Document JJN21qYy6M4egO7Y9z4K97g4r

HARVARD UNIVERSITY ENERGY AND ENVIRONMENTAL POLICY CENTER Jefferson Physical Laboratory Cambridge, Massachusetts 0213b Phone: (617) 49S-23B1 *ec\v0 22 February Z 6 ^82. Dr. John Barr Manager, Regulatory Response Air Products and Chemicals Box 538 Allentown, PA 18105 i *r. Dear John, The reprint came from a book on Health Risk Analaysis, proceedings of the 3rd Life Sciences Symposium at Oak Ridge National Laboratory, 1980, Franklin Institute Press. On your first point 1 agree; on your second, I now take Risk (R) * Potency (6 animal) x lnterspecles factor x (K animal/human) x Dose(D) x Extrapolation factor (E) If E * 1 we are linear. Many people would put E 0, but others who are clever, knowledgeable, and politically influential (Prof, Matthew Meselscn), put E * 1. If you can make a decision without arguing this point it la simpler. Also if you are adding a pollutant which produces (say) lung cancer and we have a large background of lung cancer, even the basic mechanism Is non-^ine. The additional risk of the additional exposure is linear. a** I think that we should do our Calculations and leave this point to be discussed last--if necessary. Ve are developing our mathematical formalism to this end. We believe we have a more consistent policy here than CAG or OSHA, and would like to sell it to you at industry. Ve include uncertainty--and are willing to discuss carcinogencity even before It is proven (saccharin, formal dehyde, salt). One application is to end up with an ordered list of risks (with E 1) which is more consistent than ERA* a priority list, and more logical than Squires. Squires even now puts vinyl chloride near the top of his list--yet it has killed only 100 people worldwide so far and exposures are reduced. 1 / / AP00017005 Dr. John Barr 2 11 February 1982 Saccharin or aflatoxln may be killing 500 per year! I hope we have the opportunity to work with you and/or AIHC on this?-and of describing disagreements so that the country doesn't get hung up on them. I enclose papers on waste disposal and Crouch's update on our inter species potency comparison* Yours sincerely. RW:dr Ends. Richard Wilson Professor and Chairman Dept, of Physics AP000I7006 Air Products and Chemicals. Inc. Box 536- AHeniown. PAlStOS <2tS)4St-49ll 12 February 1982 Dr. Richard Wilson Chairman, Department of Physics Harvard University Cambridge, Massachusetts 02138 Dear Dick: Thank you for the reprint which you sent to me last week. It Is an excellent article with a number of good points. The reprint did not Identify Its origin, however, and I would appreciate the citation so that I can refer to the paper* I would make two comments on the paper. First, In figure 2, I suggest that scientific data Input Is vital to the benefit assessment, as well as that of-the risk and cost. Only if we understand the under lying principles can we estimate the results of changes. Second, I would encourage you to consider modifying your call to use the proportional dose model In all cases, and to use It only for preliminary priority setting, and In those cases where we do not under stand the mechanism or comparative metabolism of the carcinogen. Our experience with the "megamouse" EDn] study and other large data bases shows us that no mathematical model taken alone gives a reliable picture of risk very far outside of the experimental range. However, Gehring, Weisberger, Squire, the work at CUT, and many other studies shows that the linear method almost always Is Inappropriate when relevant data are available. Thus, we should strive to Incorporate all available data In our final decisions. I am happy at your recognition as Chairman of the Department, and glad to hear that you*re back In Cambridge for a while. As you may have read, OSHA Is reopening Its Cancer Policy, and soon will propose Its Hazards Identification Policy, so we have a busy time ahead again In this area. JTB/sjw mm* Jan/T. EOT Manager, Regulatory Response mm msss&- .