Document MM1Q94ZaQvxmL4a837jjGe41j

INTEROFFICE MEMORANDUM To _ From DISTRIBUTION A, 0. DIGLIO DISTRIBUTION: A. R. Adams J. H. Arnold J. J. Ballker O. T. Barr C. E. Blades R. A. Blomquist P. L. T. Brian C.E. Callicott T. L. Carey M. R. Chmura J. L. Cost W. J. Cross E. Donley F. H. Femengel R. Fleming H. P. Gallagher H. L. Harwell J. V. Heider W. Hoge H. L. Oaffe 1 Date APRIL 26, 1976 SHELL'S POSITION ON TOXIC SUBSTANCES Subject---------- --------------------------------------------------------- CONTROL LAW (Location. organization, or Dapartinont) VALLEY FORGE (Location. Organization, at oaparimwit) R. E. Jones J. D. Kramer R. G. Kunz R. Lomicky J. B. Maerker J. E. HcEvoy A. K. McMillan T. J. Medovlch J. C. Novak D. E* Pryor H. A. Quigley R. J. Ryan J. A. Saner W. J. Scharle R. H. Schenck W. M. Smith R. M. Yozar H. L. Watson J. T. Wharton G. D. Grab V. A. Bonannl Attached for your Information fs Shell's position on Toxic Substance Legislation. Shell supports House Bill HR-7664 introduced by Congressman McCollister with same modifications. /mjv Attach^sn V... A. 0. DIGLIO (3201 AP00036982 Shell agreesToxic Substances Control law needed-- McCollister bill, with changes, supported Congress is actively considering legislacion to deal wich a growing alarm over the known and unknown effects ofexposure of humans and the environment to a large number of chemicals. It is likely that a Toxic SubstancesControl law will be enacted early in 1976. Shell believes in the prevention of undue risk of harm to human health and to the environment and1 strongly supports the development of appropriate legislacion. This legislacion, while needed, will be costly to everyone. The general public, chemical industry, downstream consuming industries, gov* eminent, and labor will all ultimately pay the price. Therefore, it is imperative that such legislation not impose unnecessary burdens. It should not include provisions beyond those reasonably necessary to pre vent undue risks. Currently proposed legislation, Senate Bill S776 and House Bill HR 10318, contains many provisions which are unnecessary and overly burdensome. Adoption of these extraordinary provi sions will cause unnecessary unemployment, un necessary discouragement of innovation and in vestment, and unnecessary denial of useful and $af< products. In addition, less severely regulated fbrelgr jindustry would be given a competitive edge which! would depress our balance of trade payments. ' Shell believes that soundly balanced legislation must include the following provisions: Regulation of only those chemicals found to pose an Copies of this article in pamphlet form are available from Shell Chemical Company, Room 1518, One Shell Plata, Houston. Texas 77002. unreasonable risk to health or the environment. (There are thousands ofchemicals in use today which pose no unreasonable risk. To test, report, and regulate all of these, as possible under S776, is ridic ulous. This effort should be concentrated on due real culprits.) Regulation of only those chemicals not already;fod> erally regulated. (There are many laws such at the Occupational Safety and Health Act, die Clean Air and Water Acts, the Consumer Product Safety Act and others ttat deal with chemical substances. Du plication of Overlapping laws does not increase the desired protection. The competition, redundant efforts and confusion of various agencies each assum ing responsibility for control would generally dilute the enforcement, increase the costs to do the job, and frustrate industry in its efforts to comply wich the law.) Exclusion of state regulations where the Adminis trator has ruled on a chemical substance. (Individual state regulation would unnecessarily multiply testing, labelling, record keeping and controls leading to con fusion and totally unnecessary costs. This could result in keeping 50 different sets of records, 50 different testing procedures, 50 different labels, etc. The dis ruptive effect on interstate commerce is difficult to contemplate.) Exemption from regulation of laboratory and re search test chemicals, reagents* mixtures and in termediate chemicals, chemicals manufactured or distributed for further conversion into other chem- AP00036983 icals, except where the Admin^'rator finds that coverage is necessary. (Laboraco nd research per sonnel handle only small quantities of chemicals and are trained in protective measures. Hence, extensive testing and controls for these substances would serve no useful purpose. In the case of mixtures, such as paints, and inks, coverage is unnecessary because the individual chemicals are regulated. Mixtures should be regulated onlV where the chemicals react in a sig nificant way creating a new chemical substance or exert a synergistic effect where a finding of unreason able risk can be made. Exposure of humans and the environment co chemical intermediates is already folly controlled by ocher laws.) Testing and premarket screening should be required for chemical substance* upon a finding, subject to a hearing, that an unreasonable risk may exist. (Hear ings help to ensure that all information and views are considered and that costly arbitrary action is made less likely. For example, the heavy costs to the public associated with the now redundant regulations for auto seat belt interlock systems might have been avoided.) Any regulation affecting production, use or distri bution of chemical substances posing an unreason-' able risk should be proraulpted only after a finding, subject to e hearing, that it is the least restrictive of a graded series of controls needed,to protect health or the environment. The administrator should be re quired to give successive consideration to the follow ing series in increasing order of severity; such as: (a) requiring markings and warnings; (b) performance standards limiting the extent ofhuman exposure from a particular use of usage; (c) performance standards generally limiting the extent of human exposure; (d) limits on manufacture or distribution for a particular use or uses; (e) general limits on manufacture, includ ing quotas and lastly; (f) prohibition of manufacture or distribution. (Control of a particular hazardous use will still allow beneficial uses which would not be the case if control were by quota or banning.) Ail hearings should provide for die right of crose examination by all parties. (Provides that all par ticipants have the opportunity to understand or chal lenge information presented.) When accelerated remedies are required, as in a case of a finding that imminent hazard may exist, the Administrator should be required to proceed through the courts. (Protects individual rights. Under the current bills the Administrator may pro ceed arbitrarily without going to the courts.) In general, any leg' 1 cion should limit the discre tionary powers of th administrator which could be arbitrarily and unreasonably exercised. (Avoids ex cessive regulation ofprivate industry.) In general, any legislation should require the Administrator to pub lish and consider a beneftt/risk/economic impact evaluation prior to issuing any regulation. Shell believes chat soundly balanced legislation must not include the following provisions; The Administrator should not be permitted to estab lish production quota limitations unless it is first found that less restrictive control measures would be inadequate. (Quota systems are generally difficult co administer equitably.) The Administrator should not be required to pub lish a priority list of chemical substances requiring testing. (Publication would amount to precondemna tion of chemical substances potentially valuable co the public and would be anticompetitive.) Interim regulations are unnecessary and should not he permitted unless there is a court Hndingof immi nent hazard. (Leads co arbitrary and unreasonable action.) The Administrator should be prohibited from arbi trarily establishing excessively broad groups or classes of chemical substances for regulation. (Pre cludes unwarranted regulation of a safe chemical sub stance just because it may be in the same broad family with a hazardous one.) The burden of proving the existence of "unreason able risk1' should rest with the Administrator and not the manufacturer. (Eliminates the legally and scientifically impossible burden of proving that no risk exists.) Citizen suits should be allowed only against die Ad ministrator and only where it can be shown that he has foiled to carry out his noo-dfocretaooary duties. (To avoid unnecessary litigation.) Recommendation House Bill HR-7664, introduced by Congressmai McCollister and supported by the Office of Manage ment and Budget with modifications, comes closest to! being appropriate legislation. We support HR-7664 modified in accord with the concepts nnrHr*^ and urge the general support and adoption of such a modified bill. O TRCMOijri^-. 7 AP00036984 INTEROFFICE MEMORANDUM DISTRIBUTION A. J. DIGLIO DISTRIBUTION: A. R. Adams J. H. Arnold J. J. Ballker J. T. Barr C. E. Blades R. A. Blomqulst P. L. T. Brian C.E. Calllcott T. 1. Carey M. R. Chrnura 0. L. Cost W. J. Cross E. Donley F. H. Fernengel R, Fleming H. P, Gallagher H. L, Harwell J. V. Helder W. Hoge H. L. Jaffe Subject APRIL 19, 1976 Date MCA -- CHEMECOLOGY (Leealion, O'panUatton, or DptnmM) VALLEY FORGE (UOUtion, Orgintjation, or Department} R. E. Jones J. D. Kramer R. G. Kunz R. lotnieky J. B. Maerker J. E. McEvoy A. .