Document 3Qn3nmeMLzzn3NGOXvxroo7O6

TO: Environmental Coordinators ^ <7^\ FROM: DATE: InltroWc* Cowwmiteartow SUBJ: T. G*. Grumbles February 8, 1989 PROPOSED CMA RELEASE REDUCTION POLICY AND PROGRAM VIST/ Attached is material regarding a release reduction policy being proposed, or formulated, by CMA. A briefing meeting is being held March 1 in Washington to present the attached and begin receiving member company comments. Please review the attached and let me know if you have comments on the attached drafts and/or would like to attend the meeting. I plan to attend the meeting. Please give me any comments by February 24. T. G. Grumbles dlj .520 Attachment cc: Plant Managers - R. W. Seymour-ABER, L. R. Bauer-BALT, G. D. Williams-BLANE, J. B. Maher-HMD, J. Friend-LCCP, J, W. WareLCLAB, R. A. Conrad-LCVCM, H. D. Garrison-OKC, P. L. Foote-PREM J. A. DeBernardi, T. H. Huffman, R. D. Gamblin vc X .-/ // kX1 / /-?. /: ' . .<< c 'TiT.- ' / JL-Z *-- . 000029^79 vW TSooH 0 'T&G?.) ijjblcQL' -T r- CHEMICAL MANUFACTURERS ASSOCIATION rcF _ /" ' -7 *l' e* l January 30, 1989 TO EXECUTIVE CONTACTS OF CMA MEMBER COMPANIES Dear Executive Contact: Subject: Member Company Comments on Proposed CMA Chemical Release Reduction Policy and Program -- March 1. 1969 Briefing The purpose of this letter is to urge the attendance of your senior environmental, health, safety and legal managers at a March 1, 1989, briefing on a proposed major new CMA program concerning Title III, Section 313 releases. The proposed program encourages CMA member companies to increase their efforts to reduce releases to the envizaammat and ho increase the understanding of health effects from thesmoreleaseau- Public policy debates on Section 313 release inventories are*anticipated, to- gain momentum vhen EPA releases its computerized inventory later this year. This new program will position the industry in a positive light for any follow up debates. The proposal is the product of an intensive six month process involving health, safety, environmental, government relations, legal, and communi cations experts from the member companies, with careful oversight by the Executive Committee and Board of Directors. The proposed voluntary policy and programs, built upon CMA's existing air quality policy and waste minimization program, are crafted to respond to immediate public concerns focused on the Section 313 release reports and to demonstrate industry Leadership. To assist you in preparing for the briefing, I am attaching a copy of the proposal. Please treat these materials as confidential. CMA's Environmental Management Committee will evaluate comments and make revisions over the next two months and make a final presentation to the Board of Directors in April. The March 1 briefing is designed for senior environmental, health and safety, and legal managers, to review the proposed policy and program, discuss the relationship to other CMA initiatives, its implementation, communication strategy, impact on local operations, and to provide opportunities for attendees to ask. questions. A tentative agenda is enclosed. The briefing will be held at the Ramada Renaissance Hotel, 1143 New Hampshire Avenue, N.W., Washington, D.C. (202) 887-0800 beginning at 9:00 a.m. A block of rooms has been reserved for those who will arrive the night before. (When making reservations refer to RR #392. The cut off date is February 15, 1989.) vvv 000028480 25Cn M Street. NW, Washmgion. DC 20037 202-887-1100 Telex 89617 (CMA WSH| Executive Contacts January .30, 1989 Page 2 r. To assure that all member companies will be accommodated at the special briefing, I am requesting that you designate no more than two represent atives to attend. I would appreciate your contacting David V. Carroll's office (202/887-1185, Ms. Stephanie Henry) to advise who your representative(s) will be for the March 1, 1989, meeting. Ve ask that each attendee bring a check made out to CMA in the amount of $30.00 to defray the costs for continental breakfast, coffee break, and the meeting room. If you have any questions on this matter, please contact David W. Carroll, Director, Environmental Programs, (202) 887-1164 or Ann M. Mason, Associate Attachments cc: Environmental Management Contacts Health and Safety Contacts Responsible Care Coordinators Title III Contacts CAER Coordinators Legal Contacts Washington Offices State Contacts VVV 000028481 TENTATIVE AGENDA PROPOSED CHEMICAL RELEASE REDUCTION POLICY AND PROGRAM BRIEFING MARCH 1, 1989 7:30 - 9:00 a.m. Registration and Continental Breakfast 9:00 Introductory Remarks * R. A. Roland, President, CMA 9:15 Section 313 Impact and CMA's Responsible Care Program J. Holtzman, Vice President-Communications, CMA 9:35 Draft CMA Chemical Release Reduction Policy - C. T. Seay, Chairman, Environmental Management Committee 9:50 Questions and Answers 10:15 8reak' 10:30 Programmatic Support Proposals Regional Monitoring and Modeling - R. Bradford, Leader, ad hoc Chemical Release Reduction Group Health Effects Evaluation Program - R. Van Mynen, Vice Chairman, H&SC Smaller Company Assistance - R. Bradford Communications Program J. Holtzman 11:15 Questions and Answers 11:40 Concluding Remarks -- C. T. Seay 11:45 noon Adjournment VVV 000028482 CHEMICAL N POLICY CONFIDENTIAL CHA will proaota, mobs its Banker ccspmi--, practices that protect the safety sad health of employees and residents of coHsnities In. which they operate. Onr industry's foal is to assnre that employees and eoMnaitles are not adversely affected by oar operations sad to eacoorsfe others* inclodiag oar ssppliers end costoners, to achieve the sans goal. GHA understands the poblic concern regarding health effects fron releases into the >mf limit CMA also helieves better laforaation on the effect of these releases is needed to assnre folly Info inert action by govemnant* Industry and the poblic. CMA nsnhsr will increase their efforts to redoes releases to the nvirnnsit and to increase the iinrtarafawHni of health effects fron these releases. Existing industry ectlTlties will be consolidated to bring focus to this effort so that the industry's perfornsnee will bo inproved and the industry's nargin-of*safety will be increased. This CMA policy, reeonasnded for inplanantatlon by each nenber conpany at each of its operations, includes the following elenonts: 1) Doing SARA Section 313 reports as a base, inventory existing releases to all nadia. Chonieals other than those covered by Section 313 will be^ included as appropriate. 2) Establish priorities for tho Inventoried releases baaed an factors including thsix potential inpact and the level of coanunlty concern. 3) Fornclata a release reduction plan, based an this ranking, to increase the correct aargln-of"safety, increase operation efficiency, and address areas of poblic cancan. In the plan* transferring ralaaaas fron one nedia to another should be used only if the overall volune, toxicity, and eavlrpnaantal inpact is reduced. Reductions nay be achieved by any of the following nethoda, but it la recognized that such reduction efforts are listed in declining order of desirability and nenber conpaaies will direct their efforts accordingly: i) Soares reduction. li) Reeyele/Rense. * iil) Treatirnt to redoes volune and/or toxieity before release or disposal. 4) Initiate a aysten to report release redaction progress. 