Document 2Jr875r25eX8ddGGp4Z7OJOVp

March 8, 1982 TO R. N. Bates S. F* Stowers T. D. Epps R. L. Foster R- W. Holland, Jr. R. G. Link J. R. Soice B. D. Tissue SUBJECT: Kanawha Valley Air Emissions REF : W. Va. Clean Air Coalition Press Release of March 5, 1982 (Attached) REF : INSIDE EPA, April 4, 1980, Pages 9, 10 (Attached) The attached is for your information. JLW;co Attachments (2) J. L. Worstell UCC 100210 For Immediate Release March 5, 1982. West Virginia Clean Air Coalition I J?4 Vufj'tfttQ ( , Cliliiw_ wv 21101 J4C1S9I For Further Information, Contact: Charles Garlow 346-5891 Cites Study of Charleston's FMC & Union Carbide Plants CLEAN AIR COALITION CALLS FOR NEW LAW TO CLEAN UP TOXIC CHEMICAL AIR POLLUTION The West Virginia Clean Air Coalition called today for support of the Waxman Clean Air bill which would begin to control potentially hazardous emissions from chemical plants. Coming on the heels of a W.Va. Department of Health study of increased cancer rates in North Charleston, near Union Carbide & FMC chemical facilities, a report released by the Clean Air groups specifically blasted those two Charleston area firms as being among the nine worst chemical air polluters in the United States. FMC was the third largest source of the potentially hazardous toxins, according to the 1980 report originally prepared for the Environmental Protection Agency (EPA). "EPA has been authorized to establish health standards for these hazardous pollutants for over a decade, but they have been putting it off & putting it off, no doubt due to encouragement from the petrochemical industry," said Willis Farley, a retired Machinist/chemical worker and a representative of the Coalition on Legislation for the Elderly. "EPA has established health standards for only four of the hundreds of toxic air pollutants being emitted by chemical plants around West Virginia." The EPA study listed the 235 chemical plants in the U.S, that emit more than 10,000 pounds per year in aggregate of thirty-five (35) potentially hazardous air pollutants. FMC emits over 2 million pounds per year of the 35 pollutants, while Union Carbide's Institute plant gives off over 1.5 million pounds per year. UCC 100211 MORE ' MORE MORE TOXIC AIR POLLUTANTS Page Two According to a report prepared for the Natural Resources Defense Council and submitted to Congress in December by two expert scientists, thousands of future lung cancer cases each year could be prevented by fetter air pollution control. At least 11 percent, and most likely 21 percent, of lung cancer cases now occurring each year are probably attributable to air pollution, according to Dr. Nathan Karch, formerly senior staff scientist with the Council on Environmental Quality and Dr. Marvin Schneiderman, former associate director of the National Cancer Institute. This means approximately 10,000 to 20,000 cancer cases in the U.s. population due to air pollution. In the future, the scientists said, up to 19% of new lung cancer cases may result from current levels of air pollution, unless reduced. In addition, the American Lung Association recently announced that one out of four cancer victims die from lung cancer. "Congressman Henry Waxman introduced a Clean Air bill, H.R. 5555, which addresses this problem of toxic air pollutants, just last week," said Charles Garlow Director of the W.Va. Clean Air Coalition. "It would require the EPA to establish health standards for 37 hazardous pollutants that the EPA has had under 'evaluation' for more than four years, without action. These are dozens more substances in the air of potential concern. We call upon our W.Va. Congressional delegation to support the Waxman Clean 'Air bill and reject the Dirty Air Dingell bill, H.R. 5252, a competing piece of legislation. W.Va. Congressmen Mollohan & Benedict are co-sponsors of the Dingell bill, H.R. 5252.'/" Garlow added. "W.Va. Congressman Cleve Benedict is a member of the House sub-committee on Health & Environment, which is marking up the Waxman Clean Air bill fi> the Dingell Dirty Air bill this week & next week," commented Mr. Farley. "Benedict's record has been 100% against Clean Air so far. We're very disappointed. Those of us UCC 100212 TOXIC AIR POLLUTANTS Page Three who live here in "Chemical Valley", also known as Cancer Valley, should be very concerned about Benedict's voting record, "*: "The chemicals listed in the 1980 study include such unfortunately well- known, mean-sounding compounds as carbon tetrachloride, chloroform, dioxin, formaldehyde, PCBs, phosgene, and benzenes of all sorts," added Farley. "For too long, we have focused