Document 5LeKqj9pq3z77vbyLMMNEZr4e

EPA-450/ 89- CANCER RISK FROM OUTDOOR EXPOSURE TO AIR TOXICS <* * U.S. Environmental Protection Agency n i Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 September 1989 VAB.OOOl 165183 POLLUTANT TABLE 2*6 (concluded) UNIT RISK FACTORS USED TO COMPARE CANCER RISK EPA CLASSIFICATION* UNIT RISK FACTOR^ REFERENCE 76. 1,1,2,2-Tetrachloro- ethane 77. Thiourea 78. Toxaphene 79. 1,1,2-Trlchloroethane 80. Trichioroethy1ene 81. 2,4,6-Trichlorophenol 82. Vinyl chloride 83. VinylIdene chloride C 82 B2 C B2 82 A C 5.8x10** S. 5x10** 3.2x10** 1.6x10*' 1.7x10** V 5.7x10** ^ 4.1x10** 5.0x10*' 3 3 3 3 2 3 2C 1 * For a discussion of how EPA evaluates suspect carcinogens and more information on these classifications, refer to "Guidelines for Carcinogen Risk Assessment" (51 Federal Register 33992). The EPA classifications used in this report.are: A proven human carcinogen B - probable human carcinogen (B1 indicates limited evidence from human studies; 82 Indicates sufficient evidence from animal studies but inadequate evidence from human studies) C * possible human carcinogen * b Based on Inhalation study. Oral study suggests a unit risk factor of 3.3x10. * * e Oral studies suggest a unit risk factor of 4.2x10**. O.S. Environmental Protection Agency, Office of Research and Development, Office of Health and Environmental Assessment. Health Effects Assessment Summary Tables First Quarter FY89. January 1989. 1. Integrated Risk Information System. 2. Office of Health and Environmental Assessment. 3. u.S. Environmental Protection Agency. Hazardous Haste T-SOF - Background Information for Proposed RCRA Air Emission Standards, Volume II - Appendices. Preliminary Oraft. March 1988. pp. E-8 through E-13. 4. Oraft Supplemental Rule for Hazardous Haste Incinerators. Appendix B, Unit Risks for Carcinogenic Constituents. 5. IEMP-Ph11ade1ph1a. Oeveloped from EPA's Orlnklng Hater Criteria Document. 3/2/84. 6. U.S. EPA, Office of Solid Haste. 7. Southeast Chicago Study. k 2-21 VAB. i fl * 14 . Chloroform Sztp'Sen* aforooriae Ethylene oxide Formaldehyde Gasoline vapors Methyl chloride Methylene chloride Nickel (subsulfide) Perch!oroethylene Propylene oxide Styrene Trichloroethylene Vinyl chloride Vinylidene chloride I** 4 4 7.5x10*7' 1.4x10-"7' 1.8x10"7' 3- ^3ii.x10 4 1.7x10*"4* 4 7 *4 4 5 FACTORS % -K'- June 1988 % Change 1.7x10 ; 2.4x10"* 2.8x10"* 1.8x10'* 2.3x10"* 1.2xiC 2.2X107 1.0x10"* 1.3x10"* 6.6x10"' 3.6x10"* 4.7x10"' 4.8x10"* '5.8x10*' 3.7x10"*' 5.7x10"' 1.7x10"* 4.1x10"* 5.0x10"* +6400 +500 +60770 -22 +130 445 -5 r -72 +113 -12 +2,470 +161 +45 66 -97 +97 -59 *58 19 3-51 T VAB.0001165185 YAUU I. KNOWN HUMAN CA RCINOflKNS (CantiMMdf SuImImk* CAS No." TUweco moke Trcosu I plum * Vinyl chloride 299-75-2 9I-0I-I tollgiwuit luwra off (he respiratory tree! end upper digestive (reel ere causally related to stoking various forms of tobacco. Msllgnaut tutors of the bladJer, renal polvlst and paoercas are causally related to anukliig cigarettes.* * Produced only la Vfctnnrk since IMS. Ihed in Imimu acdleioo for treating ovarian cancer. Used In the production of plastics, and the synthesis of other chemicals. Vinyl chloride - vinyl acetate copolymers are used In (lie aunufacture of vinyl asbestos floor tiles. Annual production Is about 7 billion pounds for the aonaicr aud I billion pounds for Ilia hoMupolyatr. 