----- Forwarded by Greg Nizich/RTP/USEPA/US on 11/09/2007 07:02 AM -----
                                                                        
             "Borrelli,                                                 
             Frank"                                                     
             <Frank_Borrelli@                                        To 
             americanchemistr         Greg Nizich/RTP/USEPA/US@EPA      
             y.com>                                                  cc 
                                                                        
             11/08/2007 04:35                                   Subject 
             PM                       RE: Question About Compounding    
                                                                        
                                                                        
                                                                        
                                                                        
                                                                        
                                                                        




Greg, I was traveling this week and wanted to modify the flow sheet to
correctly show the emission points for the PVC process before sending to
you.  I have attached a revised presentation with the corrected flow
sheet slide.  Regarding compounding, that is often the next step
following the manufacturing of PVC resin.  It is a completely different
manufacturing step and is purely the mixing of PVC resin with other
additives; colorants, stabilizers, and other additives.  It is usually
not part of a PVC manufacturing facility but is completed in separate
mixing equipment and mostly carried out in facilities not located where
the PVC is manufactured.  PVC compounding can result in the polymer
being mixed with ingredients that make the polymer useful in rigid
applications like pipe and in flexible application like in the
manufacturing of wire and cable jacketing and insulation materials. Some
other polymers would similarly require mixing of colorants and
stabilizers but may be carried out in different equipment.  I have
attached a paper on PVC pipe manufacturing and the compounding step in
that process. As HAPs are not usually introduced and emitted from these
processes, I am not sure how they fit into the standards.  I would think
that these facilities that involve a specific HAP material would fall
under the regulatory requirements for processing that specific material.
With PVC pipe we did not find any HAPs in the compounding and
manufacturing of the pipe materials.
Regards

From: Nizich.Greg@epamail.epa.gov [mailto:Nizich.Greg@epamail.epa.gov]
Sent: Monday, November 05, 2007 2:43 PM
To: Borrelli, Frank
Subject: Question About Compounding

Hi Frank,

I'm trying to get a better understanding of how compounding fits in with
the PVC operations.  I know Ken Akins said it was essentially mixing dry
ingredients.  Do you know if this process is also done with other
polymer resins?
I'm thinking that maybe it's already addressed elsewhere under another
standard so it wouldn't even be a concern here.
Also, were you going to send us a copy of the meeting presentation?
Thanks.
Greg.
(See attached file: RVCM 101_EPA_Oct 07_final.ppt)(See attached file: 07
06 08 Emmission Paper.pdf)