^-*3 mAP00017007 SECTION 112 OF THE CLEAN AIR ACT PROVIDING FOR NATIONAL EMISSION STANDARDS FOR HAZARDODS AIR POLLUTANTS k) fa /L ^-----t~^m-- In view of past experience, EPA Has shifted its effor' devised improved public end Internal eaneer assessment procej and protocols. This new approach emphasizes good science ingful public participation in the assessment process on d/Aubs'tance by substance basis. EPA*s listing and standards will lie defensible. Substances posing a significant risk will be identified and regulated How SPA*s Program is Working Now First, EPA screened over 600 chemicals and prioritized them to concentrate on a list of 37 for further review. Now, health and exposure assessments are being prepared for those substances. (Nine are completed currently.) Next, the Science Advisory Board reviews health and exposure assessments. (Six substances are scheduled for review in early '82.) Public comment will follow on the health and exposure assess* aents. The SPA Administrator will decide whether or not to list a substance for regulation. ^ Scientific and engineering committee will review the emission standard which is based on assessment of risk to public health. EPA proposes the NESHAP in Federal Register. .EPA promulgates NESHAP. How^Program has Worked So far, SPA has listed seven substances under Section 112 and promulgated NESHAFS for four of these (mercury, asbestos, beryllium, vinylehloride promulgated, benzene, arsenic, and radionuclides standards not yet promulgated. The pace of listing and subsequently regulating hazardous air pollutants to date has been moderate, at best, for three reasons: . 1) Agency resources have been largely devoted to programs con cerning the criteria pollutants. As agency resources have been redirected, the hazardous air pollutants program has shown mors rapid progress without any legislative change. 2) At this time, there Is insufficient evidence to justify listing additional substances as hazardous air pollutants. For example, EPA asserted that four chlorinated compounds are carcinogens. EPA's Science Advisory Board rejected the assertion, pointing out the inadequacy of the Agency's scientific data/evidence. ' 3) In recent years EPA's focus was on the its Airborne Car cinogen Poliey. The proposed generic carcinogen policy has been withdrawn because `EPA was unable to resolve many of the scientific questions raised. However, EPA has incorporated key elements of the Airborne Carcinogen Poliey into its current program. 2/62 AP00017008 Status Report Potential Air Toxics z/$z I- Regulated as Hazardous Pollutant Under $112 Mercury Beryllium Asbestos Vinyl Chloride II. Listed as Hazardous Pollutant under 5112; Regulations Under Development Arsenic (inorganic compounds) Benzene III. . Health Documents Reviewed by SAB; 'Regulations Being Considered Cadmium Polycyclic Organic Matter .(see Coke Oven Emissions, Section IV below) IV. Health Documents Ready for SAB Review;-Source Analyses Complete Acrylonitrile ? Coke Oven Emissions (Carcinogen Assessment) a*JL Methvl Chloroform Trichloroethylene V. Health Documents Nearing Completion; Preliminary Source Analyses Complete Carbon tetrechroride Nickel Toluene Vinylidene Chloride VI. Health Documents in Preparation; Preliminary Source Analyses Complete Chloroform Epichlorohydrin Ethylene dichloride Ethylene oxide Formaldehyde Manganese VII. Screening Health Documents in Preparation; Preliminary Source Analysis Complete Acrolein Chloroprene Hexachlorocyclopentadiene PCB's APOOOl7009 2 VIII. Health Document in Preparation; Source Analyses not initiated Chromium IX. ' Health Assessment not initiated; Preliminary Source Analyses Complete Acetaldehyde Ally! chloTide Benzyl chloride Chlorobenzene' Cresols Dimethylnitrosamine Dioxin Maleic anhydride para-dichlorobenzene Nitrosomorpholine Phosgene Propylene oxide Xylenes L AP000T7bl6 7 SWWWY DATA ' POTENTIAL AIR TOXICS Substance Acetaldehyde Acrolein . Acrylonitrile Allyl chloride Uses, Sources end $uentities Regulatory Activities Exclusively