4.1 x I Awr I can DundeeI Society UmsmIcsI Abstract Service Registry Huber. Source used lierei Registry of Ibile Hr fee Is of (haulcal Substances III7I. ediliou. /^* Prubabl 111 y of contracting cancer If exposed to I ug/isi* of a carcinogen for 70 years. Source* Personal Omnmlcatlon. I Mi ho Husetsliia, KJ*A/QttJpS/l*AII. torch 1915. . These factors are subject to change and should be confirmed with H'A's (hrclnegcn l before use. Heryll lisii cui|mhmmIs of cumercUi iiiportance. 4 Source for 97 percent of all arsenic products. Represent* 94 porcent of U.S. cunsisiptlon. * ' Sources Miry land Tosle Substance Registry System - Office of Cnvlromrnlal Program, Sole l}uuitlly by ilstuileel for Stale of torylaud. (blanks indicate Ilia substance was not Included * Sourcet ** Source i : klasugraphs on 11to Evaluation of the ihrclnogenlc tbndcnsed duaiilcal Dictionary, Tenth Edition, Van iuternat liaial Agency for Research on Oinecr. * Sourcei J Id sled by lAIC but nut by Nil*. k l.lstcd by Nil* hut not by IAII?. MMV. Him Sources (Uitess otiusrwlse noted) 11(lrU AiimwI lleiwrl m, 0.relw.H Sunwry, Millm.1 ltoleol<y Pr<rm. U.S. Uef.rta.nl of U.lth n| ....... Services, Scpliiiher 1993, 03-03-87 VAB.0001165186 . ir..: I- * n fw-r*1 process, fJie AALs have not been i> employed as strict ambient exposure standards. In general, the states have used the AALs as guides, and if the limit for a pollutant is exceeded then the industry and regulatory agency tend to develop a mutually acceptable plan to reduce ex- posure. One difficulty is that the AALs are often derived by a unit or agency other than that which handles the per mitting process (e.g., the Department of Public Health versus the Department of Environmental Protection/Manage ment). The permitting group is usually not firmly bound by the AALs; the AAL is just one of a number of factors to be considered in the permit process, which essentially is a risk management process (8). Another aspect of the air toxics issue is the implementation of SARA Title 313, which requires reporting of rou tine emissions (in pounds per year) to communities. What do these numbers mean in terms of human health? Risk communication is likely to be a major challenge for the industries and states, and it is likely that major differences of +>* ' k.4 .'esc c.cTss.'ons. P How this may then affect the derivation of AALs and the permitting process re mains to be seen. In summary, the EPA air toxics strat egy has led to the development of a highly decentralized approach for the regulation of air foxics at the state level. This in turn has led to the deriva tion of highly variable acceptable-expo- sure guidelines for mutagens, carcino gens, teratogens, and systemic toxicants. Such interstate variability in AALs for toxic substances may lead to differential protection of the public health from air toxics, confuse the pub lic about air pollution and health con cerns, and undercut the credibility of public health and environmental regula tory agencies. It is interesting to note that while EPA encouraged the development of such divergence in air toxics regulatory approaches and implementation at the state level, the Food and Drug Admin istration funded a National Academy of Sciences (NAS) assessment of the fed eral process of risk assessment. The goal was to determine if greater con sistency could be achieved across agen- w i w'J'iuu VVVA*,p'i V- `w` .v 4 w lP s;ons--e$pecialIy those concerning the regulation of chronic health hazards. This effort resulted in the publication of the highly influential work, Risk As sessment in the Federal Government: Managing the Process (U). Thus, while the NAS report ad dressed the lack of agreement in assess ing risk at the federal level and recom mended ways to minimize it, EPA was encouraging