5) Coanualeate overall plana and progress to anployeos and tho public. In addition, to Increaao understanding of tho efforts of chenlcal ralaaaea, CMA will work to hotter detamine the concentrations of chonieals in the anvirounent and the health affects of such chonieals. Finally, in inplenenting all of the above, CHA will footer assistance to onaller plants and eonpsnies. CMA EC 1/17/89 000028483 VVV nOIOMAL MOwrimTiB Aim Pfimr The pablle paretlatt that no --nr--it data ailata oa Sartlm 919 h--Inala nlaaiad to the air, surface vatar, or gsouodwctcr. Tbarafora, thaf baliava "taaiea" oro * baalth tbraat. Maitail anajfwrtai data iadleaca that thoxo aro vary --all o--tmloaa of ahaaiaali la coneenitl--. SPA aod others hare that tho (aaaral sir qaal Ity is Inprm fat IV- ohJactlro of tUa-pcejaet is to proaetivaly nhtalu earn data to ecnflm that facflno 913 nhanlrala g--arhlly dmaoS p-- a rlah~tOwaanannltlac In addition, it *<^4r,~4 to achieve a secondary baoafit of getting aohlaot data ayataoa la place to onoltor propaai. Thm project prop--al fnnaeae ao air s lssoao ao tha initial priority with pooaibla safaoeq--nt phaoa la of svfaeo > --d- gro--duster progra-- to- aaoara a nalti-nedla parapaatito# / Tha project will provide for data eollaetloo aslag nglrtaal air dispersion aodelling to predict hotshots aod optiaiao tho location of a slain-- of five to tan o--lfora par Mpliag location. Five to tan target tegloos are re--ended aa tha nlnln-- level of effort. 0FTHW8 CCMSIDEKiD Thr-- progranootic lavala of activity vara rnneirtarad. Tha first alternative la a baae ease- that auppuiti Options 219. Option t places tho local CZC'a in tha leadership position hot tho balk of the total coot atill asst ha fanned by the local Industry. Considering CMA's budgetary e--etraints, this la the re--ended option. Option 3 creates a sev area of activity for CMA, and carries a high prleetag, although it delivers the earl-- leverage, visibility, and credibility. 1. Baae Cm Gather available date, into a central, reference systsn(e.g., Bo--ton Baglonal Monitoring Network data, lay Area Air Toxica Study,SPA indoor air atody, and volunteer data acquisition by nanher eoopaniee). This central reference aystao on nonitored data can bo aoppl--anted with a CMft regional dispersion nodal and a CMA regional aanpl Ing protocol. Developoant of the nodaling/nonitoring protocols will coat about $50,000. Protocols can be developed by contractors by Juno-1909. Tha data gathering effort will coat appraafnataly $50,000. 2. Proactive CIC Activity Kepllcate the Hbueton Begional Monitoring project, or codified approach--, in priority are-- through CMA leadership. Loca1 progr-- vill be conducted by consultants with local industry financial support and technical direction. This option plac-- the entire financial and apoMt bard-- an local industry end is probably limited to tb--e vw 000028484 ii CONFIDENTIAL _______with uictinc, elv CXC*- Dm prtbawrt la Cbls way my hm lam credibility became the public ptreim that it is "industry" gaoereroH ritbar than a cooperative siftrt land by rimeinlfy leaders. The total coats free local iadnstry for significant dallisi/mitotiai program typically will bo in tha range of |500,000 to |1 million par rafioa par year. lisp don amageaaat support fna CHA a--har na^ianlas will ba nacaaaary to astabllsb regional --program oodar this option. 5. Proactive au Aetiwits with ^ (thing tbs looaton Regional Monitoring Network as a working nodal, CKi offar --grants aod technical assistancs to stats and local &***agencies, CIC's, or fooadations and i:omissions to establish and carry Voot regional air nenitoring program keyed aroond significant 515 releases. Funding will ba leveraged and industry will ba visibly involved in assuring valid data collection for program proposed by tbc local comunitias. Coder this option, CHA will cover at leaae a third , r*** sad pomibly aore of the total coat format least tbs initial year. CMA's direct coat will ba approninatoly fl to |5 ailllon dollars for tha initial year. . '-uKC^' HOmMEDIA TOTAL PROGRAMS groaodsatar and Surface Voter program can ba introduced on a delayed tlae line. 1. Groundwater Support state vallhaad protection program through partnership* with local govamaant. Local industry eight provide data and technical , axpartisa, i.e., teaporary locals of hydrogaologists, for axaapls, as wall as grant aeoey for groundwatar aonitoring within tha wellhead protection program. This progrm is not currently funded at the Federal level, yet the States are anxious-to protect their public water apply cs suggested in tho 1986 Safe Drinking Voter Act Amndaaats. 2. " _/ Provide grants to orgsnlssfeiam, such as, tbs Chesapeake Say _ Foundation, The Hiasiaslppi River Coalition. Surface water quality could be aonitored la the iaaediate area of amhar rnapeny facilities i to supplemot State annltoring efforts. ____/W CHA SC 1/17/89 BD 1/18/89 u VVV 000028485 CONFIDED l IAL support ikpobuxign rm regional huniiulimb modelling 1. tomtom, TX Baton Rouge, LA Bmtar Na* Tork/Nw JttMf Philadelphia, PA Falls, NT lf Atm District, CA Booth Carnot (Lew Angeles) District, CA Chicago, ZL Kaunihs Valley, W VaaUs|toft, DC (control) 2. b--m l r--Glance rj^jL-udt' Dm Booston Potions 1 Monitoring Corporation (BRO was forged la 1979 by local ores boslaoosoo to obtain anhtenf air nanltorlat data for the criteria air pollutants. Sloven (11) stations raee* established. The prinaxy pnrpooo of BBf was to snablo co^anian to satisfy Prevention of Significant Dotorioration (PSD) poraltS application reguir--ents. Since its inception, the focus of data collection and analysis has shifted to neat changing needs. Collected onoao'dota, ia particular, has bean very useful to industry and the State ia evaluating air quality, the effects of various salssioa soorces and controls, and the significance of eonitor plac--ent. In 1987, the BRM's focus was expanded to include collectint anbient air ecncentration data for about 170 specific chenicala. Including many SASA Section 313' chenicala of concern. Sanples are obtained for a 24-hour period every sixth day at six exlstlnt noaitorlng stations covering about 900 square Biles. This noaitoriat i* intended to assess long-tar*' coMuaity exposure to these-- substances ia outdoor air. During each stapling period, a 15-liter canister is filled at a rate of A ec/nia, and then the canister is transferred to the Radian Corporation for analysis. Sxteoslve QA/QC procedures are eaployed. Meteorological conditions are recorded for each site to support tasessnsots of the data. The cost of this targeted oooltorlng is approsiaately 9*0,000-100,000/atation/year. The nenitoriag stations are operated by Radian Corporation, and the satire ARM effort is supported by nsnber-ca^asy contributions of about 950-$60 per uasufactorlag eaployee. 3. lefam Sob-- At.. AAjmt Air Hon<tnHn> In early I960, several coopanies in the Baton Rouge, LA, area initiated an effort to better understand the anbient air quality in the Baton VVV 000028486 ii CONFIDENTIAL Bong* area and the effect of cnlsslons on air quality. The effort included ilwn-ttn anblent air sanpling and analysis by Radian Corporation and nodellng by Trinity Consultants. The total coat la rgyrtsil to ba approsiaataly $130,000. Hmltoriin consistad of the eollaetloa of 24-boar eonpoelte aMplaa at four (4) locations for tbraa (3) uaiasr iirlve days at aach slta and inelndad significant Q4/QC procedures. Total coat for tha 12 saaplaa, analyses, and Q4/QC, including estop of tha fsnpnrsry aonltorlng station, vaa $65,000. Tha sanpilag and analytical procadaraa vara tha sane as for tha gn*vg DM project* Modeling consisted of dispersion cal rail ations for tha anlaalons of 17 scbatancas fron 13 area facilities. In addition, tha 6SS nodal vaa asad to estlnate arpoanra and risk in tha area for too of tha substances. Total coot of tha Modelling effort is about $65,000. On-site personnel involved in the interpretation and cse of the noaitorlng and aodsling data with lntareeted public consider tha nsnitoring. data to be aoet believable and, therefore, the aoat nseful. Petrochenlcal Ccnnlex In early 1988, enhanced Indnstry Hygiene (IH) collaefetarLtabe aonltoring techniques were used to obtain anbient air quality data for eight VOCs in