Document 1Qo1NO6w6obyeadwXk5pngQQa

er,. INTEROFFICE MEMORANDUM To T. L Carey From J. T. Barr A. R. Adams A. J. Diglio R. Fleming R> E. Jenes*^ J. D. Kramer T. J. Medovich Date 4 June 1975 Subject JERSEY1 EPA CONFERENCE ON VINYL CHLORIDE - TRENTCN - 3 JIJNE 1975 Valley Forge______________ (Location, Orflanlzitlon, or Oapartmant) Valley Forge (Location, Organization^ or Department) A. K. McJiillan R. H. Schenck W. M. Smith R. R. Spiegelhalter M. H. Steimon H. L. Watson/J. Novak Hie New Jersey EPA held an informal meeting at Trenton on 3 June, apparently for the purpose of educating their staff on the present state of emissions of vinyl chloride and abatement efforts now underway. The industry presentations were well prepared and apparently effective to the degree that they could be, considering the very low level of understanding of the EPA personnel of the industry and the problem. Hie tone of the meeting was generally friendly. About 35 to 40 persons were in attendance, nearly eoually divided between industry and state and Federal EPA staff. A copy of the meeting announcement and agenda are attached. The proceedings were taped, and we were invited to check back in about a month to see if the transcripts were available. More detailed notes are available from the writer. Meeting Notes Mr. R. D. Goodenough, Director, Division of Environmental Quality, opened the meeting with a short talk, after which he left. He spoke of the need for reason and sober decisions in setting standards, especially in view of the depressed economy, and appeared defensive as to the part environmental standards had in causing the present situation. He gave industry credit for cooperation and effective action on the vinyl chloride problem. It was requested that attendees send him a letter commenting on the effectiveness and desirability of such meetings. Mr. Vince Marcianti then acted as moderator. B. F. Goodrich Presentation Goodrich decided not to bring their own medical men to speak on the health problem, and presented Dr. Henry Falk of the CDC, Atlanta. He gave a reasonably moderate review of the VC history. Ife did use adjectives such as "possibly" in referring to the community cases in Connecticut, but included them and the accountant and G. E. worker in his list of cases. lie enphasized the lack of a good early K*.. ' (320) AP00034399 T. L. Carey 4 June 1975 Page #2 Subject: NEW JERSEY EPA CONFERENCE CM VINYL CHLORIDE - TREHTffl - 3 JUNE 1975 diagnostic test, and supported cautiously the theory of early fibrosis in chemically induced cases. He also referred to the excess of tumors in other organs, again making passing mention that these were not statistically significant. Mr. D. O'Kiefe then described the monitoring work at the Pedritown plant. Grab samples in June 1973 showed an average area content of 50 ppm, with excursions to 100-200. This had been reduced to about 10 when the Bendix THC was installed, and weekly averages are now in the 2-5 range. Personal monitoring is by carbon absorption and the Bendix flasher. They reported on 98 samples taken in 1974, which ranged from 1-69 ppm, with 29% above in and 26% . between 5 and 10. Of 131 sairples taken so far in 1975, there have been 14% above in, 5% between 5 and 10, and the range is 0.01-24 ppn. He reported good reliability and 98% recovery from the flasher, with its best performance at lower concentrations. Questioning centered around whether they did anything more than just better ventilation to reduce exposures, and he emphasized their leak patrol and response to high levels on the area monitor. Mr. K. J. Kaminski discussed their environmental testing. Tests in June of 1974 on a downwind pattern showed 1 of 98 sairples over 1 ppm, with 21% less than n.oS and 51% between 0.05 and 0.5. They now take four-hour integrated carbon tube samples, but no data were given. The most recent raw data from Louisville show that of 737 samples n% are below 0.05 ppm, 6% are less than 0.1 ppm, and 4% range upward to an 0.3 ppm maximum. They are purchasing a gas filter correlation 1R instrument that is "nearly commercial" (JBL Co., San Diego) that uses a 50m sample path and will have a limit of 2S ppb. It has no interference since it uses the 9-11 micron vibrational spectra of VC. Mantua Chemical Terminal Mr. G. Barton gave a slide presentation of this terminal which was built in 1970 for redistribution of PPG monomer from Puerto Rico. Storage is in two 3.5W1 gal. refrigerated tanks. He emphasized the "dry disconnect" method of