almost soley on coal-fired power plants and have left this problem of chemical air pollution on the back burner," he continued. "These .are deadly chemicals. Sometimes only a few parts per million are all we can stand." Other W.Va. chemical plants that emit more than 10,000 pounds per day of the 35 pollutants are: Dupont ; Belle, WV Diamond Shamrock Belle, WV Union Carbide So. Charleston,WV 201,300 pounds per year 218,390 R RR 55,410 n nR Dupont Parkersburg, WV 700,000 R RR Borg-Warner Morgantown,WV 24,000 R RR Koppers Follansbee, WV 26,988 Mobay PPG New Martinsville, WV 1,256,556 New Martinsville, WV 400,170 R R RR RR American Cyanamid Willow Island, WV 17,900 R RR -30- UCC 100213 have had no difficulty in attaining compliance levels. Less standardized processes with innovative control equip* ment, however, have experienced frequent breakdowns. Typically, other processes with violation problems arc sources which either produce odors or have poor maintenance procedures." The San Diego study. conducted by Pacific Environmental Services, cites as an example of "failure with the technological forcing policy" mandated installation of vapor recovery systems on gasoline dispensing facilities for vehicles. "The mandate came too soon to have a reliable system available." the study says. Data problems. "There was a general lack of stack tests at nearly all sources," reported Pedeo in a study of compliance in the Houston area. "Compliance tests arc usually performed within a few months after the equipment is put into operation; further tests arc generally not performed unless there is reason to believe that the source is out of compliance." As a result, the study said, "current emissions are difficult to quantify" and "emissions tests are generally not performed on a regular basis." Tlie Houston study also found operation & maintenance programs "generally at a low level" ("none of the sources described a comprehensive preventive maintenance program"); and spare equipment and parts inven tories "inadequate" and in some cases "almost non-existent". Pedeo also reported that a local rule permitting sources to escape findings of violation -- if they notify regulators of an "upset condition" and show "reasonable diligence in bringing the emission under control" -- tends to be overused. "The rule seems to be utilized in some cases as a substitute for the installation of proper control equipment." But the study found "almost constant surveillance" by local regulators has been "an effective means of obtaining compliance with regulations." Reporting problems. A study of New Jersey air pollution sources, conducted by The Research Corp. of New England, found that 13 of 22 sources at some time had excess emissions but also found a relatively mature compliance program in place, "with a positive attitude toward operation and maintenance of control equipment on the part of most operators." But the study also identified some problems. The "strong enforcement posture" of New Jersey regu lators "discourages voluntary reporting of excess emission incidents. The lack of a requirement for submission of hard documentation of continuing compliance (e.g., continuous monitors, periodic stack tests) also dis courages routine accumulation of such information. It may be that the strong agency enforcement attitude promotes a source attitude which seeks to avoid having available self-incriminating material." THE NATIONAL GOVERNORS ASSN. IS SEEKING EPA FUNDS FOR A WASTE SITING STUDY, last week for mally submitting its proposal to EPA for a one-year study on problems for slate siting of hazardous waste facilities. The study would be a continuation of an EPA program to include state participation through NGA in implementation of tire Resource Conservation &. Recover)' Act. To date, those activities have focused on invol ving the states in the drafting of the regulations. That focus will now shift to hazardous waste siting. The NGA-proposed study would in pan be a followup study to a survey recently completed by the National Conference of State Legislatures which catalogued the hazardous waste disposal plans in 37 states. The NGA study would concentrate on current state problems and stale reactions to public participation financing and liability aspects of siting waste facilities in their state. The study will examine current siting regulations in each state, explore "the pre-emption issue" to discuss each state's attitude toward federal pre emption, and query states "on how they feel about regional cooperation" for siting waste disposal units. The final product of the NGA