Document 6bx2R9kLQZa8mbdMJoM2g0VEd

53i5 ; s 2 April___ , 1997 Ms. Kim E. Jenkins Division of Toxicology Agency for Toxic Substances and Disease Registry Mailstop E-29 1600 Clifton Road, N.E. Atlanta, Georgia 30333 Re: Vinvl Chloride Toxicological Profile & Dear Ms. Jenkins: /.A? On behalf of the CMA Vinyl Chloride^aafflfrl am wwiriting to bring to the attention of the Agency for Toxic Substances and Disease Registry (ATSDR) a number of corrections that should be made in the next update of the Toxicological Profile for Vinyl Chloride. These corrections account for changes in corporate ownership and/or operation of certain facilities identified as manufacturers or processors of vinyl chloride, and provide clarification of the estimated range of maximum amounts of vinyl chloride present at certain facilities. The corrections apply to Part 4, Production, Import Use, and Disposal, and mainly involve Table 4-1: p. 137 Septmd Paragraph, fifth line: '^vista Chemical Company is located in West Lake, Louisiana (not Lake Charles). The BF Goodrich facility in LaPorte, Texas, is now owned by Geon Company. Geon purchased this and certain other BF Goodrich facilities in April 1993. CMA 112941 Ms. Kim E. Jenkins April___ , 1997 Page 2 p. 138 Table 4-1. On the fourth line, the Georgia Gulf Corp. facility in Delaware City, DE should beMeleted. BF Goodrich facilities identified/m. the seventh line (Henry, IL) and ninth line (Lomsville, KY) are now Geon Company facilities. The Panel is informed, however, that BF Goodrich continues to operate a latex manufacturing plant at the Louisville site, which reportedly uses some vinyl chloride. For the Geon facility located in Henry, IL (identified on the seventh line), under the "activities and uses" column, "as a product component" should be deleted; vinyl chloride is used only as a reactant at this facility. p. 139 Table 4-1 (cont'd). The facility identified on^jeiirst line, BF Goodrich of Plaquemine, LA (wjiiefichanged to Geon Company ownership in April 1983) should be deleted. Vinyl chloride-related activity ceased at this facility in June 1992, prior to its sale to Geon, and no vinyl chloride-related manufacturing or processing has taken place since then. The entry on the fifth line should be deleted or revised. The Addis, LA facility identified as Occidental Chemical Corp. was sold to Borden. v On the ten^line, BF Goodrich of Pedrickton, NJ should be changed to Geon Company. On the 13th line, BF Goodrich Avon Lake should be changed to Geon Company, and the entry in the column entitled "Range of maximum amounts on site in pounds" (hereinafter "Range column") for this facility should read " 100,000-999,999." The current operation at the Geon facility at Avon Lake, OH, is limited to pilot plant or developmental activities. The primary vinyl chloride-related activity was discontinued prior to the acquisition by Geon. CMA 112942 Ms. Kim E. Jenkins April___ , 1997 Page 3 p. 139 (cont'd) However, BF Goodrich reportedly still operates a small pilot plant at the site where it uses some vinyl chloride. Under the Range column for Formosa Plastics Corp. (fifth row from the bottom), replace "No Data" with "1,000,000-9,999,999." c The enu> on the second to the loot row shoukrte-dejeted. Occidental does not own a facility in La Porte, TX. p. 140 Table 4-1 (cont'd). Qn-thc first row/Jpr Occidental Chemical of Pasadena, TX, "100,000-999,999" should be listed in the Range