Document wgnqZr0Bm8Zr2gJwb25pyY7R3

& JOSEPH 'E. KELLER JEROME H.KSCXkAN CHaRLIS x.heihak WILLIAM H, SORGHESANl,JR. ROBERT R.TIERNAN WirXE V. BLaCE DAVID L. RILL MARTIN V. BERCOVICI JOHN S. ELURED JOSEPH E. HADLEY. JR. Carole c. Harris MICHAEL T. HORRONE 1 if HY S. SOLOMON JOHN B. DDBECE CHRISTrWE A.KEAOHER SHIRLEY S. rCJIMOTO LAWRENCE P. H ALPRIN DEBORAH SECS TRIXEER C. DOUGLAS JARRETT EDWARD L. KORWER L-AV.* OF FI CSS Keller a>;d Heckman USO l?n SIREIT.V."'. SUITE lOOO WaSHINCTOK, D.C.2O0D6 August 6, 1980 Ot Dr. A. R. Adams General Manager Air Products & Chemicals P. 0. Box 538 Allentown, PA 18105 Inc. pjt TELEPHONE 202 457-1100 CABLE ADOBES S " EELMaX" WRITERS DIRECT DIAL NUMBER 202/457-1110 cJ^ /^:e/ ^ &A Re: SPI-VCM/PVC Resin Producers Group; Potential EPA Revision of NESHAPS for Vinyl Chloride Dear Ross: The purposes of this letter are (lJ'^Njalrprovide you and the rest of the Group with a full report on a meeting Gary Baise and I attended with the Group's Manufacturing Technology Committee and various officials of the Environ mental Protection Agency (EPA) and its contractor, TRW, on July 31, 1980; and (2) to deal, at least in a summary fashion, with what we consider to be basic issues that the vinyl chloride and polyvinyl chloride producers will need to face in the near future as a result of the way matters have and are currently developing. I might note at the outset that Gary and I have been in relatively constant contact on . this.entire situation since the middle of July, and that 4 we liavo i-h,* conclusion that the ffrftapfwi I , jLy^ fcSuaiH r 1 __ __ __________ _ with thel TM possibility that a meeting Tbf the jfuil^CQmmittee might thereafter need to be convened for the purpose) of fundamental decision-making. ` U J<nMZ As far as a report on the July 31 session with EPA nd its contractor is concerned, we are enclosing herewith an excellent summary that Gary has prepared and supplied to us this week. In reviewing this report, my feeling is that it is fair to sav that our GrouD went into the session i J v U - .. * * A A jy 5 ** .U is*' <* /yy 8CL 4-0028 Dr. A. R. Adams August 6, 198Q Page Two Ktller A_Nr> Hecema.\ with a collective open mind but also with some determination not to encourage the Agency to believe that the industry was willing to remain wholly passive vis-a-vis possible revisions of the current vinyl chloride standards. At the session we held prior to the meeting with EPA, and a shorter one after the meeting, we all agreed that if we had any assurance that the TRW study and recommendations might lead to a relaxation of the standards on such difficult questions as the emergency relief valve discharge issue, it would be foolhardy for us to categorically oppose any EPA action whatsoever. On the other side of the coin (and, basically, in keeping with an opinion you expressed in the course, bofsr fiomffi^TBl^elftSaggene ;rcas d / letter of July 3. In light of these circumstances, Gary and I have discussed the overall situation' and come to the conclusion be afrtggB&g'l-thgngggffiEffgffB or whether we should cooperate in the TRW study and anything in the way of recommendations that flow from it. The reason we say that to ha . Obviously, it would be to the industry's benefit if the recommendations are limited to the p^laxing of standards on things like emergency emissions, but One would- have to be most naive to anticipate such a recommendation without others that will impose severe neW burdens. Our notion at the moment is that the possibilities should be discussed in detail at the September 25 meeting so that, at an appropriate time thereafter, all of us will be better prepared to recommend the basic policies the entire group should follow. ^;DrA. Adams ^j.V'Augtis t 6, 19 80 J^.ni'-Page - Three r .v Vv-; -- - . . Reller 'a^d Hecem. jgM? &&L'm '*? Kr'' ^Vv. I suppose one of the roost important points that _ bears mentioning here is that we plan to come to the September 25 meeting prepared to discuss the consequences the .industry will probably need to face, depending on which basic course of action it decides to pursue. If it is decided that the industry prefers to go along with the TRW study and the thus far adhered to practice of cooperating with EPA to the fullest extent possible, there may be little in the way of new initiatives that need to be taken. On the other hand, if the industry decides that the time has come to draw the line against further regulation, a good deal of planning will probably be required, and the action options are likely to include possible preemptive initiatives at a variety of levels of government. We hope this letter will serve to provide you with our current thinking to the extent that it is possible to do so in a written communication of any reasonable length. I think it will be clear to you that my own feeling, having biseenthaintvolved in the VCM/P'cVrC^-srfrito.OafeolB^g^uns^ir$L'i't^e*albtJp^le.!iaesvet ^^l$d^7Hl,i!s!_l_ro__n__-_;_^ oiuI do'believe we will be well prepared to explain this matter further at the forthcoming Steering Committee meeting? but if you or any of the others receiving copies of this letter have questions in the meantime, by all means feel free to contact me or Gary Baise, Cordially yours. Jerome H. Heckman Enclosures cc:,/ Ralph L. Harding, Jr. Thomas J. McGrath John R. Lawrence SPI-PVC Safety Group 5PI-PVC Manufacturing Technology SPI-PVC Health Committee SPI-PVC Lawyers Subcommittee Committee wn ji_ 4-00