Document oDmbe2Nx0Qq6ny8gzdGZ8x7ao

TO: Distribution Page 2 13 May 1982 B. Reporting Provide reporting by exemption, and extend averaging time for reactor opening and RVCM. C. Malfunction Provide a malfunction clause similar to that proposed for benzene emissions. D. Leak Detecter System Vjait to see what EPA proposes in other rulemakings. Reduce records and frequency of calibration. E. Permitting Require permits only for the more strict of BACT (or LAER) under SIP and the NESHAP. Items not to be addressed at this time include recordkeeping and RVCM levels. Comments are invited from the recipients of this memo on these points* and on draft wording which will be circulated in a few days. Other points Include: - Most companies are not reporting VC releases within the process and CERCLA. Laundrie of General Tire has a letter from Region V specifically approving this decision. We agreed that if any company received a Sec, 114 request we would notify Counsel and discuss the letter before an answer is submitted. JTB/sjw APOOOI8775 Air Products and Chemicals, Inc. Box 530. Allentown. PA 18105 (2151481*4911 29 September 1982 Dr. C. Celia Monti polimeri Direzione E Uffici Via Moscova 3 20121 Milano ITALY Dear Dr. Celia: I am sorry that you were not at Toronto. We had a good meeting, even though it rained all week. There were 48 people there, from most of the usual companies. I enclose the outline which I used for my regulatory summary. Little has changed with the phthalates since I last wrote you. The National Toxicology Program ts starting an extensive study on the esters and the alcohols, but it will be a while before they are complete. I hope to see you next year In New Orleans. JTB/sjw Enclosure Aip66bt8776 Update on Regulatory Status EPA Vinyl chloride standard revisions under discussion with SPI. 0MB approved change to semiannual reports. Additional suits filed and Sec. 114 letters sent on emergency emissions. PMN exemption policy excludes VC, etc. Study of emissions. Including VC underway In Harris Co., Texas. Superfund reporting limits in revision, VC may stay at 1 lb. Revised Test Methods 106 and 107 published 7 and 8 September. OS HA Comment period is closed on proposal to reopen the cancer policy - action next year? Comnent period closed on revision of medical record retention rule. Labeling rule not expected until mid-83. Noise standard generally in effect. Respirator rule coiment period over. VC Training Film now available from National Audiovisual Center. Voluntary programs now in pilot phase. FDA Promised action on 1975 PVC proposal this October. Constituent policy comment period closed. No action on plasticizers - more tests. Others Unpublished report suggest tumors from VAc exposure. Peroxides cause skin tumors In an 8te) report. TCE bioassay being reviewed this month. States Many have own labeling, wastes, etc. rules. APOOOl8777