Document 10a9gvXQ464M5jJ0232nvKBBd

OFFICE OF TOXIC SUBSTANCES RAR 1 3 1975 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 20460 March 11, 1975 Mr. Milton Friefeld Manufacturing Chanlst Association 1825 Connecticut Avenue, N. V, Washington, D. C. 20009 Daar Mr. Friefald: Enclosed you will find a copy of EPA's Vinyl Chloride Task Fores Report, which I indicated I would nail to you. You will also find attached, a recap of each of the EPA vinyl chloride recoMandatlona Identified in the task force report, with the lead office dearly Identified In the column next to it. v Should have further questions, please contact Dr. William Marcus of the Special Chemicals Branch (Telephone: 755-0300). Sincerely yours, Don Marlow, Chief Special Chemicals Branch bdosures (2) rSV 0001309 VINYL CHLORIDE TASK FORCE RECOWENDATIONS Recommendations Responsible Office* 1. An air standard for VC shouifl be established as soon as practical under the Clean Alt Act for VC and PVC polymeciisatfon plants and, if warranted by further Investi gations, for PVC fabrication,plants Tha Agency should determine tha.ambient levels that are likely to ba achieved and, to tha extent possible, tha health risks associated with such.level* OAQPS 2. Additional ambient air monitoring should be carried out to support regulatory action under the Clean Air Act, Those efforts should include sampling at a number of care fully selected sites around, a few VC, PVC polymerisation, and PVC fabrication plants. The monitoring measurements made at these facilities should be coCTelpt*^ with specific in-plant activities such ai^ceaetor venting. :: ' ' [ }'" : 3. More detailed material balance studies should be conducted, in cooperation with industry, at a few VC and PVC poly merisation plants. Specific VC leakage points should be more clearly identified, and attempts should be made to correlate the magnitude and timing of the estimated loases with the levels of VC detected in a monitoring program. f? s < 4. A program should be initiated to determine whether and to what extent background levels of VC are present in the ambient air -- indoors, and outdoors -- due to the presence of PVC products* OAQPS OTS OTS !>. A J UiUccl VC monitoring program should be undertaken of drinking water supplies which might bo contaminated from VC discharges from nearby PVC plants* Prior to under taking the program sampling and analysis procedures should be carefully reviewed and refined ae necessary* OWPO KSV 0001310 * see lest page o o o i3 a i Co Vim CHLORIDE TASK FORCE RECOMMENDATIONS ___ -- Recommendations Responsible Office A. A study should be conducted'to.determine the amount of VC mlprating out of FVC products geed in water distri bution systems h such as. PVC pips or storage tank Ilnurs. Trior, o undertaking the progta* standardized sampling and analysis procedures should be carefully reviewed and refined as necessary* ': 1 l. r , II I * 7, 'In Ji.mirot comparability of.results between laboratories 1 r.PA Mhonld further develop its Interim method into a <ti imlni.ll7.cd method for monitoring levels of VC. Con- ronrniJy, thcAgency should also investigate the feasibility of developing a continuous air monitoring dpv Ire. { j, , ' ; II <( :, . ;, R. Monitoring and bench^scaie studies should be conducted nround IndustrialjHtorage and, disposal sites and munici pal disposal sites to determine the types and quantities of toxic substances leached pf discharged out of (a) semi- solid ond solid wastes generated by VO0/PVC facilities, or (h) RVC products discarded by consumers* If these studies indicate that.there could be a health or , environmental hazard, guidelines should be developed lo rontrol the storage am) disposal of these wastes. ORD ORD OSWHP 0. The responsible Office should continue to support currently planned VC toxicological studies. i; i i 10. The responsible Office should continue to support currently planned VC epidemiological studies. *1 11. More intensive studies should be conducted on the behavior of VC in the atmosphere and in the aquatic (miv.I moment, and particularly on its degradation product/; and related chemical reactions. These studies should be supported by both Industry and Government. ORD OTS/ORD ORD VIHYL CHLORIDE TASK FORCE RECOMMENDATIONS Recommendations Responsible Office 12. The Industrie* covered by the Effluent'Guidelines for the Plastics Industry promulgated under the Federal Hater Pollution Control Act should be expanded beyond the production of resins to include the compounding and directly associated activities that result in discharges into the veter ,of toxic metals and other chemicals of particular concern* 13. Enforcement^efforts* including spot checks of nanu- Tactorero, distributors, and retail outlets, should continue to be pursued vigorously to Insuru that pcsticldal spays containing VC as a propellant are . moved from the channels of trade as rapidly aa possible. . *, : OWQFS OBGG J4. Regional, State, and local authorities should be kept fully informed of Agency efforts under the Clean Air Act and other authorities. As the Federal approach becomes clearer, they should be encouraged to under take supportlye actions as appropriate* , . ... - . * . i i i' .. 