Document N2y751GaMz5K6wJVLDJzjj95E

minutes VINYL INSTITUTE HEALTH, SAFETY, & ENVIRONMENT COMMITTEE The Marriott City Center Hotel 100 West Trade Street Charlotte, North Carolina 28202 Thursday/Frlday July 17-18, 1986 8100 a. a. Attendeeai W. C. Holbrook, A. S. Baker J. T. Barr H. M. Blackaan 7. E. Sorrelll C. A. Celiner J. Kaehtlck J. A. King J. Ledvlna 0. T. Sandberg H. WalteMate S. L. White J. E. Wyche ZZI E. J. Zeringue P. de la Crus K. T. Gottesnan Chairman - BFGoodrich - Bow Chemical - Air Products & Chemicals - Borden Chemical Georgia Gulf - CertalnTeed Occidental Chemical (7/18 only) - Occidental Chemical - Vista Chemical - Borden Chemical (7/18 only) - BFGoodrich - PPG Industries - PPG Industries Ceorgla Gulf - Keller and Heckman - Vinyl Institute 1. Self-Introduction and Approval of Minutes. Following eelf-lntroductlona, the alnutee of the May 27th Meeting of the Coenittae held in Vaahington were diatributed. Later Mr. Barr Moved, Mr. Blackaan aeconded, and the Minutes were approved as received. 2. Discussion on EDC Cround Water Considerations. Those coMpany representatives having experience with underground water contaMinatlon fron BBC discussed their own situations. Generally, in the first KCKA ground water Monitoring, contaMinatlon by EDC was found. In several situations, the underground liquids were Mined, the organics separated and the water layers steaM-strlpped before being discharged through a permitted NPDES outfall. Neither the states of Louisiana or Texas have issued regulations, but are getting reports on what la being carried out. THE SOCIETY OF THE PLASTICS INDUSTRY. INC. 355 Lexington Avenue New York. N.Y. 10017 (212) 503-0600 BOR 007861 BOR-007861-00 BFG62014 O C5 JO VI Health, Safety, & Environment Committee Meeting Minutes July 17-18, 1986 Page Two There has been no determination of what constitutes sufficient clean-up, l.e., "how clean is clean", but in a number of cases, the company representatives indicated that they expected to continue the pumping and steam-stripping of water for some time to come. 3. Discussion of Inadvertent PCB Generation in EDC/VCM Manufacture. In a round robin discussion, company representatives mutually Informed each other regarding their situations on the inadvertent generation of PCB. Mr. Ledvlna of Vista indicated that they had found PCB in the heavy ends of their VCM plant. They have carried out registration under TSCA as an inadvertent generator. Mr. Ledvina indicated that they had not found any PCB's in any vastcvater streams and that water from the incinerator is now being analyzed. Mr. Baker of Dow Indicated in their Louisiana and Texas operations involving direct chlorination, they are finding PCB's in the heavy ends which are mixtures of heavy chlorinated materials and vinyl tars. They also have one stand alone EDC plant where they have found PCB's. Heavy ends are disposed of by incineration under a non-commercial permit. Dow has registered all of its three plants as PCB generators although Mr. Baker indicated that oxy-chlorinatlon does not appear to generate PCB's. They are currently using CC/Mass Spec for analysis, but they are trying to develop a new method due to noise and interference with the CC/Mass Spec procedures. Materials which are extracted in the analysis other than PCB lead to analytical interferences. Mr. Holbrook reported that one monomer plant is registered as a PCB generator with EPA. At a second Goodrich monomer plant they are not registered under TSCA. PCB's are found in the heavy ends from EDC cracking. Goodrich has not found PCB generation in the direct chlorination process. Analyses are done in-house by CC/Mass Spec. Mr. White of PPC reported that they have found inadvertent PCB formation in the cracking and in the heavy chlorinated materials in the direct chlorination process. They have not found PCB's in other hydrocarbon chlorination processes, but do find them when co-mingllng with vinyl chloride monomer process streams. PPG is on a track to get a PCB permit for their incinerators. They are registered as an Inadvertent generator because of the large water flow volume being discharged from the incinerators where, because of the detection limits, they would exceed 10 pounds per year. PPG incinerates their heavy ends at a temperature of 1800-2200 degrees P. PPG is interested in sharing analytical techniques and methods with the othar member companies. BOR-007862 - 0 0 BFG62015 cn o C) 43 VI Health, Safety & Environment Committee Meeting Minute* July 17-18, 1986 Page Three Mr. Zerlngue of Georgia Gulf Indicated Chat they had campled at 3 or 4 place* in their Plaquemlne operation and aample* were *ent to TKS in Indlanapoli* for Ma*a Spec and to one other laboratory. Analytical results Indicated PCB's in Che direct chlorination, but nothing downstream. They believe that PCB's are concentrating in the reactor. Georgia Gulf is registered as an Inadvertent PCB generator under TSCA. They concentrate the PCB material* and they dispose of the materials off site. Both Georgia Gulf and Dow indicate that they have had TSCA inspection* in relation to their filings a* inadvertent generator*. 