study will be position papers submitted to EPA by year-end outlining key state concerns. The information is expected to plug into EPA's own efforts to develop a siring policy. EPA last month formed an internal hazardous waste siting committee (Inside EPA. 28 March, 13) to explore these siting issues and is pointing toward development of its position following submission of the NGA study. REPORT RANKS TOP 20 U.S. SOURCES EMITTING CHEMICALS UNDER STUDY BY EPA An EPA conlractor report assessing total emissions from 35 possible airborne carcinogens has found * FMC's South Charleston. W.Va., facility with the highest exposure rate, followed by Arco's plant in Hous ton, an IMC facility in Sciplc. Pa., and Amoco's Decatur, Ala., plant. Tire report, prepared by Systems Appli cations Inc., evaluated total U.S. dosage for 35 chemicals tliai are now under sindy by' EPA to determine if these chemicals should be listed as hazardous air pollutants. Encased in that report, which ranked the 35 chemicals in terms of total exposure to the population at large (Inside EPA. 2S March, 3), was a rundown of the 20 largest U.S. emitters of these 35 chemicals. Systems Applications surveyed major point sources nation wide, providing the basis for the list, which appears on page 10. EPA officials have explained that no decisions have vet been made on which chemicals to list as hazard ous pollutants, hut they said that pending EPA decisions, these 20 major sources might become prime candi dates for regulatory control. Dow Chemical's Freeport. Tex., facility, for example, may well require new controls since the plant emits trichloroethylene and EPA officials have indicated that trichloroethylene has INSIDE E.P.A. - April 4, 1980 UCC 100214 9  o;ii a high probability ol carcinogenicity and a high exposure rale -- thus making it a prime candidate for listing. (Ifi4 the following, dosage is calculated as exposed persons X annual average atmospheric concentration of exposure). Company Rank-flocafion) Chemical 1Individual Chemical Dosage (ug/m^ x people) Company Rank-flocalion) Chemical Individual Chemical Dosage (ug/ur x people) , l^HC (S. Char^Pron, WV) 2 Arco (Houston, TX) - Carbon tetrachloride Toluene m-Xylene o-Xylcne p-Xylene 3 IMC (Seiple, PA) Acetaldehyde Formaldehyde 4 Amoco (Decatur, AL) p-Xylene 5 Allied (Mounds- ville, WV) Carbon tetrachloride Chloroform o-DichlOTObenzene Methylene Chloride Phosgene Toluene 6 Amoco (Copper River, SC) 7 Monsanto get, IL) 'p-Xylene Benzyl chloride Chlorobenzene o-Dichlorobenzene p-Dicblorobenzene 2,3,7,8-TCDD Toluene 8 Vulcan (Wichita, KA) Carbon tetrachloride Chloroform 2,3,7,8-TCDD Methylene chloride 9 Dow (Freeport.TX) A 10 D^Knt (Parkersburg, WV) 10 Allyl chloride Carbon tetrachloride Chloroform o-Dichlorobenzenc Epichlorohydrin Ethylene oxide Methylene chloride Phenol Phosgene Propylene oxide Toluene 1,1,1-Trichlorocthane Trichloroethylene m-Xylcne o-Xylcne p-Xylcne Formaldeliyde 2,310.000 12,500 9,870 3 7 J,000 302,000 695,370 9,750 581,000 590,750 * 558,750 . 725 18,900 382,000 70,600 6,190 8,290 486,705 381,000 11 Union Carbide (S. Charleston, WV) o-Dichlorobcnzene Phosgene- Propylene oxide Toluene 12 Hercules (Hopewell, VA) Nitrobenzene *13 Shell (Deer Park, TX) Allyl chloride Epichlorohydrin Phenol Toluene m-Xylene o-Xylene p-Xylene 14 Du Pont (Deepwater, NJ) Carbon tetrachloride Chlorobenzene Chloroform o-Dichlorobenzene Nitrobenzene Phosgene Toluene 145,000 4;460 3j050 5,560 158,070 158,000 2,160 40,300 1,570 7,520 647 45,200 15,700 143,550 25,000 13,900 33,300 48,800 330 3,500 6.740 1,580 282,000 15,200 24,400 1.6 960 324,142 36,400 44,700 0.73 161,000 242,100 15 Mobay (Baytown, TX) o-Dichlorobenzene Phosgene Propylene oxide Toluene 16 Dow (PJaquemine, LA) Carbon tetrachloride Chloroform Ethylene oxide Methylene chloride Nitrobenzene Propylene oxide 1 ;1,1-Trichloroethane 131,570 116,000 2,080 123 4,520 122,723 14,900 8.440 10.500 34,800 13,200 4,430 30.300 4.950 1,780 3.830 67,400 19,100 6,310 21,100 8,320 1.110 22,700 11,200 ; 71,600 1,550 180 100 84 24 1,314 199,000 17 Du Pont (Laplace, LA) 18 Union Carbide (Institute, WV) Chloroprene Toluene 9 Nitrobenzene Propylene oxide 19 Olin (Lake Charles, LA) o-Dichlorobcnzene Phosgene Propylene oxide Toluene 116,570 90,200 25,400 115,600 109.0CTO 4,130 113,130 104,000 1,320 57 4.240 20 Celanese (Bishop, TX) Acetaldehyde Formaldehyde 109,617 4,910 99,100 104,010 SntJv i/iovcj totals os indivatrdt hut individual ihcmlcol Jtncs d*nmi odd up it) total, ft individual listings were used. Shell plant would rnnk 19th (total- 113,097}. UCC 100215 INSIDE E.P.A. - April 4,1980 I