Document ymgbjZaKxMgKjJy855yJaOna4

TO: Distribution TBS: m. tsCkrf!'rf ><~n x XF* Interoffice Communication FROM: DATE: SDBJ: T. G. Grumbles September 18, 1991 EPA'S REVIEW OF SARA 313 GLYCOL ETHER DEFINITION VISIA Attached is an update on EPA activity to modify the SARA 313 definition of glycol ethers to prevent certain ethoxylates, and certain other surfactants, from being included under the definition. Although somewhat "glacial" in speed, progress is happening. The letter indicates the air office is also reviewing this issue in reference to the Clean Air Act glycol ether definition, which is the same as the 313 definition. T. G. Grumbles dlj .323 Attachment Distribution: D. Penney, J. Roheim, A. Nielsen, D, Plummer-Austin M. G. Hayes-LCCP, R. Swantkowski, T. O'Brien cc: F. G. Jeanson, J. C. Ledvina, A. Clark VVV 000007819 BAKER HOSTETLER COUNSELLORS AT LAW Washington Square, Suite U00 1050 Connecticut Avenue, N.W. Washington, D-C. 20036 (202) 861-1500 Fax (202) 861-1783 Telex 2357276 Writer's Direct Dial Number (202) 861-1668 September li, 1991 TO: Members of the SDA Glycol Ethers Task Force FROM: John M. Taladay RE: Status of EPA Review of Glycol Ethers Under EPCRA 313 As you know, The Soap and Detergent Association ("SDA") has been working closely with the EPA in an effort to convince the agency to redefine the "Glycol Ethers" definition under 313 of the Emergency Planning and Community Right-to-know Act ("EPCRA"). In February, SDA submitted extensive data on three particular "glycol ethers," pursuant to EPA's reconsideration of the category. EPA established a target of six months for review of the definition and we had expected a proposed rule to be issued in mid-August. Unfortunately, EPCRA staff_was interrupted in mid-review and was forced to turn their atteiftfLon to another matter during the summer* Apparently, Congressman Henry Waxman (D-California) proposed that EPA expand the EPCRA 313 list by over 250 substances under the heading "the Right to Know More." Congressional hearings were held at which EPA staff were called upon to testify. Eventually, the matter was placed on the back burner but only after three months of staff time had been occupied. Following that "emergency," the review of the glycol ethers category was resumed and a proposed rule is now expected in late October or early November. The upshot of the three month delay is that a final rule is unlikely before mid-1992. This means that another year of reporting probably will be required, regardless of the results of ) EPA1s review. WV 000007820 Cleveland. Ohio (216) 621-0200 Columbus. Ohio (614) 228-1541 Denver. Colorado (303) 861-0600 Houston, Texas (713) 236-0020 Long Beach, California (213) 432-2827 Los Angeles, California (213) 624-2400 Orlando. Flpriim (4<T) 649-4000 Members of the Glycol Ethers Task Force September 11, 1991 Page 2 We have, however, received two pieces of news that are decidedly positive. First, according to both EPCRA and Office of Air Quality Planning and Standards ("OAQPS") staff, the two departments are working closely on the glycol ethers review. Maria Doa expects that, following the review, the two departments will undertake concurrent (though not necessarily identical) redefinition of the category. Since we have not formally approached OAQPS to request reconsideration, a favorable change of the definition could eliminate the need for SDA to repeat this exercise with OAQPS. Second, I have been informed that EPA is working on a "very narrowly focused definition" of the category. This implies that the formula defining "glycol ethers" will be modified, most likely to establish a carbon chain-length boundary. If this happens, the carbon boundary established should exclude the three surfactants identified by SDA. I will continue to actively monitor the progress of the EPA review and will keep you advised of developments. When the proposed rule is issued, we encourage active member participation during the comment period to help assure an appropriately favorable resolution of this matter. In the meantime, please call me if you have either questions or news about EPA*s review. Sincerely, JMT/mas cc: Mr. Richard Sedlak VVV 000007821 Distribution: SAFETY DIRECTORS XF: Bruce Trego-Aber, Brent White-Bait, George Williaras-Blane, Matt Tonkovich-Hmd, K. L. Fogg-LCCP, R. V. Gantz-LCLAB, Mike LunsfordLCVCM, Mark Markerson-Okc, Greg Lipps-Premiere, R. B. Martin-Austin, J. R. Drurowright, J. G. Farrier, L. L. Zimmerman PLANT MANAGERS R. W. Seymour-Aber, L. R. Bauer-Balt, G. D. Williams-Blane, J. Pavao-Hmd, J. Friend-LCCP, J. W. Ware-LCLAB, P. Carrico-LCVCM, H. D. Garrison-Okc, P. L. Foote-Prem, V. W. Weiss-Austin TRANSPORTATION CONTACTS T. S. Randolph-LCCP, D. G. Stephens-LCLAB, K. C. Cash-LCVCM, M. F. Ticar-Balt, Kenny Akins-Aber, G. C. Lipps-Prem, J. Callen-Okc, R. G. Witt-Blane, R. T. Jackson-Austin, Matt Tonkovich-Hmd, J. G. Farrier, J. M. Kerlegon, H. L. Duckworth, R. Johnson Paul Gowan, T. H. Huffman, R. D. Gamblin, M. S. Reynolds VVV 000007822