Document 2Nb1rq6RRY0K4GbeygRq5572R

OFFICE OF TOXIC SUBSTANCES MAR i r- ib/u UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 20460 March 11, 1975 Mr. Milton Friefeld Manufacturing Chemist Association 1825 Connecticut Avenue, N. W. Washington, D. C. 20009 Dear Mr. Friefeld: Enclosed you will find a copy of EPA's Vinyl Chloride Task Force Report, which I indicated I would mail to you. You will also find attached, a recap of each of the EPA vinyl chloride recommendations identified in the task force report, with the lead office clearly identified in the column next to it. Should have further questions, please contact Dr. William Marcus of the Special Chemicals Branch (Telephone: 755-030C). Sincerely yours, Don Marlow, Chief Special Chemicals Branch Enclosures (2) ASI 00021794 ASI 00021795 Recommendations ].. An alt standard for VC should be established as soon as practical under the Clean Air Act for VC and PVC poly merisation plants and, if warranted by further investi gations, for PVC fabrication plants. The Agency should determine the ambient levels that are likely to be achieved and, to the extent possible, the health risks associated with such levels. 2. Additional ambient air monitoring should be carried out to support regulatory action under the Clean Air Act, These efforts should include sampling at a number of care fully sel.eeted sites around a few VC, PVC polymerization, and I'VC fabrication plants. The monitoring measurements made at these facilities should be correlated with specific in-plant activities such as reactor venting. 3. Mare detailed material balance studies should be conducted, in cooperation with industry, at a few VC and PVC poly merization plants- Specific VC leakage points should he more clearly identified, and attempts should be made to correlate the magnitude and timing of the estimated losses with the levels of VC detected in a monitoring program. A. 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. * 3. A limited VC monitoring program should be undertaken of dr i.iiking water suppl.les which might be contaminated Iron vd discharges from nearby PVC plants. Prior to under taking the program sampling and analysis procedures should he carefully reviewed and refined a3 necessary. Responsible Office* OAQPS OAQPS OTS OTS ONTO * see last page t-",* n Brrnnmonrln cions A studv should be conducted to determine the amount cf VC m i grn t l.ng out of PVC products used in water distri bution systems - such as PVC pipe or storage tank liners. Prior to undertaking the program standardized r.ampl 1 nr, and analysis procedures should he carefully reviewed and refined as necessary* `Li' I us11re comparability of results between laboratories i".!1 a *dmul r! further develop its interim method into a st .indnnl Lzcd method for monitoring levels of VC. Conci'i ronL 1 y, the Agency should also investigate the fens Ui ULtv of developing a continuous air monitoring device. Monitoring and brnch-scoic studies should be conducted around industrial storage and disposal sites and munici pal disposal sites to determine the types and quantities of toxic subs Lances leached or discharged out of (a) semisil.id and solid wastes generated by VCM/PVC facilities, or (h) r'VT, products discarded by consumers. If these studies indicate that there could be a health or environmental hazard, guidelines should be developed io control the storage and disposal of these wastes. Hie responsible Off Lee .should continue to support currently planned VC toxicological studies. ` tile responsible Office should continue to support currently planned VC epidemiological studies. dorc intensive studies should be conducted on the behavior of VC in the atmosphere and in the aquatic i rv ; r-'iuncni:, and particularly on its degradation ructr. end related chemical, reactions. These sl'! should be supported by both industry and Government. GRD GRD OSWMP ORD OTS/ORD ORD AS I 00021796 ASI 00021797 vinyl chloride task force recommendations Recommendations__________________________________________________________ Responsible Office The Industries covered by the Effluent' Guidelines for the Pl.-jsties Industry promulgated under the Federal Mater 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 water of toxic metals and other chemicals of particular concern. Enforcement efforts, including spot checks of manulecturers, distributors, and retail outlets, should continue to be pursued vigorously to insure that pcsticidal spays containing VC as a propellant are moved from the channels of trade as rapidly as possible. OWQPS OEGC 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 supportive actions as appropriate. ORL The Agency should build on the experience gained in responding to the problems associated with VC in strengthening its organizational, manpower, and contractor resources to anticipate and respond to similar situations involving other chemicals. Readily available information on the handling of VC should be made available to the Regional Offices to n--s iai; them in responding to rail or barge accidents resulting in the release of VC. OTS Laboratory procedures for safe handling of VC should be. developed and distributed to all LFA laboratories. Consi deration should be promptly given to how such procedures can most el feet Lvcly be developed f^a number of carcinogens that arc likely to be of concern tc^Pe Agency. ORD AS I 0 0 0 2 1 7 9 8 \'I, Wr*U;.VdxTi n>: \b< Rccommcnd.it5.ons Res msib 3.1 Office Should the Toxic Substances Control.Act be enacted, prompt consideration should be given to the need for and feasibility of (a) requirements for industrial testing of the-, toxicity of VC at low ambient levels nod the persistence of VC in different media) and (b) limitations cn the levels of unreacted VC monomer in selected PVC products . 0T3 Id. Tiic. Agency .should continue its leadership role in .bringing together the interested Federal agencies to exchange views on regulatory actions, supporting activities, and research projects directed to pro blems associated wLth VC and PVC. In addition, an appropriate interagency mechanism should be developed to address a broader spectrum of potential problems associated with the plastics industry. OTS 19. ERA should exercise leadership in stimulating Govern mental and industrial efforts to analyze 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 * Cedes OAQPS - Office of Air Quality Planning and Standards OTS - Office of Toxic Substances OWPO - Office of Water Program Operations OSWMP - Office of Solid Waste Management Programs GP.D - Office of Research and Development CEOC - Office of Enforcement and General Counsel (subsequently became Office of Enforcement) C-RL - Office of Regional Liaison Received wit?t ^on Marlow's letter (EPA) of March 11, 1975 to M. Freifeld