Document YGXXbMJXN9k2RMV64xNkpEdGn

TO: Environmental Coordinators jet: )(f- f*F ________________ FROM: DATE: Interoffice Communication SUBJ: T. G. Grumbles February 8, 1989 PROPOSED CMA RELEASE REDUCTION POLICY AND PROGRAM VISTA Attached is material regarding a release reduction policy being proposed, or formulated, by CMA. A briefing meeting is being held March 1 in Washington to present the attached and begin receiving member company comments. Please review the attached and let me know if you have comments on the attached drafts and/or would like to attend the meeting. I plan to attend the meeting. Please give me any comments by February 24. T. G. Grumbles dlj .520 Attachment cc: Plant Managers - R. W. Seymour-ABER, L. R. Bauer-BALT, G. D. Williams -BLANE, J. B. Maher-HMD, J. Friend-LCCP, J. W. UareLCLAB, R. A. Conrad-LCVCM, H. D. Garrison-OKC, P. L. Foote-PREM J. A. DeBernardi, T. H. Huffman, R. D. Gamblin VVV 000006769 ^TYjoW; & ') rT^Gr. \jjUcQL FEB 11989 'U-cF CHEMICAL MANUFACTURERS ASSOCIATION January 30, 1989 TO EXECUTIVE CONTACTS OF CMA MEMBER COMPANIES Dear Executive Contact: Subject: Member Company Comments on Proposed CMA Chemical Release Reduction Policy and Program -- March 1, 1989 Briefing The purpose of this letter is to urge the attendance of your senior environmental, health, safety and legal managers at a March 1, 1989, briefing on a proposed major new CMA program concerning Title III, Section 313 releases. The proposed program encourages CMA member companies to increase their efforts to reduce releases to the environment and to increase the understanding of health effects from these releases. Public policy debates on Section 313 release inventories are anticipated to gain momentum when EPA releases its computerized inventory later this year. This new program will position the industry in a positive light for any follow up debates. The proposal is the product of an intensive six month process involving health, safety, environmental, government relations, legal, and communi cations experts from the member companies, with careful oversight by the Executive Committee and Board of Directors. The proposed voluntary policy and programs, built upon CMA's existing air quality policy and waste minimization program, are crafted to respond to immediate public concerns focused on the Section 313 release reports and to demonstrate industry leadership. To assist you in preparing for the briefing, I am attaching a copy of the proposal. Please treat these materials as confidential. CMA's Environmental Management Committee will evaluate comments and make revisions over the next two months and make a final presentation to the Board of Directors in April. The March 1 briefing is designed for senior environmental, health and safety, and legal managers, to review the proposed policy and program, discuss the relationship to other CMA initiatives, its implementation, communication strategy, impact on local operations, and to provide opportunities for attendees to ask questions. A tentative agenda is enclosed. The briefing will be held at the Ramada Renaissance Hotel, 1143 New Hampshire Avenue, N.W., Washington, D.C. (202) 887-0800 beginning at 9:00 a.m. A block of rooms has been reserved for those who will arrive the night before. (When making reservations refer to RR #392. The cut off date is February IS, 1989.) 00000677o 2501 M Street. NW. Washington, DC 20037 202-887-1100 Telex 89617 (CMA WSH) Executive Contacts January 30, 1989 Page 2 To assure that all member companies will be accommodated at the special briefing, I am requesting that you designate no more than two represent atives to attend. I would appreciate your contacting David W. Carroll's office (202/887-1185, Ms. Stephanie Henry) to advise who your representative(s) will be for the March 1, 1989, meeting. We ask that each attendee bring a check made out to CMA in the amount of $30.00 to defray the costs for continental breakfast, coffee break, and the meeting room. If you have any questions on this natter, please contact David W. Carroll, Director, Environmental Programs, (202) 887-1164 or Ann M. Mason, Associate Attachments cc: Environmental Management Contacts Health and Safety Contacts Responsible Care Coordinators Title III Contacts CAER Coordinators Legal Contacts Washington Offices State Contacts VVV 0000067T1 TENTATIVE AGENDA PROPOSED CHEMICAL RELEASE REDUCTION POLICY AND PROGRAM BRIEFING MARCH 1, 1989 7:30 9:00 a.m. Registration and Continental Breakfast 9:00 9:15 Introductory Remarks - R. A. Roland, President, CMA Section 313 Impact and CMA's Responsible Care Program J. Holtzman, Vice President-Comrounications, CMA 9:35 Draft CMA Chemical Release Reduction Policy - C. T. Seay, Chairman, Environmental Management Committee 9:50 Questions and Answers 10:15 Break1 10:30 Programmatic Support Proposals Regional Monitoring and Modeling - R. Bradford, Leader, ad hoc Chemical Release Reduction Group e Health Effects Evaluation Program - R. Van Mynen, Vice Chairman, H&SC Smaller Company