Document aJEkrKNkQBzor1o6gYr8rOXg9

UNITEO STATES ENVIRONMENTAL PROTECTION AGENCY WA1MIM6TOM, D.C. 304M OFFICIAL IWMNtil ' FKNALTV FOR FRIVATK UK *MO AN KOVAL FFORYVNITV KMFLOVKR t-W- WjLu&r'' ^/e^RP^**^,TA.K ANO FKM FA IB VA I... -nVlRONMKMTAL FROTKCTION U (FA*M RECEIVED MAY 22 1974 R. R .WHEELER, JR, 1 O'Neill (202) 755-0344. Parkas (202) 755-0720 FOR^IM" MED'IATI E...R..E..LEASE- THURSDAY,~AP" RIL " 4, "1" 974 * EPA FORMS VINYL CHLORIDE TASK FORCE *i The Environmental Protection Agency has formed an internal task force to assess the overall environmental impact of vinyl chloride, a gaseous chemical, and the plastic, polyvinyl chloride, . Vinyl chloride has been implicated in. the recently reported .deaths of ten: workers at plants where the gas is used to produce the polyvinyl chloride. All died from a rare form of cancer, called angiosarcoma of the liver. The task force, chaired by Glenn E. Schweitzer, Director of EPA's Office of Toxic Substances, is charged with assessing possible environmental and health risks associated with the manufacture, distribution, and disposal of vinyl chloride and polyvinyl chloride. At present, the task force is reviewing, collecting and assessing data on 1) the ambient emission and effluent levels of vinyl chloride in air and water from vinyl chloride and polyvinyl chloride manufacturing plants 2) the environmental impact of all disposal methods for vinyl chloride and polyvinyl chloride wastes, including landfill, incineration, deep-well injection, and ocean dumping 3) ecological effects of vinyl.chloride in the environment. The task force plans to meet with environmental and consumer groups to discuss its mission and exchange information. A similar meeting has taken place between the.task force and the chemical industry. The task force is also working with other Federal (more) ftum (hta ah*** Kiwi* NOT th to raealw* ttilo material Q, or It chant* ot iMuw N wiNt Q (Indicate Chang*. Including tip corf*). ' KFA FORM 1110.1 IRKV, (JCC ' * 025812 2 * agencies concerned with vinyl chloride, including the Department of Labor; the Department of Health, Education and Welfare; the Consumer Product Safety Commission, and the Department of Commerce. Vinyl chloride is used as a propellant in 23 pesticid aerosols currently registered by EPA. The gas helps expel the contents from the pesticide containers. In a March 28 letter to the Health Research Group, a Washing D.C. based public interest organization, EPA said that it will shortly notify the manufacturers, formulators and distributors of these products of the need to substitute another substance for vinyl chloride* A copy of the letter is attached. The Agency said that, "Even though the health data for~ vinyl chloride are limited, we believe that it is prudent public policy for usoto request the manufacturers of these pesticides to make a voluntary change..." If a currently ongoing EPA evaluation of these pesticides indicates a substantial risk or imminent hazard to the us r, and if voluntary compliance has not been obtained, the Agency will, invoke suspension of the products or other enforceable remedies. On March 27, EPA mailed letters to the manufacturers giving them ten days in which to state any objections to the Agency's making public the brand names of the 23 products. This period for comment is required since the existence of vinyl chloride in the pesticides may be considered part of the products' confidential formulations. #11 ,R-417 (' xc*:^**.***<***$*} WffW ucc 025813 THE NEW YORK ACADEMY OF SCIENCES WORKING GROUP ON * TOXICITY OF VINYL CHLORIDE-POLYVINYL CHLORIDE "ENVIRONMENTAL CONCERNS BEIOND THE WORKPLACE" Glenn E. Schweitzer Director, Office of Toxic Substances Environmental Protection Agency ' 401 M Street, S. W. Washington, D. C. 20460 Presentation to the Working Group on Toxicity of Vinyl Chloride-Polyvinyl Chloride The New York Academy of Sciences New York City, New York May 11, 1974 "ENVIRONMENTAL CONCERNS BEYOND THE WORKPLACE" Glenn E. Schweitzer Director, Office of Toxic Substances Environmental Protection Agency Washington, D. C. During the past several months vinyl chloride has awakened all elements of the environmental community to the presence of the plastics Industry. In some respects it is fortunate that we have been alerted in a rather dramatic fashion to the need for greater attention to this important segment of our industrial base which will surely continue to expand in the years ahead. While this symposium is directed to the