Document q3E68vGB1xDR7VLvkqOBDqd7E

c. Up* jfftOMC M. HCCMftAM CH*IILI H. MUMM W1UIAM M. MMHttAM. rfA. RQMNT R.T1RWAM MAlCOlH O. NACAATHUIt MAVNC V. #|p*CH MAMT1M , WIICOVICI JOHN a. CLfiNCO CAHOkf Q- MAAIhS MICHACl F. MCMONC LAatcr a. solomom JOHN f. OUMCH CMMarwa a. **** MIT a. pw<hoto nl--ctHcFrCNiC.Cp<.AMeAnIu^Wz IN OCBOmAH AMU* rWMCCH e. oouolac jmwktt MWHQ 1. HOimrtR HULA A. MIUAN m. re* LCC M. WUNCft tMOTMT CHOMFH ibCNl ftlNOIk HlUfA RECEIVED JUL 1 8 1983 ftuu ic TO: LAW OTFIC2S LLER AND HECKM 11BO IT* STREET, N. W. SUITE lOOO WASHINGTON, D. C. 80036 (808) 457-1100 July 14, 1983 COPIES TO: J FILE: c101>* CAIg AOO*Cft"llCLMAN' nrTKH'a oiaccr dial, rvmi (202) 457-1116 To: SPI Vinyl Institute SPI Vinyl Institute Manufacturing Practices Committee SPI Vinyl Institute Legal Committee Re: EPA Review of the Vinyl Chloride Standard Ladies and Gentlemen: Enclosed is a draft letter to the Environmental Protection Agency (EPA) suggesting changes to the relief valve discharge provisions of the vinyl chloride standard. The letter follows a May 26 meeting with EPA and a June 20 meeting of the Manufacturing Practices Committee. Tftie minutes of that meeting are also attached. The main feature of the draft letter is the sug gestion that facilities be required to submit a relief valve discharge elimination plan to EPA detailing the training, maintenance, written procedures and other action the facility will routinely follow to prevent relief valve discharges. Following approval of a plan by EPA, a source would be deemed to violate the relief valve discharge pro visions only if it fails to comply with its plan. EPA would retain authority to require revisions to the plan if a facility's history of relief valve discharges indicates to the Agency that additional preventive measures are needed. fc; JsThe Manufacturing Practices Committee's current plan iii&b finalize the letter at its August 4, 1983 meeting. We wouloappreciabe your sending comments through your repre sentative on the Manufacturing Practices Committee. If that is not feasible, please contact us with your comments by August 3. In particular, we are requesting additional case histories like those in the enclosed draft letter (pages 10-12). The EPA staff at Research Triangle Park indicated that an internal EPA v/orking group meeting is tentatively scheduled for August. We hope to submit the letter in early UEU-240045 SPI Mailing July 14, 1983 Page Two Ksxjlsr aiti> Heckman August so that it may be considered during that meeting. Prompt submission of any suggestions is also desirable in light of the recent District Court decision declaring the relief valve provisions of the standard unenforceable. While EPA has not determined whether it will appeal that decision or repromulgate the standard, it behooves us to act quickly in the event that the Agency decides to pro ceed with repromulgation. While working on the draft letter to EPA/ one research area was the cost imposed by the standard. In the past we have referred to a 1979 EPA report to Congress' (copy enclosed). We recently obtained from EPA an updated draft report being prepared by Development Planning and Research Associates, Inc. A copy is enclosed for your review and comparison. One peculiarity is an assumption I of zero investment costs after 1981. EPA is checking with the contractor on this point. I look forward to seeing you on August 4 and 5. in the interim, if you have any comments or questions, please feel free to contact us. Cordially yours. Enclosures Peter L. de la Cruz & gEU-240046