4. Update on EPA'a EDC Hatardous Air Pollutant Regulatory Development* Mr. de la Crus reported that they had had recent contact with Bob Shell at EPA, Janet Meyer at EPA/Research Triangle Park, David Beck In the EPA counsel'* office, and Bob Romano at CMA. Be has learned that EDC will probably be regulated by July 1987 as a hasardous air pollutant along with ethylene oxide and butadine. Mr. de la Crus noted that EPA is trying to develop a generic MISHAPS standard. Such a standard would Involve Incinerator vent*, storage vessels, fugitive control*, normal inspection, monitoring, repair*, and air oxidation vents. A meeting is being held with CMA representatives at Research Triangle Park on July 24th, where EPA will provide a briefing on its action plan. The CMA contact on this is Alice Mayer. Mr. de la Crux noted that a HAPTAC Meeting Is scheduled for September 17th and 18th. Mr. Ledvina will be attending this awe ting and will report to the Health, Safety, and Environment Committee at lta next meeting on thia. Actions Mr. Ledvina to report on September 17-18 NAPTAC Meeting at next Health, Safety, and Envlronswnt Cosaaittee Meeting. Mr. Ledvina and Mr. Holbrook advised that they have received questionnaires concerning EDC under Section 114 of the Clean Air Act. These were received in mid-July and are due by July 25th. The main subject the Agency appears to be addressing is waste water snd essentially they have asked for a material balance around the biological treatment plants. 5. Update on EPA's VCH Hazardous Air Pollutant Regulatory Developments. Mr. de la Cruz reported that based on a contact with Fred Dlnnaick at EPA, the EPA proposal of January 1985 la in red border review and Dlmmick expects to see It issued in a few months - i.e., August or September 1986. Mr. de la Cruz expressed skepticism that this date will be met. He also reviewed the history behind the NRDC suit, and the proceedings in the DC Circuit Court. He noted that a decision can be out any time and he would expect one by September beceuee circuit court judge* like to issue decleions on caeee heard before they change lew clerks. BOR 007863 BOR-007863-00 BFG62016 O Ci VI Health, Safety, & Environment Committee Meeting Minute* July 17-18, 1986 Page Four 6. Dlacuaelon of VCM, PVC and PVC Compound Labeling. Company repreeentatlvea diacuaaed their company practice* with regard to label* and material safety data aheets. These are summarized in Table I for VC, Table II for PVC Resin and Table III for PVC Compounds. ran rwitwm usiis mattes** n mm* fmna ar.su Imi be ear Cam Mf fa* ter terry M 0H4 It MM ten m tss VI MM lll--l. UM1 - -mt VI Ob MtirUli ihipfil at f yin mn tu MSMSCICB VI tit - teltet luUt ten M f ink nr. nm tel na - emmsm* VI VI - *tlillll-- WltfJ 7/17/M U ft ImIU, tai7 * SIMM MUM ----1* any Ml "Cm lapMi tent* Itel. in mattertag Matter u M "te**rte fm lin* lalmilw ink avi< A copy of the PPG product information label on vinyl chloride is attached to these minutes. BOR 007864 BOR-007864-00 BFG62017 7 ,ik Q) cn VI Health, Safety, & Environment Committee Meeting Minute* July 17-18, 1986 Page Five ii frc uwtnm ib am* mens** (mstx) n bm nfirai umneM m un f-- Imi Ukl bny to MU *Caur iN^aK UMla UtoU IU - Ot to|*' Wife mti to alUii ! Utol torry lau* (laa b|aH toin tott laaa Utol torry laia* llaa to Fir*/ totoa*. laiarlf mi ana Xsalto* FC "Caaaar ! aaai 4|aat* laialiaa to toot to a ii- Til m totalito to Fir*/ toatoatito laaaHt Til HKZ5HB- w to to m TU IU aeacu ssT" HI to ki|) bU Mfl uucassui STHTn^Two? o not to to to ns m hi Otortotlf avatollai afcatta? la pal intolaa. HaiaMi m Ml. 0 tti TU TU All too*, tolk un to Um at* m Utolto. Imm nataa an , BoooKna-" zx > i.s pm ires, vaaM to m lalato. AmuaII, mlu in < (.7 m m* an H aa lakalM. TXSI4 to liaaa STM la < - fto e n UA to 1X1 TU Mu " TU hi TU tortolly aratollai alattat Utol atoalt ham aaiatUai m Ami to tin aatoitiai so to tU TU mu* liliwlln mttnl 7/17/14 M TX iHlik, tilatr hih--l OmIiim ImiU#. mu xn censsmi. toa Utol torry to Otto "Gamar laryaat -------------- BfBE lL UMi'I U! to* Ml toaa Utol Imi Utol laalala TC- Stoat ito torry toa* torry Bala* fiaiar laa* to tot to