13. The Agency should build on the. experience gained in responding to the problems associated with VC in strengthening its organizational, manpower, and controctor resources to anticipate and respond to similar situations involving other chemicals. Readily available information on the haodling of VC should be made available bo the Regional Offices to. assist them in responding to rail, op barge accidents resulting in the release of VC. iL 26. Laboratory procedures for safe handling of VC should be. developed and distributed to all KPA laboratories. Consi deration should bo promptly given to hovr such procedures e.-m most effectively be developed for a number of carcinogens that arc likely to be of concern to the Agency. OIL OTS ORD ?TTOOO ASH RecommcndatIons VINYL CHLORIDE TASK FORCE RECOMMENDATIONS 111................. I IIIIIH.IW I-I I I m Responsible Office . Should Che ToxicSubstances Control.Act be enacted, prompt consideration should be given to the need for and feasibility of (a) requirements for Industrial teotlng of the toxicity of VC at low ambient levels and the persistence of VC in different media, and (U) limitations on dhe levels of unreacted VC mounmor in selected PVC products. i .ii , LB. The Agency should continue Its leadership role In bringing together thq interested Federal agencies to exchange views on regulatory actions, supporting activities,,qpd research projects directed to pro* blems associated with VC and PVC. In addition, an appropriate,interagency mechanism should be developed to address a brooder spectrum of potential problems associated with the plastics industry. OTS OTS 19. F.PA should exercise leadership in stimulating Govern* mental ond industrial efforts to analyse in depth the other high volume chemicals .(e.g. to top 50 In terms of pounds of production) to Identify those which deserve additional testing or controls to clarify or reduce potential environmental problems. OTS * Codes OAQPS - Office of Air Quality Planning and Standards OTS * Office of Toxic Substances . CWPO - Office of Water Program Operations OSWMP - Office of Solid Waste Management Programs ORD - Office of Research end Development OEGC - Office of Enforcement and General Counsel (subsequently became Office of Enforcement) ORL - Office of Regional Liaison RSV 0 0 0 1 3 1 3 Received with Don Marlow's letter (EPA) of March 11, 1975 to M. Freifeld . APR 141975 Notice This document has not been formally rele-v:r.J by EPA and should not now be construed Lj represent policy. It is being circulate-** for cj.nr.ent on its technical accuracy and policy implications. Standard Support-Environmental Impact Document An Investigation of Health Effects and Emission Reduction of Vinyl Chloride in the Vinyl Chloride Monomer and Polyvinyl Chloride Industries Volume I Principal Health Effects Investigators Special Studies Staff National Environmental Research Center Principal Technical Investigators Leslie Evans Charles Kleeberg Principal Environmental Impact Investigator Susan Wyatt Principal Economic Investigator Allen Basala William Hamilton William Vatavuk United States Environmental Protection Agency Office of Air Quality Planeinn and Standards Emission Standards and Engineering Division Research Triangle Park, North Carolina 27711 Telephone: (919) 688-8146 March 1975 RSV 0001314 a *f * Notice APR 141975 This document has not been formally released by EPA and should not now be construed to represent Agency policy.' It is being circulated for comment on its technical accuracy and policy implications. Standard Support-Environmental Impact Document An Investigation of Health Effects and Emission Reduction of Vinyl Chloride in the Vinyl Chloride Monomer and Polyvinyl Chloride Industries Volume II Principal Health Effects Investigators Special Studies Staff National Environmental Research Center Principal Technical Investigators Leslie Evans Charles Kleeberg Principal Environmental Impact Investigator Susan Wyatt Principal Economic Investigators Allen Basal a William Hamilton William Vatavuk * United States Environmental Protection Agency Office of Air Quality Planning and Standards Emission Standards and Engineering Division Research Triangle Park, North Carolina 27711 Telephone: (919) 688-8146 March 1975 RSV 0001315