Document zoeN5GJ9a2GNrzyaK9JVoneYB

JOSEPH E. SELLER JEROME H. HECKMAN' CHARLES M. MEEHAN WILLIAM H. BORGHESANI, JR. ROBERT R. TIERNAN WAYNE V. BLACK DAVID L. HILL MARTIN W, BERCOVICI PETER M.NEMKOV JOSEPH E. HADLEY. JR. CAROLE C. HARRIS MICHAEL F MORRONE LARRY S. SOLOMON JOHN B. DUBECK CHRISTINE A. MEAGHER SHIRLEY S. FtIJIMOTO JOHN S ELDRED LAWRENCE P HALPRIN DEBORAH SHUR TRINKER LAW OFFICES Keller and Heckman USO ITU STREET, N. W SUITE lOOO WASHINGTON', D. C. 30036 TELEPHONE SOS 457 - llOO CABLE ADDRESS"EELMAN" WRITER'S DIRECT DIAL NUMBER (202) 457-1116 May 21, 1979 To: SPI-PVC Safety Group SPX-PVC Manufacturing Technology Committee SPI-PVC Communications Committee SPI-PVC Lawyers Subcommittee Ladies and Gentlemen: Enclosed herewith is a retyped copy of a memoran dum from the Environmental Protection Agency Office of Enforcement in Washington, D. C. to the Chief of the Enforcement Branch of Region I. This document, supplied to us by Harvey Rosenzweig of Borden's Law Department, represents the latest thinking of EPA relative to emer gency relief valve discharges. It was retyped in our offices because the copy sent to us was not sufficiently legible for photocopying. Suffice it to say, the bottom line of this memo randum is that "... in developing the vinyl chloride regulations [EPA] envisioned the use of gasholders to prevent or contain relief valve discharges. Therefore, ... PVC manufacturers can reasonably be expected to in stall gasholders to prevent discharges if other preven tative measures, implemented in a timely manner failed." We have been in touch with Gary Baise relative to this memorandum and its implications and will soon be in touch with you relative to what course of action we rec ommend be taken with regard to it. Cordially yours, Enclosure UCC 104519