Document wgwqLYN01qpvqj0xEMdj3KMVQ

> erfaThoductS- tmd CAemieofa CHEMICALS GROUP P.0. Box 538, AllMtown, Pa. 18108 ^ <^(SN -vL PLASTICS DIVISION 5 April 1977 A. R. Adam. Ganarat Managw Tal: (216) 308-8823 Twx; 847410 Dr. Daniel P. Boyd DANIEL P. BOYD & CO. Leesburg, Virginia 22075 RECEIVED. APR 1 3 1G77 Dear Dr. Boyd: In reply to your request of 7 March 1977 regarding our costs In meeting the various governmental regulations for vinyl chloride, we attach a tabulation which shows that we have spent approximately $500,000 In preparing for the standards, $5.8 MM In fixed capital thus far, and our operating costs have Increased by $2.8 MM per year. This makes no allowance for lost production due to these changes. In addition, we expect to spend an additional $7 MM, and Increase our costs an additional $2.5 MM per year. This latter figure does not Include changes that may be needed because of the proposed revision of the EPA standard brought about by the EDF lawsuit. In reply to question three, the shortcomings of the present regulatory system stem from the fact that they are arrived at by an adversary procedure In a strongly political and emotional atmosphere. Industry Is cast regularly as the villain and Its testimony Is not believed, thus the only technical input Is from agency employees or environmental or labor groups. These latter usually have little or no knowledge of the Industry being regulated. tljifi the regulation Is promulgated It falls Into the usual bureaucrat^ eorass. Enforcement Is uneven between different regions and again, faffl|i4n people who are unfamiliar with the process, or even IndustrlaPepiratlons, In many cases. An example Is the recent EPA standard which was promulgated after a two-and-one-half year process. It has a two year deadline for compliance, yet five months after the effective date we have had no reply to our proposed compliance program, and the EPA has just announced a plan to revise the standard as the result of a suit by the Environmental Defense Fund. Much of the blame must fall on the Congress, which abrogates Its legislative powers to "law by regulation," and which establishes unrealistic schedules with no concept of the economic or technological implications. AP00025665 and Dr, Daniel P. Boyd -2- 5 April 1977 fUStf Improvement In the regulatory process must start with more realistic laws which are enforced by persons who believe that they are servants of the public and, therefore, strive to understand the process and Its results. The Input of the standards-setting teams must be improved, but It must also be accepted by the political hlerarcy, and not annulled for political reasons. Enforcement officials must not stand in fear of doing something that will displease our self-appointed saviors and thus bring down their disfavor. In short - a total revolution of the attitude toward regulation. The present response of the public to the ban on saccharin is a very hopeful sign. My greatest concern Is the tremendous costs that are associated with marginal changes in standards without perceived health benefit to anyone. On the contrary, the greatest harm is being done to our aged and future generations with the Inflating effects of the standards already set and coming In the future. Me trust that this Information will be useful to you. If you have further questions,do not hesitate to call. ARA:kab Attachment Very truly. (a A. Ross Adams bcc: J. T. Barr . T. L. Carey A. J. Dlgllo, R. Fleming^/ R. Schenck AP00025666 1. Spent Prioring for VC Standard OSHA EPA FDA $150,000 250,000 100,000 $500,000 2. Comply with Standard OSHA Monitoring Personnel Protection ENG Controls Recordkeeping Oper. Exp. EPA (completed) Eng Controls Monitoring Recordkeeping Operating Costs Planned Fixed $ 350 M 50 M 4,250 M 50 M --- $4,700 M $1,000 M 100 M --... $1,100 7.000 $12,800 Ongoing $ 150 M/yr. 10 M 900 M (ex depreciation) 250 M 500 M $1,810 M $ 250 M/yr. 250 500 $1,000 2.500 $4,310 ftRA AP00025667 > Vt ^ CE .il- ^A 101LThaUatinmuaA EXPENDITURE AUTHORIZATION REQUEST NO. DIVISION/SUBSIOIARY Escambia Plant Manuflcrur inR in a ysaa suoaer CAPITAL O DEPARTMENT PVC/Environmental AfMWAt NOT in t VCAA BUOOCT B 0**1A* A09fO*l--AreeoMd New Merit Cqul0wM ot r>*t O 9 Q AUTHORIZATION REQUIRED 3Y COMPLETION OATE EXPENDITURE ACCOUNT NO. DEPRECIATION ACCOUNT NO. 990-2021-600 6HA-7421-h20 AfflOVltl II NIP14III SAuC Or CCUIAMCNT G tXTAAOAOlNAAV Q LEASE ACOUISITION, MtAOEA, JOINT VCNTUAC Q DEPRECIABLE LIFE (Yearl 9.5 Indicate amount of rcquoitd axpaoditur# rtquirid for nvironmantal quality control. If none, indicat* "non*''. $ 1,250.000. PVC PLANT - EQUIPMENT REQUIRED TO COMPLY WITH EPA STANDARDS FOR VINYL CHLORIDE The EPA Standards for Vinyl Chloride Emissions specify limits from process equipment and fugitive sources. They also specify approaches to be followed to meet these limits. A system of primary and secondary control devices has ben specified to satisfy the standards. The primary devices include mechanical s.eals for containment pf VCM fugitive emissions from pumps, compressors and agitators, and rupture discs for relief valve losses. All wastewater streams containing VCM will be steam stripped and all VCM from reactor emissions and equipment openings will be piped with recovered fugitive emissions to a gasholder and a series of condensers. The secondary control device consists of an incinerator which abates VCM emissions to less than 10 ppm in comDliance with the standards . It is also capable of meeting the 5 ppm requirement of the proposed revision to the standard. Continued -- AP00025668 t ) DESCRIPTION AND BENEFIT (cont'd) PVC Plant - Equipment Required ta Comply with. EPA Standards for Vinyl Chloride This project will provide for all the control devices'and abatement equipment required to comply with the recently established standard. It also provides for a computer controlled monitoring and alarming system to determine and document vinyl chloride levels. Applications for a waiver of compliance have been filed with the EPA. This mechanism was provided with the new standard for operation through October, 1978. AP00025669