existing and potential risks involved in the manufacture, distribution, _ and use of vinyl chloride monomer (VCM) and polyvinyl chloride (PVC), many of the types of considerations and uncertainties that punctuate these deliberations undoubtedly characterize a far broader swathe of concerns over chemicals in general. Hopefully, we can extrapolate from our current experiences with VCM and PVC in identifying problems with other potentially important commercial chemicals early in their embry onic stage and thus minimize the economic dislocations attendant to corrective actions. Unfortunately, the proposed Toxic Substances Control Act has been lodged in a Joint Committee of the Congress for ten months. Thus, a very powerful tool for addressing the vinyl chloride problem, and similar problems with other chemicals. In an adequate manner Is not available to the Federal Government. We must rely on other statutory authorities and on the power of persuasion In our efforts to insure that our population is not being unnecessarily exposed to concentrations of VCM and other chemicals used in connection with VCM. It is particu larly distressing that until this statutory authority is on the books, the Federal Government will not be equipped -- in terms of experienced personnel and supporting resources -- to grapple with the intricacies of this type of toxic substance problem in a manner which will Insure full attention to the balancing of risks and benefits. Today I will report to you on the preliminary Investigations under taken by the Environmental Protection Agency during the past three months. We are still several weeks away from reaching even tentative conclusions as to what additional steps, if any, should be taken by the Agency concerning VCM/PVC activities. Our monitoring data are not yet UCC 025815 In hand. Similarly, our analytical studies are not yet completed. Nevertheless, we are pleased to share with you some of our initial thoughts. We will welcome your comments on the.efforts to date and on further steps which are necessary. In this regard, the prioritization of our efforts Is particularly Important in view of the speed with which this problem is evolving and the limitations on our resources. At the outset it is important to underscore that the progress made to date would not have been possible without the extensive cooperation of other federal agencies, industry, and environmental groups. We have profitted greatly from our discussions with these organizations, through our on-site industrial visits, and through constructive suggestions that we have received. EPA Regulatory Authorities To date EPA has exercised its authority in the pesticides area to suspend the use of vinyl chloride as a propellant in all pesticide pro ducts registered for indoor use in homes, food handling establishments,, hospitals, and other enclosed areas, with a mandatory recall of stocks in the channels of trade. In addition, in response to the Agency's request, all registrants of pesticides which are used outdoors have agreed either to withdraw their registrations or to amend them to provide for the substitution of another propellant in their products. We are currently investigating what regulatory actions, if any, are needed with regard to air emissions, water effluents, and solid waste disposal at facilities involved in VCM and PVC activities. In addi tion the Agency has responsibility in the areas of drinking water standards, ocean disposal, and municipal waste disposal -- all areas of some relevance to the VCM/PVC concerns. As previously mentioned a principal authority which is currently missing is the Toxic Substances Control Act. The requirements for reporting of Industrial production data envisaged in the Act would enhance our knowl edge of the types and extent of different uses of VCM. The testing pro vision would enable us to obtain much needed data -- and particularly data on toxicity and persistence -- for assessing the risks associated with low concentration levels of VCM, including those levels that are likely to persist beyond the workplace. The proposed regulatory provisions would provide a mechanism for addressing those products using VCM not now subject to regulation under other laws. Also, if considered appropriate, steps might be taken to limit the amount of unreacted VCM in certain PVC products which may eventually migrate out of these products to pose an unnecessary risk. r 2 ucc 025816 The Materials Balance EPA's Initial concern in this