OXYCHLORINATION PROCESSES OP ALIPHATIC HYDROCARBONS AS NEW INDUSTRIAL SOURCES OP PCDDfl AND PCDFs. E.H.G. Evers*, M'. Buring, M. Slie and H. Govjsrs, Laboratory of Environmental and Toxicological Chemistry, University of
Amsterdam, Nieuwe Achtexgracht 155, 1018 MV Amsterdam, The Netherlands.
in the last few years extensive sediment and waste water
monitoring studies in the river Rhine area' have been performed with special attention to industrial oouraea cf PCDDs and PCDPs. From these studies it was concluded tilat hitherto not recognized industrial sources contributed ii^jnificantly to the pollution of the Dutch river delta with theii e compounds. The PCDD/PCDF isomer patterns and spatial vaaviations of their
relative levels indicated vinylchloride momdraa r (VCM) production
as a principal source for PCDDs and especiall]3y PCDFs. Analysis
of process and waste water, sampled at varidut points in the VCM production process confirmed these indicatione. The crucial st p was found to be the oxychlorination of ethylene to 1,2dichlorocthano catalysed by alumina-CuCla at 50 - 300"C.
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Adresaee F.a.o.
BFGOODRICH / Cl v land
0012164476172
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i Mr. I*e M. PUCKETT .
Director of Licensing :& International
Manufacturing Support |
At the laboratory the oxychlorination process j and the effect of various reaction parameters (catalyst content and pretreatment, temperature and input gas flows) on the formation of PCDDs, PCDFs and some precursors (polychlorinated biphenyls, -benzenes and -styrenes) was studied.
It was established that transition metal halogenidea play a key role in the high temperature formation of the Ijalogenated DDs and DFs and an attempt is made to elucidate thie major formation
mechanisms.
unquote
i
Please let us know your comments a.s.a.p. Kind regards,
W. BORMANS
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ECVM, 250 Avenue Louise,
Box 122, B 1050 Bruxelles, Belgien .
att. Mrs. N. Rusotto
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ASSOCIATION Ok t,AjfJCS UANVMCTUMM IN (UflOAf
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PVC discussion - Denmark.
In an abstract from Dioxin 85 (Toronto) reference is made
(Sou 14) to a paper by Evers, Buring, die a-nd Covers from La
boratory of-Environmental and Toxicological Chemistry, University
of Amsterdam
Catalytic Oxychloririation Process of Aliphatic
Hydrocarbons aa New Industrial Sources of PCDDs and PCDFa ".
Comments contained in thia paper are now used by the Danish
Environmental Protection Agency aa yet an argument against the use of PVC
I am sure that our industry has already studied the mentioned
paper and that comments to its conclusions have been formulated.
To help us in our future discussions with the EPA would you
kindly let us have your comments to the enclosed abstract.
F. Ring Hansen
CA.'IMASK
co Norik Hydro
lnduj'.rlnj Huj '.*t!e,Srord 1 C CK if 2C Kifciruvn V
Tlfon: 01 11 48 86
Tlgram: norikhydro
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Tlx: 1S659
01 22 11 90