the vicinity of a najor petrorhenicsl conplex. Tha enhanced techniques vara capable of qoantlfying- lav ppb concentrations of the substances. Seapling vss conducted st eight locations with seven 48-hoar ccnposite espies obtained at each location over a three-vest period. Total cost for sampling, analysis, sad Q4/QC vss $50,000. Based on the success of this affort, tha sans technique has been eaployed at othar locations. Dispersion nodalling is nov being initiated la the area to estlnate the snblent eontribntlcn at 400 receptor locations of ten chenlcsls. Fron 200 enlaslons aooreaa at five facilities, the nodellng cost 1s estimated st $25,000. SC 1/17/89 SD 1/18/89 Vki T VVV 00002B487 CONFIDENTIAL aarranrem. options rat casmm HKAT.TB EMCIS KVALOATION PSOGBAH ttft Ad Hoc PhwicBl liliMt UAtetlon Work Oroup, ad th Health and Safety CoanittM bm cbmlopad eight options for rseponding to th* public's concern about oponn to rhamlnal releasee. That options an pressated to help identify tbs noot beneficial course of action for iaplaaontlng this program slanant. Inlwtiat tbs offset of chsmical awpoeurs an eaaniti health la control to addressing tbs public's concent about ebaadeal releases. Clear and widely accepted netbods to identify acceptable levels of exposure are assantial to explain tho meaning of Title XIX, release redaction, and waste aiaimiMtloa date. After a discussion of all options, tbs eonseases of the Ad Hoc Verb Creep, sod tbs Hoaltb and Safety Coonlttse foeaaea increasingly on CHA sponsoring the development of consensus asthodologyis) at ant ergsnixstioa sneb as CXXT. (See Options 3 sad 6 below.) lbs cost oft perselng this option Is approximately $230,000. The longer ten appliestlott of tbe rnacsncnc netbod(s) by other groups to a wide variety of substances entails additional coats. mmiUBSsmm. Tha Conanaity Health Effects Evaluation progran seeks to identify aethode to characterise exposures of tbe general public to chenicals. The effort will work to identify existing netbods to determine safety, cad to improve tbe existing state of science In determining safety. Moreover, tbe progran will work to improve the public acceptability of the matures used to judge safety, / iK.mqwi? Options considered for tbe progran are listed in their order of resources required: Option 1: Safety is a natter of public perception and acceptability. Industry's activities will always be suspect and CHA should j encourage govemnent regulatory agencies to set sefsty stsndsrds. Until standards are sat, industry will use ' existing measures to Judge sefsty and explain these to tbs g' public. Option 2: Bacourane Ksaearch. Industry could encourage research by government agencies and universities to improve methods by which to judge sefsty. vvv 000028488 Such sneouragsmnt will only b suggestions that this is s sorloua iiatM that nasrla attantioa. Option 3: Industry coaid fond raaeaxch by universities, national laboratories or consultants to l^.imia osthods by which to Judgs safaty. Option 4: Ssild. for CiMiuitr Ott eoald --tbs eaananity eipoanre values obtained throo|h its lafOnotion --prngroe. Consansva areas eoald be identified, and a needs assesrant and feasibility stndy eoald be dono for future work In developing exposure values. Option 5: Develop Consensus on HethodoloarU). Industry eoald farther develop consensus on nothod(s) by which to establish rn--unity exposure values. The nethod(s) will not be applied to specific chenicals, but published in the scientific literature for use by individual colonies or tovsmnsnt agencies. The application ad enynsthod to specific chenicals will often require the developsant of additional data on that substance to fozsa scientific decision. Option 6: ^^soendent Orranixation. The chsnleal Industry eoald fund on outside organisation, such as CIIT, to develop and apply a nethod for setting eoannaity exposure values. Option 7: Industry Could Develop end AppIv a Methodoloev for rnWIII I \ 1 niNMiga_yalMas. An Industry group coaid develop a nethod for setting eoanunity exposure values. This nethod and data on specific ehenicels coold then be turned over to a standard setting organisation such as AIEA, AC6IH, AS1H, or SPA. Option A: Fund an Independent Itnert Scientific Panel to Develop and AppIv a Msthodoloxv.fnv f timiT* Yllttea. Tha chanical industry- could fund an independent expert scientific panel, through a university research center or national laboratory, to developssad apply a consensus nethod for setting eonnunity exposure velues. ;>The nethod and valuas will then be node available to standard knotting organisations. VVV 000028489 Costs: Tins: CONFIDENTIAL Costs will Tory itrinrllin an tta options oslsotsd. Costs rap ftcn nothing for option 1, to $30,000 - $50,000 for option 4, $250,000 for options 5, 6 sad 7, sad $000,000 for option 0. flipsnritnt on ths options saloetsd, iaplsnsntstion eonld tsks two to fin years. Ths tins roqnirad dspsnds greatly on ths gssonrcss denoted to ths project. Option 8, for iastaaee, will require 2 yosrs whils option 1 will dspsnd on ths speed with which regulatory agencies set. Options 5, 6, sad 7 will teqaire ons yssr to develop consensus awthod(s) with additions! tins rsqnirsd for application to spsciflc GKA SC 1/17/89 ID 1/18/89 VVV 000028490 u/\U0MNFCIDENTIAL AfflISTAHCK TO m*trwm The weaker riapauise of CHI cn eoalttad to tbo eocenesfnl lapliMBtttiai of both tho lottos ad tho spirit of Titlo IZZ. Booms, oomy oaollos fiopain oso Mat * difflcnlt tiao lapisnoting key riopiwati (--rgemry planning, seeidemt prevention. Mooion reporting, te.) of tho loo. Poor porfoggonro bp any eoapeny, oaoll os large, atf offset tte sop positive proective ooooosoo oodo by OB ooobos rr^unlio. Oil ooohos companies oboold psopido^toohoicol scalarante to thoir cwetoaecs ad --oilor nnopoolio to ahaaamU4 -nine--tel hoolth sod safety profroo^ omow C0N81 Tho following optioos wore considered to assist saol thoir emviroccMntal, hoolth oad oofotp programs. Tho work troop is thst so implementation strategy that coo thooo optioos sill bo tho asst effective. 1. Pfeaher companies will rnnmnnlrats to ad prorido direct ossistones to. oaollos caopoalos through sxlstlnt product stewardship protrows Boil Information poekoto - Invito customers in for tzsinint - Send tschnicol service reprssoatotivea oot to customers CMA will work with tho Cornell of Chemical Association Sxecu- tivea, 0.8. Chamber of Crrsrco, State Choaical Cooncila and other national organiaations to develop eaaaaaieatioa pieces on technical assistance available to ensiles companies and how to access the process. Approximate coot for CMA to l^leaant the activity la $10,000. Commnnicatiooa regarding technical assistance to smaller companies will in earlp Map. Member componlea and CMA, poealhlp oalng eontrectors, will coodnct on-site training for companion' In the following areas: Vasts miniaisatiom/release redaction principles and methodologioo - Process safsty Emergency planning and preparsdness - Ciinnlcatlng with ceployeec and the ccamonity - Public health iaanea. Aa an alternative, CMA and nenber companies will develop seminars/ workshops on a regional/local basis to provide information on the key issues highlighted above. They will be highly participatory and hands-on. They will use ease studies presented by experienced plant personnel. The saainart will partially pay for th--elves. yVV 000028A91 *& CONFIDENTIAL although foods will bo needed to develop fniHiiww aatexials la sone of tho tttia --ofionod (ipproii--ttly $75,000). Tho workshop# coaid bo oehodalod for lato attawr or early foil. Ibo senlner/vorkshops will bo developed and eo-tponsond by: Individual mbor companies - State chanical ertttiMtlaw - CHA/other trodo associations Connell of Chanical iseoclatlnn Kxaentlvee. 