area centered on reports in February of a materials loss of six percent in the PVC production process. Our detailed investigations Indicate that these initial reports were in the correct range. Clearly, the percentage of losses will vary with the type of process, the age of the plant, the level of technology that is employed, and manufacturing practices. However, there is no doubt that in the United States substantial amounts of VCM -- probably exceeding 200 million pounds annually -- and large quantities of PVC -- probably exceeding 50 million pounds -- are being discharged into the environment during the PVC production process. Most of the VCM escapes directly into the atmosphere as air emissions, with lesser amounts dissolved in water effluent streams and entrapped in sludge and solid wastes. PVC losses occur as particulate in air emissions, suspended solids in water effluents, and components of solid wastes. Clearly, a principal area of VCM leakage is associated with the operation of the polymerization kettles, including losses when they are opened for recharging, cleaning, or sampling. Other losses occur during the transfer of VCM from tank cars to storage, during the drying process,and from leaks at a variety of valves, flanges, and pump seals throughout the process. Polymer losses are similarly distributed among a variety of activities Including dust collector losses, disposal of oversize particles, and sampling losses. The enclosed flow diagram for a typical suspension process reflects such losses which according to our estimates usually range from four to eight percent. In this regard two aspects are particularly significant: there are a variety of PVC processes with differing problems and control possibilities, and in every case the num ber of potential leakage points Is very large. For economic reasons and in view of the fire hazard from VCM,industry has always been concerned with reducing its losses down to a point. Now some plants are taking steps to reduce these losses further in view of worker and environmental concerns. We understand that the tightening up on maintenance and housekeeping activities can Indeed have a significant Impact, and several PVC plants reportedly are now operating close to the four percent level for total losses. The data needed for conducting material balance analyses during VCM production and PVC compounding and fabrication processes are less readily available. However, we do not believe that these activities pose as serious an environmental concern beyond the fence line of the plant, at least at the present time, as the polymerization process. At the same time in the absence of constant vigilance VCM losses to the atmosphere during the latter phases of the VCM production process and during trans fer to and from storage can be significant. Also, throughout the process there are many seals and valves which inevitably lead to leaks. With regard to compounding and fabrication, unreacted monomer is inevitably ; 3 ucc 025817 associated with the polymer following the polymerization process. In some cases this monomer concentration reaches 7000 ppm although a more representative level probably is in the range of 500 to 1000 ppm. Dur ing the mixing and heating processes in the compounding and fabrication plants, some of this VCM undoubtedly escapes into the environment. Now, in efforts to reduce further the level of unreacted VCM in the final product many companies are introducing new techniques which Increase the migration rates during this phase of production. The Need for Epidemiological and Toxicological Studies Since some elements of our population in addition to the plant worker are being exposed to some level of VCM, we must address the question: What is the risk of such exposure? In considering non-worker populations, we are confronted with a host of new unanswered questions. How relevant to this concern are the data generated for estimating worker exposure risks? Can meaningful extra polations be made from toxicological tests at relatively high dose levels, to the lower levels of the dose-response relationship? Can realistic extrapolations be made from intermittent exposure, which characterizes the past and present toxicological and epidemiological investigations (e.g. eight hours per day, five days per week) to sustained exposure at the same dose levels or at lower levels? Are synergistic effects that result from exposure to other chemicals as well as VCM influencing the worker's response to