Document 7M1pJbKL32928gEm64r9199LE

* rnsion of The Society of The Plastics Industry, Inc. August 28, 1989 TO: The VI Health, Safety & Environment Committee RE: California Air Resources Board Draft Report on Vinyl Chloride Enclosed is material I received today from Peter de la Cruz relating to the development of a report by the California Air Resources Board outlining "Public Exposure To, Sources, and Emissions of Vinyl Chloride in California". As noted, the comment period on the preliminary draft closes on September 8th; a revised draft will then be developed with a 20-day comment period before the final draft is forwarded to the Scientific Review Panel. If you have separately received this document and filed or plan to file comments, please let me know. As the material I received notes that "landfills are the largest source category of vinyl chloride emissions in California", I have copied the appropriate VI Technical Committee contacts. MNS/pmb enclosure cc: C. Bush J. Krokosky R. Gottesman Meredith N. Scheck Assistant Director CTL018228 Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (201) 890-9299 ;UG 2"1 '89 IB: 29 FROM GOODYEAR RES RM 256 PAGE.B02 George Oeckmtjlen. August 1, 1989 Dear Sir or Madam: D-C.af t.. Re&ar,t.jm-Yiny 1...Ch 101.i.da As you requested, enclosed fop your review and comment is the preliminary draft report on vinyl chloride. Public review of this report includes two comment periods. The first comment period begins with the mailing of is report and you have until September 8, 1989 to submit your itten comments to us. The staffs of the Air Resources Board R3) and Department of Health Services (DHS) will review and respond to all the comments received. Your comments and our responses to them will be compiled in Part C of the report and where appropriate, the report will.be revised. The revised report will be mailed out to you and other mnmbnrs nf thr public for a second and final review. It will inc.lude Parts A, 8 and C of the report as well as an Executive Summary which summarizes Parts A and 8. At this stage, the ARB and OHS staff will only accept comments on the Executive Summary and any revisions made to the draft report. A 20 day comment period will be given for your review; comments received, and our . responses will then be incorporated as an addendum to Part C. After reviewing all public comments, the final draft report along with Part C will then be submitted to the Scientific Review Panel foritsrevlew. The Scientific Review Panel has requested that all public comments be directed to the AR8 during these two comment periods. Please note that. In accordance with this process, the Panel will not receive or consider any comments submitted directly to It, or received by the ARB after the close of each comment period. CTL018230 .UG Zl '89 i0-'29 FROM GOODYEAR RES RM 25S PAGE.003 August 2# 1989 In order fo- r vyo-u-'r comments tvow wbeb wcouniitsidered uonit tuhi iis) version of the report, they must be received by September 8, 4$$9 and submitted to: Mr. Robert Barham, Chief Toxic Air Contaminant Icfentificetion Air Resources Board Attn: Vinyl Chloride P. 0. Box 2825 Sacramento, CA 95812 Branch IF you have any questions concerning the report or the comment procedure, please contact Mr. Richard Corey of the Substance Evaluation Section at (9J6) 323-8543. nolosures Scientific Review Panel Peter 0. Yenturini, Chief Stationary Source Division CTL018231 fl'UG tl 'S3 !0i30 FROM GOODYEAR RES RM 25S PRELIMINARY DRAFT TECHNICAL SUPPORT DOCUMENT part a PUBLIC EXPOSURE TO, SOURCES. AMD EMISSIONS OF VINYL CHLORIDE IK CALIFORNIA REPORT TO THE AIR RESOURCES BOARD OH YIHYL CHLORIDE PAGE.004 Principal Author* Richard Corey ggntrlfruUag-Anthprs. Tom Parker Chris Nguyen Paul Alien Steve Hui Reviewed and Approved by.