\U McMillan T. J. Medovlch J. C. Novak D. E. Pryor . H. A; Quigley R, J. Ryan J. A. Saner W. J. Scharle R. H. Schenck W. M. Smith R. H. Vozar H. L. Watson J. T. Uharton_ G. G1'Grab ` Attached for your Information Is the April 1976 Issue of the MCA Chemecology publication. /mjv Attachment A.,-4-' 'vA. J. DIGLIO (320k AP00036985 (TDD Published by the Manufacturing Chemists Association to promote a clean environment April 1976 Ease Demands, Water Commission Urges Congress The National Commission on Water went to Congress in mid-March, urges the requirement of best available technology Quality is recommending that Congress legislators to: for industrial dischargers, while retaining make major mid-course adjustments in the Authorize extensions and waivers of the 1983 goal of fishable/swimmable Federal Water Pollution Control Aw to keep the July 1, 1977 deadline requiring secon waters. The commission recommended, the nation on a realistic course in restoring dary treatment for municipal sewage plants however, that effluent limitations to elimi and maintaining the physical, chemical and and application of best practicable technol nate the discharge of toxic pollutants in biological integrity of the nation's water. ogy for industry. toxic concentrations be Implemented as The commission's final report which Postpone for live to 10 years the 1963 soon as possible. Redefine the 1985 goal of zero dis Mini-Monitor Measures VC in Workplace charge of pollutants to encourage recycl ing, reuse, land application and other forms A small, badge-iike pollution monitor, as easy to wear as a piece of costume jewelry, has been invented by a Louisiana State University research team to measure expo sure to vinyl chloride, a gas linked with oc cupational cancer. The clip-on device, which is about one- quarter inch thick and weighs less than one ounce, will directly benefit workers em ployed in industrial plants which manufac ture viny chloride and polyvinyl chloride or use PVC in producing vinyl plastics. Moreover, the small monitor, the first of Ha kind ever developed, will require very littfe modification to monitor other hazard ous gas pollutants, reports Dr. Philip W. West, LSU Boyd professor ofchemistry and director of the University's Institute for En vironmental Studies. He said the first results of industry field tests of the new device have been "beauti ful." Several industries are cooperating in testing the monitor. The small vinyl chloride monitor can re place existing monitoring devices which re quire Industrial workers to wear, in varying combinations, bulky plastic bags, noisy air pumps and batteries that have to be re charged frequently. LSU Coed Susan Wolf demonstrates the new monitor for measuring exposure to VC gas. chromatograph for accurate measurement In an alternate technique, the vinyl chloride captured on the membrane is tfssolved in a carbon disulfide solution and then injected Into the chromatograph. of waste management. The recommendations were opposed by only one of the 15 commissioners, Sen. Edmund Muskie (D-Me.), who called them a retreat from the effluent limitations of the 1972 amendments to the act and a return to the water quality approach of earlier federal laws. The commission predicted it wll take at least another decade and $100 blfRon to reach the standards set for 197t. After wards, it recommends making another study to determine what additional action may be necessary. The commission reported that the water cleanup program nationally is behind the schedule set by Congress because of in tricacies of the law, bureaucratic compiexttiee. extensive litigation and the Im poundment of federal construction funds. Even so, the commission said its studies revealed that"in many areas of Ihecountry, the water is not only improving but improv ing faster than anyone had expected." In vestment in wastewater control and treat ment and the recuperative capacities of streams are combining to create better water quality quickly, the commissioners said, adding: "We are encouraged." Industrial employees who work around Toxic Substances Bill Passes Senatevinyl chloride would tum'jn their "badge" monitors at the end of eachworking day for laboratory analysis. Thus, the amount of The toxic substances control bill passed The burs other drawback, Mr. Heckert exposure to the hazardous gas during by the Senate late last month "will make it said. Is that it represents overregulation. specified time periods can be accurately more difficult for industry and government "There are already many laws which deal gauged before the networking day begins. to provide additional protection for the pub with employee and public health and If laboratory analysis shows that workers lic and the environment." according to safety," he pointed out. have been exposed to excessive concen Richard E. Heckert, a Du Pont Company Mr. Heckert emphasized that the chemi trations of vinyl chloride, the situation can vice president and chairman of MCA's spe cal industry supports effective toxic sub be remedied immediately by shifting per cial committee on toxic substances legisla stances legislation and endorses HR 7664, sonnel or modifying plant operations to re tion. one of the bills currently pending before the duce output of the gas. The Senate bill has two majordefects, he House Interstate and Foreign Commerce Air entering the monitor permeates a said. "It calls For broad-scale testing and Committee. plastic membrane, and vinyl chloride in the screening of substances without adequate However, a spokesman for the House air sample is captured in an absorbent. In regard to relative levels of risk. Effective committee indicated that a more stringent analysis, the air sample materials retained regulation should permit the chemical in measure, HR 10318, sponsored by Repre by (he plastic membrane are placed into a dustry and the Environmental Protection sentative Bob Eckhardt (D-Tex.), remains small heated chamber and the vinyl Agency to concentrate on the chemicals the centrai bill on which markup is expected chloride is "flashed off" into a gas most likely to represent a hazard." to begin in the near future. AP00036986 2 First CUT Studies: Air Is Cleaner, but Not Free Ethylene, Toluene The first two research projects of the new Chemical Industry Institute of Toxicology are long-term inhalation studies of ethylene and toluene in rats. They will be conducted by Industrial 8io*Test Laboratories, Inc, at The President's Council on Environmental Quality has just revised upward its estimate of the coat of implementing federal pollution control laws over the next decade. The new figure--217.7 billion--will cost each American an average of $98 annually. The estimate, CEQ says, Is $22.9 billion higher than last year's figure, largely because of inflation. CEQ, claims, however, that citizens are beginning to get what they're paying .for--a cleaner environment. Decatur, III. "By most conventional methods of measurement, air quality in the United States has Dr, Leon Golberg, the institute's presi greatly improved during the five years since passage of the Clean Air Act Amendments," dent, said "we chose ethylene and toluene CEQ says in its latest annual report. for our first projects because they are two of the most widely used chemicals. They form Pollution Control Cost The council also found "that our efforts to restore and protect our nation's waters the b asis for a great variety of Industrial and $32 Billion in 1973 consumer products and, while we have ex have made some encouraging progress. The water quality Indicators, trend analyses tensive data on them, there are gaps in our Spending for pollution control by U.S. and studies ell show that many of the worst knowledge which should be filled in." consumers, business and government to point sources of pollution are being effec The Chemical Industry Institute of Toxi- taled 332 billion in 1973. according to latest tively controlled and that some of our most cologywas formed last May by 11 chemical companies to test large-volume chemicals for toxicity, particularly the possible effects. of long-term, low-level exposure. There are now 19 members, and headquarters have been established at Research Triangle Park, Raleigh-Durham, N.C. In addition to the first two research proj ects, Dr. Golberg said the institute's scien figures from the Department of Commerce. This is an IS percent increase over 1972. Business accounted for 513.2 billion with nearly half of the total going to combat water pollution. Ninety-four percent of an tipollution spending was for goods and ser vices to reduce emissions, while the re maining amount went for regulation, monitoring, research and development. heavily polluted waterways are being cleaned up," Regarding air quality, CEQ says that over the past five years concentrations of "par ticulate matter measured in the atmosphere declined an average of 14 percent and av erage sulfur dioxide concentrations de clined about 25 percent Many urban loca tions show improvement in ambient levels tific advisory panel is considering studies Further information is in the February of carbon monoxide and photochemical on aniline, chlorine, dinitrotoluene, issue of Survey of Current Business, avail oxidants." ethylene oxide, formaldehyde, n-hexane, able for an annual subscription rate of CEQ's conclusions on water quality are maleic anhydride, methylene dichioride S48.30 from the Government Printing Of based on the 1974 National Waler Quality and phenol. fice, Washington, D.C. 20402. Inventory, and.on the results of observa tions conducted at 87 monitoring stations NRC Wants Ideas on Pollutant Studies operated by the U.S. Geological Survey's National Stream Quality Accounting Net Public suggestions or selecting the best methods for studying potential pollutants are being sought by a National Research Council committee in conjunction with a study for the Environmental Protection Agency. The agency has asked the committee to study two specific pollutants and develop recommendations on how such studies should be structured and conducted to ob tain the best available scientific and techni cal information. Some of the Issues the committee win consider include: Whatmsthodsofrvtrievaiandanalysls of information are most jfkely to assure that the information and conclusions used by EPA are scientifically reliable? Whatanalytical approaches to issues, such as assessment of carcinogenic risk, extrapolation of health risk to low-dose levels in the environment and cost/benefit assessment, can provide information in a form most useful for the decisions EPA may have to make? and e What degree of policy analysis should be performed in a scientific and technical evaluation of Information (or lack thereof) and how should It be presented to decision makers? Panels are being organized currently to study nitrates and haiogenated methanes (excluding fluorinated compounds), the two pollutants specified by EPA. The panels* work (NASQAN) which ahow "a reduction in the composite frequency of violations-- an improving trend. 