Document 8VpKrjMerQOO9zyVYXXzEvZ9B

TVTsC' Nf April ada ! J - V.V. _1< -tV^ "f O \ I 0 -jr' > t. o s r X (| I *i < `i l A ' *" t < --. 1 i t 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: Vinyl Chloride Toxicological Profile Dear Ms. Jenkins: ide4i On behalf of the CMA Vinyl ChlorideTanei, I am writing 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 ow nership 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 Second 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. BFG 00429 ; r'&fca Ms. Kim E. Jenkins April___ , 1997 Page 2 p. 138 Table 4-3. On the fourth line, the Georgia Gulf Corp. facility in Delaware City, DE should be deleted. 5315;* 3 e BF Goodrich facilities identified on the seventh line (Hemy, IL) and ninth line (Louisville, 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 4-2 (cont'd). The facility identified on the first line, BF Goodrich of Plaquemine, LA (which changed 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. On the ten^line, BF Goodrich of Pedricktcpi, 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. BFG o0430 PM ; PEsiB Ms. Kim E. Jenkins April___ , 1997 Page 3 2024575315;S 4 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." e ! SU < fit The entry ont-thserooGond to the last row" shouidTie-deleted. Occidental does not own a facility in La Porte, TX. p. 140 Table 4-1 (cont'd). Qn-tbe-first row/jpr Occidental Chemical of Pasadena, TX, "100,000-999,999" should be listed in the Range columns-- 7- BF Goodrich of Deer Park, TX, the second e-ntiy/should be changed to Geon Company. -The third entryrOccidental 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. BFG 00431 ; vc Ms. Kim E. Jenkins April___ , 1997 Page 4 f 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, Manager Vinyl Chloride Panel A BFG 00432 Facility KEYSOR-CENTURY CORP. UNION CARBIDE CORP. FORMOSA PLASTICS CORP. GEOR^A-GUIT CORP; WESTLAKE PVC CORP. UNION CARBIDE CHEMICALS GEObf CO. BF-GOODR1CHCOt BORDEN CHEMICALS & PLASTICS GEON CO. Bf GOODRICH CO, AIR PRODS. & CHEMICALS INC. WESTLAKE PVC CORP. WESTLAKE MONOMERS CORP. VULCAN MATERIALS CO. BORDEN CHEMICALS &. PLASTICS PPG IND. INC. CERTAINTEED CORP. VISTA CHEMICAL CO. FORMOSA PLASTICS CORP. RHONE POULENC BASIC CHEMICALS DOW CHEMICAL CO. Table 4*1. Facilities That Manufacture or Process Vinyl Chloride Location1 Range of maximum amounts on site in pounds Activities and uses SAUGUS, CA 1,000,000 - 9,999,999 As a reactant TORRANCE, CA 10,000 - 99,999 As a reactant DELAWARE CITY, DE DELAWARE ClTYgDfi 1,000,000 - 9,999,999 As a reactant 1,000,000 9.9P&999 _*_" rAtoc au Tmtev%4uvmnr PACE, FL 1,000,000 - 9,999,999 As a reactant TUCKER, GA 100,000 - 999,999 As a reactant HENRY, IL 1,000,000 - 9,999,999 As a reactant; As a produot component ILLIOPOLIS, IL No Data As a reactant LOUISVILLE, KY 1,000,000-9,999,999 As a reactant CALVERT CITY, KY 10,000-99,999 As a reactant CALVERT CITY, KY 1,000,000 - 9,999,999 As a reactant CALVERT CITY, KY 1,000,000 - 9,999,999 Produce; Forsale/distribution GEJSMAR, LA 100,000-999,999 Produce; For on-site use/processing; As a by-product; As a reactant GEISMAR, LA No Data Produce; For on-site use/processing; For sate/di&trvbuUon; As a reactant LAKE CHARLES, LA No Data Produce; For sile/distribution; Asa by-product; As an