Document NqNgQJ6gXNEn5ov8gnaM6Vx8

Visto Chemkol Company 15990 N. Barker's Landing Rd. Post Office Box 19029 HoustonJexos 77224 Phone {713} 531-3200 March 21, 1986 Mr. B. I. Raffle Supervising Counsel Environmental & Engineering Group Conoco Legal Department P.0. Box 2197 Houston, TX 77252 Certified - Return Receipt Requested VIST/ Mr. H. J. Neeld Director, Environmental Programs Environmental Conservation Conoco Inc. P.0. Box 2197 Houston, TX 77252 Certified - Return Receipt Requested RE: U.S. v. Conoco Case # 83-2518 Gentlemen: Pursuant to the Asset Purchase Agreement dated as of July 20, 1984, among E.I. Du Pont de Nemours and Company, Conoco Inc., and Vista Chemical Company, and the Consent Decree entered in the above action, we hereby provide notice of recently-discovered information which may lead to the filing of an Environmental Claim. On February 28, 1986, the Vista LC VCM plant experienced a relief valve discharge from the VCM product Loading Bauxite Dryer. As a result of the incident report sent to the State, the enclosed request for further information has been received. Please contact George Hopkins at the VCM plant if you have any questions regarding this matter. Sincerely, Thomas G. Grumbles, C.I.H. Environmental Quality Manager ajo/8 cc (w/att); W. L. McClain J. C. Ledvina R. A. Conrad VVV 000000399 UNITED STATES POSTAL SERVICE OFFICIAL BUSINESS SENDER INSTRUCTIONS Print your rum*, address. and ZIP Coda in tha ipaca below. Compiati itams I, 2. and 3 on tha iwaoa. Attach to front of artiela if space permits, otharwita affix to back of article Endorse artiela "Return Racaipt RaquaitatT ______ adjacant to number. RETURN TO ___&ram Lies (Name ofSender) Q. /*9o 9 f(QStlrneyeitt rotrr PP.CO\. DBonovt)\ /t, 7? (City, State, and ZIP Code) UNITED STATES POSTAL SERVICE OFFICIAL BUSINESS ---------------------SENDER INSTRUCTIONS Print your nama. addrws.end ZIP Coda in tha space balow. Complata item* t. 2, and 3 on tha reverse. * Attach to front of artiela if ipaca pirmin, othirwaa affix to back of article. Endorse article "Ritum Raeelpt Requottod" adiacent to number._______________________ _ RETURN TO T. G. Grumbles. (Name of Sender) P.O. Box 19029 (Street or P.O. Bax) Houston. TX 77224 (City, State, and ZIP Code) VVV 000000400 Wv 000000401 PATRICIA L. NORTON SECRETARY OFFICE OF AIR QUALITY AND NUCLEAR ENERGY March 13, 1986 CERTIFIED MAIL - RETURN RECEIPT REQUESTED P 669 936 930 GREG J. GASPERECZ ASSISTANT SECRETARY CC * Gen PtfA flr/ ScA. Mr. R. A. Conrad Plane Manager Vista Chemical Company P. 0. Box 605 Westlake, LA 70669 Dear Mr. Conrad: The Air Quality Division is in receipt of your 76.18 letter dated March 10, 1986 relating to a VCM release on February 28, 1986. Our mandate under La. R.S. 1089 I is to make a determination of preventability for each VCM release covered under 76.18. Accordingly we would appreciate a response to this letter 15 days after receipt. To help us with our determination, please supply the following information: - A sketch of the entire system involved, to include instrumentation, pumps, valves, vessels, etc. Please make specific reference to the VCM recovery system at the Shiploading Facility since our file information indicates this equipment to be activated carbon absortion beds, and - if possible tie in the pressuring up of the system with a copy of the PRC or PI chart reading, and - a copy of your unit supervisor's log book entry relating to this event, and - the size, material of construction, the manufacturer, and specification for the rupture disk protecting the VCM Product Loading Bauxite Dryer SRV, and a copy of your calculations attesting to the quantity of ^VCM released, and - a completed copy of your internal investigative report relative to this event. 000000402 MR QUALITY DIVISION P O. BOX 44fl9fi RATON ROUGE. 