'The proportions of NASQAN stations in the good or fair categories increased from 61 to 77 percent between 1961 and 1974," the report found. It notes that "the propor tion of stations In the very poor and severe categories dropped from 16 percent to three percent over these years. No stations were in the severe category in 1974." NASQAN measurements also showed improvements in drinking water suitability. Despite the progress, the council says, substantial problems remain. According to the report: "Undesirably high levels of the major air pollutants continue to occur at many lo cations. Only about one-third ofthe nation's Mayo Shifts to EPA Lab, reports will serve as case studies in meth 247 air quality control regions are fully odology and will be used by EPA in prepar meeting the health protection ambient Alexander Heads Region 5 ing for possible regulatory action. The standards for alt pollutants at present. Francis T. Mayo, former administrator of the Environmental Protection Agency's re gion five, has been appointed director of committee also will review past pollutant reports for methodology in preparing its final recommendations. Anyone interested in commenting on the "Evaluations of water quality clearly in dicate that nutrients, trace metals and land runoff are going to present difficult and per sistent challenges. ERA'S Municipal Environmental Research Laboratory in Cincinnati, Ohio. Mr. Mayo's former position wilt be as sumed by George R. Alexander Jr., who is currently deputy director of regional and intergovernmental operations in EPA's Washington headquarters. committee's study should submit written statements by April 9 to Charles R. Malone, Coordinating Committee on Scientific and Technical Assessments of Environmental Pollutants, National Research Council, 2101 Constitution Ave., N.W., Washington, D.C. 20418. "Most lakes studied in the Eastern states are suffering some degree of accel erated eutrophication primarily attributed to the nutrients, often phosphorous, that drain from agricultural and urban land, although industrial effluents and municipal sewage treatment plants also contribute." AP00036987 o3 MCA Releases Fluorocarbon Data On Global Production, Sale, Use A iwen-story environmental `radiator' la being built by Northwest Alloy*. Ine., a sub sidiary of Alcoa, at a new magnesium and silicon plant In Addy, Wash. The tubas arc giant air-to-air but exchangers which cool fumece gaaaa bafora thay raaeh contami nant-trapping filter bags. Nearly 280,000 cubic feat of fumta are deaned each minute. World-wide figures on the production, sale and use of chlorofluorocarbon (com monly fluorocarbons) have been released by the Manufacturing Chemists Association in an effort to resolve uncertainties, caused by lack of accurate data, in scientists' ear lier calculations of their possible effect on the ozone layer. Total world production from the date of first manufacture through 1975 has been 7,562 million pounds of FC-11 (tnchloro- Huoromethane), 11,197 million pounds of FC-12 (dlchlorofluoromethane) and 1,670 million pounds of FC-22 (chlorodifluoromethane). Production through 1973 was higher than the previous estimates used for modeling calculations by 9,2 percent for FC-l 1 and 10.0 percent for FC-12. The rate of growth between 1967 and 1973 averaged 13.3 percent per year for FC-11 and 9.5 percent per year tor FC-12 compared with previous estimates of 14.4 and 13.0 percent per year respectively. However, production of both compounds only increased by about live percent in 1974 over 1973 and decreased by approx imately 15 percent in 1975 from 1974. A fluorocarbon research program de signed to contribute to scientific under standing of the effects, if any, of fluorocar bons on the depletion of ozone is being administered by MCA. Twenty manufacturers throughout the world, representing more than 99 pereent of free world production and more than 95 percent of total world production, support the research program and supplied the production and sales data to Alexander Grant & Company, an independent ac counting firm. Sales by major use categories for the past 20 years also were supplied to permit a calculation of the timing and quantifies of fluorocarbons released to the atmosphere. Production data were obtained from sev eral other small producers and the produc tion of ail the remaining producers in the world was estimated. All production data excludes those fluorocarbons used as in termediates in the manufacture ol other chemicals or plastics. Copies of ths report by Alexander Grant & Company are available to atn^pspheric scientists from MCA, 1825 Connecticut Ave., N.W., Washington, O.C. 20009. Lifestyle Is Most Prevalent Cause of Cancer, Expert Says Although some chemicals can cause cancer, a prominent research scientist says a person is much more likely to contract the disease through the lifestyle he chooses. Dr. John Weisburger, of the Naylor Dana Institute in New York, says the increase in king cancer since the 1930s "Is not due to air pollution or exposure to chemicals, but to cigarette smoking." Other personal habits that can cause cancer, Dr. Weisburger says, include un balanced diets, excessive exposure to sun and improper personal hygiene. The cancer expert analyzed the causes of the nation's numbec&ie health problem (behind heart dlsesseft a seminar in At lanta on chemicals And cancer. It was sponsored by the SyrrtrfeHoOrganic Chem ical Manufacturers Association. Regarding cancer contracted from expo sure to agents in the workplace, he esti mated that there may be as many as 5.000 cases annually and said they are a small percentage of the 900,000 cases diag nosed each year from ait causes. Another seminar participant. Dr. Gary Flamm of the National Cancer Institute, stressed the need to identify the risks from exposure to chemical carcinogens. "Where such carcinogens cannot be eliminated," he said, "we must have accurate informa tion to determine exposure levels threaten ing to human health." Without such information, he said, soci ety and government might spend billions of dollars trying to eliminate a given carcino gen which might be extremely small--less significant than "a lifetime exposure to one-tenlh of one puff from a cigarette." Society must decide how many man made substances it's willing to give up which cannot pass this test, the NCI spokesman said. He speculated that most people are unprepared to replace all items In their homes made from polyvinyl chlo ride, even though the "one-hit" hypothesis may imply some degree of risk of contract ing cancer. One thing seems certain, Dr. Flamm said, "complete and total safety can't be guaranteed As desirable as this goal may be, it will elude us even as we develop the ability for assessing the acceptable levels of risk, equai to no more than one-tenth of one puff of a cigarette." Chemical Is Possible Cancer Preventative A chemical relative of vitamin A has been reported as a possible cancer preventative by Dr. Michael B. Sporn of the National Cancer Institute. "Chemopreventlofl" Is seen by Dr. Spom as an alternative approach to conventional treatment which stresses therapy after cancer has appeared. He emphasized that the material has no effect on persons who have already contracted the disease. The synthetic vitamin, less toxic than the natural substance, could be used on popu lations with a higher-than-average inci dence of cancer, such as cigarette smokers and certain industrial workers in high-risk exposures. In NCI's most dramatic experiment, two groups of rats were exposed to a cancercausing agent. One half was fed daily doses of the new synthetic vitamin, in this group, only 22 percent developed cancers as compared to 48 percent in the controls. "We must begin to think about cancer as a disease that begins many years before we record It." Dr. Sporn saya. Arresting the development of ths disease in Its earliest stages would take advantage af the long lead time--often 20 years--before cancer reaches the life-threatening stage. Such an approach, he said, will be necessary since it wiiJ be virtually impossi ble to eliminate all carcinogens. AP00036988 1 4 PCBs Yield to Good Vibes, Bugs Discovery of a scientific technique for rendering polychlorinated biphenyls virtu ally harmless also may help answer en vironmental problems related to a whole range of other persistent toxic chemicals. Dr. Dickson Liu. a research scientist at the Canada Centre for Inland Waters in Bur lington, Ontario, is responsible for the breakthrough. It involves a newly* daveloped strain of bacteria and a special technique for providing them access to the hitherto almost indestructible compound. PCBs are highly valued as electrical in sulating fluids because of their resistance to fire. The compound has become an en vironmental health problem, however, be cause it dsgrades extremely slowly. The oily PC3 material is highly insoluble In water. Thus, its carbon content remained largely inaccessible as a food source for bacteria. Dr. Liu reasoned'that the solution might be found through increasing the PCB-to-water interface. Ultrasonic vibra tion was used to disperse the PCBs Into very fine particles, and a common pulp-mill effluent was then added to maintain an emulsified suspension of the chemical. This technique provided the opportunity to introduce bacteria, obtained from sew age sludge, which feed on the dispersed PCBs. A highly-acclimated strain of bac teria is so effective that even the most chlorinated and stubborn members of the PCB family, such as arochlor 1254, are re duced in one week from concentrations of 300,000 parts per billion to 19 ppb, Dr. Dickson claims. The value of the discovery Is seen in treatment of PCB-rich industrial wastes and in disposing of such things as transformers which contain the chemical. The new tech nique may not answer the problem of PCBs already in the environment nor be applica ble to diffuse sources in which the pollutant already has been mixed with other effluents. Still in the 'developmental stage, a pilot plant is being planned at the Canada Centre (or Inland Waters. Dr. Liu also is commencing experiments with the new bacteria on pesticides such as lindane and chlordane. Pr I Hi trextt rrn with high fraqiienrj euumJ wave* in a aonte AsmemDnMer. `Quick, Dr. Watson, the Laser!' A way to "fingerprint'* spitted pollutants with a laser beam and trace them to their sources has been developed by chemists at the University of Rhode Island. The laser technique has already proven effective in fingerprinting some 25 contami nants, the URI chemists have found. They hope to perfect the technique and provide the first method capable of identifying most of the hundreds of waterborne substances classified as hazardous by the Environmen tal Protection Agency and the U.S. Coast Guard. As part of the same study, the URI team has monitored Narragansett Bay and the Sakonnet River and found a variety of toxic chemicals including chlorinated hydrocar bons, petroleum hydrocarbons and tar flakes. One of the big advantages of the experi mental laser system,'preset director Dr. Christopher Brown explained, is that it could bs easily adapwtto remote sensing of harbor pollution from a buoy, or ft could be installed as an on-board system that could continuously monitor harbor pollution from a steaming patrol craft. Toxic chemicals can be analyzed quickly in the water sample simply by beaming the laser into the water. No two contaminants are believed to scatter the laser light in the same way. so the light reflected is analyzed for the unique "fingerprint" which Instru ments monitor and record. Dr. Brown says the laser should be effec tive up to 100 leet away from the sample, making possible a system which could, from a ship, continuously monitor adjacent waters. The chemical detectives already have used the laser to fingerprint 20 hazardous materials down to a level as low as five parts per million. With a more sophisticated