impurity; As a reactant SULPHUR, LA 1,000,000 - 9,999,999 As a reactant WESTLAKE, LA No Data Produce; For sale/distribution BATON ROUGE, LA 1,000,000 - 9,999,999 Produce; For on-site use/processing; For sale/distribution; As a by-product; As a reactant BATON ROUGE, LA 10,000-99,999 Ancillary uses PLAQUEMINE, LA No Data Produce; Forsale/distribution; As a reactant; As a manulaclunng aid; Ancillary uses BFG 00433 238497 -1- 1000,000-999,999 As a reactant 1:000:000 - 9.999.999 As a reactant v :e > < Zi to -11 6 alt >> .5 > b. I <tn9 CO m V> tt tt Crt tfl V3 < < <<<<<< 9. a 2Ov 2O' oC Os Oi' O' SS Sg,, o --2 3 a ^ fJ ^ 2O' &O' Ox' xO' , O'" O'" O'" O' O O' O. O' O' Z OO'* OO'*' O ' 9O>'* 2 * s s s- l oo o" 2 " L* 3 .5ga&_ .0sm5s0 fi | 60 s g. <_C<O. .--caa .s 8o 8 to < o I S_ *> s i u T3 5-2 < (9 ^ <I &t7> bhOuO- 1 <9 ,3 u& s e <* V) < 8 o. to tn < 3 03 *8 2 < S <8 &3 Vos I nM S'. Sn S', g J nI oS'. o\ oV P 8o9, 015^ 0o. ssi s s 8 oa. GARLAND, TX TEXAS CITY, TX UNION CARBIDE CHEM ICALS* UNION CARBIDE CHEMICALS O ou v.1 u. -1 C> => eCll < o C) 5u U. WQ si o 0 u < u 1 Xo 5 g<H frij o o -<J u ui 5 2 Oue/5 O PCO 2 < CO O 2 BFG 00434 C(| If) +X) o:4 Facility Table 4-1. Facilities That Manufacture or Process Vinyl Chloride (continued) Location' Range of maximum amounts on site in pounds Activities and uses CHEMICAL CORP. LA PORTE, TX 1,000,000 9,999,999 ---AncillAry uw RHONE-POULENC BASIC CHEMICALS HOUSTON, TX 10,000 - 99,999 Ancillary uses OCCIDENTAL CHEMICAL CORP. PASADENA, TX 100,000-999,999 As a reactant I ~ u DL/nUttnU DEER PARK, TX DEER PARK-rTX 1,000,000 - 9,999,999 As a reactant Javvr*aVniBfa _ ri uuutdi ryi'jHwuim iuuiiuii GEON CO. OCCIDENTAL CHEMICAL CORP. LA PORTE, TX GREGORY, TX No Data 100,000-999,999 knlyv* ni7^uutji Produce; For sale/distribution Produce; For sale/distribution BONDCOTE CORP, PULASKI, VA 100,000 - 99,999 As a formulation component Source: TRI92 1994 1 Post office state abbreviation used BFG 00435 238497 -3- Ipr' (s>azcl{ tct\ 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*Jjedrich 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 Ingieside, 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' BFG 00*36 Table 4-1. Facilities That Manufacture or Process Vinyl Chloride Facility Location' Range of maximum amounts on site in pounds Activities and uses .. PRODUCTION, IMPORT, USE, AND DISPOSAL DRAFT FOR PUBLIC COMMENT*** KEYSOR-CENTURY CORP. UNION CARBIDE CORP, FORMOSA PLASTICS CORP. GEORGIA GULF CORP. WESTLAKE PVC CORP. UNION CARBIDE CHEMICALS op cr. BORDEN CHEMICALS & PLASTICS .BF-COODBICH. OTL, AIR PRODS. & CHEMICALS INC. WESTLAKE PVC CORP. WESTLAKE MONOMERS CORP. VULCAN MATERIALS CO. BORDEN CHEMICALS & PLASTICS PPG IND. INC. CERTAINTEED CORP. VISTA CHEMICAL CO. FORMOSA PLASTICS CORP. RHONE POULENC BASIC CHEMICALS DOW CHEMICAL CO. SAUGUS, CA TORRANCE, CA DELAWARE CITY, DELAWARE CITY, PACE, FL TUCKER, GA DE DE ILLIOPOLIS, IL LOUISVILLE^-- CALVERT CITY, KY CALVERT CITY, KY CALVERT CITY, KY GEISMAR, LA GEISMAR, LA LAKE CHARLES, LA SULPHUR, LA WESTLAKE, LA BATON ROUGE, LA BATON ROUGE, LA PLAQUEMINE, LA 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 i.onn niin n nnn -qclo---- No Data l, aoor oee-*'9r9^9r^9 9 10,000-99,999 1,000,000-9,999,999 1,000,000-9,999,999 100,000-999,999 No Data No Data 