1 OUIS1ANA 70S04 PHONE J42-I2M Reprinted from British Journal of Industrial Medicine 1985;42:750-753 Copyright (g) 1985 British Journal ofIndustrial Medicine AU rights of reproduction qf this reprint are reserved in all countries of the world Exposure to vinyl chloride and angiosarcoma of the liver: a report of the register of cases D FORMAN. B BENNETT. J STAFFORD. AND R DOLL 06 1 Copy: Fils: co British Medical Association, Tavistock Square. London WC1H 9JR Wv 0000042Q British Journal of Industrial Medicine 1985;42:750-753 Exposure to vinyl chloride and angiosarcoma of the liver: a report of the register of cases D FORMAN,1 B BENNETT,1 J STAFFORD,1 AND R DOLL1 From the Imperial Cancer Research Fund Epidemiology and Clinical Trials Unit.1 Radcliffe Infirmary. Oxford OX26HE, and Imperial Chemical Industries pic,1 Thornton Cleveleys, Blackpool FY54QD. UK abstract The Association of Plastic Manufacturers in Europe maintains a register of all cases of angiosarcoma of the liver (ASL) resulting from exposure to vinyl chloride monomer (VCM). This register has recorded all known VCM related cases of the disease worldwide that have been histologically confirmed. Although likely to be incomplete, it is the most comprehensive tabulation of such cases available and, by the end of 1984, 118 men had been registered. The information from analysis of the cases currently on the register is used to make an approximate projection of the number of cases to be expected in the future. The conclusion from this projection is that the industry is reaching the halfway stage in the appearance of VCM related ASL. The idea that vinyl chloride might cause cancer was first suggested by Viola in 1970 as a result of experi ments in rats.1 This was subsequently confirmed by Maitoni in 1973 with his comprehensive series of experiments in rats. mice, and hamsters.2 Among the tumours that developed in these animals was the nor mally rare angiosarcoma of the liver (ASL). It was not, however, until three cases of ASL were observed in men who had been heavily exposed to vinyl chloride in a polyvinyl chloride (PVQ polymerisation plant in the United States that the reality of the hazard was generally accepted.2 ASL is normally so rare that only three or four cases occur each year in the whole of Britain (see below) so that the occurrence of three cases in a small group of industrial employees in the United States was, in itself, sufficient to justify the belief that the chemical caused the disease. If. how ever. any doubt has persisted it was soon dispelled by the steady accretion of new industrial cases and the finding that angiosarcomas and various other tumours could be produced in rets by levels of exposure that were appreciably less than those that had previously occurred in industry.* Steps were therefore quickly taken in the mid- i 970s to reduce the extent to which individuals could be exposed from levels of the order of several hundred ppm to 5 ppm (13 x 10* ngm/m2) or less.3 This reduction followed Received 25 February |98S Accepted 25 March 1985 an earlier lowering ofexposure levels in the mid-1960s after concern was expressed about the narcotic effects of vinyl chloride and the risk of it producing aeroosteolysis. Before then exposure to some empic was often in the range of several thousand ppm. rarity of ASL, even under conditions of heavy exposure, has made it difficult to study its epi demiological characteristics* and it seemed, therefore, that it might be of value to summarise the data that have been recorded in the register of cases that has been maintained by Imperial Chemical Industries pic on behalf of the Association of Plastics Manu facturers in Europe (APME). This tabulates informa tion about all the cases of ASL known to have occurred in men exposed to vinyl chloride that have been reported by individual manufacturing compa nies. trade associations, and occupational health organisations in Europe. North America, and Japan. The register is, doubtless, incomplete. It includes. Table l Sumbers of vinyl chloride related cases of angiosarcoma of the liver by date of death Period 1955-9 I960-* 1965-9 1970-4 197J-9 1980-4 1955-84 No of deaths 2 4 9 12 46 Ji 115* Three men diagnosed in 1980--* were still alive ai I January 1985. 750 vw 000000405 Exposure to vinyl chloride and angiosarcoma of (he liver 751 Table 2 Numbers of vinyl chloride related cases of angiosarcoma of liver by age at diagnosis Age lytarsl 35-39 40-a 45-->9 50-5* 55-59 60-64 65-69 70-74 All ages No of cases 11 24 17 IS 20 17 8 5 118 however, all the cases known to the collaborating organisations and they will probably have been informed, in one way or another, about nearly all cases that have been diagnosed among the relevant groups of employees. Results Until the end of 1984. 