computer system, Dr. Brown said, it will be much more sensitive. Inorganic water pollutants analyzed in clude phosphates, nitrates and sulfates, as well as carbon disulfide, hydrocarbons and chemical dyes. The system does not work as well on organic oils, but Dr. Brown said an earlier fingerprinting system URI de vised, which uses infrared spectosoopy, Is an effective way to analyze for oil. Dr. Brown estimates that an effective laser system could be purchased and set up for under $25,000. Ottawa Implementing Contaminants Act Canada's Ottawa province is gradually implementing the Environmental Contami nants Act requiring plants to give full details on all chemicals used in processing or re leased to the environment. Passed last December, the law au thorizes the federal government to demand a full disclosure, order removal of materials judged harmful and to set penalties up to $100,000 and two years Imprisonment. One important feature is the law's power to Impose restrictions on new chemicals in classes previously judged to be dangerous. Hazardous Chemicals Labeling Standard Prepared by MCA A new standard for the labeling of haz ardous industrial chemicals has been ap proved by the American National Stand ards Institute. The standard, Z129.1. was prepared by the Manufacturing Chemists Association's Labels and Precautionary In formation Committee. It was adopted in keeping with ANSI's rigorous review procedures to Insure that it is In the public Interest According to ANSI, there has been a need for a national and international stand ard in the area covered by2129. i, and the new standard represents a significant con tribution toward the continuing Improve ment in sate handling of hazardous Indus trial chemicals. The development and introduction of new chemicals and chemical processes into ever-widening fields have produced a needto furnish informationforthe guidance of workers who use, handle or store haz ardous industrial chemicals, ANSI says. The Labels and Precautionary Informa tion Committee of MCA is a group of chemi cal Industry specialists in precautionary labeling, backed up by research and devel opment personnel with knowledge of the physical and chemical properties of indus trial chemicals. Copies of standard 2129.1 may be or dered from: American National Standards Institute, Attention: Sales Department, 1430 Broadway. New York, N.Y. 10018. AP00036989 5 Library THE ENVIRONMENT: COSTS, CONFLICTS. ACTION P.-c'iii'q* i-z~) * cc'ft'sne* is ica^a.*1! r**j "`toi -' "a K"a.o'* ef rviro.-irar-a. .ssi.'es. ci"t9-" . -i* !.*s^ esnMfvat,'-;us- : i'%:s a: ?.;***: ms a*: Accay -s 5iJ.75 l'5_' V*S .15 !rvc.. Ms^/ion Ava.. Ns* Vs*<.N.V. ENVIRONMENTAL CUAU7Y AND SAFETY A 54' 4 VSL3*S l'3S"! SS3/ -!*--*: 2-- SC *n- ; o:i sie;t* ;l j osy arc is:'-;:;/ * :r i"rn.s v> r* ss'sr/ of j-.-s i~a~,*oai a^f'S a'' 6 -f. Acopy '* >*3 JO `a1-- Asar*~c ar*ss Inc.. Pvs-j.n*'*. Ill F.ftri A,.. '.** 'z-<. \.v :0CO3. ENCYCLOPEDIA OF ENVIRONMENTAL SCIENCE AND ENGINEERING, VOL- t. II ;<* 2` *J Q9*:far aiJiftcrs^s s5f' '.* En* P"-k;:.i A;*ney. Esso aaiaaov ait Lasarais'ss f : Sm<3 Osr^ora^on u rs`srsron oasic s-v 'zr.r-r-v sc sr.s a.*iotacnro:cgy. 3*20; '.-;i i s S*2 ana VoL ll. S82. from Go'con and Breacn. 1 Pa*.< A.*.. S* Yorit. N.Y. 'OOfE. INDUSTRIAL NOISE CONTROL MANUAL Th.-ry :m *rom cH*rrwai. yecyc: packtg- ing. piutcs a-d :axi.'i :rdu*tr* dascrb* l".s pros- 'ens. a'S '.ji*. r*:ticcs and svmiuaJ sol ders to par ticular c;j* r-j^oamartais of sound control art dlic.JKO. sfc.* new lo sa'act a no'Sa cortrcx corv suitjnr R*'9'-c* soc** ft Tsted. A copy s S3.25from U.S Oapt sf Hat :n. E:-canon, and NasanaJ Institu'.a for Ocs.oitonai Safaty and Haaftn. Cncfrviab, Cnio *3202. LANO TREATMENT AND DISPOSAL OF MUNICIPAL AND INDUSTRIAL WASTEWATER Tha c< .ar angnaanrig rratnoos ana saiign. laMibi-u'/. conaac.ancas. aconomlca andanvironrrantai poiicias and aasaca :n making preiirninav costasdmatas lor a *u i :-aas.T*rt pnc|aO. Us* ol wastr*atar nuxtnij for ii-fl anren--nt and leoar/ traatmant through ind e-soosa` vs considarad. A cosy is 520 from Arn ~tw Scarca auSasnara. Inc.. P.O. Sox 1425, Ann Areer. McH-ganuaiOS. New Emphasis on Health Regs Predicted by OSHA Director The chemical industry can expect closer scrutiny in the future from the Occupational Safety and Health Administration as the agency begins to focus more attention on health hazards in the workplace. That message from Dr. Morton Corn, OSHA's head, came during a recent industry-government luncheon sponsored by the Manufacturing Chemists Assocla* lion. The shift toward occupational health will not diminish OSHA'e safety ef forts, Dr. Corn said, but is designed to "reach some pant/1 in the two areas. In 1974, for example, less than 10 percent of the agency's/ plant Inspections were for health matters. To help remedy the situation, he said all new compliance officers hired during tha next two years will be health Inspectors. Dr. Corn noted that OSHA's change in direction calls for major new components within the agency. A technical support arm will be created, he said, to perform much expanded analytical laboratory functions relating to engineering controls and abate* ment periods. A toxicology referral center also will be set up, according to OSHA's chief, to help compliance officers evaluate chemicals encountered during their inspections. For the immediate future. Dr. Com said his agency will change its past practice of concentrating plant inspections in indus tries with the highest incidence rates. Occupational diseases have not been factored into the priority scale for schedul ing Inspections, he said, because incidence rates are not known. From now on, however, the agency plans to recognize the classic, well-known haz ards caused by chemical and physical agents as a first step in its new drive lor health protection in the workplace. Dr. Salk's Rx for Worry Dr. Jonas Salk, developer of the Salk polio vaccine, has a new prescription for people worried about cancer-caUsing sub stances in the marketplacethat are Increas ingly being reported by news made. "The best thing to do," says Dr. Salk, "Is guH reading the newspapers." There is so much sensationalism about such substances, he says, that the gov ernment sometimeserrs in Interpreting lab oratory tests that too often have not in volved humans. OSHA Denies Firestone's Request on VC INDUSTRIAL TOXICOLOGY Two protossc-* *rom Ha/vard UnN-arsty h*v da- sigrad in-s bock to intra m cccupabonal rradtc'ra carea'S. Tha.taxt covara htaltb up*cts of piast.es ?c :as. rain energy, mineral duat and soma ccggc*< nizarcs. A copy *525 from Pubjsrvng Science* Qrou:. 'nc . 152 Great Road. Acton. Maas. 01720. AT ISSUE: THE BEVERAGE CONTAINER Kaiser A'yrr-%j*n & OamrM! Corporation offer* soma &:rrat,.esto<rusnarleflial*ao:!merov*ment proc.r cs-gn and mnvt*cttrlngtachno!ogy to la*sen rrate- use;*, sror* CMUTar recycling and ft*\on*-c* ccmm.tmant toSfeurc* recovery. Wmlan !c' non.:*;-- caj -aadan. m^bookfat Is in;*,need as ;* a cemravar*N issue, it >s Yea from Kaiser A"jir>-*.-^ A Chemical Corporation, 300 Lakasiba 2nve. Cskis-d. Calif. 3*842. CARBON MONOXiOE D-si-'sutad -/ Cccysatronai'Safety and Heaitft As-mnistrat.onas ac-acs.bpnary parnsraion |-az- a-cs o` ana smtaej-a measures for CO. 03HA 221* n free fro-'t-tu 5 Daot. :< Lasor. OSha. 230Cc.nbtotor Av.. N ,*V . Waan.ngton. O.C. 200ifl. INDUSTRIAL HEALTH HAZARDS CUE TO ATMOSPHERIC FACTORS This racer? contains assTacts of rasearen on induatr.ai Tes.cma. occusatonsi aisaasas and *.n tox:cc log ical factcrsd .-anc-s so lurants. Tha Sipicgracr.y is 525 [ram me Narenai _acn~,c*i information Service. 5263 Pod Poyal Pa . 3s'"'gfie!3. v*. 22191. The Occupational Safety and Health Administration haa denied the request of Firestone Plastics Company, Pottstown, Pa., for an exception to the April 1 deadline requiring workers exposed to vinyl chloride to wear respirators under certain condi tions. ' Firestone sought to extend the deadline until September 30. Under OSHA's vinyl chloride standard, effective this April 1, employees are re quired to wear respirators in areas where EPA Extends Ban On Mercury Pesticides Responding to petitions from several manufacturers, the Environmental Protec tion Agency has postponed until June 30 its ban on the production of most mercury pes ticides. Since the pesticides pose no immi nent hazard, the producers say, they re quested a delay until federal courts can rule on several lawsuits challenging the cancel lation. vinyl chloride concentrations are greater than one part per million parts of air. The vinyl chloride standard was issued in 1974, but was held up by court action and (fid not become effective until last April 1. It granted a one-year delay in mandatory wearof respirators to permitworkertraining and indoctrination in their use. During the delay, workers could choose toworkwithoutrespiratorsinVC concentra tions no greater than 25 ppm. In seeking a temporary variance, Fir stone Mid that respiratorswil not be needed after September 30. Until then, however, the company said some production work could not be done while workers are wear ing respirators. In denying toe delay, OSHA pointed out thattemporary variances can be authorized only if materials or personnel needed to comply with the standard are unavailable. OSHA said the request for more time to permit completion of engineering methods to control vinyl chloride emissions is nol consistent with the intent of the original year's delay in mandatory wear of res pirators. AP00036990 6 Rainmaker Studies Role Of Pollutants An experimental device that makes "rain" to order is being used at Oak Ridge National Laboratory to study the effects of sulfur and other atmospheric pollutants on vegetation and solids. ORNL, one of the nation's largest re- search laboratories, is operated by Union Carbide Corporation's Nuclear Division for the Energy Research and Development Administration. Designed by ORNL scientist David Shriner, the fully automatic "rainmaker" can be programmed to control the size of rain drops, the Intensify with which they fall and their chemical composition. The sys tem has been installed in a controlled* environment greenhouse, and can operate unattended for one week. The acidity of precipitation is receiving world-wide attention because of the in crease In sulfur and nitrogen oxides re leased to the atmosphere from coal-fired The rainmaker, scientist David Shriner, prepara* an acid rainfall for kidney b*an piarrta. power plants and industrial emissions. Washing out in rainfall, these contaminants can provide a shower or a storm of any quences of prolonged exposure pf natural become incorporated in the hydrologic cy* desired duration. ecosystems to acid rain and will guide deci cie. Metering pumps supply controlled -con sions on whether new environmental Ordinary