used as feedstock to produce sever*! ether organic chesicals 500,000 tons produced (1978) Produced end used *t 5 ehcaieal plsnts, used *t 13 others to cake other chealcels (1750 tons annual emissions) Hazardous water pollutant* * Hazardous solid waste** Regulated by OSHA*** Exclusively used es a feedstock to produce other organic cheieals 175,000 tons produced (1578) Produced *t 4 eheciiea! plsnts, used *t 4 others to r.eke other eheslctls (48 tons annual emissions) * Hazardous end toxic water pollutant s Kaiardous solid waste c Restricted pesticide use**** Regulated by 05UA x Feedstock for several IrporUnt plasties end fibers ecrylics end eodaerylles) 850,000 tons produced (1980) Produced it 5 eher.fe*1 plants, used et 25 others to Bike other chealcels (5100 tons annuel emissions) Hazardous and toxic water pollutant Hazardous- solid waste Restricted pesticide use Regulated by QSKA e Exclusively used es ft feedstock" to produce eplchlorfchydrin (see below) ",, 1 5,000 tons produced (1978) Produced et 3 ehsnical plants. Used bnly et these plants, (550 tons annual emissions) * Hazardous water pollutant Regulated by OSM . rnaaarflous water pollutant (1311 Ctean Water Act). Toxic water pollutant (1307 Clean Water Act, hazardous solid waste under Resource Conservation and.Recovpry Act foroei . ***The Occupational`Safety and Health Administration has set allowable concen trations for workplace air ****Restrieted under the Federal Insecticide, Fungicide, Rodenttcide Act (fIFRA) AP000I7011 z SUMMARY DATA . eomrriAL jur toxics SubstlACt Arsenic tlnorganle Compounds) Sfl2enc Uses, Sources end Quantities Regulatory Activities Recovered as bypreduet from copper smelting. Used In pro duction of pesticides* wood preservatives, end filets. Also trees element In eoel end contaminant In other non-ferrous ores e About 50 sources {not Including coal combustion) e Approxlsately 14,000 tons sir emissions * Inorganic arsenic listed as a hazardous air pollutant under f 112, CAA, 6/5/80* * Regulations being studied. Toxic solid waste, toxic and hazardous water pollutant Regulated under the Safe Drinking Vater Act Inorganic arsenic regulated by OSHA a Restricted pesticide use (voluntary restriction) e Component In gasoline (few percent) * Pure benzene is septrated from petroleum end also produced (from toluene) for use at feedstock In manufacture of several leper* tant chemicals * 7,000,000 tons produced (1900) as a chemical. An additional 6,000,000 tons are produced In gasoline * tiamjfactured at mast refineries end coke plants (approx, 700* sources). Used at about 50 chemical plants. About 50,000 tons rfr.emlsslons from stationary sources; about 150,000 tons air emissions from mobile sources * Hazardous and toxic water polluant Hazardous solid waste Regulated by OSHA * listed as hazardous air eollutant under 1 112 of CAA, Regulations proposed. - AP00017012 3 SUMMARY DATA ' POTENTIAL AIR TOXICS Substance l/ies, Sources and Quantities Regulatory Activities Benzyl chloride Eeryllfim (pur* r.stil end ill stable compounds) Used exclusively is i feedstock to produce other organic ehewleels e 57,000 tons produced (1978) * Produced it < ehtsrtcil plants, used it about 13 others to uke other cheslcels (50 tons annual Missions) Hazardous water pollutant Regulated by 0SHA Hazardous solid Mist* Used fn atomic ind eerotpiee products and for cereal es. rtetal Dined end processed In U.S. 3750 tons used to U.S. (1978) Ore processed it 5 plants, fiery* Ulus oetil then processed it core thin SO others larylliua 1*"also tnee element In coil; releised during carnhuitlon e 1 A3 tons ennui! estsslons (all sources) Regulated In 1973 under CAA 1112 for 'berylliosis, S'taftdirds under review In 19B2* Toxic vater-pollwtant;. Sine .compounds listed ti hazardous water pollutants Hazardous solid waste "Regulated by 0SKA Cadrulix* (principally . Inorgenle compounds) Used In production of piyneffts, * batteries, plasties end In electroplating. Recovered is by-product from non-ferrous smelting. Also-trace element in coal, Approximately 5500 tons consuaed t Several hundred sources (not Ineluding coal eembustion) e Approximately 900 tons ilr Missions i i Hazardous solid waste s Toxic and hazardous water pollutant Regulated under the Safe Orlnklng Veter Act Regulated by 05KA FIFRA Regulatory decision package In preparation AP00017013 4 SUMMARY OATA POTENTIAL AIR TOXICS Substance Carbon tetrachloride Uses, Sources end Qyentities PrinelpilTy used es * feedstock for fluorocarbon* Kany small solvent uses .