Assistance - R, Bradford Communications Program - J. Holtzman 11:15 Questions and Answers 11:40 Concluding Remarks -- C. T. Seay 11:45 noon Adjournment VVV 000006772 CHEMICAL VKTXAXK agpocnOH POLICY CMA will promote, nmniif its member companies, practicss that protact tha safety and health of employees and residents of cosonitles In.which they operate. Oar Industry's p>d is to assure that employees and communities are not adversely affected by oar operations and to encourage others, including our suppliers and customers, to achieve the sane goal. CMA understands the public concern regarding health effects froa releases into the environaent. CMA also believes better information on the effect of these releases is needed to assure fully Informed action by government, industry and the public. CMA member companies will Increase their efforts to reduce releases to the environaent and to increase the understanding of health effects froa thess releases. Existing industry activities will be consolidated to bring focus to this effort so that the industry's performance will be improved and the industry's eargin-of-safety will be increased. This CMA policy, recommended for Implementation by each aaaber coapany at each of its operations, includes the following elements: 1) Using SARA Section 313 reports as a base, inventory existing releases to all media. Chemicals other than those covered by Section 313 will be included as appropriate. 2) Establish priorities for the inventoried releases based on factors including their potential impact and tha level of community concern. 3) Foraulate a release reduction plan, based on this ranking, to increase the current margin-of-safety, increase operation efficiancy, and address areas of public concern. In the plan, transferring releases froa one media to another should be used only if the overall volume, toxicity, and environmental impact ia reduced. Reductions may be achieved by any of the following methods, but it is recognized that such reduction efforts are listed in declining order of desirability and member companies will direct their efforts accordingly: i) Source reduction 11) Recyele/Reuse ill) Treatment to reduce volume and/or toxicity before relume or disposal. A) Initiate a system to report release reduction progress. 5) Coaaunicate overell plane and progress to employees and the public. In addition, to increase understanding of tha efforts of chemical rslsases, CMA will work to better determine the concentrations Of: chemicals in the environment and the health effects of such chemicals. Finally, in implementing all of the above, CMA will foster assistance to smaller plants and companies. VW 000006773 CMA EC 1/17/89 REGIONAL MONITORING AMD MODELLING PROJECT fOMnnrjvrn JWiii . w 2 * i i PROJECT RACTCBOUND The public perceives that no neasurensat data exists on Section 313 ehsnicals released to the air, surface water, or groundwater. Therefore, they believe "toxics" are a health threat. United nooltorlng data indicate Im* there are very snail concentrations of chanicala in connunitlea. EPA and others have indicated that the general air quality is inprowing. The objective of this project is to proactively obtain wore data to confine that Section 313 chenleals generally do not pose a risk to ecnnmltias. In addition, it designed to achieve a secondary benefit of getting onblaat data systens In place to nonitor progress. The project proposal focuses on air issues as the initial priority with possible subsequent phase in of surface and groundwater progress to assure a uulti-nedia perspective. The project will provide for date collection using regional air dispersion nodelling to predict hotshots tnd optimise tbs location of a nininun of five to tea nonitors per ssapling location. Five to ten target regions are reeonaended as the nininun level of effort. OPTIONS CONSIDERED Three prognostic levels of activity wars considered. The first alternative is s base case that supports Options 2 b 3. Option 2 places the local CIC's in the leadership position but the bulk of the total cost still oust be assuaed by the local industry. Considering CHA's budgetary constraints, this is the reeonaended option. Option 3 creates a new area of activity for CMA, and carries a high prieetag, although it delivers the nssianin leverage, visibility, and credibility. 1. Base Case Gather available data into a central reference systaa (e.g., Houston Regional Monitoring Network data. Bay Area Air Toxics Study,SPA Indoor air study, and volunteer data acquisition by nenber conpaaiea). This central reference aysten on uonitored data can be supplenented with a CMA regional dispersion aodel and a CMA regional ssapling protocol. Developaent of the nodeling/aonitorlag protocols will cost about $50,000. Protocols can be developed by contractors by June 1969. The data gathering effort will cost approximately $50,000. 