Document XOpXk1bzqQm9eKEBEV54da0LR

May 30, 1974 EPA Action ^ Vinyl Chloride Mr. F. L. Biasinger This information from Durham tends to confirm your message to me* If press release occurs today, June 6 or 7 timing may be in error. EWC/cm Attm. cc: Mr. D. H. Bradford, Jr. r `.jgriia&j EAsa? Callous E. W. Callahan AS 1 000017063 ALLIED CHEMICAL CORPORATION MEMORANDUM May 30, 1974 A. J. von Frank E. w. Callahan W. s. Ferguson J. M. Quinn w. L. Sullivan SUBJECT: EPA Action - Vinyl Chloride (Dictated by phone 8:30 a.m.) It is expected that on June 6 or 7 Russell Train of the EPA will hold a press conference reporting on EPA activity to de fine necessary controls for vinyl chloride. Reportedly, EPA sampling adjacent to monomer and polymer plants has indicated "high concentrations of viny chloride. Word is that Train will condemn industry as not having taken sufficient steps to control vinyl dis charges and states that concentrations arc well-'--------those which would be indicated by emission survey data. He will use vinyl chloride as an example to Congress as to why the Toxic Substances Act should be passed. At the present time, the vinyl chloride investigation lead rests with the Office of Toxic Substances headed by Schweitzer The EPA believes that the primary problem is in the air area and, as such, the Durham offices will be given the lead position. Ac tion by them will be: a) Visits to key monomer and polymer plants to conduct actual testing and obtain industrial estimates of emission levels. A contractor (Houdry) will assist. b) Houdry will determine the cost for air pollution controls. c) The EPA will determine the level of control needed. At this time, their preliminary thinking will be based on achieving a concentration of ^60 ppb. d) The EPA Strategy for Air Standards Division indicates that vinyl chloride would be cited as a hazardous pollutant with the establishment of Federal emission standards being proposed within three weeks. The Houdry study is being managed by L. Evans of the EPA and it is expected that Allied will be one of the firms contacted. There is some concern that high fugitive losses of VCM could lead to the establishment of an ambient air standard. However, this is doubted. A.S I 000017064 EPA Action - Vinyl Chloride Page 2 May 30 , 1974 Fence line testing by the EPA i n several regions has shown "high" (?) levels of vinyl chloride . Levels may be on the order of 2-10 ppm and are far in excess o f what would be calculated by the dispersion equations. However , this is understandable because of the high molecular weight of v inyl chloride and the normally short stack heights used as emis sion points. The writer's experience has shown that it is most diff icult to disperse vinyl chloride. It may travel at ground levels for distances of several hundred yards before being dispersed, Th e regional EPA representatives are meeting in Atlanta next week to submit preliminary contro recommendations in time for Train's news conference on June 6 or 7. MCA activity in the vinyl chloride area has been limited primarily to the OSHA problem. There is feeling within MCA that the vinyl chloride problem does not cover enough of the member com panies to mandate strong MCA response. There have been a consider able number of statements made that the SPI should be the umbrella for industrial activity. WMR/j sp L() .! \ 1 - ' W. M. Reiter AS I 00001 7065 ALLIED CHEMICAL CORPORATION MEMORANDUM May 31, 1974 (OK. TO: E. W. Callahan W. s. Ferguson J. M. Ouinn W. R. Jochem T. n. Kent II. J. Wallum J. Kaiser H. Shanahan R. Cornell (Attn. P,,. J. Curtis SUBJECT: Information For Use in Responses Resulting From ERA Announcement on Vinyl Chloride__________ At 10:00 a.m, today ERA, Washington, D. C., made a Press Announcement (copy attached) which is the opening step in their campaign on vinyl chloride. In the ensuing weeks they will charge industry with being derelict in its control. The attached statement is designed for use by the plant, community relations personnel, technical and manage ment personnel at Morristown site in the event of press inquiry. AJvF/jsp Attachments: (2) /I A. J. ;yon Frank ASI 00001T066 Vinyl Chloride - EPA Allied Chemical Corporation manufactures vinyl chloride monomer at its Baton Rouge location. We have operated in close accord with Governmental criteria on emissions of vinyl chloride with respect to both employee exposure and exposure of our neigh bors. Pwe have reacted promptly to the change in direction by the Federal Government on worker exposure. Prior to April 5, 1974, the permissible ceiling figure of 500 ppm was the Federal occupa tional health standard. On April 5, OSIIA reduced this standard to 50 ppm in the face of information supplied by industry.! Our plant testing indicates that' levels in excess of the lower figure were seldom experienced. j4 f a^.