just the opposite with re spect to air toxics regulation at the state level. For example, the NAS commit tee strongly recommended "that uni form inference guidelines be developed for the use of federal regulatory agen cies in the risk assessment process" (12). Although there can be compelling reasons for different emission regula tions in different regions and states, EPA should strongly encourage the development of consistent risk assess ment methodologies that assist the risk manager in the final decision-making process. References (1) Calabrese, E. J, Methodoiogic Ap proaches to Deriving Environmental and Occupational Health Standards; Wiley: New York. 1978. -- TABLE 2 Highest and lowest ambient air levels (AALs) standardized to a 24-h averaging time by compound lor representative known and probable human carcinogens, In Mg/ma * Compound Acrylonitrile Arsenic end compounds es As Benzene Epichtorohydrln Ethylene dibromide Ethylene oxide Formaldehyde Nickel subsulfide PCBs Vinyl chloride Original AAL 15 (NY) Standardized highest AAL 257 0.67 (NY) 100 (NY. Rl) 33.3 1500 (VA) 450 (IN) 7.2 (Philadelphia) 24 (NV) 1.67 (NY) 6.57 (Philadelphia) 11.5 1718 572 1500 160 123.7 8.54 28.7 112.9 Original 0.15 (MA) 0.0002 (Rl) 12 (MA) 2.7 (MA) 0.045 <NC) 0.01 (Rl) 0.77 (MA) 0.0017 (NC) 0.0081 (MA) 0.038 (NO Standardized lowest AAL 0.15 0.0034 1.2 2.7 0.773 0.17 0.77 0.026 0.0081 0.65 Retie standardized htgheet/loweet AAL 1713 3382 1432 212 1940 941 161 294 3543 174 The original AALs and thalr averaging times wart obtained Irom Reference 4. These substances are ell classified In IARC groups 1 or 2A. AALs were standardized to 24-h averaging times for convenience based on information provided in Reference 1i. Annuel averaging times ere in reality more appropriate for chronic endpoints such as carclnooenlclty These figures are highest snd lowest standardized AALs; other state and local agencies may have had higher or lower original AALs. When unstandardtzed highest and lowest AALs are compared, the differences are generally larger. !-- MPIWM--i I I I m -- rere IIM1W ------*I MM .......... m --<-- m mm i mm m * ww--mmtmmmre--M ,i, i -- -- rei -- m m ---------- i wt TABLE 3 Highest and lowest ambient air (avals (AALs) standardized to a 24-h averaging time by compound for representative noncarcinogens, In pQlm3 Compound Acetone Ammonia Ethylene glycol Mhexane Napthalena Phenol Tbluene Xylenes Original 35.6 (NY) 0.36 (NY) 2.978 (NY) 30 (VA) 0.167 (NY) 0.456 (Philadelphia) 7.5 (NY) 1.45 (NY) Standardized highest AAL 611.7 6.186 1.06 30 , 2.87 7.84 128.9 24.91 Original 11.8 (CT, SO) 0.024 (MAI 0.17 (MA) 1.8 (NO) 0.014 (MA) 0.095 (IN) 0.051 (MA) 0.0592 (MA Standardised lowest AAL 4.2 0.024 0.17 0.64 0.014 0.034 0.051 0.0592 Ratio standaidbeed Mghast/towest AAL 146 258 6.2 47 205 230 2527 421 'The original AALt and their averaging times were obtained from Reference 4. Units are standardized to 24 h for comparison, based on information provided In Reference 11. These figures ere highest and lowest standardized AALs; other state end local agencies may have had hlghar or lower original AALs. When unstandardized highest end lowest AALs era compared, the differences ere generally target Environ. Scl. Teehnol., Vbl. 23. No. 11,1989 t^B.0001165187 ,r '"v VUto OMtmicd Compony TQJUINYL INSTITUTE 900 Thisodrtssdk HouiM, T#*m 77079 (713) 568-3000 JUL 5, 1990 11:44AM P.O. Sox 19029 Houston, Texas 77224 Fax (713) 5664236 #033 P.01 f k July 5, 1990 Meredith Scheck The Vinyl Institute 155 Route 46 Vest Vayne, NJ 07470 DP l_ STTU-L. DeaA*T(l4(^ AlO- T"QX