column*-- '^-*-*-<-^0 J BF Goodrich of Deer Park, TX, the second entry/should be changed to Geon Company. The third enffyrOccidental Chemical Corp. of Deer Park, TX should be deleted. Occidental does not conduct activities involving vinyl chloride at the facility. The fifth entryfOccidental Chemical of Gregory, TX should state " 100,000-999,999" in the Range column. p. 145 Under "5.2.1 Air," fifth line, it is noted that 1992 TRI data are used to estimate the total amount of vinyl chloride released into the air. More recent data are available, and would provide a more accurate estimate. p. 155 At section 5.6, the title "POPULATIONS WITH POTENTIALLY HIGH EXPOSURES" should read "POPULATIONS WITH POTENTIAL EXPOSURES." Use of the term "high" may wrongly suggest that exposure levels for the populations identified are above effect levels. A revised version of Table 4-1, reflecting these changes, is enclosed. Ms. Kim E. Jenkins April___, 1997 Page 4 The Panel recommends that ATSDR change the format of Table 4-1 to provide information more useful than the wide ranges shown as "maximum amounts on site in pounds." While the PaneKnot have access to any specific storage data, we would be pleased to provide the nameplate capacity of each of these facilities if ATSDR would present this information in lieu of the ranges. If you would like more detailed information on any of the corrections the Panel recommends, please do not hesitate to call me at (703) 741-563/. Thank you for your consideration. 7 Very truly yours. Hftsmnlfhr ShahrPh p jManager Vinyl Chloride Panel A fC. .I 1 CMA 112945 c*j > f- in c'tl Col Facility Table 4-1. Facilities That Manufacture or Process Vinyl Chloride l-ocalioti' Range of maximum amounts on site in pounds Activities sad uses KEYSOR-CENTURY CORP. SAUGUS, CA 1,000.000 - 9,999,999 As a reactant UNION CARBIDE CORP. TORRANCE, CA 10,000 - 99,999 As a reactant FORMOSA PLASTICS CORP. GEORGIA GULF CORP delawarecitv.de i\ci Au/tDcriTV r\c J ,000,000 - 9,999,999 1 nAAA AAA A AAA AA As a reactant WESTLAKE PVC CORP. PACE. FL 1,000,000-9,999.999 As a reactant UNION CARBIDE CHEMICALS TUCKER, GA 100,000 - 999,999 As * reactant BORDEN CHEMICALS & PLASTICS GEON CO BF GOODRICH CO. HENRY.IL ILLIOPOLIS, IL LOUISVILLE, KY 1,000,000 - 9,999,999 No Data 1,000,000 - 9,999,999 As a reactant; As a product component As a reactant As a reactant AIR PRODS, ft CHEMICALS INC. WESTLAKE PVC CORP. CALVERT CITY, KY CALVERT CITY, KY 10,000 - 99,999 As a reactant 1,000,000 - 9,999,999 As a reactant WESTLAKE MONOMERS CORP. CALVERT CITY, KY 1,000,000-9,999,999 Produce; For sale/distributioa VULCAN MATERIALS CO. GEISMAR, LA 100,000 - 999,999 Produce; Foroo-sjtcuse/processing; Asa by-prodact; As a reactant BORDEN CHEMICALS ft PLASTICS GEISMAR, LA No Data Produce; For oa-site ase/proccssing; For salefdistributioo; As a reacUnt PPG INI) INC. LAKE CHARLES. LA No Data Produce; For stlddutribution; Asa by-prodact; As an impurity; As a reactant CERTAINTEED CORP. SULPHUR, LA 1,000,000 - 9,999,999 ' As a reactant VISTA CHEMICAL CO. 4 FORMOSA PLASTICS CORP. WESTLAKE, LA BATON ROUGE, LA No Data 1,000,000 - 9,999,999 Produce; For sale/dtsribtition Produce; For oa-site ase/processmg; For sak/distribntion; As a by-product; As a AS reactant O) o RHONE POULENC BASIC CHEMICALS BATON ROUGE, LA 40 DOW CHEMICAL CO. PLAQUEMINE, LA 10,000 - 99,999 No Data Ancillary uses Produce; For sale/distribulion; As a reactant; As a manufacturing aid; Ancillary