^ps, ~Air Pollution controls for this chemical are a matter on which we have been working with the State of Louisiana and the Federal EPA for some time jmder the broader title of reactive hydrocarbons.) This activity culminated in a schedule of engineering work designed to eliminate emissions from all significant sources. ^This schedule was sent^ to the State of Louisiana and the Federal EPA on May 24. We feel that this extensive activity has been responsive to Governmental direction. We can find no evidence of exposure of the general public to hazardous levels. Careful examination of our water borne wastes reveals no detectable quantities of vinyl chloride AS I 000017067 FOR IMMEDIATE RELEASE EPA Contact* I Mr. Arsht (202)755-0496 Mr. O'Neill (20^755-0344 EPA Requests Vinyl Chloride Data From Manufacturers MAY 31--The Environmental Protection Agency has requested "process, emission and air quality data" from the 27 U.S. manufacturers of vinyl chloride a gaseous chemical, and polyvinyl chloride, a plastic derived from the gas. The information is being sought from 14 vinyl chloride and 35 polyvinyl chloride plants operated by those 27 companies. EPA said in letters to the manufacturers dated May 30, 1974, that the Agency is "gathering information for `possible use in the development of air pollution control standards for vinyl chloride in accordance with the Clean Air Act of 1970." EPA is now taking atmospheric samples near polyvinyl chloride and vinyl chloride plants to determine amounts of the gas present in the ambient air. The monitoring data will be available to the public as soon as it has been processed and verified. At present, no Federal air pollution control standards exist for vinyl chloride. The EPA request for information from the manufacturers covers three areas: -more- ASI 000017068 '( , r -2- v `i ' AW 1) Identification of emission points in the manufacturing process and the amounts lost from those points. The identification of emission control procedures that have been or could be instituted and an evaluation of their effectiveness are also being sought. 2) Cost and economic data including the capital and operating costs for each emission control device or procedure. 3) Ambient air quality data which ha3 been collected by the manufacturers near their plants. EPA is requesting the information under the authority of Section 1.14 of the Clean Air Act., which enables the Agency to develop data needed for standard-sotting pursuant to the Act. Vinyl chloride ha3 been implicated in 19 world-wide cases of a rare but fatal form of cancer, angiosarcoma of the liver, among workers engaged in the conversion of the chemical to poLyvinyl chloride. Similar cancers also have been produced in experiments exposing rats and mice to vinyl chloride. In both cases, exposure to vinyl chloride gas occurred repeatedly over extended periods of time. Today's action follows several steps already taken by EPA in an effort to protect the public from the potential adverse effects of vinyl chloride. -- February 14 , 1974 , Administrator Russell E. Train formed an internal, task force to assess the overall environmental impact of the chemical. -- April 5, 1974, EPA notified the producers of all pesticides with aerosols containing vinyl chloride of the need to substitute another propellant. I* ASl 000017069 ' .f -- April 10, 1974, EPA Regional Administrators were asked to assess the extent to which vinyl chloride is escaping beyond the confines of the polyvinyl chloride production facilities in their regions. -- April 17, 1974, EPA released the brand names of 20 pesticides containing vinyl chloride. -- April 24, 1974, EPA suspended from sale and requested a recall of all pesticide aerosols for indoor use containing vinyl chloride. Based on the April 5 notice and a follow-up of April 30, all of the manufacturers of pesticide aerosols containing vinyl chloride either have substituted or are now in the process of substituting an alternate propellant. ### Companies coni'.acted by EPA; Air Products Chemicals, Inc. ^American Chemical Corp. Borden Chemical, Inc. Continental. Oil Diamond Shamrock Ethyl Corp. Firestone Plastics General Tire & Rubber B.E. Goodrich Chemical Co. Goodyear Tire & Rubber Great American Chemical Co. Hooker Chemical Keysor-Century Corp. Monsanto National Starch & Chemical Co. Olin Corp. The Pantasoto Co. of New York, Robintech, Inc. Stauffer Chemical Tenneco Chemicals Union Carbide UniRoyal, Inc. Inc. Allied Chemical Dow Chemical Monochem, Inc. PPG Industries, Shell Chemical Inc. ASI 000017070