preventing VC release, and redundancy of protective equipment. Bulk Process Ray Abramovitz of Hooker showed a 15 minute promotional film on the two-stage process, and discussed their operation. He claimed environmental advantages for the AP00034400 T. 1. Carey 4 June 1975 Page #3 Subject: NEW JERSEY EPA CONFERENCE CN VINYL CHI/RIDE - TRENTON - 3 June 1975 process as: no effluent (although they are installing Iff water cleaning of reactors); good material balance and efficiency (now 1.01 lb/lb.); and low emissions (fence-line results average under 20 ppb and range from 2 - 493 ppb). They are working on post treatment to reduce residual VO!, and are now below 50 ppm on "bulk shipments to customers," but emphasize that some product types may be endangered at the proposed EPA level of 400. He said that the only limit to VCM removal was economic. Fabricators Mr. J. B. Hardwick of Pantasote said, in effect, that there was no problem at fabricators because the residual VC is so low. There were no questions or comments from the floor. Suspension and Dispersion Processes Mr. W. P. Anderson of Tenneco introduced Bill Mendendoff who said earlier losses from suspension processes averaged 2.5 - 4.51, including PVC, with fugatives (1-25) and drying (1.8?) being the largest contributors. Present losses were estimated to be in the 2-35 range. They would not give any results of their carbon bed adsorption work at the Texas plant. Dispersion process losses were estimated at'1% higher. Mr. Paul Kever discussed their analytical techniques. They have chosen GC over al* other types for its precision and selectivity. The preferred solvent for standards is THF, not carbon disulfide. He prefers UCON 55^5 columns to Poropak because it suffers less from water interference. They do not back flush, but run 4-5 samples, then wait for the solvent to elute. The use of pure oxygen for flame fuel rather than zero air increases sensitivity by a factor of 3. They also report better recovery from carbon tubes at low concentrations, averaging 961. They prefer the headspace method for residual VC in PVC, but it is only satisfacto' for dty resin ot solutions of compounds. The sensitivity is about 50 ppb. Water samples are more difficult to manipulate, but give sensitivities of about 5 ppb with direct injection of 50 microliters. The headspace method with water samples will allow measurements in the sub-ppb range, and headspace combined with carbon absorption allows measurement in the ppt range. Handling techniques are the most serious source of errors. EPA Methods The poorest presentation of the. day was made by a Mr. Ed Finfer (spelling ?), who reported on the Region II activity soon after the VC problem .became known, and on a tentative monitoring method. APOOO34401 T. L. Carey 4 June 1975 Page M Subject: MEW JERSEY EPA CONFERENCE ON VINYL CHLORIDE - TRHNTON - 5 JUNE 1975 EPA Inspected two PVC operations and six monomer plants last year. This was principally educational ot them. They checked for vegetation damage near plants and found none. The air at the house of the woman who died near the Niagra Falls plant was tested and VC was found at the ppb level. He talked at great length about the proposed EPA method, ink gave no details, and said the method is not yet available to the public. I have requested a copy when it becomes available. It is reputed to be a 24-hour integrated sample sensitive to 1 ppb with a range to 8 ppm with 6% precision, and is based on carbon absorption. There are "no common interferences, except hydrocarbons and Freons." SPI John Lawrence then gave a short unscheduled talk, which I considered superfluous, on the desire of industry to cooperate, the past action of industry, and the over reaction of U. S. agencies as compared to their counterparts abroad. MISCFJJANY Dr. Falk joined a conversation between Lawrence and myself on the recent Firestone study released by IJKW/NIOSH to protest that the results were preliminary and should not have been released. He conceded that the final results will not be significantly different when they are released later this month. Lawrence talked to Don Goodwin, EPA, Durham, and was told that they expect to start the final session of the proposed standard through the agency review routine the third week of June, and we should be able to get copies then. An "action memo" is being prepared which details their strategy, and G. Baise of Ruckelshaus, Beveridge, Fairbanks ^Diamond, will attempt to get a copy. JTB/mjv Attachments AP00034402