rain is somewhat acidic, with a centrations of chemical elements to purified standards are needed. pH oi about 5.7. This compares to a neutral water used to stimulate acid rainfall. An value of 7 on the scale used to measure identical system is operated as a control, NIOSH Suggests Limitsvarying degrees of acidity or alkalinity. and Is programmed to produce unpoituted ORNL says that any lower pH value in pre rainfall. For Five Chemicais cipitation is caused by some chemical in the Preliminary studies indicate that simu atmosphere, such as sulfur or nitrogen lated acid rain may significantly affect the Recommendations for limiting occupa oxides. physiological processes of plants. The tional exposure to nitric add, hydrogen Data collected from the Walker Branch weathering of protective surface waxes on fluoride. Isopropyl alcohol, ethylene Watershed, a 25-acre experimental site at both forest and agricultural plant species dichloride arid methylene chloride have Oak Ridge, indicate that sulfur levels in rain was found to be accelerated when they been forwarded to the Department of Labor fall account for 55 percent of the total sulfur were exposed to acid rain. This couirfresuit by the National Institute for Occupational Input to the watershed. The acidity of indi in Increased leaching of nutrients from the Safety and Health. vidual rainstorms monitored at Walker Branch has been as low as pH 3.25. The yearly average rain acidity measured at the watershed is pH 4.2. The rainmaldng device permits the dupli cation of rain intensity anddroplet size with variations typical of nature?precipitation, it leaves of the plants. The study also shows that simulated acid rain Inhibits nodule formation on root sys tems of leguminous crops and causes soms plants to be more susceptible to dis ease. Future studies will focus on cortse- The criteria documents suggest nitric add and hydrogen fluoride retain the estabfished standards: five milligrams per cubic meter on a time-weighted average (TWA) for nitric acid on a 10-hour day or 40-hour workweek, and three parts per million (TWA) for HF. However. NJOSH recom mends a change in the ceiling concentra EPA/New Jersey Clash Over Air Quality Regs tion tor hydrogen fluoride to six ppm In a 15-minute sampling period. The Environmental Protection Agency has come down hard on New Jerse/s re cent decision to authorize 10 companies to bum fuel with a higher sulfur content. ERA regional administrator, Eric B. Outwater, said that the state's decision was made without the necassary approval by ERA and that the 10 companies could be in violation of the Clean Air Act. The intended relaxation would have al lowed the burning of the cheaper, more available fuel which N.J.'s Department of Environmenta! Protection says would pro vide economic relief to the companies and lower utility rates to power company cus tomers. Mr. Outwater said that a study of air qual ity In N.J. has been undertaken that will provide a sound, technical basis for any Changes on the sulfur-in-fuel requirements, "it may very well be that the study will pro vide sufficient data to support any N.J. re quest for lowering of standards." Mean while, he said, the action is "premature." Isopropyl alcohol should be limited to 400 ppm TWA and 600 ppm as a ceiling con centration for a 10-hour day/40-hour work week, NIOSH says. Peak exposures for sthylene dichloride should be set at 15 ppm in 15 minutes with 6 ppm (20mg/cubic me ter) TWA. Methylene chloride recommen dations allow no exposure in excess of 75 ppm for a 10-hour day/40-hour workweek and peak concentrations not in excess of 500 ppm (1,740 mg/cubic meter of air} for 15 minutes. AP00036991 7 One Plant's Waste Is Another's Product The idea of an Industrial waste exchange seems to be catching on in several different areas. In the United States. Iowa State Uni versity has an Industrial Waste Information Exchange, while in Canada, an industryoriented magazine has set up an informal waste exchange. Meanwhile, the St. Louis Industrial Waste Exchange established several months ago has issued its first listing. Forty-three available wastes include ther moplastic resins and spent nitric acid con taining copper and nickel. Eight items are wanted, including spent nickel catalyst and liquid caustic soda. The exchange, run by the St Louis Re gional Commerce and Growth Association, will publish listings quarterly. Participation is open to industries throughout North America. Similar in philosophy, the two newest ex changes accomplish- their purpose in slightly different ways. The Iowa clearing house offers detailed information on waste products by listing the type of material, a descriptiorVanalysis, the available quantity per week or month, the form (packaged, liquid) and the materials' general location. All listings are confidential and are listed free for one year. Responses are forwarded to concerned firms for action. Participants' only obligation to the exchange is to let them know when the material can be re moved from the listing. The Canadian magazine advertises that firms having waste products, or in need of materials formerly regarded as wastes, should contact the editor who will act as their confidential agent by running an anonymous entry in his magazine. For further information, contact Iowa In dustrial Waste Information Exchange, CIRAS, Bldg. E, Iowa State University, Ames, Iowa 5001!, or Thomas E. Suck, editor, Canadian Chemical Processing. 1450 Don Mills Road, Don Mills, Ontario, Canada M3S 2X7. Goodyear Grants Fund Erosion Control Studies Grants of 52,500 each from The Goodyear Tire & Rubber Company have been made to the Universities of Rhode Island, Michigan and North Carolina State to evaluate scrap tires as erosion control devices. The Universities of Hhode Island and Michigan will continue full-scale testing of Goodyear-designed tire barriers to control shore erosion from storm waves along die shores of Narragansett and Chesapeake Bays and Lake Michigan. North Carolina State University will inves tigate tires as sand dune and marshland protective structures. The university has successfully used a tire mat to shield a coastal marshland area from wave erosion. The program is part of a major Goodyear effort--including sunken artificial reefs, highway crash barriers and recycling of old tires--to reuse the 165 million tires scrapped by American motorists each year. Universities Study Unique Uses for Industrial Wastes , Certain industrial wastes are being packed off to school to see if they can ac quire any redeeming social values. For example: The University of Illinois has been awarded a research grant for 522,000 by Pfizer Inc. to uncover potential agricultural or commercial uses for iron oxide wastes from the company's pigments plant In East St Louis, lil. Or. Carl S. Larson, assistant dean of the College of Engineering, is coordinator of the project aimed at recycling what may prove to be a valuable natural resource. The effluent is a by-product of iron oxide pigments manufactured lor the paint, coat ings, magnetics and electronics Industries. Generated at a rate of about 200,000 pounds per day, the sludge-* currently de posed of as landfill. Possible uses the unfverstty sees tor the waste: a fertilizer or flBftBfoner for Irondeficient soils, a ceraifflfcryactory cement and a strengthening jBmt tor pressedboard construction materiai - In a similar project, the feasibility of re cycling certain Industrial wastes into ce ment substitutes is being studied at Carnegis-Mellon University under a Na tional Science Foundation grant Edward M. Krokosky, professor of Civil engineering at CMU, said wastes being tested Include red mud from bauxite refin ing, fly ash. blast-furnace slag, open-hearth slag, waste sludge from paper making and lime from calcine scrubbers. A recent progress report stated that combinations of red mud and high-calclum Pfizer's Wayne McCoy (top right) explains iron oxide process to University of Illinois profeeaors, who will try to find useful, commercial purposes for the wastes now being landfilled. fly ash and combinations of blast-furnace slag and high-calcium fly ash seemed promising. The wastes were mixed to conform with Type I Portland cement spedfications. Mr. Krokosky said an important feature is that very much less energy is consumed producing the material from wastes than if the original raw material were used, The potential also exists, he said, for using such wastes as the starting material tor an inexpensive fireproof insulation. AP00036992 *i$D!U-L4iC Product Responsibility a `Must' Economy/Ecology Balance Necessary, States NPA For Industry: Du Pont's Bours In a recent policy statement, the National Planning Association says that "much of Industry must take affirmative action to ensure that its products can be made and used safely and without damage to the en vironment or governmentwlll restrain man ufacturers with a ring of controls, Du Pont Addressing a meeting of the National Paint and Coatings Association, he said it is "the moral and ethical obligation of man ufacturers to provide quality products at fair prices that can be made, transported, the advocacy for environmental regulation has been singleminded and has not taken into account the possible deleterious ef fects on the economy of remedial action." The NPA points out that altering man's Company Vice President William A. Bours predicts. Environmental Events Environmental Law Short Count, April 19-23. Washington. D C. Contact th# drector of continuing tnginethrg tOuca&on, Co<gt Washington University', Washington. 0 C. 2C052. Environmental Symposium an Air and Watar Pol lution, Apnl 27. indlanapail*. Ind. Contact L. M. Lototzk,, 0*vo>t0ioi >J*on Orv.. P O BoxSM-P-11. IndanapeS*, Ind. *420. Watar Technology Seminar, May 3-5, San Juan, Puerto flloo. Contact Wm. S. Bell, NUS Coro.. 1910 Cochran Rd., Pinburgh, Pa. 15220. Offshore Technology Conference and Exhibition, May 3-4. Houston. Tex Contact Sherry Andersen, OTC, 6200 N. Central Expwy-. 