uses 238497 -1 - CO 024576315 tt Facility &u*oonR ten ro. Table 4-1. Facilities Thai Manufacture or Process Vinyl Chloride (coitinucd) Ixrcalion* Dl AAI ICLJfKir F A Range of maximum amounts or site in pounds Activities <nd uses i Art ruin non onn GEORGIA GULF CORP. UNION CARBIDE CORP. MARINE SHALE PROCESSORS INC. OfX:ir>FNTAI /'uirwir'Ai mon PLAQUEMINE, LA HAHNV1LUF, LA AMELIA. LA No Data No Data 1,000 -9,999 tnnnnA nnaimn Produce; For oa-site use/processing; For sale/distribulion; As a reactant As a by-product As a reactant DOW CHEMICAL USA MILES INC. VISTA CHEMICAL 00. OCCIDENTAL CHEMICAL CORP. ] ea>n Co BF GOOPRICHCO.--g-- GOODYEAR TIRE A RUBBER CO. VYGEN COW. GEON CO. BF GOODRICH AVON LAKE aC4O o, 2 a. co 0 1 VISTA CHEMICAL CO. OCCIDENTAL CHEMICAL CORP. GREENWOOD PLATING DOW CHEMICAL CO. SHINTECH INC. FORMOSA PLASTICS CORP. UNION CARBIDE CHEMICALS A UNION CARBIDE CHEMICALS 238497 MIDLAND. MI KANSAS CITY. MO ABERDEEN, MS BURLINGTON, NJ PEDRJCKTOWN, NJ NIAGARA FALLS, NY ASHTABULA, OH AVON LAKE, OH OKLAHOMA CITY, OK POTTSTOWN, PA GREENWOOD.SC FREEPORT, TX FREEPORT, TX POINT COMFORT, TX GARLAND, TX TEXAS CITY, TX 2- - 100,000 - 999,999 As a reactant; Ancillary uses 100,000 - 999,999 As a reactant No Data As a reactant 1,000,000 - 9,999,999 As reactant 1,000,000 - 9,999,999 As t reactant 100,000-999,999 As a reactant 1,000,000-9,999,999 As i reactant 100,000 -999,999 As i reactant 1.000,000 9,999.999 1,000,000 - 9,999,999 As reactant 1,000,000 - 9,999,999 As a reactant 1,000,000-9,999,999 As a product component No Data Produce; As a by-product; As an impurity, As a reactant; As a chemical processing aid No Data Import; For on-she use/processing; i ooo.uou- 111, I'D As a reactant > __No Daiao- Produce: For on-site use/processing; As a by-product; As a reactant 1000,000 - 999,999 Asa reactant 1.000.000 - 9.999.999 As reactant M CO -fv O) 0 2 4 S 7 6 3 1 S ;* BS Table 4-1. Facilities That Manufacture or Process Vinyl Chloride (continued) Facility Location' Range of maximum amounts on site in pounds Activities and uses OCCIDENTAL CHEMICAL CORP. LA PORTE, TX 1.000,000-9,999,999 Ancillary uew RHONE-POULENC BASIC CHEMICALS HOUSTON, TX 10,000 - 99,999 Ancillary uses OCa DENTAL CHEMICAL CORP. PASADENA, TX 100,000 - 999.999 As a reactant No Data DEER PARK, TX 1,000,000 - 9,999,999 As a reactant OCa DENTAL CHEMICAL CORP. GEONCO. OCCIDENTAL CHEMICAL CORP. LA PORTE, TX GREGORY, TX No Data 100,000 - 999,999 i tv Dm Produce; For sale/distrftHition Produce; For sale/distribution BONDCOIL CORP. PULASKI, VA 100,000 - 99,999 As a formulation component Source: TRI92 1994 Post office state abbreviation used am4 a. aX. a o to O, o > to CO U ~sl 23B497 -3 - 1' '1 fa'F' (ytzzclf Sc l-X 4. PRODUCTION, IMPORT, USE, AND DISPOSAL 4.1 PRODUCTION Production of vinyl chloride monomer in the United States was approximately 13.75 billion pounds in 1993 (C&EN 1994; USITC 1994), an increase of nearly 22%. This exceeds the latest available U S. estimated total production capacity figures (beginning of 1993) of 12.79 billion pounds at the beginning of 1993 (SRI 1993) and represents a substantial recent increase in production and capacity, even if vinyl chloride production is at full capacity. Previously, vinyl chloride production had grown only 1-5% per year over the last 5 years (C&EN 1994), Over the last 10 years, vinyl chloride production has grown at an average rate of about 7%, not including the large increase in 