* Doan Denton, Manager Substance Evaluation Section Robert Barham, Chief Toxic Air Contaminant Identification Branch Peter 0. Venturing Chief Stationary Source Division July 1989 CTL018232 '29 10:30 FROM GOODYEAR RES RM 255 PAGE.005 DRAFT I. INTRODUCTION Part A of this report is an evaluation of vinyl chloride's 35, emission sources, ambient and indoor air concentrations, and 3uiation exposure in California. Also included are discussions of the ysical properties-and atmospheric persistence of vinyl chloride, lifornia Health and Safety Code Section 39655 states that substances stj^y the U.S. Environmental Protection Agency (SPA) as hazardous * ^putants (Section 112 of the Clean Air Act) shall be identified as tic air contaminants (TACs) by the Air Resources Board (ARB), jrefore, because the EPA has listed vinyl chloride as a hazardous air Uutant, the AR$ is directed by statute to identify vinyl chloride as i AC. The ARB is the state agency responsible for the. identification TACs in their non-pesticldal uses. .The California Health end Safety is Section 39655 defines a TAC as "an* air pollutant which nay cause or itribute to an increase in mortality or an increase in serious 'ness, or vhich may pose a present or potential hazard to human i1th.* The findings of the Part A report are considered with the 11th effects findings (Part B report) of the Oep&rtment of Health -vices (DHS) to determine if a compound should be identified as a I by the ARB. In 1978, the AR8 adopted an ambient air duality standard for yl chloride of 10 ppb for t 24-howr average. The standard resented the limit of detection for vinyl chloride at the time it was pted. Vinyl chloride is an extremely volatile compound that is marily used for the production of polyvinyl chloride (PYC). PVC i ricated for use in several products of vhich many are used by the A-1 CTL018233 flUG '89 10:30 FROM GOODYEAR RES RM 255 PAGE.006 construction Industry. In California, the Identified sources of vinyl chloride emissions are landfills, PYC production and fabrication facilities, and sewage treatment plants. Available information indicates that landfills are the largest source category of vinyl chloride emissions in California. Vinyl chloride has been measured in the ambient air near hazardous waste and municipal waste landfills. Numerous studies have documented the presence of vinyl chloride in the landfill gas of these and other landfills, and have shovm that vinyl chloride can be formed in landfills where chlorinated organic compounds have been disposed. Therefore, because disposal of such chlorinated compounds is prevalent, the staff reconroends that all landfills (hazardous and municipal) in the state be regarded as potential vinyl chloride emission sources. In this report, ambient monitoring data and meteorological data are used with an atmospheric dispersion model to estimate population exposure to vinyl chloride near two California landfills. The modeling results show that people living near these landfills are exposed to elevated levels of vinyl chloride. The results also imply that people residing near other landfills in the state may be exposed to elevated levels of vinyl.chloride. In addition to estimating ambient air exposure, this report also evaluates indoor air exposure to vinyl chloride. Based on limited monitoring data, indoor air exposure to vinyl chloride Is probably not significant for the majority of the population. However, for people residing near landfills, inhalation of indoor air may represent the most significant source of vinyl chloride exposure. This is because vinyl chloride can migrate underground from landfills and accumulate in nearby structures. The concentrations of vinyl chloride measured in homes located near landfills have been reported to be several times greater than the corresponding ambient concentrations. CTL018234 A-2  | .AUG 21 '89 10:31 FROM GOODYEAR RES RM 25S f8 PAGE.00? uno^1 4 * Prepared by: California Departaent of Health Services Principal Editor: I Morsan Cravit2, Ph.D.. MPH, Staff lexicologist I Revieved by: Ceorge V. Alexeeff, Ph.D. Michael J. Lipsetc, M.D. Douglas N. Cox. Ph.D. (California Publie Health Foundation) l j I Based in part on verk aubnittted by: Carla C. Christensen and C. Tucker Heines, Biological