118 men had been recorded as having vinyl chloride related ASL, of whom three were still alive on 1 January 1985. AH the cases had been confirmed histologically: 117 were reported to be hepatoangiosarcomas and one a choiangios&rcoma. No cases were recorded in women, but few women have been employed in manufacturing PVC. Table 1 shows the breakdown of the cases by date of death. .It should be noted that the register was begun in 1974 when vinyl chloride first became firmly established as a risk factor for ASL. Under-reporting is. therefore, less likely to .be a problem after this date when special attention began to be paid to the disease. Table 2 gives the age distribution of the 118 men at the time of diagnosis. The mean age at diagnosis is 52. Table 3 gives the number of cases diagnosed and the number of PVC producing factories in each of the 12 countries reporting at least one case of ASL. Some countries have had cases in most of their factories (France. West Germany); others have had cases clus tered in a small number of factories (United States, United Kingdom). Indeed, the United States has had 23 of its 33 cases in just two factories. Other countries that produce PVC but have not reported any cases are shown in table 4. Table 5 shows the numbers of cases by time since first exposure and maximum exposure lime possible. It seems that the incidence of ASL reaches a peak 20-29 years after first exposure but substantial num bers of cases may still occur after more than 30 years. The table also gives hypothetical numbers for expected new cases based on the distribution of cases in men who could have experienced the maximum latency period. These calculations show that the occurrence of vinyl chloride related ASL is not yet at the halfway stage and one might reasonably expect another 150 cases or so with an unknown number of further cases occurring 35 years or more after first exposure. Table 6 shows the principal occupations of the 118 affected men. At least 43% of the men (51/118) had been employed as autoclave cleaners, an occupation that has been thought to have necessitated the highest exposure to vinyl chloride monomer. Discussion The reassuring feature of these results is that the num ber of cases on the register is so small, and. in partic ular. that only 80 new cases have been diagnosed since 1975. despite the large size of the industry. In the decade 1975-84, 19 cases were registered from the United States and seven from the United Kingdom. In men aged over 15 about 3300 deaths a year are attributed to all types of liver cancer in the United States and about 550 a year in the United Kingdom. Many of these cancers are probably sec- Table 3 Distribution of vinyl chloride related cases of angiosarcoma of liver by country. (Number offactories with three or more cases in parenthesest Country .Vo of cases No of factories reporting cases Totai No of factories making PVC Pre-1974 Pre-)964 Capacity* in !9'2 United Stales W Oermanv France Canada United Kingdom Sweden Italy Yugoslavia Czechoslovakia Japan Belgium Nonsav All countries reporting cases 35 26 18 10 9 5 4 4 * * \ 118 10 131 6 (31 5 43) i ID 2m 1 (1) 4 ( --! 1 <l) l 4--1 1 4--) 1 <--1 1 1-) 34(13) 44 9 7 4 7 11 3 l 31 I 122 28 7 5 3 4 l 7 1 16 l 1 76 'Capacity in ktlolonnes pvc production a year (Information supplied by 1C! and by recipients of the register!. 