1993, although production volumes were fairly volatile (C&EN 1994). Vinyl chloride is currently produced in the United States by 10 companies at 12 facilities, which are as follows (SRI 1994): Westlake Monomers Corporation in Calvert City, Kentucky; Borden Chemicals and Plastics in Geismar, Louisiana; Dow Chemical in Oyster Creek, Texas, and in Plaquemine. Louisiana; Georgia Gulf Corporation in Plaquemine, Louisiana; PPG Industries in Lake Charles.' Louisiana; Vista Chemical Company in Lake Charles, Louisiana; B.F. Goodrich Company in LaPorte, Texas: Formosa Plastics Corporation in Baton Rouge, Louisiana, and in Point Comfort, Texas; Occidental Chemical Corporation in Deer Park, Texas; and Oxymar in Ingleside, Texas. Table 4-1 summarizes the facilities in the United States that manufacture or process vinyl chloride. This information was obtained from the 1992 Toxic Chemical Release Inventory (TRI92), and it summarizes the reported release data for 1992 (TRI92 1994). Table 4-1 also lists the maximum amounts of vinyl chloride that are present at these sites and the end uses of the vinyl chloride. Vinyl chloride was first produced commercially in the 1930s by reacting hydrogen chloride with acetylene. Currently, vinyl chloride is produced commercially by the chlorination of ethylene through one of two processes, direct chlorination or oxychlorination. Direct chlorination reacts ethylene with chlorine to produce 1,2-dichloroethane. Similarly, oxychlorination produces 1,2-dichloroethane, but this is accomplished by reacting ethylene with dry hydrogen chloride and oxygen. After both processes, the 1,2-dichloroethane is subjected to high pressures (2.5-3.0 megapascals) and temperatures "'DRAFT FOR PUBLIC COMMENT" CMA 112948 o 8 O Table 4-1. Facilities That Manufacture or Process Vinyl Chloride Facility Location* Range of maximum amounts on site in pounds Activities and uses KEYSOR-CENTURY CORP. UNION CARBIDE CORP. FORMOSA PLASTICS CORP. GEORGIA GULF CORP. WESTLAKE PVC CORP. UNION CARBIDE CHEMICALS OF GOODRieil C.------------------- BORDEN CHEMICALS fc PLASTICS BF-GOODRICH. CO i AIR PRODS, f. CHEMICALS INC. WESTLAKE PVC CORP. WESTLAKE MONOMERS CORP. VULCAN MATERIALS CO. BORDEN CHEMICALS & PLASTICS PPG IND. INC. SAUGUS, CA TORRANCE, CA DELAWARE CITY, DELAWARE CITY, PACE, FL TUCKER, GA HENRY -II- DE DE 1,000,000-9,999,999 10,000-99,999 1,000,000-9,999,999 1,000,000-9,999,999 1,000,000-9,999,999 100,000-999,999 ILLIOPOLIS, IL LOUISVILLE., KY' CALVERT CITY, KY CALVERT CITY, KY CALVERT CITY, KY GEISMAR, LA No Data 1, Q00r OeO'9r9T9r99 9 10,000-99,999 1,000,000-9,999,999 1,000,000-9,999,999 100,000-999,999 GEISMAR, LA No Data LAKE CHARLES, LA No Data CERTAINTEED CORP. VISTA CHEMICAL CO. FORMOSA PLASTICS CORP. SULPHUR, LA WESTLAKE, LA BATON ROUGE, LA 1,000,000-9,999,999 No Data 1,000,000-9,999,999 RHONE POULENC BASIC CHEMICALS DOW CHEMICAL CO. BATON ROUGE, LA PLAQUEKINE, LA 10,000-99,999 No Data As a reactant As a reactant As a reactant As a reactant As a reactant As a reactant i--a -reaofeaftb > An a preduc fc-compeneatAs a reactant As_a. reactant As a reactant As a reactant Produce; For sale/distribution Produce; For on-siteuse/processing,- As a by-product; As a reactant Produce; For on-site use/processing; For sale/ distribution; As a reactant Produce; For sale/distribution; As a by-product; As an impurity; As a reactant As a reactant Produce; For sale/distribution Produce; For on-site use/processing; For sale/distribution; As a by-product; As a reactant Ancillary uses Produce; For sale/distribution; As a reactant; As a manufacturing aid; Ancillary uses PRODUCTION, IMPORT. USE, AND DISPOSAL oi ? 