laUltaa 11m to llaa to Fir*/ raat Aftot" A "toi* to FU/ S41 M SO TU M SO TM M so SO Utol alaa aar rlaa lalawiiua Mtottlricy mesMticB pfmZf noi < l.l so B0 ns TU TU nm so so BO tetmuln MtfHl 7/17/M U TI lMltk, Mlt7, 4 Inlnaw so dT 1V> i HulU|. TU Note that the composition* of PVC Compound* were not discussed, but are likely to vary. BOR 007865 25013136 BOR-007865-00 BFG62018 VI Health, Safety. & Environment Committee Meeting Mlnutea July 17-18, 1986 Page Six Actioni Company representative* are requested to review the table* hown above and advise Ms. Scheck of any change* and/or revisions/addition* needed to properly reflect their company's practices. Mr. de la Cruz distributed a letter dated July 16, 1986 regarding OSHA regulation of PVC resins and compounds in which he reviewed a "less than satisfying" meeting with John Miles, Director of Occupational Safety and Health, Administration Directorate of Field Operations, and Roy Gibbs andCall Brlnkerhoff of the OSHA staff. After a review ofthis meeting, it was agreed that Mr. de la Cruz should develop additional information to submit to the Agency. Dependent on the response Mr. de la Cruz, Dr. Gottesman, andMr. Barr will brainstorm this and if OSHA is not forthcoming with a clarification on the status of PVC resin compound under the OSHA Vinyl Chloride Standard, we will ask for a meeting with the appropriate Agency personnel. Action: Mr. de la Cruz will develop additional Information to submit to OSHA and if necessary, make arrangements for an additional meeting with the Agency. 7. EPA Proposal of June 13, 1986 Regarding the Hazardous Waste Management System. There was discussion concerning the proposal in the Federal Register of June 13th relating to EPA's Hazardous Waste Management System, identification and listing of hazardous waste, notification requirements and reportable quantity adjustments. The representatives present Indicated that no one currently has equipment to run the proposed TCLP tests. Messrs. King and Blackaun indicated that they feel that there will be trouble with regard to both resin and waste materials. Mr. Ledvina indicated that Vista plans to have the old EP toxicity testing run on tote streams to see what the results would be. It has not carried out any tests at this point. Mr. Barr indicated that while no tests have been run at Air Products, he has no doubts that any PVC containing greater than 1-2 ppm, will exceed 50 ppb of VC in the extract. Mr. Barr further noted that the teflon-lined vessels cost approximately $1,000 each and probably have limited life. Company representatives from the following organizations indicated that they will file comments on behalf of their companies! Air Products and Chemicals Borden Chemical Occidental Chemicals Georgia Culf Vlata Chemicals BOR 00786$ ro (; o ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- & C) BOR-007866-00 BFG62019 VI Health, Safety, & Environment Committee Meeting Minute* July 17-18, 1986 Page Seven Mr. Holbrook indicated that BFGoodrich had made some equipment and carried out some teat* and are proceeding to do others. They have tried to simulate the TCLP extraction procedure. Their Initial results show that in general, process wastes from their PVC operations failed the TCLP test. Filter cake from the waste treatment plants has given mixed results, l.e., some passed and sosie did not. As regards products, except for latex, Mr. Holbrook believes that materials having a residual VCM of up to about 30 ppm will not give extracts exceeding 50 ppb VC. It was agreed that the Vinyl Institute should be on record offering consents on this proposed rule. At Kr. Barr's suggestion. Dr. Cottesman spoke with Ken Kastner, an attorney at CMA who specialises in RCRA activity. He advised that the August 12th deadline for consents has been extended by AS days on all factors except for the TCLP procedure. By statute, EPA Indicates it must issue regulations regarding landfilling by November 8th and since the TCLP is involved in that regulation, it is not extending the date for consents on that feature. A task force consisting of Kr. King as Chairman, Messrs. Barr, Ledvina, Blackman (or a designee from Borden), a representative to be named from Georgia Gulf, Mr. de la Cruz, and Ms. Scheck serving as staff vill be responsible for developing these comments. Actioni Kr. King to convene this task group to develop coonents on the EPA Hazardous Waste Management System proposed rule. Action! Mr. de la Cruz to write-up comments for Dr. Cottesman's signature regarding the reservations expressed concerning the TCLP procedure. Mr. Barr developed an outline for use by the task force which could serve as the basis for developswnt of these consents. His outline is as follows! I. General A. Support 1. Degree of hazard. 