UOOKlMe "TO GUiOfi . visia Tuooea-n UOOueD H6XP- us k>*Dv4 00*1* Mou P-lf'iD Dear Meredith, We are being told by the State of Mississippi the unit risk factor for VCM is 4.2 x 10w*/mtcvogr. Multiplication of the unit risk factor by the fenceline concentration provides a worst case estimate of risk from a particular facility. As state air toxic programs become prevalent, the unit risk factor will bo more of an issue. I am Interested in others' experience or knowledge on what factor is being used to estimate rick from their facilities. If you could poll the members 1 would appreciate it. S lncere ly, cc: FCJ t VAB.0001165188 STATE OF MISSISSIPPI DEPARTMENT OP ENVIRONMENTAL QUALITY RAY MABUS GOVERNOR June 20, 1900 Mr. Frank G. Jeanson Senior environmental Coordinator Vista Polymers P.O. Box 91 Aberdeen, Mississippi 39730 Dear Mr, Jeanson: Re: Facility No. 1840-00014 Aberdeen, Mississippi Based on your letter dated June 18, 1990, we understand that a net decrease in vinyl chloride emissions of 11,000 Xbs/yr is expected upon completion of both the Slurry Stripping Optimization Protect (SSOP) and the S?!**"1 Rn*ac*mmt Project (SRP). We further understand that the CSRP wmincreaee production by 40 MM Ibs/yr and 5,825 lbs/hr (maximum dotty production capacity), Since the NESHAP vinyl chloride emission limitation for the reactor opening loss and residual yinyl chloride is 0,00042 lbs/dry solid lb of PVC resin produced, the production capacity increase would causs an increase in the amount of vinyl chloride emissions allowed of 2.4 lbs/hr and 18,800 Ibs/yr. We propose issuance of a construction permit which maintains the allowable vinyl chloride mass emission rate af current levels. Thus, the permit will limit vinyl chloride mission* from reactor opening loss and residual vinyl chloride to 0.00038 lbs/dry solid lb of PVC resin. We plan to recommend issuance of this permit to the Permit Board on Tuesday, June 28, 1990, l have enclosed a draft permit. Your comments before Tuesday are welcome. This permit action is in regard to the SSOP and CSRP projects only. Pursuant to our June 15, 1990, meeting, action on the companys request for permit action to become a minor source is on hold. We plan no further action until the^ company provides information to resolve concerns over carcinogenic emissions and appropriate emission limitations. If you have any questions, ptease let me know. Very truly, yours. Jay RZ Barkley North Air Emissions Section JwmHmmB^ :er BUREAU OF POLLUTION CONTROL. P.O. BOX 10385. JACKSON, MS 392894385. (601)981-5171 Enclosure VAB.0001165189 w* V w t-W- .. W V HMt 11^ W 'V VV _. .V f <1 *k ,V T V V M V V a V rk W W I WV A STATE OF MISSISSIPPI AIR POLLUTION CONTROL PERMIT TO CONSTRUCT AIR EMISSIONS EQUIPMENT THIS CERTIFIES THAT Vista Polymers Hwy. 25 Aberdeen, Mississippi has been granted permission to construct air emissions equipment to comply with the emission limitations, monitoring requirements and othe conditions set forth herein* This permit is Issued in accordance with the provisions of the Mississippi Air and Water Pollution Control Law (Section 49-17-1 et* seq., Mississippi Code of 1972), and the regulation! and standards adopted and promulgated thereunder. Issued this day of MISSISSIPPI ENVIRONMENTAL QUALITY PERMIT BOARD DIRECTOR, BUREAU OF POLLUTION CONTROL MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY Permit No. 1840-00014 % r*Ml VAB.0001165190 n V h VV V i-p PART I PART I GENERAL CONDITIONS Page 2 of 6 Permit No. 1840-00014 1. The plans, specifications, schedules, dates and other data submitted to the