3 C o o f ro to tn o Facility Table 4-1. Facilities That Manufacture or Process Vinyl Chloride (continued) Location1 Range of maximum amounts on site in pounds Activities and uses or-ooopnicH-eo. GEORGIA GULF CORP. UNION CARBIDE CORP. MARINE SHALE PROCESSORS INC. OCCIDENTAL CHEMICAL CORP. DOW CHEMICAL USA MILES INC. VISTA CHEMICAL CO. OCCIDENTAL CHEMICAL CORP. GOODYEAR TIRE & RUBBER CO. VYGEN CORP. VISTA CHEMICAL CO. OCCIDENTAL CHEMICAL CORP. GREENWOOD PLATING DOW CHEMICAL CO. SHINTECH INC. FORMOSA PLASTICS CORP. UNION CARBIDE CHEMICALS & UNION CARBIDE CHEMICALS OCCIDENTAL CHEMICAL CORP. RHONE-POULENC BASIC CHEMICALS PLAQUEM INEr-LA PLAQUEMINE, LA KAHNVILLE, LA AMELIA, LA ADDIS, LA MIDLAND, MI KANSAS CITY, MO ABERDEEN, MS BURLINGTON, NJ NIAGARA FALLS, ASHTABULA, OH nvUH^ UnnU| Ini OKLAHOMA CITY, POTTSTOWN, PA GREENWOOD, SC FREEPORT, TX NY OK FREEPORT, TX POINT COMFORT, TX GARLAND, TX TEXAS CITY, TX LA PORTE, TX HOUSTON, TX 100.r000.-999r999--------- frg~n reactant No Data Produce; For on-site use/processing; For sale/distribution; As a reactant No Data As a by-product 1,000-9,999 As a reactant 100,000-999,999 As a reactant 100,000-999,999 As a reactant; Ancillary uses 100,000-999,999 As a reactant No Data As a reactant 1, 000,000-9,999,999 *1 } find nnn.-- oft As a reactant 100,000-999,999 As a reactant 100,000-999,999 As a reactant Aa--a rsaefcemt 1, 000,000-9,999,999 As a reactant 1. 000,000-9,999,999 As a reactant 1, 000,000-9,999,999 As a product component No Data Produce; As a by-product; As an impurity; As a reactant; As a chemical processing aid No Data Import; For on-site use/processing; As a reactant No Data Produce; For on-site use/processing; As a by-product; As a reactant- 100,000-999,999 As a reactant 1, 000,000-9,999,999 As a reactant 1, 000,000-9,999,999 Ancillary uses 10,000-99,999 Anci1lary uses 2 0c 9 1 Cs 3 Mm io o 3 T a b le 4 1. F a c ilitie s T hat M anufacture o r P rocess V in y l C h lo rid e (c o n tin u e d ) 4. PRODUCTION, IMPORT. USE. AND DISPOSAL W 0 W 3 T3 C <0 w 1) u < (Q m 'D ?! c 3 0 a <v |Q I cn E C3 aQ; *Sh 4) jj x (0 c 0 ccc H0 *0* 0 Jj Jj Jj 3 3 3 Jj *Q J2 -fl C UUc 0 WH 01 *w*4 Vs. Vv Vs ^<v a Qj (0 <0 co w to k4 u Li O t0o t0o -43 ........ ..E. VDtlO U u O m* 333 *U *0 *0 flj 0w 0w 0u w aaa< U4 U0 U0 9ff^) SQlQ IQ Q 9) * 0 0 O o> 2ZZ9)i o o o o o M X- c 0 Jj ITS < tzo Q < <: -: ^ j: < w g" > H.i ga. 2K i<si u to m03 n 3 to D tf to cc u d a ia a a I 8 a 8 U j< j J < 5 5J>J au(Hd ow ' Xu1, ouHQU-<6ZU3-I C11((i> I3 ztMo o M XU ' X 0. U m3 uo Jo < 6- W ggss Hq Z aM vQ oSuz 8wo o o o m 0 c *p04 jJ (6 *H > a> hJ .0 .0 <0 V 9\ 0> Jj (0 CN a* 4) o 2 0 a! u u 3 O to ao CO --DRAFT FOR PUBUC COMMENT-- CMA 112951 4. PRODUCTION. IMPORT. USE. AND DISPOSAL (55O-550C). This causes the I.2-dichloroethane to undergo pyrolysis, or thermal cracking, which forms the vinyl chloride monomer and hydrogen chloride. The vinyl chloride monomer is then isolated (Cowfer and Magistro 1985). The technical grade product is available in 99.9% punty (HSDB 1994). Efforts are being made to minimize by-product formation in 1.2-dichloroethane pyrolysis (Cowfer and Magistro 1985). 