3. Hanhsr conpaalos eoald aobilino their rotiroon to provide say of tho services liatod above. There aro any nnlmnwia laeladiai poraaonol availability and Interest, east, and tialat. Nevertheless, this option la worthy of farther coop Adoration. 4. OU coaid establish a technical assistance hotline for anal lor cenpaaios to eall and roqaost help. Vo rocogHio that each ccnpany requesting aasiataneo will have different needs, pressures, and tine constraints. Tho hotline coaid cost opprosinetoly $170,000 per year (including staff) it can bo consolidated into an existing CHA service. The hotline will begin operation in July 1999. 5. Establish assistance progress with key oolversihies whereby ondergrodaate and gradnate engineering students asaiatr analler conpaaiaa in their waste nlnlmlsatlon end releeae redaction profrees. A teas (3-4 etndaats) conld have a project (defined by the canpany) to work on for the aenester. The final report will include ways to eininiae vaate/rcleaaes and operational coats, and axislze effectiveness of isplanantation plana. This process could be initiated through state chenical organisations. Pro jected costa are not dearly defined at this tine. CMA EC 1/17/99 B0 1/19/89. yyy 0000284^2 REGIONAL amp mnrr.r.-mn pwumt PROJECT BACKGROUND Ik* public pttetivM that no --iiirwat dti aslati on Isctinn 919 rhanirala released to thn air, nrfau voter, or groandvstar. Thsrefore, they hallow "toUes" oro health thrust. unulfnrlng dita Indicate that than oro nry avail coigaifritiwn of rhanirala in ccununltlas. SPA and others haw Indlrntad that thn gaonrnl ale- quality la iapmving. The abjective of this project la to proactively obtain core data to nnaflra that faction 919 rhanirala generally do not peaa a rich to oanoanltiee. In addition, it * to achieve a aaconrlary benefit of gsttlng anblant data syateau in place to nonltor progress. Ha project propoaal focaaea on air Sawaaa aa the initial priority with poaaible amhavacant phaae in of aarface and. grondvatar propna to aaaare a nalti nadla perspective. The project vill provide for data collection using regional air diaperalon nodelliag. to predict hetahota and optinlae- thn location of a alnlnnu of five to tea nonitora per aanpliag location. Five to tan target regions are recoaneaded aa the *--m level of effort. OPTICTIS CONSIDERED Three prograanctlc levela of activity were eenaldared. The first alternative la a base caae that aopporta Options 219. Option 2 plaeaa the local CZC's la the leadership poaitian bat the bvlh of the total coat still east be aaaimed by the locel industry. Considering CHA's budgetary constraints, this is the miumiuiJni option. Option 3 creates a oev area of activity for CMA, and carries a high prlcetag, elthoogh it delivers the nairlann leverage, visibility, and credibility. 1- Base Caae Gather available data into a central referenca syaten (e.g., Honeton Regional Monitoring Network data. Bay Area Air Tories Study,BPA indoor air study, and volunteer data acquisition by oanber colonies). This central reference ayatan on nonltored data can be snpplenented with a CMA regional dispersion nodal and a CMA regional aanpling protocol. Developnent of the nodellng/nonitoring protocols will cost about $50,000. Protocols can be developed by contractors by June 1989. The data gathering effort will cost approxinataly $50,000. 2. Proactive CIC Activity Replicate the Honeton Regional Monitoring project, or nodlfled approaches, la priority areas through CMA leadership. Local prograns vill be conducted by consultants with local industry financial support and technical direction. This option places the entire financial and naapover burden on local industry and is probably United to those Wv 00028493 confidential SUPPORT INFORMATION FOR REGIONAL HONXTGftZHB MODELLING 1* Tarwet Arn for Model liax/Hooltorinx Donstom, IX Baton Rouge, U Snitir Nov Totk/Naw Jersey Philadelphia, PA Mfalo/(Ua|flr Falls, NT lay Iras District, CA loath Coast (Loo Angolas) District, CA Chicago, n Kanawha Valley, W Washington, DC (control) 2. Houston Regional Hcanjw< rionco The Hooston Regional Monitoring Corporation (HRM) was formed In 1979 by local area boslaassas to obtain anbiant air nonitorlng data foe the criteria air pollutants. Kievan (11) monitoring stations wocm^ established. The primary purpose of HRM was to enable eonpantan to satisfy Prevention of Significant Deterioration (PSD) permits application requirements. Since its inception, the focus of data collection and analysis has shifted to neat changing needs. Collected osone data, la particular, has been very useful to industry and the Stats in evaluating air quality, the effects of various enissioa sources ami controls, and the significance of aoaitor placement. In 1987, the HRK's focus was expanded to Include collecting anbient air concentration date for about 170 specific chemicals, Including easy SARA Section 313 chemicals of concern. Senplee are obtained for a 24-hour period every sixth day at six existing nonitorlng stations covering about 900 square nilea. Ibis nonitorlng is intended to assess long-tern 11--niffy exposure to these substances in outdoor sir. During each sampling period, a 15-liter canister is filled at s rats of A cc/nia, sad then the canister is transferred to the Radian Corporation for analysis. Extensive QA/QC procedures are employed. Meteorological conditions are recorded for each sits to support assessments of the data. The cost of this targeted nonitorlng Is approximately $80,000-100,000/station/year. The nonitorlng stations are operated by Radian Corporation, and tha entire HRM effort is supported by member-*company contributions of about $50-$60 per manufacturing snployas. 3. Baton ROUXS Amhimat: Air frwitavW In early 1968, several companies in the Baton Rouge, LA, area Initiated an effort to better understand the ambient air quality in the Baton VVV 000028495 OPTIONS POK CGmONTIT wgAT.ni KFFECTS EVALUATION PROGRAM The Ad Hoc Chsmical I>liw Redaction Work Orovp, and the Hultli and Safety CoalttM hm developed sight options for responding to the pobUe's about iipoMrs to rhsnicsl rtlnsss. Hum option* an prsMotad to holp identify tin aoot beneficial course of actloo for 1npT --it tin this pfopa elamamt. Evaluating tho offoet of ehaicsl exposure on rn--nnlty health Is central to tho public's concern shoot chsnlnl rolossos. Close sod widely sccsptsd osthods to identify sccoptsblo loroIs of exposers sso ossoittlsl to explain tho nsswing of Tltlo III, rolosso reduction, snd waste minimisation dots. Aftsr s discussion of oil options, tho consensus of tho Ad Hoc Vork Group, snd tho Health and Safety Coonlttee foensos increasingly on CHA sponsoring the development of eoaseasns wsthodologyCs) at am. orgaalsatloii snch as ClIT. fSee Options 5 and 6 below.) The cost of? pursuing this option Is approximately $290,000. The longer tern application of tho censonsus nothod(s) by other groepe to a vide variety of substances entails additions! coats. 4 PROGRAM DESCRIPTION; The Coanmity Health Effects Evaluation program soaks to identify methods to characterise espoeures of the general public to chemleals. The effort will work to identify existing methods to determine safety, and to improve the existing state of science in determining safety. Moreover, the program will work to improve the public acceptability of the measures used to judge safety. / PROGRAM OPTIONS: Options considered for the program are listed in their order of resources required: Option 1: Encourage Government Action. 