Permit Board are filed with and considered as a part of this permit. .2 pollution control facilities shall be designed and constructed such as to allow proper operation and maintenance of this permit. The necessary facilities shall be constructed so that solids removed in the course of control of air emissions may be disposed of in a manner such as to prevent the solids from becoming windborne and to prevent the materials from entering State waters. The air pollution control facilities shall be constructed such that diversion from or bypass of collection and control facilities is not needed except (i) where unavoidable to prevent loss of life or severe property damage or (ii) when approved by the Mississippi Environmental Quality Board. The construction of facilities shall be performed in such a manner as to reduce both point source and fugitive dust emissions to a minimum. permittee shall allow the Mississippi Department of Environmental S pUu**on Control and the Mississippi Environmental Quality Permit Board and/or their representatives upon presentation of credentials: (I V ^ Xa. To enter upon the permittee s premises where an air emission source is located or in which any records are required to be kept under the terms and conditions of this permit; and At reasonable tiroes to have access to and copy any records required to be kept under the terms and conditions of this permit; to Inspect any monitorlug equipment or monitoring method required in this permit; and to sample any air emission, After notice and opportunity for a hearing, this permit may be modified suspended, including, or revoked in whole but not limited to: or in part durins its term for cause a. Violation of any terms or conditions of this permit; b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts, or c. A change in any condition that requires either a temporary or permanent reduction or elimination of authorized air emissions. VAB.0001165191 -tMlh- ^1 ,mm*m., i^| w i L ** Pw w 1 * * 1 ij w w\ w A4l , V ^ w .. .. - \ ^ w1 ry ^ J v W ^w w 'w w \ PART I Page 3 of 6 Peruit No. 1840-00014 Except for data determined to be confidential under the Mississippi Air & water Pollution Control Law, all reports prepared in accordance with the terms of this permit shall be available for public Inspection at the offices of the Mississippi Department of Environmental Quality Bureau of Pollution Control. The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorise any injury to private ur any invasion of personal rights, nor any infringement of Federal, State or local laws or regulations, 10. Nothing herein contained shall be construed as releasing the permittee from any liability for damage to persons or property by reason of the nstallation, maintenance, or operation of the air cleaning facility or from compliance with the applicable statutes of the State, or with local laws, regulations, or ordinances. 11. This permit is non-transferable. 12. This permit is for air pollution control purposes only. Approval to construct will e one (1) year of the issuance suspended for one (1) year o Prior to startup of air emissions equipment at this source, a Performance Eyaiuation Permit must be obtained. The permittee shall submit certification by a professional engineer registered in the State of Mississippi that construction completed in accordance with the approved plans and specifications and a written request for the permit. S I S. a. uOg) u u VAB.0001165192 A PART II Page 4 of 6 Permit No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS Beginning ISSUANCE DATE, the