2. Use of toxicity base. 3. Use route specific toxicity. 4. Quantitative levels. 5. No added safety factor on carcinogens. BOR 007867 BOR-007 867-00 BFG62020 VI Health, Safety, 4 Environment Comittee Meeting Minute* July 17-16, 1986 Page Eight B. Concerns 1. EPA Risk Assessment Programs. 2. 1,000 fold safety factor to no-effect level. 3. Ollvater coefficients. 4. Choice of candidates. 5. Use of proposed MCL. 6. Inadequate data base. C. Definition of mismanagement. D. Multiple Test System - May have to run two tests for container and solution. E. There are 9 items that EPA is not ready on. F. Conflicts with RCRA rules. C. Conflicts with non-RCRA rules. Problem with sludge until EPA makes up its mind. Discussion regarding water and surface impoundments. H. Impact analysis faulty. ZI. III. XV. V. VI. Specific concerns for specific substances. Specific questions. Test methods. Specific products. Recommendations - Testing Methods - Listings 8. Update on PVC Solid Waste Disposal Subcommittee. Mr. Ledvlna advised that he had developed a survey form which has been sent out to companies for evaluation of their practices on land disposal of PVC. To this point, he has had six responses from five companies, and he anticipates having all information tabulated for presentation at the October meeting of the Vinyl Chloride Safety Association. 9. Discussion on Community Emergency Planning Actlvitiea. Mr. Baker of Dow presented a video developed by the Texas division regarding the CAER (Community Awareness Emergency Response Program) in Brasosport, Texas. He Indicated that the program is now being initiated in Texas and the video is being used on public broadcasting stations. Further Information can be obtained from Tim Scott at (409)-238-2099. Following this, there was discussion concerning establishing a trigger level for notification or evaluation of the public when there is a discharge of vinyl chloride monomer of significance. BOR 007868 _______________________ BOR-0 07 8 6 6-00 BFG62021 r* o w LA C) VI Bulthi Safety, & Environment Committee Meeting Minute* July 17-18, 1986 Page Mine It was established that none ef the companies present have a trigger level, no one has such a level under consideration, and a coaanralty Itself has never been evacuated although there have been Instances at Dov and PPG where highways have been barricaded and temporarily closed. It is recognized that the real danger in a large VCM discharge is from fire and explosion rather than health effects on the community. By a vote of 8 to 3, the group voted against establishing a trigger level for notiflcadon/evacuatlon of the public based on health effects. It was also suggested thati 1. The Vinyl Institute should not establish a trigger level at this time. 2. Whether there should be community evacuation or highway barricading and closing is an "on the spot call", which must be based on safety considerations. 3. Mr. Baker Is to determine whether ORC (the Organization of Resource Counselors) is going to establish a trigger level for VC. A. Roy Gottesman is to advise the Executive Board of the Committee's recnHMisndatlon at its September 10th meeting. Mr. Borrelll provided the Committee with his thoughts for a Community Awareness Survey, which he proposes to carry out. This Includes questions concerning the distance of a plant to the nearest cowalty residence, whether the plant has an emergency plan which Includes local community emergency response plans, elements of the plan, notification systems, etc.. It was agreed that Mr. Borrelll could proceed with this survey as proposed under the aegis of the Vinyl Institute, and that if the survey is complete before the Vinyl Chloride Safety Comittee Meeting in October, it would be presented there. 10. Pinal Approval of Vinyl Institute VM Storage and Handling Guidelines. Mr. Barr indicated that he has received final consents and is putting the revised draft of this document into final form. Actloni Mr. Barr is to send final draft of VCM storage and handling guidelines to Roy Gottesman. Actlom Roy Gottesman la to obtain legal approval and then submit this document to the Executive Board for their approval and issuance. BOR 007869 >.