VCM, and are there similar opportunities for such synergism within a non-worker population? There are not sharp answers to these questions, and indeed they go to the heart of many of the fundamental uncertainties of the biological sciences. To date the epidemiological and toxicological data that have been generated have been directed almost exluslvely to concerns over workers. This Is the data base that we in CPA presently have available. I doubt that anyone Is more aware of Its Inadequacy than are those of us responsible for regulatory actions based on this data. Unfortunately, we often have no choice but to make judgemental decisions using whatever scientific information 1$ available. Other reports presented at this symposium review past, current, and future studies directed to VCM. While they will undoubtedly be helpful to our assessment of the environmental problem, from our point of view they are clearly not adequate in improving the basis for estimating non worker risks. Let me cite three examples of the types of studies tyhich appear to be needed: Epidemiological investigations of populations near chemical plants that are likely to have been exposed to low ambient levels of VCM over a prolonged period of time. It .Is the 4 UCC 025818 responsibility of Industry to support such efforts which will help clarify whether manufacturing activities pose a risk to neighborhood residents. At the same time we recognize the com plexities involved in designing and carrying out such studies, the advantages of drawing on governmental experience in this area, and the prototypic nature of such an undertaking. There fore, it seems likely that EPA will be prepared to participate in such efforts along with Industry and other interested parties. -- Toxicological tests at appropriate dose levels, with a suffi ciently large number of animals, and with appropriate exposures to provide the basis for meaningful conclusions concerning the likely health effects of VCM in ambient air near chemical plants. Such tests are clearly the responsibility of industry. Indeed, industrial responsibility for the testing of the safety of its products is a basic tenet of the Toxic Substances Control Act. At the same time, we are aware that some industrial firms are concerned about the possible inadequacy of commercial test facilities to accommodate the needed tests. Therefore, if necessary, the National Center for Toxicological Research, which is supported by FOA and EPA, is prepared to work with industry toward suitable arrangements for utilizing available buildings in Jefferson, Arkansas. -- Research on animals and in vitro experiments to help clarify the toxicological significance of impurities in VCM, synergistic effects due to exposure to other chemicals in addition to VCM such as vinylidine chloride, and metabolic reactions induced by VCM. Government, industry, and academia all have responsibilities in this area, and EPA is currently considering specific steps that might be taken to contribute to advancing the frontiers of our knowledge. Monitoring, Persistence, and Migration Studies We are obviously concerned about current and future background levels of VCM in the air and in the water throughout the country. Our more Immediate efforts, however, are being directed to determining ambient and peak levels near chemical plants. Recently, we initiated a nationwide sampling and analysis program to determine, at least in a preliminary fashion, the VCM levels in ambient air and in water and semi-solid effluents at about ten PVC plants. These activities are currently underway, and we hope to have the results within several weeks. 5 ucc 025819 it As a precursor to this nationwide effort, several weeks ago we conducted a preliminary monitoring program at the B. F. Goodrich plant In Louisville using inadequately tested sampling and analysis methods. At that time VCM levels were detected of 1 to 2 ppm In the ambient air outside the plant, 2 to 3 ppm in the primary water effluent, and 100 to 200 ppm in the sludge at the plant site. However, these numbers could be in error by as much as an order of magnitude due to the pioneering nature of the effort, and no conclusions should be drawn at this time. During the past several weeks we have made a major effort to develop credible and standardized sampling and analysis procedures, building on this initial experience. Our current monitoring efforts are based on this recently improved methodology. The limit of detection for our current