2. Proactive CIC Activity Replicate the Houston Regional Monitoring project, or nodifled approaches, in priority areas through CMA leadership. Local prograns will be conducted by consultants with local industry financial support and technical direction. This option places the entire financial and manpower burden on local industry and la probably United to those vvv 000006774 FIDENTIAL areas with existing, active CIC's. Data gathered in this way eay have less credibility because the public perceives that It Is "industry" generated rather than, a cooperative effort lead by rn--imlty leaders. The total costs fron local Industry for significant nodelling/nonltorlng prograns typically will be In the range of $500,000 to $1 nillion per region per year. Top down nanag--ant aupport fron Qtt nenber conpanies will be necessary to establish regional aonltorlng prograns under this option. 3. Proactive OlA Activity with Kconosiic and Hmmemmr teveraae Using the Houston Regional Monitoring Network as a working nodel, CMA can offer Batching grants and technical assistance to atate and local agencies, CIC's, or foundations and coBBisslons to establish and carry out regional air nonltoring prograns keyed around significant 313 releases. Funding will be leveraged and industry will be visibly involved in assuring valid data collection for prograns proposed by the local coBBunitles. Under this option, CMA will cover at lease a third and possibly nore of the total cost for at least the initial year. CHA's direct cost will be approxlnately $1 to $3 Billion dollars for the initial year. MULTIMEDIA TOTAL PROGRAMS Groundwater and Surface Vater prograns can be introduced on a delayed tine line. 1. Groundwater Support state wellhead protection prograns through partnerships with local government. Local industry sight provide data and technical expertise, l.e., temporary locals of hydrogeologists, for exanple, as well as grant noney for groundwater nonltoring within the wellhead protection progran. This program is not currently funded at the Federal level, yet the States are anxious to protect their public water supply as suggested in the 1986 Safe Drinking Vater Act Anendnents. 2. Surface Vater Provide grants to organizations, such as, the Chesapeake Bay Foundation, The Mississippi River Coalition. Surface water quality could be nonitored in the innediate area of nenber-company facilities to supplement State nonltoring efforts. CMA SC 1/17/89 BD 1/18/89 VVV 000006775 '\ : CONFIDENTIAL SUPPORT INFORMATION FOR REGIONAL MONITORING MODELLING 1. Target Areas for Regional ModalHw>/Han<tarin> tatODy TX Baton Rouse* LA beater New York/New Jersey Philadelphia, PA Buffalo/Niagara Falla, NT Bay Area District, GA South Coast (Los Angeles) District, CA Chicago* IL Kanawha Talley, W Washington* DC (control) 2. Houston Regional Monitoring The Houston Regional Monitoring Corporation (RRM) was foraed in 1979 by local area businesses to obtain anblent air monitoring data for the criteria air pollutants. Eleven (11) aonitoriag stations were established. The primary purpose of HRM was to enable companies to satisfy Prevention of Significant Deterioration (PSD) permit application requirements. Since its inception, the focus of data collection and analysis has shifted to meet chcng*ng needs. Collected osone data, in particular, has been very useful to industry and the State in evaluating air quality, the effects of various emission sources and controls, and the significance of monitor placement. In 1967, the HRM's focus was expanded to include collecting ambient air concentration data for about 170 specific chemicals. Including many SARA Section 313 chemicals of concern. Samples are obtained for a 24-hour period every sixth day at six existing monitoring stations covering about 900 square miles. This monitoring is intended to assess long-term community exposure to these substances In outdoor air. During each sampling period, a 15-liter canister is filled at a rate of 6 cc/nin, and then the canister is transferred to the Radian Corporation for analysis. Extensive QA/QC procedures are employed. Meteorological conditions are recorded for each site to support assessments of the data. The cost of this targeted monitoring is approximately $60,000-100,000/station/year. The monitoring stations axe operated by Radian Corporation, end the entire HRM effort is supported by member-company contributions of about $50-$60 per manufacturing employee. 3. Baton Rouge Area Ambient Air In early 1968, several companies in the Baton Rouge, LA, area initiated an effort to better understand the ambient air quality in the Baton VVV 000006776 CONFIDENTIAL Rouge stm and the affect of talas ions on six quality. The effort included short-tan aabltnt sir stapling end analysis fay Radian Corporation and aodaling by Trinity Consultants. Hie total cost is expected to be approximately $130,000. Monitoring consisted of the collection of 24-hour coaposite staples at four (4) locations for three (3) consecutive days at each site and included significant QA/QC procedures. Total cost for the 12 staples, analyses, and QA/QC, including setup of the teaporary aonitorlng station, vas $65,000. The stapling and analytical procedures were the sane as for the ongoing HRH project. Modeling consisted of dispersion calculations for the ealesions of 17 substances froa 13 area facilities. In addition, the (SMS aodel vas used to estivate exposure and risk in the area for too of the substances. Total cost of the noddling effort is about $65,000. On-site personnel involved in the interpretation and use of the aonitorlng nodeling data with Interested public consider the aonitorlng data to be aost believable and, therefore, the aost useful. 