4^u> Safety is a matter of public perception and acceptability. Industry's activities will always be suspect end CMA should encourage government regulatory agendas to sat safety standards. Until standards are set, industry will use existing measures to judge safety and explain these to the public. .tU-Ccp Option 2: Encourage Research. y* Industry could encourage research by government agencies and universities to improve methods by which to Judge safety. VVV 00028497  Cocci: Tins: J `v!t- CONFIDENTIAL Costs will ff depending on tbs options sslsctsd. Costs range fros nothing for option 1, to $30,000 - $50,000 fox option 4, $250,000 for options 5, 6 sod. 7, sad $600,000 for option 8. Depending on tbs options sslsctsd, iapl--sntstloo canid taka two to five years. Tbs tins required depends greatly on the resources devoted to the project. Option 8, for Instance, will require 2 years while option 1 will depend on the speed with which regulatory agencies set. Options 5, 6, sad 7 will require one year to develop consensus nethod(s) with additional tins required for application to specific substances. QSA EC 1/17/69 BD 1/18/89 VVV 000028499 s. CONiFIDENTlAL IMISTiHCK TO pioject BACPaoam Ibi Mabtr wihiiIh of Qtt are eoaitted to the successful lop1msaatetlon of both tho lottor aod tho spirit of Titlo IXX. Hoiwrig, May smaller companies oro having difficult tin i^l- anting hoy components (emergency planning* accident promotion, amission rtpntiai, otc.) of tho low. Poor porfotoonro by any company, sooXX or large* ooy offset the many positive proactive measures made by CHA member companies. Oil maaber nopMlii should provide; technical miitnet to thoir cootooorr ad smeller nn^iswiss to oahaeo overell onilrnn--Tol. health aod. aefoty programs. amas. Tbo following options wore eooaidorod to aaaiat smaller thoir environmental, health and aefoty programs. The m work |ronp la that an laplamantatioo strategy that comb: theae options oil! be the aoot effective. .ea with ; of tho oral of ` I. Hamber coopaaiea vill eaoaaieata to and provide direct assistance to anallor coopaaiea through existing product stewardship prograos Hail infornation packets - Invite easterners In for training - Send technical service representatives oot to enstoners CMA will work with the Connell of Chaaleal Association Exseatlvos, U.S. Chsnber of Coansrcs, State Chapical Cooneils and other national organisations to develop coomualcetlon pieces on technical assistance available to snaller conpaaies and how to aceaaa the process. Approximate coat for CHA to implement the activity is $10,000. Coanonications regarding technical assistance to snaller conpaaies will begin In early Hay. Henber companies and CHA, possibly using contractors, will conduct on-site training for companies In the following areas: - Vasts nlnlnization/release redaction principles and methodologies - Process safety Enarganey planning and preparedness - Communicating with employees and the community Public health issues. As an alternative, CHA and amber companies will develop seminars/ workshops on s regional/ local basis to provide information on the key issues highlighted above. They vill be highly participatory and hands-on. They vill use csss studies presented by experienced plant personnel. The seminars will partially pay for themselves. VVV 000028500 d ` kdyfif) A^ "/ #m '-- 3-r// /i J ? X' I^^vl/?''*}<- 6C4&V*&-4> y^O h j______________my y "** Otfi^jksO i A GcJiu/brS h <#eA>^Awv^^if -- -- -- ---------7---. *.:-- r----------iA>*o >VU4^^ ^Ivi' /u-^! jj^*isfer iivn ft > ' r ^/6(L - -- ^ ; i>/& J/J tj' -----J t Co*4&ft /Jj-p/Gfe___________________jz> J.'S'* & ^ gO Lch^ vkjoO- j4t% o /O / __________________________________________________ 7-T^ ro*fP-&; 7*fK V/<- 220_ ` &/ f/yyY)tV) f #a t --o^Lj ^) 7 <Poju^ - C&j> - hzbsJbfc'*4. a+*&t~*Q5 t>v ^vw/. , /^lyl' frf ((jLjtJiJb?L- 54/Ur Sfj 7& &-4J? qO fa 0triX* P*z> ritxtKsC4Z**J SK) pyy*~-bp*-*-*#' J. `ZjJ&Q W&' ^7T---------- -1 K**ff*^ a^'3 7*2' H#*#. v;-# ^' ^'vf' :'- / . \> Fmv^^O-P(^\ '' /" ~: 3'C~ (ImJl**-*^j**i&\ oj-~\ dsfoe ` U)tM%4 4gd!c*-$-S\ t J, <P/J(Jpf/Q Aa^*s~i<>-^ 77 ^mp )b <^<WJ - *npd*0 .gy <34 ***-&-? <^0 dX--*q f&4****\-i**~*^xtf ~___________________________________________________ -fo dttsv*$ p&JL***^ f*~& ^7'Ps^^JxfP^. -ZZpr*' -- '~^#^rwir^pT^ W*frtvHinrjjf*^ tAr*7 Of iprrjf- ~}r? /&fV r^p AryW <ysY -T^p^TjcfJWpt A --&*&***frr ' -*$ -'"'*6 &77^1 g^g> fast fas? ?6/-- -L ^JU^ f<L^d ^ 4) &- >C> 1 J+JLjdhp 40W**4% r^^L - 6<D *f CO A XAtU&s\ ^>^7 7 ^(L ll~(y^Oi 2*^Tfyl4 *h> 0$&AJ -- ^ _______________________________ (2p*y$4++*< HjOCr --> &* ______________________ ^ VVV 000028510 1 minutes HEALTH r JOINT MEETING SAFETY & ENVIRONMENT COMMITTEE AND SAFETY SUBCOMMITTEE The Sheraton Music City 777 McGavock Pipe Nashville, Tennessee Wednesday January 25, 10:30 a.ra. 1989 Attendees: Frank Borrelli, Georgia Gulf Bruce Brocka, CertainTeed W.C. Holbrook, BFGoodrich Company Jim Kachtick, Occidental Chemical Joe Ledvina, Vista Chemical Gabe Lefebvre, BFGoodrich Company Jack Lippman, Dow Chemical Cris Lunn, Borden Chemicals Bob Oubre, Dow Chemical Irv Power, Occidental Chemical Meredith Scheck, Vinyl Institute ; Opening of Meeting The meeting convened at 10:30 a.m. with Mr. Holbrook, Committee Chairman, asking for self-introductions. Safety Workshop Mrs. Scheck reviewed the discussions held at the December 15th Executive Board Meeting regarding the Safety Seminar concept. Mr. Lunn distributed a list of discussion items and the tentative outline for a pamphlet/brochure announcing the meeting. Following discus sions, action items agreed to were: A. Location: Wyndham Greenspoint Hotel Date: April 25, 1989 B. Hotel Requirements: Block of Rooms (50-100) Meeting Room Audio Visual (Overhead, video/monitor, slide projector/screen) Lunch 2 Coffee Breaks C. Panel Members: Lunn, Graybill, Lippman, Power and Holbrook to provide names and brief biographical sketch to Scheck by Febru ary 3rd. Power to include paragraph explaining morning presen tation. yVV 000028512 The Vinyl Institute. A Division of The Society of the Plastics Industry, Inc. Wayne Interchange Plaza II, 155 Route 46 West, Wayne, New Jersey 07470, (201) 890-9299 t fc . 2- - D. Lippman agreed to moderate afternoon session and to arrange for video presentation in conjunction with the luncheon. E. Budget to be developed by VI to allow for project to be self-funded and supported by registration. F. Assessment sheet to be developed by Lunn/Scheck for development of report to the Board. Hazard Ranking System Mr. Holbrook introduced Mr. Lefebvre of the BFGoodrich Company, noting Mr. Lefebvre's involvement with activities of the Chemical Manufacturers Association on the Hazard Ranking System and related issues. Mr. Lefebvre noted on December 21st that EPA had published in the Federal Register regulations related to the National Contingency Plan and on December 23rd had published the proposed rule on the Hazard Ranking System. He reviewed CMA activity to date on both of these items and noted that the comment period on both items closes February 21st. Mr. Lefebvre noted that he has taken a lead role on the HRS Task Force and Mr. Holbrook reviewed the potential impact of the HRS proposed rule on his and other VI member companies (referencing such items as on site landfills and impoundments). Mr. Lefebvre urged those present to review the proposed rule to determine its impact on each of their facilities. He noted the current involvement on the CMA Task Force of representatives of 2 Vinyl Institute member compa nies (Dow and PPG), and noted his eagerness to have the input and involvement of others. In this regard, Mr. Lefebvre distributed four items he had prepared which Mr. Holbrook asked be appended to the minutes as follows - NCP Issues for Comments; Proposed Rule - NCP, comments being developed by CMA; Draft Comments on Hazard Ranking System; and Hazard Ranking System - Comments Requested by EPA. TCLP Update Mr. Ledvina stated that although he had been earlier informed that the TCLP would be finalized in March, that it now appears as though the date may be June. He commented further that he understood the vinyl