0alias, Tex. 7520. Nonblologtcal Transport and Transformation of Pollutants on Land and In Watar, May 11-13. Qailtv ersburg, Md. Contact Or. l_ H. Gevantman, A-52S Administrefon Blog- National Bureau of Standard!, Wash ington. D.C. 023*. stored, used and disposed of safely. activities can lead to "serious dislocation in "This responsibility Is imposed at all the areas of capital resources, non- levels of the manufacturing and marketing utilization of worker skills and new geo chain, from the raw material supplier to the graphic distribution of Industry. ultimate customer. "Many ecologists whose creed is the Its objective Is to interdependence of ail living things do not provide the op seem to realize that the same interde timum measure of pendence exists between man and his ar protection for the tifacts whether technological, social, cul public health and tural or aesthetic." safety and for the The association allows that man's impact environment." on the environment has reached a level He said man where serious damage will be done if some agement must ad controls are not Instigated, but contends dress Itself vigor thatthe relative importance of the particular W. A. Bours ously and uncom environmental problem must be balanced promisingly to the against "protecting' the individuals whose affirmative concept of product responsi livelihood depends on the offending opera- bility--taking positive steps to prevent In . ton." f jury or pollution. This is the foremost moral, ethical and social responsibility of industry, he said. MCA* IMiaf if/* > Fugitive EmmlesJona: Measurement end Control, The key .issues in product responsibifity U*nu!teti*n0 G**rVtU . May 17-1, Hartford, Conn. Contact EiaabethM. Helm ing, program manager. TRC--The Research Carp. of New England, 125 Slas Deane Hvry., Wettterelald, Conn, 06109. ... Industrial and Municipal Wastewster Treatment: Prooaaa Oeelgn andOpareten, May 17-21, Clemson. S.c. Contset ProrsesorT. M. Ksmem. Ueot. o' enviiw mantaisystamsengineofing.Clem$on UnM., Damson, are not the laws or the technical problems, Mr. Bours said, but the Integrity and cour age of the people vtfio run industrial organi zations. " -- "By integrity," the Du Pont executive said, "T mean a firm pledge that we will not make or sell any substance, or use any aa;1 tiw-an hanoted byJ*CA' m*tavta*nwdithwo<ut eon?vnuMn i o< Maty eadaftsts * a AMOduen. MCA offtM waanaaGwwciMutAvMmN W,,WMnan.O.C,3000S. EDfTO*; JinN P. Turnor S.C. 29631. Fornm on Ozone Disinfection. June 2-4. Chicago, 111, Contact Edward 3. Focnenan, IfT Research Institute, 10 W. 35th St. Chicago, II. 60616. Legal Implieetlone of Existing and Wear Quality Control Legislation, June 6-10.1 IngtOfl, O.C. Contact Professor W. Wesley E Jr., Venderbiit Urwereity, Box 6222, Sta. B. i Toon. 37236. production process, unless this can be done safely. "By courage, I mean nothing less than a . policy thatwe will immediately make known, to employees, customers, shippers or others who may be affected any naw, perti nent, factual information Indicating poten tial dangers not already well understood." TECHNICAL AOWSORS: J. P. Syr*. J. T. QarrM IMIW. ttaoior'. <rom MCA'* Wr Rasouroaa Oortvnmaa: 3. 3. Tint. Jr. from tha Atr Oualty Oetnaiiffit. and R. J. Bcwinar, R. 3. Oalrids *n<JW. A PaOaraon fromjha SoWWutwMwi^MM CommMaa PiWTitjiMCACnv Outfly andCngloav- *9 aff.A C. CWX, C. AOetfna. M. FrUWd 3.W. inata, K. O. JehMM. *na J. c. vtnr atadn.imCmivdiutlmanl hba apreduoai My ANTHONY J C IGL fO A I R PftOO & CHtlJ INC WANUFACTUft I kG- 0 I V 5 EXECUTIVE MAUL WAYNE PA IP 05 7 PU MANUFACTURING CHEMISTS ASSOCIATION iat eaxMterieuT Afua a. w. m*wmix* e imm AP00036993 C. INTEROFFICE r/ELMORANDUM Date MARCH 29, 1976 Subject TOXIC SUB5TANCE CONTROL LEGISLATION DISTRIBUTION To From A, J. DIGLIO (Location, Orgami*t,on. or Deortmnt) ________________________________________ VALLEY FORGE {Location, Organization, or Dapartmanti DISTRIBUTION: A. R. Adams O. J. Ballker J. T. Barr C. E. Blades R. A. Blomquist P. L. T. Brian J. J. Bungs C. E. Cal 11 cott T. L. Carey M. R. Chmura 0. L. Cost W. J. Cross E, Donley F. H. Femengel R. Fleming H. P. Gallagher H. L. Harwell J. V. Heider W. Hoge H. L. Oaffe R. E. Jones J. D. Kramer R. G. Kunz 0. B. Maerker J. E. HcEvoy A, K. McMillan T. J. Medovlch J. C. Novak D. E. Pryor H. A. Quigley R. J. Ryan J. A. Saner W. J. Scharle R. H. Schenck R. M. Vozar H. L. Watson J. T. Wharton EPA continues to campaign for tough Toxic Substance Control legislation. Attached is EPA Administrator Train's speech at the National Press Conference. /ntfv Attachment (320) i AP00036994 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 20460 February 26, 1976 A J. D,!C-'.fO Robinson (202) 755-0344 NOTE TO CORRESPONDENTS: Environmental Protection Agency Administrator Russell E. Train told the NationaL Press Club in Washington, D.C. on February 26, 1976, that it's time to start testing chemicals, not people, in the fight against cancer and other major diseases. He urged the enactment of Toxic Substances Control Legis lation that would give "the American people not only the opportunity to understand and assess the risks and benefits of these chemicals, but a decisive voice in sorting out these risks and benefits." I am attaching a copy of his remarks for your considera tion. If we can answer any questions you may have on this issue, please call. Sincerely Attachment T_-^POffice of Public Affairs AP00036995 KW4ARKS HY THE HONORABLE RUSSELL E. TRAIN ADMIN1STRATGR, U.S. QA/TROt^'tLNTAL PROTECTION AGENCY PREPARED FOR DELIVERY BEFORE THE NATIONAL PRESS CIUB THURSDAY, FEBRUARY 26, 1976, 1:00 P.M. Testing Chemicals, Not People: Bringing the Chemical Threat^Under Control W.H. Auden once remarked that: "Today in the technologically advanced countries ... we have little to fear frcm nature; our only serious problem is man . . . His mastery ever nature has, as it were, brought man back to the same point at which he stood when he was utterly helpless before her." There are, however, sane differences. It is, to begin with, no longer the creatures and forces of the natural world that most threaten us: it is no longer even such historic diseases as the pox or the plague; it is, instead, such strange new creatures of our cwn making as "bischXorcinethyl ether" and "nitrosamines" and "polychlorinated biphenyls" and "polyvinyl chloride." They are all around us -- in our air, our water, our food, and in the things we touch. When they hit us, we don't feel a thing. Their ill-effects nay not show up until decades later, in the form of cancer -- or even generations later, in the form of mutated genes -- when it is, often, too late to undo the damage. Most Americans had no idea, until relatively recently, that they were living so dangerously. They had no idea that when they went to work in the morning, or when they ate their breakfast -- that when they did the things they had to do to earn a living and keep themselves alive and well -- that when they did things as ordinary, as innocent and as / \ AP00036996 essential to life as eat, drink, breathe or touch they could, in fact, be laying their lives on the line. They had no idea that, without their knowledge or consent, they were often engaging in a grim gaire of chemical roulette whose result they would not know until many years later. They had no idea until, increasingly over recent years, they picked up the morning paper or turned on the evening news and learned of sore new chemical hazard they had been exposed to, often for years and alnost always unwittingly. Increasingly, as well, they learned about the appal Lingly high death rates as a result of cancer and saw people they knew' and loved go through the awful agony of a death by cancer. As a * result, I think, the American people are deeply concerned both over the pervasive presence of chemical contaminants throughout the environment and over the high death rates from cancer. And they nay even rake the connection between the two. But I do not think there is, among the public at large, any real understanding of the precise nature and extent of the hazards posed by chemical contaminants -- as causes not only of cancer but of other serious ills and afflictions -- or of what we can and oust do to deal with than. Let me highlight seme of the most important points we should keep in mind about chmicals and their effects upon human health and life: 1. Over the past few decades, and especially since the end of World Weir II, we have released into the environment a vast volute of entirely new chemical ccnpounds with little or no knowledge of their health effects and virtually no effort to determine those effects and to regulate the release of many chemicals that might be hazardous. t AP00036997 2. We have rea^xxi enornous benefits fran these chemicals -- indeed, fran the truly marvelous advances in chemical knowledge and technology that we have achieved throughout modem times. We rust measure these benefits, not only in the econanic terms that are apparent to us all, but in health terms as well. The fact that we are the first generation in human history to be virtually free of the major infectious diseases is, in no small degree, a result of. the application of chemical advances to modem iredicine and modem life. 3. The World Health Organization, estimates that between 60 to 90 percent of all cancers are the result of environmental factors -- HOw/c- v C_<_, _ ^ r. _i . s o rV in the broadest sense of that phrase.' National Cancer Institute studies have shown that the highest cancer rates in the country occur in areas with the heaviest concentrations of industrial chemical use and activity. Yet of all the chemical agents in the environrrent, probably only a very small fraction is responsible for that large share of cancer .^Indeed, the odds are that only a relatively small portion of the chenicals in ' |jj our environrrent pose any serious health threats. -- 1 T* it may take only limited exposure to contract cancer, It / typically takes anywhere frcm 15 to 40 years after that exposure for the first onset of cancer to occur. Because of that long latency period, we have reason to believe that the full impact of the chemical explosion we have experienced over the past 30 years has cnly begun to show up in our1 * cancer statistics. Yet already, the experts tell us, one out of every four Americans new alive will ultimately contract sane form of . cancer. AP00036998 1 r,. A large and graving share of the diseases that cripple and kill us arc caused by environmental factors -- again, in the broadest sense of that phrase. These diseases are going to take an increasingly heavy toll upon our lives and well-being, unless and until we stop trying to deal with them by treating them after they occur, and start taking serious steps to prevent them fratv occurring in the first place. Our national health care effort must increasingly stress the prevention rather than the treatment of disease, and effective Treasures for the assessment and control of potentially dangerous chemicals and other agents before they enter the environment must be a key element in this new shift toward preventive medicine. To expand on these points: There are today more than 2 million ' different known chemicals; every .year, this list gxovs by an estimated i, 25,000 new compounds. There are today more than 30,000 chemicals in actual coimercial production; every year, this list grows by seme 1000 new compounds. Of the more than 2 million known chemicals, only a few thousand have been tested for carcinogenicity and -- aside frem those used in food additives, drugs , and pesticides -- only a few hundred have been adequately tested. We know, in fact, very little about the health effects even of the 3Q,000 chemicals already in ccnmercial production, we have no way of systematically screening the chemicals that do go into production; we have no way of knowing precisely which chemicals go into production every year. In other words, we not only don't know whether AP00036999 1 -5what's going out there is dangerous -- we don't even know what's going out there. We have/ however, learned one thing: it's what we don't know that can really hurt us, even kill us. Long after they have been loosed upon the world and the public at large, we have learned what an appallingly wide range of disease and death can be caused by chemicals -- they can attack the liver, the lung, the kidney, the central nervous system; they can cause cancer, infant mortality, and genetic damage. We have learned, for example, that: -- mercury, lead and cadmium can attack the central nervous. system; -- carbon tetrachloride and chlorinated phenols can destroy the liver; -- ethylene glycol and cadmium sulfate produce kidney disease; -- asbestos and beryllium often lead to lung disorders; -- vinyl chloride and arsenic cause cancer. We have seen our fish contaminated by phthalates, our cattle poisoned by polybrcrunated biphenyls, and our horses killed by dioxin. Fluorides have destroyed forest seedlings, chloramines have killed oysters, and zinc has damaged our wheat crops. And new the fluorocarbons may be threatening the ozone belt. wnen I became the first Chairman of the Council on Environmental Quality in February, 1970 -- almost exactly six years ago -- my very AP00037000 1 -6first directive to our snail staff was to develop a legislative proposal for coping with the class of problems presented by chemical and other contaminants. a year later# in February, 1971, this legislation, known as the Toxic Substances Control Act, was submitted by the President to the Congress. Twice, over the past five years, the Senate and the House have passed versions of this legislation, but have been unable to agree cn the same version. last week, the Senate Commerce carmittee reported out Toxic Substances Control legislation for action by the Senate. In the House, the legislation is being considered by a subcommittee of the Interstate and Foreign Comerce Oermittee. Over the five years since such legislation was first proposed, we have introduced into the ccrmercial market an estimated 5000 new chemicals. We have done so without any systematic, advance assessment of their potential irrpact upon public health or our ecological resources. We find ourselves still without the authority we need to cope with such longstanding problems as those posed by polychlorinated biphenyls. ' last week,- you may recall, it was announced that, for the first time . history, the Huiscn Fiver will be closed to earnercial fishing because it is cent 'tntad by these chemicals. In the Great lakes, ccnxnercial and sports fisheries that are being restored as the result of massive pollution clean-up efforts are now being threatened by PCB contamination. We remain almost entirely unable to discover how harmful a compound can be until years after it has beccxne a rather camcnplace item in our everyday life, even a significant factor in our econary. And, over and over again, we find ourselves engaged in an extrsnely difficult and AP00037001 1 drawn-out struggle to protect the public fran a hazard to which it has already been exposed while at the sane tine trying to avoid putting people out of business or out of work. --/''""Polyvinyl chloride, for example, was first intrcduced cctcmercially same 40 years ago. It is the backbone of much of our plastics industry. Its manufacture, according to industry figures, accounts for one percent of our Gross National Product. Vet it was not until 1974 that we discovered four cases of an extremely rare form of liver cancer among workers in a poly vinyl chloride plant in Louisville. Not until later did we find among these workers excessive cases of more camon forms of cancer as well. Ctily in the last decade or so have we developed the scientific skills and analytic techniques that would enable us to anticipate these effects of vinyl chloride, and a Toxic Substances law enacted several years ago would hardly have helped us prevent this problem. But the odds are that, until we enact such legislation, we will be confronting more and more such situations in the future -- and we can be absolutely certain that, until we enact such legislation, we will be unable to prevent- them fran occurring. I might add that our experience with vinyl chloride as well as with such chemicals as asbestos and, most recently, Kepcne underscores the fact that it is an the job and in the workplace that the hazards posed by such chanicals are most immediate and acute. It is the workers, and the families of workers, in the shops and factories where such chemicals are made and used who bear the brunt of the chemical threat and would benefit most fran the early enactment of toxic substances legislation. iJ 4 AP00037002 -8The plain fact is that, had the Toxic Substances Act been enacted five years ago when it was first proposed, we would be a lot farther ahead in dealing with same potentially very serious hazards: -- We would have begun to reverse the spread of polychlorinated biphenyls which are new destroying same of our valuable fisheries? -- We would already have, as we now do not, reliable test informa tion concerning the effects of vinylidene chloride which is widely used throughout the plastics industry; -- We would have a greatly improved data base for determining the extent to which benzidine-derived dyes reconvert to free benzidine, a ' well-known human carcinogen, when these widely-used dyes are accidentally ingested or absorbed; -- We would have taken a number of steps to clarify the chronic effects and, as necessary, to limit exposure to tris 2,3-dihremopropy1 phosphate, which has mutagenic effects in microbial systems and is widely used as a fire retardant in textile products, including children's pajamas. 1 do not think any of us is under the illusion that there is, or is ever goin- -o be, any such thing as a simon-pure, anti> ^cicalV' safe world. 1 do not think any of us imagines that there is, or is ever going to be, a real world without very real risks. But there is absolutely no reason why we cannot -- there is, in fact,' every reason why we nust -- take sensible steps to exercise sane`Intelligent and effective control over the risks that we curselves create. The basic aim of the toxic substances control legislation before the Congress is to help us gain AP00037003 -9- that kind of control -- to help us protect human health by bringing down to reasonable levels the risks that chsnicals pose while preserving their benefits. We are not talking, in other words, of getting rid of all risks fran chemicals, but rather of finding out what the risks are and, eventually, of removing "unreasonable" risks.. We are saying that, whatever we do with these chemicals, we ought to know what we're doing before we do it, and we ought to do it with our eyes wide open. We are saying, more specifically, that before people are unwittingly and unwillingly exposed to a chemical that could hurt or kill them, we take the trouble to find out what the health effects of that chemical might be, and we insist that the public interest be taken fully into account in the process by which we determine those effects and decide whether, or in what circumstances, we "go public" with that chemical. Ihese decisions to test ard go public cannot -- as they now cure -- be left siirply and solely in private hands. The public at large is deeply and directly affected by these decisions, and it must have -- it now does not -- a very real say in the process by which they are mao_- -e toxic substances legislation now before the Congress vr uld, for the first time, give the public that say. As ycu might suspect, there is seme disagreement about sane of the details of the legislation before the Congress. The Administration strongly supports toxic substances legislation, but wants-to make certain that it does not inpose unnecessary red tape upon industry or government. Inevitably enough, environmentalists are concerned that the legislation AP00037004 -10will not be nearly strong enough; and industry, or at least sate segments of it, is concerned that it vpll be strong enough to strangle the industry. Sad as it may seen, dull and undramatic as it may appear, the truth lies sanewhere in-between. The differences in detail about, and among, the different pieces of legislation before the Congress are far less important than the fact that their ccnmon aim is to give public health far more of the weight that it deserves in the decisions by which chemicals enter and spread throughout the human envircnnent -- the caiman aim of giving the American people not only the opportunity to understand and assess the risks and benefits of these chemicals, but a decisive voice in sorting out these risks and benefits. The legislation before the Congress would giv which we do not now have: -- to get: better information about the health and ecological effects, the distribution, the uses, the kinds and levels of exposure, of both known and new chemicals; -- to help prevent hazards and harm to human health ard ti. environment from chemicals before we rake major ecananic investments in them; -- to balance the various costs, risks and benefits involved before deciding whether, or under what conditions, a potentially hazardous chemical should be introduced into the environment; -- to help coordinate the presently fragmentary and piecemeal Federal approach to toxic substances. AP00037005 -u- I consider it of urgent importance that the Congress act now -- in , / / /c c*. y A/' /,*( f* ` r this session -- to eqact effective toxic substances legislation. Remain?