4. Patrochaaical Comp lax Monitoring fTltKf,> In early 1988, enhanced Industry Hygiene (IH) collection tube aonitorlng techniques were used to obtain aabient air quality data for eight VOCs in the vicinity of a najor petrocheaical coaplex. Hie enhanced techniques were capable of quantifying low ppb concentrations of the substances. Sampling was conducted at eight locations with seven 48-hour coaposite samples obtained at each location over a three-week period. Total cost for sampling, analysis, and QA/QC was $50,000. Based on the success of this effort, the same technique has been employed at other locations. Dispersion noddling is now being initiated In the area to estimate the aabient contribution at 400 receptor locations of ten cheaicals. Froa 200 amissions sources at five facilities, the nodding cost is estimated at $25,000. <2fA EC 1/17/89 BD 1/18/69 VVV 000006777 CONFIDENTIAL Options rat community HEALTH m'EC-rS EVALUATION PROGRAM BACKGROUND The Ad Hoc Ch--leal Reducti-- Work Group, and the Health and Stfity CoittM have dtrtloptd eight options for responding to the public's concern about exposure to eh--icsl releases. These options are pres--ted to help Id-tlfy the nost b--eficlal coarse of action for inpl--anting this progr-- el--nt. Evaluating the effect of ch--leal exposure on ca--ity health la central to addressing the public's concern about chenlcal releases. Clear and widely accepted --thods to id--tlfy acceptable levels of exposure are ess--tlal to explain the maiming of Title III, release reduction, and waste minimisation data. After a discuss!-- of all options, the consensus of the Ad Hoc Vork Group, and the Health and Safety Co--ittee focuses increasingly -- CMA sponsoring the develop--t of consensus --thodology(s) at -- organisation such as CUT. (See Options 5 and 6 below.) The cost of pursuing this option is approximately $250,000. The longer tern application of the consensus --thod(s) by other groups to s wids variety of substances --tails additional costs. PROGRAM DESCRIPTION: The Co--unity Health Effacts Evaluation progr-- seeks to identify --thods to eharacteriza exposures of the g--ersl public to ch--icals. The effort will work to id--tify existing --thods to determine safety, and to inpxova the existing state of scl--ce in determining safety. Moreover, the progr-- will work to improve the public acceptability of the measures used to Judge safety. PROGRAM OPTIONS? Options considered for the progr-- are listed in their order of resources required: Option 1: Incamra-- Govern--t Action. Safety la a --tter of public perception --d acceptabi1ity. Industry's activities will always be suspect and CMA should --courage governwant regulatory agencies to sat safety standards. Until standards are set, industry will use existing measures to judge safety and explain these to the public. Option 2: grTTTr*IT PMa*rrtl Industry could --courage research by government agencies --d universities to improve --thods by which to judge safety. OOOGO6778 VVV Sueh rocottrayant will only be suggestion* that this is a serious 1ud that needs attention. Option 3: Fond Research. Industry could fund research by universities, national laboratories or consultants to laprove aethods by which to Judge safety. Option 4: Build on CHAf s Inforaatlon values. for Comity CMA could ermine the coaaunity exposure values obtained throng its Inforaatlon exchange progran. Consensus areas could be identified, and a needs assessaent and feasibility study could be done for future work in developing exposure values. Option 5: Develop Consensus on Methodology(s'). Industry could further develop consensus on nethod(s) by which to establish coaaunity exposure values. The aethod(s) will not be applied to specific cheaicals, but published in the scientific literature for use by individual coapanles or governaent agencies. The application of any aethod to specific cheaicals will often require the developaent of additional data on that substance to fora a scientific decision. Option 6: Fund an Independent Organization. The chealcal industry could fund an outside organization, sueh as CIIT, to develop and apply a aethod for setting coaaunity exposure values. Option 7: Industry Could Develop and AppIv a Methodology for Setting Coaaunity Values. An industry group could develop a aethod for setting coaaunity exposure values. This aethod and data on specific cheaicals could then be turned over to a standard setting organization such as AIHA, ACGIH, ASTM, or