chloride level being considered is 200 ppb. Mr. Holbrook commented on the impact of this item on surface impound ments. He noted that it is his understanding that it is in "red border review" by EPA and that publication could be anticipated as early as March. Mr. Holbrook noted that the effective date will be six months after promulgation. The committee had a round table discussion on current activity within member companies on impound ments and ponds. vvv 000028513 ft. . -3- Vinvl chloride Standard Ms. Scheck noted that amendments to the standard implementing the provisions of settlement agreement in SPI v EPA have not yet been published, but noted that the Agency is required to file a monthly update with the court. SARA Mrs. Scheck distributed additional copies of the chart developed as a result of member company input. Mr. Ledvina offered to provide additional input gleaned from FOI requests and asked that Mrs. Scheck distribute this chart to all committee members. Mr. Holbrook asked for a roundtable discussion on the treatment of relief valve discharges under 61.65 and the definition of "otherwise federally permitted" vis-a-vis SARA's reporting provisions to the NRC. VI Awards Mrs. Scheck noted that forms for the VI Environmental Recognition and Safety Performance Awards along with the nominating ballot for the Annual VI Safety Award were mailed the previous day. Mrs. Scheck noted that the OSHA calculation sheets were the same as in past years and did not reflect discussions at the March 1988 Committee Meeting concerning incorporation of contract maintenance personnel. Mr. Lippman noted the procedures his company follows in dealing with and assigning responsibility for contract employees. Following a lengthy discussion on appropriate amendments to the Safety Award calculation to assure fair and equitable comparisons that would satisfy the varying practices and legal views of VI member companies, it was decided that the issue would be discussed at the Committee's next meeting. ADSTR Mr. Borrelli inquired as to the interest of VI involvement in providing comments on the second 25 draft toxicological profiles released by the Agency For Toxic Substances and Disease Registry and EPA. It was the consensus of the group that companies should provide appropriate input to the CMA (see attached memo on subject). OHEIC Mrs. Scheck inquired whether any member of the Committee wishes to serve as a VI representative to the SPI Occupational Health Environ mental Issues Committee. Members commented that they would be willing to participate on special task forces/projects of OHEIC and suggested that Mrs. Scheck attend the next meeting of the committee and provide some recommendations following that meeting. VVV 000028514 Next Meeting The next meeting is scheduled for May 8th in conjunction with the VI Annual Meeting, unless the Chairman decides that an earlier meeting is necessary. Following the May meeting, it was suggested that tentatively the next meeting would be during the last week of Septem ber. Mav 8th Agenda In summary, it was agreed that the agenda for the May 8th committee meeting would include: 1. Update on measurement of fugitive emissions, with presentations by Vista and Borden. 2. Review of criteria presently used in computing VI Safety Perfor mance Awards and discussion of appropriate changes to those criteria. 3. Update on labeling. There being no other business, the meeting adjourned at 3:00 p.m. K.cd.l Hi li ,'j/ /( f / VVV 000028515 NCP Issues for Comments 51407 51409 10 51413 51415 51415 51415 51416 51418 51418 51419 51419 51420 o Definition of "on-site" for permitting purposes. o Removal limitation implementation. ^ o Deferral policy/remedial site evaluation poliiccyY,1 (PA/SI). J ***<. \o Merits of creating a construction completion category for sites on the NPL. ** o Whether deferral should be extended to state authorities. * o Whether deferral should be extended to sites where PRPs enter into Federal enforcement agreements for site remediation. Deferral policyextension to other federal authorities. * o The appropriateness of deferring generally to \ Federal authorities and whether these authorities should be required to meet some or all CERCLA standards. \ o Comments on two state deferral options deferral based on State petition requesting deferral. fotr/ous] deferral based on states certification of it commitment and ability to address the site according to CERCLA standards. - TAG grants - public notice (public meeting) - ATSDR - Non NPL listing for deferral sites o Deferral policy - sites regulated by multiple authorities. * o Deferral of sites with agreements undpr CERCLA enforcement authorities - 2 options deferral prior to NPL proposal based on agreement to carry out EPA - RD/RA pursuant to consent decree. deferral at time of proposal based on agreement to conduct a RI/FS for that site, with the proposed sited dropped if PRP vw 000028516 f . ft ' 51420 n 51421 t 51421-2 51426 I 51431 7L 51432 subsequently agrees to perform RD/RA pursuant to consent decree, Appropriate method for if those sites are not because of deferral to agreement. identifying problem sites, proposed for the NPL CERCLA enforcement Deferring placement of sites on NPL when other authorities are available to address contamination at the site and deferring sites when PRPs have signed enforceable CERCLA consent! orders. Deleting final sites based upon deferral to other authorities/criteria Risk ranges -_Jwo in particular current 10 to.10 - alternative 10 to 10 issues related to these or alternative ranges risk Potential advantages and disadvantages of alternative site-specific balancing approaches related to type of criteria considered steps for making statutory findings degree of proposed structure Two alternative approaches are site specific balancing with a costeffectiveness screen sequential decision making approach"** 'A Appropriateness and desirability of pursuing on< of the following alternative strategies point of departure \* - site stabilization Potential advantages and disadvantages of' the following analytical techniques screening against threshold criteria - pairwise comparison ranking alternatives or criteria - scoring (measuring alternatives against a consistent scale) - weighting alternatives or criteria construction of a multi-attribute model e/P VVV 000028517 731 51433-5 o Groundwater remediation approach \ 7Z1 7l IT 51436 fa o51439-4CW Criteria for ARARs Waiver of ARARs interim remedy equivalent performance - fund balancing - specific amount \ ,,j \ C6** 51440 k 51450-2 ^?(0 Where ARARs must and TBCs should be attained Community relations/public comment ii51452-3 i 51454 ^ Vo Community relations during RD/RA phases Interpretation of "restore ground and surface] water quality" and on the merits of alternatives EPA has not adopted. 51454 o Whether ten year O&M rule should extend to i situations where primary purpose of ground watei ** *. treatment is to provide drinking water supplies f f from water contaminated at the site without ( 6*// restoring it. 51454 51455 Appropriateness of requiring regions to enter into SMOAs if states request them and have demonstrated capability to take the lead for response action. 51456 3 Comment on criteria for state lead designation - overall expertise - legal authorities administrative and contracting capability - financial management systems availability of general resources complexity of site - availability of site-specific resources workload and expertise past Federal and State actions at the site - past State cleanup activity (should other criteria be added?) 51461 Subpart H comments - consistency with NCP for private party cleanups 1 "51468 Should a notice of availability of administrative record or of commencement of public comment ) period be published in the Federal Register?