(30,000 tons annual eslsslons) Produced et 10 chemical plants, used at IS others to make other chemicals (2,500 tons annual emissions) Regulatory Activities 1 e Hazardous and toxic water pollutant Restricted pesticide use * Hazardous solid waste o Regulated by OSHA Chlorobenzene Chloroform Chloroprene Principally used as feedstock for pesticides and as a cleaning solvent 178,000 tons produced (1978) t Produced at 6 chmfcal plants, used at about S additional chemical and pesticide plants (21,099 tons annual eal&slons) Principally used as a feedstock In manufacture of fluorocarbons. Sene solvent usage 155,000 tons produced (1978) e Produced at 7 chesleal plants and used at about 15 others to Bike other chenictls (550 tons aonual emissions} . *4 Many solvent uses (11,500 tons annual elisions) e Hazardous and toxic water pollutant e Hazardous solid waste e Regulated by OSllA e FIFRA A* Hazardous and toxic water pollutant Hazardous solid waste Regulated by OSKA Drinking water e Exclusively used as feedstock In production of polychloreprane (synthetic rubber) a 139,000 tons produced (19761 a Produced and used at 3 chcalcal plants (1700 tons ann, .) e Regulated by OSHA AP00017014 5 \, SWfW DATA * POTEKHAL-AIA TOXICS Substance Uses, Sources end . Quantities Regulatory Activities Chrotf.ua (Hexevalent fora of most concern) Coke Oven Emissions (Subset of Polycyclic Organic Matter, see below) * Cresols (3 isomers) * e Ketal Important In production of Iron end steel. .Also used In refrectorles end In paint end piooents. 1,109.000 tons ore imported (1972) (17.600 tons enn. am.) Trees element In coal. Toxle water pollutant Hazardous solid waste t Regulated by QSKA . <6,000.000 tons of coke produced each year from coal, principally for use In the iron and steel Industry a Produced at 59 iron and steel . plants. Coke oven missions Include particulate matter with many complex organic chemicals adsorbed onto the particle surfaces.'. The organics ere generally rsnoved for analysis by extracting with benzene (Benzene-Soluble Organics, or BSO) 1600 tons of BSO are emitted annually 4 Being considered for listing under 1112 . of CAA e Several specific polycyclic organics listed as toxic water pollutants e Regulated by OSHA e Several specific polycyclic organics listed as hazardous solid wastes ' Principally used as a feedstock .In manufacture of several organic chemicals and plastics. Also used as solvent and in ore processing # 16,000 tons produced (1978) Produced at 7 chemical plants.' Used at more than ZSO other plants to make other chemicals (11,000 * tons ann. ea.) Also 1,500 tons ann. from coke - evens. e Hazardous water pollutant e Hazardous solid waste * Regulated by OSKA - . * * AP00017015 6 StmWV DATA POTENTIAL AIR TOXICS Substance Uses, Sources end Quantities Regulatory Activities Dlesthylnltrosaslne Produced it one facility as inter* * Hazardous solid vatic mediate to Mfct other cheslcals c Ecfstiort estlexted'to (? very* low. Dioxin (2,3,7,8-TCDO) Eplchlorohydrin Ethylene dlchlorfde Trace contaminant in sooe chemical a Under Bsltfaedfs evaluation by EPA, processes* Also formed during can- Toxic vtter pollutant bustion.of sooe chlorinated cos* e Hazardous solid waste pounds. e Rough estlcite of less than 100 1b. emitted nationwide each year. e Produced freo allyl chloride * Hazardous water pollutant. (see above). Used calnly to sake c Regulated by OSHA glycerin and epoxy resins end glues, e 150,000 tons produced (197) e Produced and used at 3 chemical plants