SPA. Option 6: Fund an Twriertendant Expert Scientific Panel to Develop and AppIv a Methodology for Setting Coaaunity ` Exposure Values. The eheaieal industry could fund an independent expert scientific panel, through a university research center or national laboratory, to develop and apply a consensus aethod for setting coaaunity exposure values. The aethod and values will then be aade available to standard setting organizations. VVV 000006779 wrwctth RKQDIItKMgNTS CONFIDENTIAL Cotta: Coitt will vary dtptadini on th options atltcttd. Coots rn| fron nothing for option lv to $30,000 * $50,000 for option 4, $250,000 for options 5, 6 and. 7, and $600,000 for option 6. Tins: Depending on tha options sslsctsd, Inpl--sntatlon coaid take two to five years. Tha tins required depends greatly on the resources devoted to the project. Option 6, for Instance, will require 2 years while option 1 will depend on the speed with which regulatory agencies act. Options 5, 6, end 7 will require one year to develop consensus nethod(s) with additional tine required for application to specific substances. CMA EC 1/17/89 BD 1/18/89 VVV 000006780 CONFIDENTIAL ASSISTANCE TTl BMAT.TJttt COMPANIES PROJECT BA tike member companies of CMA ere committed to the successful implementation of both the letter and the spirit of Title III. However, Mny smaller coapsnles ere having difficult time Implesentins hey components (emergency planning, eccldent prevention, emission reporting, etc.) of the law. Poor performance by any company, smell or large, nay affect the many positive proactive measures made by CMA member companies. CMA member companies should provide technical assistance to their customers and smaller companies to enhance overall environmental, health and safety programs. OPTIONS CONSIDERED AND RECOMMENDATIONS The following options were considered to assist smaller companies with their environmental, health and safety programs. The sentiment of the work group is that an implementation strategy that combines several of these options will be the most effective. 1. Member companies will communicate to and provide direct assistance to smaller companies through existing product stewardship programs. - Mail information packets - Invite customers in for training - Send technical service representatives out to customers CMA will work with the Council of Chemical Association Execu tives, U.S. Chamber of Commerce, State Chemical Councils and other national organizations to develop communication pieces on technical assistance available to smaller companies and how to access the process. Approximate cost for CMA to implement the activity is $10,000. Communications regarding technical assistance to smaller companies will begin in early Hay. 2. Member companies and CMA, possibly using contractors, will conduct on-site training for companies in the following areas: - Vasts minimlzatlon/release reduction principles and methodologies - Process safety - Emergency planning and preparedness - Cownlcatlng with employees and the community yyy 000006781 - Public health issues. As an alternative, CMA and member companies will develop seminars/ workshops on a regional/local basis to provide information on the key issues highlighted above. They will be highly participatory and hands-on. They will use case studies presented by experienced plant personnel. The seminars will partially pay for themselves. CONFIDENTIAL *1though funds will bo needed to dtvtlop guidance materials in iom of the areas Mentioned (approximately $75,000). The workshops could be scheduled for late saner or early fall. The seminar/workshops will be developed and co-sponsored by: Individual member companies - State cheaieal organizations - CHA/other trade associations - Council of Chanical Association Executives. 3. Member companies could aobilixe their retirees to provide aany of the services listed above. There are aany unknowns Including personnel availability and interest, cost, and tlaing. Nevertheless, this option is worthy of further consideration. 4. CMA could establish a technical assistance hotline for saaller companies to call and request help. Ve recognise that each coapany requesting assistance will have different needs, pressures, and tins constraints. The hotline could coat approximately $170,000 per year (including staff) unless it can be consolidated Into an existing CMA service. The hotline will begin operation In July 1969. 5. Establish assistance programs with key universities whereby undergraduate and graduate engineering students assist smaller companies In their waste minimisation and release reduction programs. A team (3-4 students) could have a project (defined by the coapany) to work on for the semester. The final report will Include ways to minimise waste/releases and operational costs, and maximize effectiveness of Implementation plans. This process could be Initiated through state chemical organizations. Pro jected costs are not clearly defined at this time. CMA EC 1/17/89 B0 1/18/89 vw 000006782