2090 1155 627 88 so: 105 778 60 48 1694 195 65 9462 vvv 00QG0042X 752 Forman. Bennett. Stafford, and Doll Tabic 4 Countries with PVC factories operational before 1974 with no cases reported to register Country Total h'o of factories Pre-WU Pee-1964 Western Europe Austria Finland Greece Holland Portugal Spain Switzerland Eastern Europe Bulgaria East Germany Hungary Poland Rumania USSR South America Argentina Brazil Chile Colombia Mexico Peru 1 1 1 T 4 1 , 2 1 2 5 3 3 21 2 S 1 1 -- -- 1 1 3 f _ T i 4 1 3 2 -- -- 2 -- Source: information supplied by 1CI and by recipients of the register. ondary liver cancers originating in other organs, par* ticularly in men over 60. but if this is ignored it appears that only about 0-06% of liver cancers in adult men in the United States (19/3300 x 10) are attributable to vinvl chloride and about 0*13% in Britain (7/550 x 10). Two pieces of evidence suggest that an extremely high exposure to vinyl chloride may be needed to induce ASL. Firstly, the fact that so many of the cases were among men working as autoclave cleaners in which the highest exposures are thought to have occurred: it was in these jobs that employees some times became faint and unconscious before the 1960s. when the main concern about vinyl chloride was its narcotic effect. Secondly, in some countries there is a remarkable clustering of cases into a small number of factories. This suggests that the working conditions and hygiene standards varied in different factories. Fifteen of the 16 Japanese and 19 of the 28 United States factories operating before 1964 have reported no cases, and it would be helpful if it could be shown that the exposures in these factories was appreciably less--unless, of course, the number of employees in these factories were all very small. It is the rarity of this tumour that has enabled its rapid identification as an effect of exposure to vinyl chloride. Baxter et al have calculated that the back ground incidence of ASL in the United Kingdom is between two and seven cases a year--that is. cases unaitributable to exposure to vinyl chloride or to tho- rotrast, the other established aetiological agent.7 That being so then the seven industrial.cases in the decade 1975-84 represent an increase in the national figures of between 10% and 35%. The mean induction period (time from first exposure to initial diagnosis) tor me ns caiCS is years. Most cases have occurred 15 to 29 years after first exposure as is common with occupationally iBdmxrUannrrs. There are also, however, substantial numbers ofcascsoccumng after longer time intends. 18 having been diagnosed 3Q or more vgars aftgr_6rcr exposure. This means that new cases are likely to diagnosed well into the 1990s even if it is assumedlh exposure* u/ffi.gnifiganilv in thi when the first major, improvements in standards of hygiene were made. The mean induction penod of the cases currently on the register (22-6 years) must there- Table S Cases of vinyl chloride related angiosarcoma of liver tabulated by years from first exposure to vinyl chloride la diagnosis and rears to 31 December 1984 (maximum possible latent period), fNumber ofcases expected to occur shown in parenthesesm) ________________________________________________________ Years from first exposure to Ji Oecemoer 1964 Years from first exposure io date of diagnosis 5- 10- 15- 20- 25- 30-34 Total within 35 years 35 or more >35 30-34 25-29 20-24 1J-19 0-14 Total 2 1 10 12 7 32 i t 4 12 7 3 (+ 4) 27 < 4- 4) 3 10 $ 4 (+9) 0(4-101 25(4-19) 4 IS 2(4-25) 0 (4- 29) 0(4-22) 21(4-76) __l 2 2(4-7) 0< + 1?) 0( + 18) 0(4-14) 5 14-561 0l+T)t 1 12 * 32(4-7) 32 ( + 421 23 ( + 56) 10(4-50) 110(4-155) if*-): Number of cases expected to occur calculated by comparing proportion of cases in relevant years since first exposure category lor previous time penods with proportion in other categories--tar example, for 25-29 years since first exposure and 25-29 years maximum latency expected: As four cases have already been diagnosed, another nine may be expected. ___ tNumbcr o( new cases to be expected among workers who had less than 15 yean since first exposure at 51 December 1984 will be dependent on whether the hazard of vinyl chloride was eliminated in the late 1900s or in ihe mid-1970s. In the former instance no esses would be expected, in the latter a number approaching the 01 cases protected for those with 15-19 years since first exposure by the end of 1984. tit is virtually impossible to estimate the number o( expected new cases 35 or more years after first exposure. Wy 000000403 Mr. R. A. Conrad March 13, 1986 Page Two Thank you for your cooperation in this matter. questions, please call. Sincerely, Should there be WHDsaa File: 12.40.5 Willvstfin. Davis Chief, LESHAP Unit Wv 00ooo*04 I