to sake glycerin. Also used at IT chemical.plants to make epoxies. (240 tons annuel emis* slons). Principally used as feedstock la Hazardous and toxic water pollutant production of vinyl chloride,* Also Hazardous solid waste used in leaded gasoline to . V Regulated by CSKA scavenge lead from'engines.) e FIfRA 5,700,OOO tons produced'(1978) e Produced it 18 ehesfcal plants, used at 28 others. Used at cost U.S. refineries (about 250) 55,000 tons air emissions (not Including osissfons from gasoline) Apoooma 7 Substance Ethylene oxide Formaldehyde Kexaehleroeyelo* pentadlene Kaleie anhydride SUWARY DATA fOTCHTlAL AIR TOXICS Uses., Sources and Quantities Regulatory Activities Principally used as a. feedstock In canufecture of several organic ehesfeals, catnly ethylene glyeol antUfreeze* Scan use u a sterilent* 1,620,033 tons produced (1978) Produced at 13 chemical plants and used at Z ethers (1003 tons annual emissions}* Hazardous solid waste e restricted pesticides use e Regulated by 0SHA e Feedstock In ctmif&eture of reny products* Largest use various plastics (e.g., ctltolne) and wood resins* 3,200,000 tens produced (1976). a Produced at 53 plants and used at core than 350 others* Also product of combustion. e Hazardous water pollutant Hazardous solid paste Regulated by OSH* t FIFRA Exclusively used as feedstock in e Hazardous and toxic water pollutant cenufacture of pesticides and floe Hazardous solid waste retardants e FIFRA t 3500 tons produced (1978) Produced at 3 chemical plants, used at 5 others (30 tons annual emis sions)* a Used as the feedstock in the manufacture of polyester resins* 250,000 tons produced (1978) t Produced at 8 chemical plants, ' used.it several others to cake polyester resins* i Kaleie anhydride Is t solid* Scissions are low* Hazardous water pollutant, e Hazardous solid waste e Regulated by OSKl APOOOf7017 6 SUMMARY OATA FCTthTIAL AIR TOXICS Sul stance Uses, Sources end Quantities Regulatory Activities para-Dichlorobenzene Principally used as a spec* j. deodorant end for cotfa control. Ssall use is pesticide inter calate. e 27,000 tons produced (1978) e Produced at 7 cheraleal plant* and used by as cany as 100 pesticide plants (200 tons cnn. eft.) Deodorant usage too widespread to Quantify e Hazardous and toxic water pollutant Hazardous solid waste e Regulated by OSHA Kar>ftries e (Specific cor^ouni* not well * established} Ketal trportint In production of Iron and steel 1,600.000 tons used (1S78); tsust * leported . e Used at over 600 iron and steel facilities (4600 tons ann. era.) 4 Also trace element in coal, erzltted during coriustfon e.g.. power plants, coke) (3330 tons ann. era.) e Regulated by OSHA Kethyl Chlorofore Used principally as a eetal .cleaning solvent;{ovtr 90S). 310.000 tons produced (1678} e Produced it 4 charslcal plants (1609 tons ann. e,} . a Used in core than 20,COO sail! degreasers (270.003 tons ann. era.) e Toxic water pollutant Hazardous solid waste Regulated by OSHA e FJFftA N w* AP00017018 9 SUtfARY DATA POTENTIAL AIR TOXICS Substance Uses.) Sources and Quantities Regulatory Activities Methylene Chloride Used.principally as a pair* recover, a-ttal cleaning advent and aerosol propellant 260,030 tons produced (1978) Produced at 7 chemical plants {60S tons ann, ea) a Used in care than 7000 snail degreasers# Some household, use (2M,000 tons ann, esu). Toxic water pollutant Hazardous solid waste e Regulated by 05KA FIFRA Kick cl .