- .. .. . / > ing differences should be resolved as rapidly as possible. But it is more important to get legislation on the books new than it. is to seek perfection. There will be time to improve legislative authority later as we gain more experience. But we can no longer afford to wait for the . basic authority to deal effectively with the problems of chemical pollution. We have done a great deal over the past several years to improve \* the regulatory process at EPA -- in particular/ to make it far more open and equitable. Our decisions are subjected to more searching scrutiny, more critical review, from sources inside and outside the Agency and the government, than those of any other agency. We have made a strenuous and increasingly successful effort -- most recently in developing oxir Drinking Water regulations and in setting minimum standards for procurement under EPA grants for the construction of wastewater treatment plants -- . to get all the major interested and affected parties actively and effective ly involved throughout the process of developing a regulation. also have the most open and rigorous process of economic inpact analysis performed by any agency of the Federal government. It is along these lines, according to these processes, that we would exercise our authority under toxic substances legislation. If the legislation does not require it, I would -- cn ny own -- appoint an Advisory Camittee which is broadly representative of all major interests to help advise us on implementation of the Act. AP00037006 1 f \ It is unfort'd-'^Us c2iat segr.ienta of the ohcnu.cai industry, \ / which originally tock an (?xtrert!l.y constructive approach towards <ho legislation, have taken to actively lobbying against it. T. dc >iOt. believe that either the public interest, or the interests o tho industry, t are well served by charges that the legislation could -- ir. the words -.',one industry spokesman -- "cripple" the chemical industry aivd give tho Administrator ci: EPF, "iviar-diCTctor i *1 audicrity ovf-?r the u-trcouct jch I of new chemical products.'' The only ro.il "cripf-fir.g" that js go:rig on is^the kind which this ltx;is ration would try to prevent -- the crippling of who knews how marly 'rcricans every yeizr who contract ouveer -\ or scnct other affliction after ex}X>s-are to sorr** hazardous ehcmicaj agent. Mor has it beon on <-hc "near-dictatorial authority" cf tf.e '..ih Administrator that no many such agents are introduced into the env.-ironnoi-.twithout any effort to find out what their health effects arc, much less let the public have any say about whether or not, or in`what circrxtsLances.- it is willing to he fixpostd. cc them. Let theic he no mistake: the only kind of authority the legislation before the Ccngrosu wculrt giv the only kind of authority wvv would intend to else, is the , and uy to act reasonably ard rcsvcnaibly in the puclit- interest -- and tf* t includes the very real interest, cbe public has in a healthy and orcoo-zrrr. ~ chenical industry. the chardcal industry has annual sales cf over S100 billion. We .... . - have estimated that the annual costs to industary as a result of *:his legislation would range between $79 rriilj.cn ard 5142.? million. The < AP00037007 1 -13- Manufacturing Chemists Association has estimated costs ranging frart $360 million to $1.3 billion a year, with "start-up" oosts of over $100 million. Dow Chemical Company estimates an annual cost of $2 billion. At the request of Congress, the General Accounting Office (GAO) analyzed and assessed these different estimates. The GAO concluded that the Dow Chemical estimates were the "least reliable," and that the EPA estimates were the "most reliable" -- although they believed EPA' s figures wore about 30 percent too lew. In testimony before Congress, a GAO spokesman said that "the EPA interpretation is' closer than the industry studies to an accurate picture of what the legislation will entail." Indeed, recent developments suggest that real breakthroughs are being made in the development of faster and less costly testing methods. The GAO further pointed out that none of the estimates considered the costs to society in avoidable and unnecessary suffering and death as a result of exposure to hazardous chemicals -- the huge expense that society bears because of the failure to invest enough time and money in determining the hazards of chemicals. I should think, indeed, that industry would reap fzTM very real benefits ian the approach this legislation contemplates. The testing of potentially hazardous chemicals before "going public" with them would let us knew, not only which ones are likely to be harmful, but which ones are not. Since these tests are by no means fail-safe or fool- - proof, we cannot precisely give a chemical an absolutely "clean bill of health," but the industry can market and the public can accept it with !n' 8 | I y ... i AP00037008 -14far greater confidence than they can now. frtoreover, the "preventive" approach would increasingly reduce the likelihood that we would have to take action against a chenical after industry has invested extensive resources in its production. Par frexn "stifling innovation/' the legislation should serve to encourage the industry to turn its remarkable skills and resources toward the discovery and use of less hazardous chemicals. The issue before us is really very clear? will we continue to set so lew a value on human life and health that we will refuse to take the thoroughly sensible and modest steps to protect than that the legislation before the Congress would involve? Will we, instead, bring better * balance to the decisions by which chemicals are made and marketed by giving full weight to public health in reaching those decisions? It is not, as sane have suggested, a question of assuming that every chemical is dangerous until proven otherwise -- although I would find that, a preferable alternative to assuming, as we dp now, that every chemical is harmless until we ccme up with a body count and a clear-cut case. It is a question, rather, of honestly and openly ackrr- 'ledging that We simply don't know whether a chemical is dangerous or no wi that, before we expose the public to it, we should'take at least * reason, le amount of trouble to find out. It is time we started putting chonicals' to the test, not people. It is time we gave the people of this country seme reason to believe that, every time they take a breath or eat or drink or touch, they are not taking their life into their hands. APOOO37009 -15It is tints that, down here on earth, we took a couple of small, sensible steps on behalf of human health and life. *i AP00037010 vi f. l r~ u; * r ------------------ -a 1 INTEROFFICE MEMORANDUM Date MARCH 29, 1976 Subject EPA AIR EMISSION STANDARDS PREVIEW To _ From DISTRIBUTION A. J. DIGLIO DISTRIBUTION: A. R, Adams J. J. Ballker J. T. Barr C. E. Blades R. A. Blomquist p. L. T. Brian 0. J. Bungs C. E. Calllcott T. L. Carey M. R. Chimira 0. L. Cost W. J. Cross E. Donley F. H. Fernengel R. Fleming H. P. Gallagher H. I* Harwell W. Hoge (Location, Organization, or Oapartmant* VALIEV FORGE (Location, Organization, or Dopirtmtni) H. L. Jaffe R. E. Jones J. D. Kramer R. G. Kunz J. B. Maerker J. E. McEvoy A. K. McMillan T. J. Medovlch J. C. Novak D. E. Pryor H. A. Quigley R. J. Ryan J. A. Saner W. J. Scharle R. H. Schenck R. M. Vozar H. L. Watson 0. T. Wharton J. H. Robertson Attached for your Information Is the MCA Air Emission Standards and Criteria Task Force Report prepared by S. N. Robinson after an Informal visit to the EPA. This Information gives a preview of air emission standards that the EPA Is now considering. Attachment AP00037011 mall:nckrodt, inc. ST. LOUIS. S. N. Robinson I. Activities - Emission Standards and Engineering Division Mr. Don Goodwin suffered a mild heart attack in December, 1975, and he is^just now returning co pare time work, Mr. George Walsh is serving as temporary Director. Mr. Walsh noted the status of tne following studies: A. Coke Ovens; The support document has been revised and should be issued in March, 1979. Refuse Combustion Units: A regulatory package is being prepared, C. Coal Gasification Plants: The support document is now due in May, 1979. D. Crushed Stone Plants; A regulatory package is being prepared. E< Carbon Black Plants: The support document is due in April, 1976. P. Phosphate Rock & Lime plants; Technical information will be reviewed with the Techniques Advisory Committee in March before preparation of a support document. S. Various Hydrocarbon SoutSas ('Surface Coatings, Drv Cleaning. Solvent Degreasing, etc.); Studies are underway on most, but it will be up to a year before support documents are completed. H. Steel Mills - Electric Arc Furnaces Phosphe.te Fercilisar Operation Copper-Lead-zinc Smelters New source standards have been promulgated. I. published rules on implementation of Section lll.d. J. proposed emission standards for Vinyl Chloride. K. Published regulations on modification and reconstruction. MK 14170 n 2/74 AP00037012 Inissiort Suuvi.ir>i * Ta3k Force Report Criteria 1/19/76 Page 2 \ II Status of "{^-.5ep.co Scm.'.1" ot 11ircdia L-n:sslona I contacted Dr. Robert Banning at Monsanto1^ Dayton Laboratory (513-268-3411) to learn the status of their contract with EPA to "continue the Koudry Investigation" Dr. Benning described a program "that goes beyond the original investigation by Houdry: A. The program's objective is to "assess the environmental impact of multi-media emissions from a list of sources, using common judgment criteria, in sufficient detail to enable EPA to determine the need for the development of control technology". B. The scope of work includes investigating 600 sources in major categories; 1. Organic materials 2. Inorganic materials 3. Open operations 4. Combustion operations The prodfiflUffe cAns tor an eight step evaluation of each source: 1. Select sources to be studied by using an evaluation model that quantifies each of several environmental factors * (e.g. emission levels, TLV of item, number of people exposed), tempered with "qualitative judgments" (i.e, political pressure). 2. Prepare a work plan that identifies cost and time. 3. Collect current information and prepare preliminary evaluation document; send this to affected Industry, 4. Get EPA decision on whether a sampling program is required. 5. Prepare a sampling plan. -- 6. Conduct the field work.. ?* Prepare a final draft of the environmental assessment document; distribute this for comments. 8. Publish. T" ---------- 5. This project is funded at $1.3 million/year, starting in April, 1975, and continuing for three years. AP00037013 Emission se-ir.dard? and Criteria Task Force .iepo_*L 1/19/76 Page 3 II. Status rii :: ;r jcn:o ^r.y.uv of ' .'.Ici-vsdi.* _ _j___ ' Cor. tinned) E. In 1975, nineteen preliminary docu" --^? uud four completed documents were published, and live ; 2r.ni1.ns programs were undertaken. There are about torev sources in various staged of investigation now7" ineluding': "" _ "7' 18. 19. .20 .21 22. 23. 24. 25. Acrylonitrile Phthalic Anhydride Carbon Black Maleic Anhdride Acrylic Acid Coal Fired Industrial & Commercial 3oilers Oil Fired Industrial 4 Commercial Boilers Fuel burning Stationary Engines - Reciprocating Fuel Burning Stationary Engines - Turbine Fertiliser Mixing Plants Ammonium Nitrate Antonia Ethylene 4 Prooylene Rubber Ethylene Dichloride Varnish Manufacture Solvent Evaporation - Degreasing Rubber Processing PVC Polychloroprene Flat Glass Manufacture Barium Chemicals Lead Acid Battery Manufacture Zinc Oxide Lead Chemistry Coal Storage Piles AP000370I4