} (; 0 1A ----------------------------------------------------- b . \ 6 BOR-007869-00 BFG62022 VI Health, Safety, & Environment Cossslttee Meeting Minutes July 17-18, 1986 Page Ten 11. VCM HESSAPS Performance Tracking and Annual Awards. After discuaaion, the group agreed on the following formula for calculating performance indices. Performance Index For PVC Plantsi RVCM Ex PIPVC 100 - RVCM 100 * ROL Ex ROL VCI Ex 100 * VCI 100 - RV - RD - KV - BPI Where: PI " Performance Index RVCM " Daily average of excursions on residual vinyl chloride monomer. ROL " Reactor opening losses. VGI " Excursions at the vent gas incinerator. RV " Number of relief valve discharges. MV " Number of manual venting discharges. RS * Number of rupture disk incidents. BPI " Number of incinerator by-passes. Ex Excursion Performance Index Tor VCM Plants: Piyc - 100 - 100 *T ** 10n Oxy Rx By-Pass Hrs. Operating Hrs. 100 - RV - RC It was agreed that the reporting would be by plant in January of each year for the preceding calendar year and that the performance index would be calculated to two decimal places. Action: Mr. Holbrook will develop instructions for the collection of data and method of calculation. This proposed program will be presented to the Executive Board for approval at its next meeting. 12. Quarterly Safety Statistics Reporting. Mr. Barr reported that some companies have not submitted their 1985 safety statistics and has requested that these be submitted as soon as possible. BOR 007870 _____________________ BOR-007870-00 BFG62023 r-i o C/J r. e 4-* VZ Health, Safety, & Environment Consulttee Meeting Minutes July 17-18, 1986 Page Eleven 13. Dlscuaalon of Plant/Worker Safety Action Information. Mr. Walteaate of Goodrich provided a detailed description of the Incident at Pedrlektovn, vhlch led to an explosion and fire on May 13 th. He also described the corrective measures which have been taken. Mr. Barr reported on an incident a few days prior to the meeting at their Pensacola plant where electrical power was lost on both Incoming lines. Reactors In progress were controlled by manual addition of cbalnstoppers and manual venting. When power was re-established about 5 hours later, all agitators could be restarted. 14. Company Discussion of Recent State and Federal Enforcement Activities. The company representatives discussed their individual recent experiences regarding enforcement. Mr.Baker reported that in their Louisiana division, Dow had gotten a request under Section 114 of the Clean Air Act for information regarding their use of flares. Dow has filed suit against EPA Indicating that it had properly reported all discharges to the flare and that all prior inquiries for information under Section 114 had led to suits by the Agency for violations. Per agreesmnt with the Agency, the suit is being held pending resolution of a relief valve discharge case. 15. Discussion of "Air Toxics" Activities. Under the date of January 20, 1986, CMA announced an Air Toxics Program complementary to their CAZR Program. This program deals with both accidental releases and process emissions. Pursuant to CMA's air toxics policy, it was Indicated that Dow, PPG, Air Products and Georgia Gulf have old programs underway to evaluate existing environmental controls, and that they are taking another look at these programs in view of the CMA recommendations. None of the companies are carrying out fault tree analyses pursuant to CMA's proposed air toxics policy and because the EDC/VC/PVC industries are so highly regulated, no one is planning to predict community health risks for their operation. 16. VI Participation in 1986 VCSA Meeting. The Vinyl Institute will not be making a presentation at the Vinyl Chloride Safety Association Meeting as no invitation has been received. Actiont Roy Gotteaman is to ask the Executive Board for approval to smke available the Cosmiunity Health Effects Document and the Handling and Storage Document to the members of the Vinyl Chloride Safety Association. BOR 007671 BOR-007871-00 BFG62024 VI Health, Safety, & Environment Committee Meeting Mlnutei July 17-18, 1986 Page Twelve 17. Pinal Revlev of Committee Document. The final draft of the Community Health Effects of Vinyl Chloride developed by a subcommittee consisting of Messrs. Holbrook, Barr, de la Crus, and Cottesoan was reviewed In great detail by the Committee and numerous changes were made. ActIont Roy Cottesman will arrange to have the final draft re-typed, submitted to Mr. Barr for his review, and then sent to Mr. Luss for legal approval. 18. Kcxt Committee Meeting Date. The next meeting of this Committee was tentatively set for October 8, 1986 in Washington, D.C. at the SPI offices. This is the day lmediately preceding the Vinyl Chloride Safety Association meeting. Action> Mrs. Scheck to make arrangements for this meeting. The sweting was adjourned approximately 2:30 p.m. on July 18th. RTG/pmb BOR 007872 BOR-007872-00 BFG62025 N (7T O C3 M Cj