and Envitonoental Cheatstry Departaent, SRI International, 333 Ravensvood Avenue, Menlo Park, California 96023, Under Contract 83*3667$ (C45A) and by: Deborah Crady, M.D., K.P.H. School of Medicine, University of California, San Francisco, and Allan Saith, M.D., PH.D. University of California, Berkeley i i CTL018235 RUG 21 'e9 10:31 FROM GOODYEAR RES RM 255 PAGE.008 l.o SxgsMt&ft-SufflaaKy Vinyl chloride Is a short-chain halogenated hydrocarbon used predoainantly in the manufacture of polyvinyl chloride and various packaging and construction products. Vinyl chloride has a very low degree of acute toxicity, with cvo-heur inhalation LDjq values ranging from 27,419 ppm in sice to 236,215 ppm in rabbits and guinea pigs. Exposure to high concentrations can lead to narcosis, cardiovascular and respiratory irregularity, convulsions, cyanosis and death. Several husan deaths have been attributed to occupational . exposure to very high levels of vinyl chloride. Autopsies of these patients revealed congestion of the liver, . spleen and kidneys. Acute toxicity symptocs are thought to occur above 100 ppa. * Chror.ie exposure of workers to vinyl' chloride has been shown to lead to "vinyl chloride disease", characterised by occupational acro-osteolysis, vasospasa of the hands siallar to Raynaud's syndrome, dermatitis, circulatory and central nervous system alterations, thrombocytopenia, splenomegaly and changes in liver function. Eight symptoms commonly reported by workers exposed to vinyl chloride (including dizziness, headaches and nausea) were observed even at dose levels below 50 ppa. Vinyl chloride has been shown to induce cancer in animals in utero., but has not been sh vn t cause any other reproductive or 1*1 CTL018236 32 FROM GOODYEAR RES RM 25S PAGE.009 nD p a f i\ 115 developmental effects in rats, mice and rabbles. Epidemiologic studies of families of vinyl chloride workers or communities having vinyl chloride processing facilities suggested the possibility of an increased incidence of birth defects and spontaneous abortions among people at risk; however, subsequent reviews of these studies have concluded that there is Inadequate evlde-nca to Hi^ -O. SnyjSflHSgntAl .?r gAS--exposure _ to Vinyl chloride with birch defects or spontaneous abortions in humans. The noncarcinogenic effects occur &c concentrations near or above *10 ppm. which is greater than four orders of magnitude above possible general ambient levels in California (0.5 ppb). The noncarcinogenic effects also occur at concentrations greater than 3 orders of magnitude above tha highest concentrations measured near landfills <10 ppb). Consequently, D3S--staff do not expect noncarcinogenic adverse heelth effects . to occur from acute og chronic exposures co_ vinyl chloride In ambient air. JhS__ International Agency for Research on Cancer_ flARC>. tha United States Environmental Protection Arencv (ETA^_and-the. California Department of Health Servlcee (CPUS) have identified vinyl chloride as e chemical____ for which there is sufficient evidence of carc1norenieitv in both humans and experimental animals. Chronic inhalation and. oral exposures of rats, mice and hamsters to vinyl chloride have been associated with an Increased incidence of malignant and benign rumors at several sites including tha liver, lung, mammary gland aad th nervous system. In humans. ; i-2 CTL018237 '89 13:32 FROM GOODYEAR RES RM 25S PAGE.010 epidemiological studies of occupationally exposed workers have linked vinyl chloride exposure to development of a rare cancer, liver angiosarcoma, and have suggested a relationship between exposure and lung and brain cancers. Although pharmacokinetic studies in humans exposed to vinyl chloride are rare, limited evidence indicates that, following inhalation of lov levels of vinyl chloride <3 to 24 ppa), up to 71% (vith a mean value of 42%) of the given dose may be absorbed. Vinyl chloride absorption appears to depend on its metabolism, which is a dose*dependent, saturable process. Due to saturation of the