permittee is authorized to modify the operating control ayetem of air emissions equipment for the emission of air contaminants from the Vinyl Chloride Reaction and Storage Process, Process Code AI including: Emission Point No. Descrintion AI-001 AI-002 Al-003 AI-004 AI-005 AI-006 AI-007 AI-008 AI-009 AI-010 AI-011 AI-012 AI-013 AI-014 AI-015 Al-016 Al-017 AI-018 AI-019 AI-020 AI-021 AI-022 AI-023 Al-024 AI-025 AI-026 AI-027 AI-028 AI-029 AI-030 AI-031 AI-032 AI-033 AI-034 AI-035 AI-036 Al-037 AI-038 AI-039 Railcar Unloading Stations PVC Reactor D-300 PVC Reactor D-400 PVC Reactor D-500 PVC Reactor D-600 PVC Reactor D-700 PVC Reactor 741 PVC Reactor 742 PVC Reactor 743 PVC Reactor 744 PVC Reactor 745 Evacuation Jet - Old Module Evacuation Jet - New Module Slurry Dump Systems - Old Module Slurry Dump Systems - New Module Slurry Dump Systems ~ 745 Reactor Slurry Dump Systems - D-700 Reactor Slurry Blend Tank 550 Slurry Blend Tank 551 Slurry Blend Tank 552 Slurry Blend Tank 553 Slurry Blend Tank 646 Slurry Blend Tank 647 Slurry Blend Tank 648 Slurry Blend Tank 649 Slurry Blend Tank 650 Slurry Blend Tank 651 Slurry Blend Tank 652 Slurry Blend Tank 653 Slurry Blend Tank 654 Slurry Blend Tank 655 Slurry Blend Tank 407 Slurry Blend Tank 501 Slurry Blend Tank 502 Slurry Blend Tank 747 Normal Kill Solution Mix Tank Normal Kill Solution Charge Tank Suspending Agent Tank D-103 Slurry Blend Tank (Low Mol) Cl II II i fS tm k S W,-I* # Vw y v, if \ <. ,Vl o iW y~\ w w w v 4 I> rw f PART II Page 5 of 6 Permit No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS Continued from Page 4 of 6 kh* PVC fradon, KnHfiMnn Point! Hmyfrf-^rU*ttjAA'0}i' Tha11 ba modified to comply with the amission limitations and monitoring requirements specified below. EMISSION LIMITATIONS Vinyl Chloride 0.00038 lb/dry solid lb of polyvinyl chloride resins including latex resins, verifiable by 40 CFR 61.67(g)(6). r n^oH..r?^8in ensure thst at the proposed maximum daily v!nvr^w?5P" y V2;000 lb"'hf * will not be an increase in the emission rate allowed by NESHAP, given the current maximum daily production capacity of 56,375 lbs/hr. The permittee shall comply with 40 CFR 61.68. RECORDKEEPING & REPORTING REQUIREMENTS Tha permittee shall comply with 40 CFR 61.70 and 61.71. PERFORMANCE testing STSrilfiwmS* T?~TV^U be by tMtln* in accordance with A0 CFR /if and *ub*ittal of tbe teat report. For the purpose of compliance demonstration, the permittee shall operate at the maximum rate. period^ co"pli""ce sha11 ba demonstrated during the performance evaluation . \ s' ww > w Ww > w * \J f * - - *' W -ih V'**4- U ,\ V W-AW' ^ ^ w O *4 s 1I - -A V-w ^ O'.A Aw, w> ^ ^ ^ v V ** 'v v #> >J a V W oi .i PART III PART III OTHER REQUIREMENTS Fags 6 of 6 Permit No. 1840-00014 Th operator of the squipmant r.nvarnd hy fhis permit shall operate and maintain this equipment to assure that the emission rates will not, at any time, exceed the rates allowed by the Mississippi Air Emission Regulations. (2) The permittee shall comply with all applicable National Emission standards for Hazardous Air Pollutants (NESHAPS), 40 CFR 61, Subpart A - General Provisions and Subpart r - Vinyl Chloride. A pretest conference at least thirty (30) days prior to the scheduled tost date is needed to ensure that ail test methods and procedures are acceptabio to the Bureau of Pollution Control. Also, the Bureau of Pollution Control must be notified prior to the scheduled test date least TEN (10) DATS notice should be given so that an observer may be scheduled to witnees the teet(e). 3 SR-15AC VAB.0001165195