technique is approximately .06 mg/liter in water and .06 ppm (volume/volume) in air. However, when vacuum cans are used, the detection limit is .2 ppm because the gas sample must be diluted. The technique we are using is now publicly available with the hope that our efforts toward standardization will lessen the chaos characterizing current monitoring efforts of several federal agencies and industry. While the near-term objective of these monitoring efforts is to gain a limited perspective of the levels of VCM near PVC plants, we should also learn more about the persistence of VCM in air and water from our measurements. Samples are to be taken during daytime and at night, and there undoubtedly will be a range of temperature and humidity conditions. However, we have not structured the measurements with research as a prin cipal objective, and we will not be able to quantify persistence char acteristics with any degree of precision. Limited laboratory experiments are also being attempted to clarify persistence characteristics of VCM. Related to our decision to suspend pesticide sprays containing VCM, one laboratory test showed that in an unventilated and unlighted chamber, less than one percent of the VCM initially present was dissipated after four days. Current efforts are directed to clarifying the rate of retention of VCM entrapped in water effluent streams, as well as further work to understand the effect of light, heat, and moisture on VCM In air. There has been considerable discussion of the amount of unreacted VCM monomer remaining In PVC and the rates of migration out of the PVC. Many companies are now seized with this problem, and I suspect the number of samples being taken to determine VCM concentrations and migration rates has increased considerably in recent weeks. We do not know whether such migration from finished products contributes significantly to back ground levels of VCM, but as you are aware FDA is seized with several aspects of this problem directly related to food. Should there be high levels of VCM background in the environment, then.our concern over all sources of VCM -- Including migration from many products -- should Intensify. 6 ucc 025820 In all of these areas industry has a major responsibility for determining and alerting the public about the behaviour of its products. I would hope that in the months and years ahead industrial monitoring efforts at the fence line will increase dramatically; persistence will become a key concern; and the ultimate fate of chemicals will be less uncertain. Already some chemical establishments have rather broad sampling and analysis programs, and as a direct result of VCM concerns, others are also making new efforts in this regard. At the same time EPA has a responsibility to help insure the adequacy of the national effort in keeping abreast of the chemical crosssection of our environment. Concerns over Disposal of PVC While we tend to lump all types of PVC into one category, I am sure you are aware of the variances in the chemical and physical properties of different grades of PVC. Also, end products made from PVC include a variety of other chemicals which are added throughout the production cycle._ To date EPA's principal concerns relating to PVC have been directed to possible problems attendant to its disposal -- either in incinerators or landfills. We have not investigated in depth any of the special problems associated with inhalation or Ingestion of low concentrations of PVC particulate. With regard to incineration, HC1 Is a primary product of concern. Also, toxic metals may be present as additives and thus cause inhalation problems, either as metal or oxide vapors. Landfill disposal operations have traditiohally assumed that PVC is stable with little likelihood of biological degradation or undesirable leachates. Taking a long-term perspective these assumptions seem clearly overly simplistic, and we should address in greater depth problems attend ant to the disposal of plastics. Experiences in the tropics, for example, have demonstrated the effect of bacteria on PVC which has not been specially treated for use in humid areas. The Risks, the Benefits, and the Costs The current problems with VCM have brought Into sharp focus the practical aspects of balancing the risks and benefits associated with commercial chemicals. The costs Involved to reduce these risks substan tially may be formidable -- or indeed may be prohibitive. The aspect which Is perhaps the most troublesome goes to the heart of this meeting What is the risk now and under alternative regulatory approaches? 