enzyme systems responsible for the metabolism of vinyl chloride - (cytochrome P-450 end ' alcohol dehydrogenase), exposure to concentrations above approximately 250 ppa will not necessarily lead to an increasing incidence of tumor development. Metabolism of vinyl chloride leads to formation of chloroethylene oxide and chloroecetaldehyde. evo reactive intermediates which undergo covalent binding to cellular saeromoleeules and are thought to be responsible for the toxic effects of vinyl chloride. These and other metabolites may be further metabolized and excreted la ehe . urine. Unaetabolisftd vinyl chloride is eliminated primarily la exhaled air. Vinyl chlorlde..ls mutagenic in both prokaryotic and eukaryotic test systems, with significantly greater genotoxlclty seen after me Cab lie activation. DBS staff have found __r*> _ fyidence,of ^^arcinogeMc thresh ld_ level and because vinyl rhlorld .-JA 1*3 CTL018238 3`iJG 21 '83 10:33 FROM GOODYEAR RES RM 255 PAGE.211 ruescenic. the tt*ff recormendfl char vlnvl -chloride be considered i as ?.ot having a threshold fox, carcinogenicity V .> .V Several animal carcinogenicity and human epidemiological studies occupationally exposed workers have been analyzed for risk assessment purposes. Although actual exposure levels are not known, exposure estimates have been used to evaluate the Vaxveiier et al. (1976) study of vinyl chloride workers. Based on these estimates, DHS staff has calculated that a lifetime exposure to 0.465 ppb might result in an incremental Individual eaaeer risk of 1 x 10*^(as*uming liver, brain and lung cancer are all related to ; f vinyl chloride exposure). This yields a risk estimate of 2.1 x 10'Vppb. Ia the ease that only liver cancer is assumed to be linked to exposure, a lifetime exposure to 1.0 ppb may be expected to result in a risk of 1.0 x 10*^. Due to inadequate exposure data, follow-up time and other sethodological*problems, DKS staff suggest that eke human risk estimates be used only for eosparetlve purposes. Evaluation of animal experiments by the linearized multistage model yields a range of human risks spanning fro l.S^x 10**3/ppb to 3.9 x 10 *6/'ppb, with most estimating a risk of between 10 4 and 10-5/ppb'. Evaluation of animal tuaorigenicity data indicates Chat vinyl chloride's carcinogenic potency la dependent on sex, tumor sice end age of exposure, taking these factors int i account. 9SS staff believe ehac the human risk estimates are consistent with those obtained for laboratory animals. The staff - of DHS recommends that the animal data be used to evaluate the risks resulting from vinyl chlorid exposure. Coneeauefitiv. the `i .1 CTL018239 1-4 ' S9 10 t FROM SOODYEFlR RES RM 25S PAGE.012 4 i range nf risks, estimated froa-- of animal srjdltt and recommended hv PHS. ,^f.o.r. regulatory__ purposes lie__ between 3.9 * and Jl>.3, a 19~3/??b- Vinyl chloride has not been detected In the ambient air of California (Unit of detection - 0.5 ppb) except at certain "hot srots". Air Resources 5oard (AR3) staff has aonitoted vinyl chloride eaisslons from the SICK hazardous waste site in Vest Covina and the Oil landfill in Monterey Park. Estimates of peak expcsure cone ncrations for saxiaally exposed receptors range froa 2 to 10 ppb at the BKJC landfill and froa 0.6 to 9 ppb at the Oil site. Air Resources Board staff has estimated chat between 17,000 and 131,000 individuals nay be exposed to 1 ppb at the BKX site. A. life tine exposure of 131,000 residents eo 1 ppb would be associated with an upper bound estimate of 0.5 to 236 excess cancer cases. The calculations represent the upper range of plausible excess cancer risk: the actual Sisk,, which cannot be calculated, say be insignificant. Based on ehe finding of vinyl chloride-induced carcinogenicity and the results of the risk assessment, H2-JLSg __ thae vtnvl chloride .is. an. .air pollutant which wav causa er contribute- to, an increase In mortality or an increase in serious illness, or which wav pose a presene or potential hazard to huain hsilrii.,. CTL018240