1,000,000-9,999,999 No Data 1,000,000-9,999,999 10,000-99,999 No Data As a As a As a As a As a As a reactant reactant reactant reactant reactant reactant .compen<rL As a reactant A&*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 BFG 00437 .. PRODUCTION. IMPORT, USE. AND DISPOSAL DRAFT FOR PUBLIC COMMENT*** Facility Table 4-1. Facilities That Manufacture or Process Vinyl Chloride (continued) Location Range of maximum amounts on site in pounds Activities and uses OF-qeopnicrr'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 fit UNION CARBIDE CHEMICALS OCCIDENTAL CHEMICAL CORP. RHONE-POULENC BASIC CHEMICALS PLAQU EM l NE-t--LA PLAQUEMINE, LA No Data HAHNVILLE, la AMELIA, LA ADDIS, LA MIDLAND, MI KANSAS CITY, MO ABERDEEN, MS BURLINGTON, NJ -PBDRieftTPWIf, "WJ NIAGARA FALLS, NY ASHTABULA, OH AV0N-LAKET,~OH OKLAHOMA CITY, OK POTTSTOWN, PA GREENWOOD, SC FREEPORT, TX No Data 1,000-9,999 100,000-999,999 100,000-999,999 100,000-999,999 No Data 1,000,000-9,999.999 1> 0QQ, 000 -t990*93 100,000-999,999 100,000-999,999 in 000,000 9,33379J9 1,000,000-9,999,999 1,000,000-9,999,999 1,000,000-9,999,999 No Data FREEPORT, TX POINT COMFORT, TX No Data No Data GARLAND, TX TEXAS CITY, TX LA PORTE, TX HOUSTON, TX 100,000-999,999 1,000.000-9,999,999 1,000,000-9.999,999 10,000-99,999 --Arr-a--reactant Produce; For on-site use/processing; For sale/distribution; As a reactant As a by-product As a reactant As a reactant As a reactant; Ancillary uses As a reactant As a reactant As a reactant As a reactant As a reactant Ae-~a-.ro acfeanfc As a reactant As a reactant As a product component Produce; As a by-product; As an impurity; As a reactant; As a chemical processing aid Import; For on-site use/processing; As a reactant Produce; For on-site use/processing; As a by-product; As a reactant As a reactant As a reactant Ancillary uses Ancillary uses BFG 00438 Table 4-1. Facilities That Manufacture or Process Vinyl Chloride (continued! Facility OCCIDENTAL CHEMICAL CORP. OF COOPftiOH^O: OCCIDENTAL CHEMICAL CORP. GEON CO. OCCIDENTAL CHEMICAL CORP. BONDCOTE CORP. Location' PASADENA. TX DC DR PARK, <^X DEER PARK. TX LA PORTE, TX GREGORY, TX PULASKI, VA Range of maximum amounts on site in pounds No Data 1,000/600 P,QQQrt>M No Data No Data No Data 100,000-999,999 Activities and uses As a reactant .Aj u"l'(JUluut Produce; For sale/distribution Produce; For sale/distribution Produce; For sale/distribution As a formulation component Source: TRI92 1994 Post office state abbreviation used PRODUCTION, IMPORT, USE. AND OISPOSAL DRAFT FOR PUBLIC COMMENT" bfg 00439 4. production, import, use, and disposal (550-550C). This causes the 1,2-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% purity (HSDB 1994). Efforts are being made to minimize by-product formation in 1.2-dichioroethane pyrolysis (Cowfer and Magistro 1985). 4.2 IMPORT/EXPORT Imports of vinyl chloride totaled 119 million pounds in 1992 and 164 million pounds in 199! (CPS 1993). Imports 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 179c 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 (1ARC 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 COMMENT BFG 00440 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 450-l,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 COMMENT' 00441