7 ucc 025821 In the years ahead more chemicals will be in commerce, the pr' perties of many chemicals will be better understood, and consequently the list of chemicals considered to be hazardous to man and the environment will undoubtedly be much longer. Also, improved research and analytical capabilities will show that the effect!, of thes* chemicals -- acting individually and synergiscically * me much farther reaching than currently susoected effects. As these realities of the chemical age unfold, there must fv> greater sophistication in approaches to responsible regulation 'c. fully, we will develop the necessary precautionary measures cha- ..ii: limit exposure to chemicals when necessary, out not unnecessarily cur tail commercial activities. uec 0 025822 OUTDOORS PREUfflARY ESTIMATE OF LOSSES M PVC SUSPESS123 PClYLIESIZATiCR ClYPICAL PWCES EHCLOSED IH BUILDft5$ BME8US1S MULHCE IK PVC KAKOFJlCTUtt -a. okaruvo>sjt >O<r? usi& wtotawo. pBucraefmo we HAY CCDTAIN 0-1KO f?a UBIEKTED UYC t Interim Method for Monitoring Vinyl Chloride in Water Effluents and Air Emissions Being Used by the Environmental Protection Agency The sampling and analysis method described in the enclosure reflects current state-of-the-art and undoubtedly will be improved in the months and years ahead. Indeed, it should be recognized that these interim pro cedures have not been adequately tested. Several additional caveats should.be recognized. It is exceedingly difficult to prepare stable aqueous calibration solutions of VCM. For this reason carbon tetrachloride solutions of vinyl chloride are used to calibrate the gas chromatograph for aqueous samples of vinyl chloride. Even these are difficult calibration solutions with which to work. The calibration procedure developed by the Southeast Environmental Research Laboratory is described in the enclosure. Another weakness is that the stock'solution of VCM in carbon tetrachloride must be determined against mixtures of VCM in zero nitrogen. The FFAP on Gas Chrom Q packed columns which is used for aqueous sample analysis is not well suited to analysis of gas samples of VCM. ' * :-j . At present, there is no adequately tested method for continuously monitoring vinyl chloride. Based upon the experiences of the National Institute of Occupational Safety arid'Health and EPA Region IV, the carbon adsorption column is being used. Time constraints have made it necessary to specify Fischer Scientific activated coconut shell charcoal for standardization of interim EPA procedures although other charcoals or adsorbents may.prove to be more efficient. _ ;; ' . Vinyl chloride to be used for calibration purposes (50 ppm in zero air) is being obtained from Scott Laboratories and tedlar bags from Fluorodynamics, Inc. However, the use of these sources of supply in no way reflects endorsement of their products as preferable to comparable products of other organizations. Should there be questions concerning these procedures. Dr. Robert B. Medz (Area Code 202, 426-2382) may be able to clarify further the methodology that has been developed. Environmental Protection Agency 5/2/74 UCC 025824 . " * '. . ` ` METHOD FOR VINYL CHIDPJDE (VC) IK INDUSTRIAL WASTE WATER EFFLUENTS AND ATMOSPHERIC SESSIONS 1- Scope and Application 1.1. This method is. applicable to VC monomer' determinations in .industrial effluents, sludges and scums, and atmospheric , emissions. 1.2. The limit of detection is approximately 0.06 mg/l in water (0.06 ppm v/v in air samples). When vacuum cans are used, the detection limit is 0.2 ppm because the gas sample must . he diluted from 100 ml to about 350 ml. 2. . Summary . ' - -uw; 2.1. Water composite and air and water grab samples are anaylzed ; without cleanup by gas chromatography (GC). Separations are effected by selection of one of two types of columns depending upon the nature of the sample. Detection Is by means of the v flame ionization detector (FID). Tetrahydrofuran extracts of . -7l, X"V'sludges and scums are used for injection intro the G.C. Air continuous samples on activated carbon are extracted with carbon disulfide and analyzed fey G.C. . 2.2.