^ (administrative record for remedial action)"^ f v sfc&sey JT 0000285X8 . k. 51469 51469-70 51470 Should public comment be solicited on activities that have already been completed at the time the record is made available? -*r (administrative record for removal action) o Comment on approaches to developing ,, administrative record for removal actions.**" o Comment on adding documents tourecord after selection of response action. "7s VVV 000028519 p PROPOSED RULE Federal Register - 12/21/88 NATIONAL CONTINGENCY PLAN Comments Being Developed by CMA How to keep score on clean-up progress: Establish a separate category for sites construction completion, or Establish a separate category for sites after in 0 &, M phase ^ Establish a mechanism to re-score sites after a removal action is completed, or new information is available, such as after an RIFS is completed. Selection of ARAR's: Support an expansive definition of "on-site" to miniHtize need for permits for on-site response activity. Insist on a strict definition of "relevant and appropriate". Specifically discourage the wording "generally relevant and appropriate". Comment on importance of waiver for "inconsistent application" of State ARAR's. Comment on point of application of ARAR's: point of use, or fence line, but not within the contaminated area itself. Use of TBC's: Request clarification of the use of the term "to be considered" (TBC ) . List of TBC's should be deleted. Five-Year reviews: Comment on the application of up-dated ARAR's during the kfive year review of completed or 0 M sites. This is a major issue, because with the expected ratcheting of all environmental standards, eventually every completed site will require additional remediation to meet future ARAR's. Remedy Selection Process: Comment on risk range to be used - 10`4-10`6 , and support less stringency. Endorse their proposed utilization of the nine factors involved in remedy selection. Offer a better definition of "cost-effectiveness", which includes an analysis of the unit, cost of remedlation. wv 000028520 1 NATIONAL. CONTINGENCY PLAN Comments Being Developed b,v CMA (Continued) Administrative record issues: Judicial review of 106 Orders seeking and injunction. Content of the Record- Only "final" documents Only documents "considered" by decision maker. Timing of the Record's availability, the onset and length of the public comment period, and the timing of the EPA ' s response to comments. Applicability- Not applicable where the RI commences after the promulgation of new standards. Not applicable to third-party clean-ups including states that seek to recover costs under CERCLA 107. NPL Criteria: States should not have veto power over delisting petitions. Request clear definition of "significant release" that would result in re-listing a deleted site without HRS rescoring. Deferral policies- EPA oversight is not required for sites deferred to states. Procedures should be established so that it is not likely that sites remediated under state authority will ever become CERCLA sites and require remediation by the PRP's again. Sites should be deferred to a clear single authority, not to a mix of authorities. PRP's should not be required to sign a Consent Order for full remediation (a blank check) before the ROD as a condition of deferral. GFLe febvre 1/20/89 t , ft r PROPOSED RULE HAZARD RANKING SYSTEM Comments Requested bv EPA 111. C . V.C. 1 . V. C . 2 . V.C. 5 . V .C . 6. V.C. 7 . V.C . 8 . Functional equivalence of cut-off score under current and proposed rules. - Statistically equivalent scores after scoring a cohort of sites both ways. - Score that generates the same size NPL after scoring the same sites. - Determine new score that corresponds to the same quantitative risk level. Potential revisions under consideration: - Revise format to resemble quantitative risk assessment. - Use logarithms of numbers for factors. - Move waste quantity factor from Waste Characteristics section to Likelihood of Release section. - Remove caps (maximum values) from some or all factors. - Is default value of 3 (on a scale of 1 to 5) appropriate for toxicity factor if no data is available? - Are toxicity rating scales appropriate for acute, carcinogenic and chronic exposures? - Is it appropriate to use the toxicity factor for the single, highest scoring, hazardous material in scoring each pathway? - Inclusion of populations in Level 2 if substances from site without health-based benchmarks are found in drinking water. - Methodology of combining bench-mark ratios for substances found in drinking water. - Alternative approaches to assessing actual drinking water exposure risks. - Relative weighting of "sensitive environmental" vs. "public health" impacts, - Listing of "unique biotic communities". - Should food chain threat be included in scoring air and/or ground water pathways? - How should frequency of incursion from nearby populations be taken into account in scoring Onsite Pathway? VVV 000020522 1 . V. C . 9 . V.C. 10 V.C. 1 1 V.C.12 V.D.1 . V.D. 2 . Should an MEI factor be included in scoring Onsite Pathway? Should sites be scored on "Initial Conditions" or "Current Conditions"? If re-scored after a removal action, should the site be re-sampled, or should the Hazardous Waste Quantity Factor be adjusted? How should low population density target areas be handled in the HRS? How should standby water wells and intakes be handled? - Assign value based on % of supply or % of year utilized. - Consider only regularly maintained supplies, or only ones used more than a cut-off amount. - Assign standby sources a fractional value. Ground Water Pathway - Is two mile radius appropriate for evaluation of: - Aquifer connections? - Hydraulic conductivity? - Sorptive capacity? Target Distance - How should karst aquifers be handled? Likelihood of Release - Are sorptive capacity factors OK? - Should physical state factor be eliminated? Targets - Future use vs. current use? - How should unused but contaminated ground water resources be rated? - How should sources within a Well Head Protection Area (WHPA) be rated? - How should EPA meet requirements of Section 118 to give high priority to sites that have contaminated principal drinking water supplies? Surface Water Pathway Target Distance - 15 miles vs. current 3 miles? Likelihood of Release - Should physical state factor be eliminated? - How should flood potential and containment be evaluated? - How should potential to release contaminated ground water to surface waters be evaluated? Food Chain Threat - LTse of 0.2 factor for fishing catch/standing crop ratio? -2- VVV 000028523 V . D. 3 V. D. 4 Recreation Threat - Can we offer refinements to their approach in evaluating this sub pathway? Air Pathway Potential to Release - Are the three proposed factors appropriate {for source type, source mobility and source containment)? Onsite Pathway - Is breakdown of exposed population groups appropriate? Resident Population Threat - How should contaminated area be defined? Targets - How should high-risk population be defined? Nearby Population Threat - Likelihood of Exposure - Is proposed algorithm appropriate? 