4.2 IMPORT/EXPORT Imports of vinyl chloride totaled 119 million pounds in 1992 and 164 million pounds in 1991 (CPS 1993). Impons have been steadily declining from a high of 302 million pounds in 1989. prior to which they had been increasing (CPS 1993). Exports of vinyl chloride were 1.63 billion pounds in 1992. down from the all time high of 1.78 billion pounds in 1991. Over the past 20 years, exports of vinyl chloride have fluctuated fairly widely, but have been generally increasing an average of about 17% per year since 1975. 4.3 USE Vinyl chloride is an important industrial chemical because of its wide variety of end-use products and the low cost of producing polymers from it. Furthermore, polyvinyl chloride (PVC) is one of the most efficient construction materials available when analyzed on an energy-equivalent basis (Cowfer and Magistro 1985). Major end-use products include PVC products, such as automotive parts and accessories, furniture, packaging materials, pipes, wall coverings, and wire coatings, as well as vinyl chloride-vinyl acetate copolymer products, such as films and resins (Cowfer and Magistro 1985: Eveleth et al. 1990). End-use data for 1992 indicate that 98% of vinyl chloride monomer production is for making polyvinyl chloride and various polyvinyl chloride copolymers; the other 2% is for miscellaneous uses (CPS 1993). Vinyl chloride has been used in the past as a refrigerant, as an extraction solvent for heat-sensitive materials, and in the production of chloroacetaldehyde and methyl chloroform (IARC 1979). In the United States, limited quantities of vinyl chloride were used as an aerosol propellant and as an ingredient of drug and cosmetic products; however, these practices were banned by the EPA in 1974 (IARC 1979; HSDB 1994). "DRAFT FOR PUBLIC COMMENTTM CMA112952 4.4 DISPOSAL 4. PRODUCTION. IMPORT, USE. AND DISPOSAL Since vinyl chloride has been identified by EPA as a hazardous material, its disposal is regulated under the Federal Resource Conservation and Recovery Act (RCRA) (EPA 1993d). The transportation of hazardous materials for disposal is regulated by the Department of Transportation in compliance with this act (DOT 1993). The recommended method of disposal is total destruction by incineration. The temperature of the incinerator must be sufficient to ensure the complete combustion of the vinyl chloride in order to prevent the formation of phosgene. The recommended temperature range for incineration is 45CM.600C, with residence times of seconds for gases and liquids, and hours for solids (HSDB 1994). If in solution, the vinyl chloride product may need to be adsorbed onto a combustible material prior to incineration. Recommended materials include vermiculite. sawdust, or a sand-soda ash mixture (90/10) covered with wood and paper (OHM/TADS 1985). The vinyl chloride can also be dissolved in a flammable solvent prior to incineration. An acid scrubber should be used in conjunction with the incinerator in order to remove any hydrogen chloride that is produced by the combustion process (HSDB 1994; OHM/TADS 1985). Alternatively, chemical destruction may be used, especially with small quantities. One-to-two days is generally sufficient for complete destruction (HSDB 1994). Aqueous by-product solutions from the production of vinyl chloride are usually steam-stripped to remove volatile organic compounds, neutralized, and then treated in an activated sludge system to remove nonvolatile organic compounds remaining in the waste water (Cowfer and Magistro 1983). DRAFT FOR PUBLIC COMMENTTM cMA 112953