{Nickel carbonyl and soluble salts of sttst concent) Kstal ieportant in production of iron and steel 168,000 tons produced (1978), of which 100)000 tons ieported One eint In U.S., tvs.production plants. More than 500 using plants (850 tons ann, era.) Trace element In coil emitted during combustion (5000 tons ann. **) e Toxic water pollutant Some compounds lasted at hazardous solid wastes a Regulated by QSHA Saee nickel compounds - FIFRA Nitrobenzene' Alaost totally used as feedstock to cake aniline (dye intermediate) Produced at 7 chemical plants,, teed at 13 ethers (500 tons annual editions) . e 425,000 tons produced <1978JT e Solvent uses (6000 tons annual editions Hazardous and toxic water pollutant Hazardous solid waste a Regulated by OSH& AP00017019 10 SUtttAAY DATA POTENTIAL AIR TOXICS Sulstance kltrosomorptotlfie Perchleroethylene Phenol Phosgene Vies, Sources and. Quantities Regulatory Activities One.of 4 group of ottrosKsInes . famed es contaminants In some dtstlca) processes Hot Intentionally produced Eslsslon* estimates'to be very low e Kent Drycleanlnp solvent of choice# Also used in setal cleaning 320,000 tons produced (1978) Kanufaelured it 10 eheoieal plants used at about 45,000 drycleaners And several thousand degreasers e 168,000 tons air emissions Totlc water pollutant Hazardous solvent caste a Regulated by OSHA f FJFRA * Feedstock In production of various . organic cheaicals andothec: product*. e i;2X,000 tons produced (1978) e Produced at 15 chemical plants and used, at core than 25 others (3000 dons ann. ea.) a Hazardous and toxle water pollutant Hazardous solid waste e Regulated by OKSA e F2FRA t Feedstock In production of several organic ohvalcsli and plasties, e 660,000 -tons produced (1978) e Produced at 18 chemical plants. . and used at 2t others (100 tons ' ann# sc.) e Hazardous water pollutant Hazardous solid waste a Regulated by OSHA #A AP00017020 77 5WHWY SATA POTMTIAL'AIft TOXICS Substance Polychlorinated biphenyls (PCB's) Polycyclic Organic Hatter (several different orgtMe compound) Propylene oxide Toluene * Uses, Sources And . Quantities Regulatory Activities Ko Terser produced In U,S.f Although PCS eontsining electrical transformer* capacitors still In use. e Emissions predoxinately during transformer eelfunetfons And whareequffn-uit Is disposed of In waste dic^s end incinerators, f Emissions estimate 15 tons per year nationwide. e Hazardous and texle water pollutant, 7SCA* prohibition and phase-out t See Coke Oven Emissions -Produced during, inefficient, embustlcn (e.g., residential. heating, wood stores). i Sane POM are toxic water pollutants Sane POKare hazardous solid wastes Feedstock in production of several organic cheaieats and plastics. 1.000,000 tons produced (1978), c Produced at 7 ehsaieal plants, used at 5Q others (650 tons ann. errs.). e Hazardous water pollutant Regulated by CSKA s FIFRA component in gasoline (few per** * cent). Pure toluene separated - from petroleum to wake benzene cad for solvent usage, 33.000,000 tons produced (1978) a Produced at mst refineries and coke* plants (approx* 300 sources) 4000 tons arut* era.), used at several hundred other sources u a solvent, then ssitted from thousands of sources.where paints, costings, end adhesives are used, e 1,100,000 tons air emissions. e.Hazardous and toxic water pollutant e Hazardous solid waste, e Regulated by OSHA til* - toxic ^uoslanctt Control Act APOOOI702f 12 StMttftY DATA WTINTIAL AIR TOXICS Substanee. TrJehloroethylene . - Yinylldene ehlorfd* Xylenes (3 isomers) Uses., Sources end Quantities Regulatory Activities Principally used as a Mtal : defining solvent 1<5,000 tons produced (1978} e Produced at 3 chmictl sources (400 tons ann, es.) . . Used In core than 20,000 degreasers (120,000 tons ann. eo,}., e Hazardous and toxle water pollutant Hazardous solid waste Regulated by OSHA t feedstock In c&nufecturc of . . plasties (principally Saran wrap) 135,000 tons produced (1978} Manufactured at 3 chenieal plants. used at about 33 others (400 * tons am, os.) _ Hazardous water pollutant * I Component In gasoline (few percent ; Pure xylenes separated frets petrolem for use. as a solvent and In production of various organic eher.leals 40,000,000 tons produced (1S78) e Manufactured at nost refineries and coke plants (approx. 300, , sources)(3700 tons ann. era.). Usee at several hundred other sources as solvent (250,000 tons ann. an.) then emitted froo'thousands of sources where p&tnts, coatings and adhesives are used. Hazardous water pollutant a Hazardous solid waste Regulated by OSHA FIFRA ' * ; APOOO17022