3 VVV 000028524 t \ DRAFT COMMENTS ON PROPOSED RULE HAZARD RANKING SYSTEM III.C. V.C.l V.C. 2 Functional equivalence of cut-off score: Engineering-Science will identify several sites for which they developed an RIFS, and which they feel are fairly representative of the universe of sites to be scored. These sites will be scored with the new rule, and the results studied to determine if there are any specific parts (factors, weights, caps, etc.) of the new rule that they feel should be challenged because the score does not accurately reflect actual risk to human health or the environment. fIf there are no obvious ^ will recommend that EPA option, i.e., determine corresponds to the same level as 28.5 under the incongruencies, we implement their third the new score that quantitative mean risk old rule. Potential revisions under consideration: We should encourage the agency to leave the Waste Quantity Factor in the Waste Characteristics score of each pathway. Putting it in the Likelihood of Release score is inappropriate (it's adding apples arid oranges), and will make it almost impossible for a pathway to score 0 under any circumstances. Toxicity i ssues: E-S will review the algorithm for toxicological issues. vM A s hould suppo t a CO nc e n t r at i on/qu a n t it e i gh ed tox i c i t y fa c t.o r i CO n s id e ring a 1 1 t n d i v i d u a i hazar dou s ma te r i a 1 s k nown t o be r e se n t,, in s tead o f the s i n ersr 1 e , h ighe s t c o r i ng app roac h La k en i n t h e P r o p o s e d r ul VVV 000028525 t kt V.C.9 Definition of Maximally Exposed Individual (MEI): We may wish to identifies the an incongruity comment on this issue, if E-S Target score of any pathway as resulting from the MEI fsict.or. Y.C.10. Site rescoring: CMA should develop very persuasive comments support of the use of "Current Conditions" instead of "Initial Conditions" whenever a site is scored. in V.D.l. Ground Water Pathway: CMA should reiterate its earlier comment that up-aquifer targets score as zero. CMA should make a positive supporting comment on the use of groundwater dilution factors in the proposed rule. V.D.2. Surface Water Pathway; CMA should support the current rule's 3 mile target distance, instead of the 15 miles proposed. y CMA should comment on the complexity of the rule, and the importance of determining realistic and appropriate default factors when site and/or chemical specific data is not available. E-S was asked to study whether an index could be developed to limit the number or portion of the score that could be developed with default factors. This would require that a certain minimum amount of site specific data be collected and available for the scoring process at each site. GFLe i'ebv re 1/11/89 oooozs^6 /.'///' k. r CHEMICAL MANUFACTURERS ASSOCIATION December 5, 1988 '' ' - /} TO: Health and Safety Contacts of CMA Member Companies SUBJECT: ATSDR Draft Toxicological Profiles On April 17, 1987, the Agency for Toxic Substances and Disease Registry (ATSDR) and EPA published a list of the 100 most hazardous substances found at waste sites and guidelines for the development of "toxicological profiles" on those substances (52 Federal Register 12866, 12870). These profiles will be used to estimate "significant human exposure levels", to identify data needs, and to recommend further testing. ATSDR has developed toxicological profiles on the first 25 substances. The profiles will be available in final form in December. The Agency's next step is to develop draft profiles on the second 25 substances identified on the enclosed priority list. Although ATSDR will conduct its own scientific peer review on each of these chemical-specific toxicological profiles prior to public disclosure, CMA believes that a similar industry review of the profiles is warranted. I solicit your help in volunteering knowledgeable industry scientists, reputable consultants or other industry trade groups to evaluate the second 25 draft toxicological profiles scheduled for release this December. Although this CMA activity is focused on specific chemicals, the reviews prepared by industry panelists will be the basis for an overall CMA evaluation of the general content, format, and process by which these draft toxicological profiles were developed. Our assessment of the profiles on a chemical-specific and general basis will be important to the development of profiles on other listed chemicals during the next few years. As you know, the profiles will likely be used not only for the purposes originally intended by SARA, but as the basis for other federal and state regulatory activities. You can help CMA ensure that the data and conclusions in the profiles are supportable by industry. Please return the attached form by December 30, 1988, indicating each substance of interest to your company and the industry health scientists that will help review and evaluate the toxicological profiles on those substances. Remember to note the names, addresses and the phone numbers of other persons outside of industry known to have expertise on any of the substances. In addition to participating in this activity, you are encouraged to submit comments to ATSDR on behalf of your company. 2501 MStreei.NW, Washington, DC 20037 202-887-1100 Telex 89617 (CMA WSH) y VV 000028527 Health and Safety Contacts Second 25 Draft Toxicological Profiles December 5, 1988 Page 2 Note that while it is unlikely that member companies will submit confidential data to CMA in response to this request or as a result of reviewing the toxicological profiles, CMA has set up special safeguards to protect confidential information on specific chemicals from disclosure to competitors or the public. To assure this protection against disclosure, please clearly designate such documents submitted to CMA as "CONFIDENTIAL." Any such submittal should be on plain bond paper and should contain no reference to your company or bear any signature. In January, I will communicate with the persons you've designated as participants in this important activity. Please call Leslie J. King of my staff at 202/887-1323 if you have questions or need more infor mation about the priority list of 200 substances or the development of toxicological profiles. Sincerely yours, Enclosure Vice President-Technical Director VW 000028528 SECOND 25 PRIORITY SUBSTANCES FOR ATSDR TOXICOLOGICAL PROFILE DEVELOPMENT (53 Fed. Reg. 41280) CAS NO.Substance Name____________________ 56- 23-5 ............ Carbon tetrachloride 57- 74-9 ............ Chlordane 62-75-9 ...............N-nitrosodiraethylamine 72-55-9 ...............4,4-DDE, DDT, DDD 75-00-3 ...............Chloroethane 75-27-4 ...............Bromodichloromethane 75-35-4 ............... 1,1-Dichloroethene 78-59-1 ...............Isophorone 78- 87-5 ............ 1,2-Dichloroethene 79- 00-5 ............ 1, 1,2-Trichloroethane 79-43-5 ....... 1,1,2,2-Tetrachloroethane 87-86-5 ...............Pentachlorophenol 91- 94-1 ............ 3,3-Dichlorobenzidine 92- 87-5 ............ Benzidine 107- 06-2 .......... 1,2-Dichloroethane 108- 88-3 .......... Toluene 108-95-2 ............ Phenol 111-44-4............Bis(2-chloroethyl)ether 121-14-2............2,4-Dinit rotoluene 319-84-6 ............ BHC-alpha, gamma, beta, delta 542-88-1 ............ Bis(chloromethyl)ether 621-64-7 ............ N-nitrosodi-n-propy1amine 7439- 97-6 ........Mercury 7440- 66-6 ........ Zinc 7782-49-2 ..........Selenium VVV 000028529 i l' CHEMICAL MANUFACTURERS ASSOCIATION INDUSTRY PEER REVIEW PANELS TO EVALUATE TOXICOLOGICAL PROFILES ON THE SECOND 25 PRIORITY LIST.SUBSTANCES UNDER SECTION 110 OF SARA RETURN BY: December 30, 1988 RETURN TO: Leslie J. King Manager Health, Safety and Chemical Regulations Chemical Manufacturers Association 2501 M Street, NW Washington, D.C. 20037 . (202) 887-1323 *** * * * Substances (Circle one or more) Address and Health Sclentist(s) Telephone Number Carbon tetrachloride Chlordane N-nitrosodimethylaroine 4,4-DDF., DDT, DDD Chloroethane Broraodichloromethane 000028530 VW I k. 1.1- Dichloroethene Isophorone 1.2- Dichloropropane 1.1.2- Trichloroethane 1.1.2.2- Tetrachloroethane. Pentachlorophenol 3.3- Dichlorobenzidine Benzidine 1.2- Dichloroethane Toluene Phenol Bis(2-chloroethyl)ether 2.4- Dinitrotoluene BHC-alpa, gamma, beta, delta BisC chlorooethy1)ether N-nitrosodi-n-propylamine Mercury -2- VVV 000028531 L. Zinc Selenium ** * * * ***** SUBMITTED BY: NAME: COMPANY: ADDRES S: TELEPHONE NUMBER: SIGNED -3000029532 vvv