- VC confirmation may be made by mass spectrometric analysis. . of the GC eluent*" Independent confirmation may also he made . in the event of extraordinarily high VC concentration samples ! -Tr' by submitting " the samples to NERC-RTP for long-path Fourier C ' r transform X.R. spectrophotometry (requires 20 cu. ft. air samples ~ r but for high levels 2-3 cu. ft. of sartple can be diluted)., 3.. Interferences . v-- 3.1. Certain volatile hydrocarbons have elution characteristics . V. similar to VC." None of these have been shown to be present in discharge or air samples which have been analyzed in the " limited field experience so far. . 4* Apparatus and Materials 4.1. Gas Chromatograph. V"; 4.2. Flame ionization detector. 4*3. Recorder - any pctenticaetric rtrip chart recorder which is compatible with the detector system. \JCC 025825 4*4* -GO Column Materials. i 4.4*1. For waste .water, sludge or scum, samples. 4.4.1.1. Borosilicate glass tube - 6* x 2.5 mm I.D. ; preferred. When G.C. oven configuration requires shorter columns, these should he . Vy' ' . used. .* v .: '' 4.4.1.2. Solid Support - 60/80 mesh Gas Chrom Q. 4*4il.3. Liquid Phase - 1$ IFAP on solid support (weight percent). -. ...- .. ' . 4*4.2. For air sasples. "y.".'. * . V,;- ; \r':. y,r.' , 4*4*2.1. Borosilicate glass tube - S' x 2.5 mm I.D.'' .y preferred. When G.C. oven configuration requires shorter columns, these fl be . used. , . -i ' . ` * . 4.4.2.2. Solid Support - Carbopak A. \:X.- ;.4.4*2*3* Liquid phase.- 0.4# Carbowax 1500 on solid .> : v.J |u...-- ... .. support (weight percent). . 4*6. Continuous Air Monitoring Materials. v-"y ' ' *. . * "** , . - ' \.' - w *** * * .v * ` * ,* . * * '*"; .i` *^ * . .. . '. y' 4.6.1* Tubing, pyrex 'glass, 1&nx3/&w 0.i).\'*'/v ;v::'y" y ; .... . 4.6.2. Activated coconut charcoal, 8-16 mesh, Fischer . ; Scientific Company. . y-y-; *. ; 4*^.3. Becton-Dickson 27 gage 3/3" hypodermic needle flow ..* ~ control. ; yy . " 4*6*4* Vacuum pump. -4.6.5. Air flow meter.. . y `y- 4.10. Pressure Gas Regulator (0-5 PSIG). 4.12. Microsyringes - 10, 25, 50, and 100 ml. . ' 4.13. Gas-tight sample syringes - 1 ml, 50 ml graduated, 4.14. Vacuum Sampling Cans - 370 ml steel Vacu-Samnlers. ' . ucc 025826 .] . , ' . ''.: ._ 3: .. ' 4.15. Tedlar Bags - 12" x 12", 36" x 36", equipped -with sampling system. `4- 4*16. Automatic sampler - compositor (manual sampling optional) equipped -with sample refrigeration capabilities, a means to prevent loss of vinyl chloride from open bqttles. 4.17. . Glass sampling bottles with teflon lined screw type caps - 50 ml capacity (or other depending upon sampler require ments). : ' >; . 4.16. Septum-sealed vials - 1 to 10 ml capacity.. ; , 4.19. Dedicated G.C./M.S. for confirmatory test. ; ; ' 4.20. Barometer... iv. . ..-.V.- 4.21. Thermometer. Reagents. Solvents, and Standards / ' > .'*4 *- 5.1. * Carrier gas - zero nitrogen, and helium. i:.'y ; ' v T. ' 5.2. HD gas - zero hydrogen, oxygen.' V' * 5.3. * Tqtrahydrofuran. ' ' ' '\X-; '.'v.'. 5.4., . . Carbon tetrachloride (G.C.' grade).. -1 - . ^ v`- v 5.5*....Carbon,disulfide (G.C. grade).vV.,V'--/--- - > * *' 1 * * v. ' , ' '*"" .* ' `y ' 1 .'i *'" </<. - ? v :\ . ` . , . . . ^ t t *\* ' ~ ...5.61. Standards.'- - >' ; V- - . * f ; 5.6.1. . VCM in zero air, 50 ppm (+ 2JS) v/v. 6. Sampling "V; V ' v" :v'X;.V'- ' ..X , , i- . 6.1. Water. Sample . 6.1.1. AH waste water discharge points identified in NPDES . permits should be sampled for VCM. Three successive 24-hour composite samples of each site should be taken. Compositing interval should be 1 hour (manual or automatic sampling is optional). Compositing interval cf 20 minutes may be used if automatic' . sampler has this capability. Samples should also be taken at waste water treatment units such as clarifiers. ucc 025827 i and scum and sludge separators. Two 8-hour composites should be taken from the effluents from each of these points, and one 8-hour composite should he taken of scum and sludge from each separator unit. Compositing interval should he 1 hour. Three grab samples of clean process water (city or well) should he taken as blanks. 6.1.2. Samples should be taken in 50 ml bottles with gas tight, teflon sealed,, screw-cap closures, or in . . - equivalent containers required by the characterists of automatic samplers. All water, sludge, and scum ' samples should he refrigerated dining collection end storage. Compositing volumes should be selected to . assure head space above tha samples are minimized to VV avoid losses of CM by its partitioning into the gas V. ... . phase. Provisions should he made to avoid such losses ` when using continuous monitors. ` 6.1.3. Estimates of discharge flow should be* made using any' , appropriate measuring device (venturi, weir, magnetic mater,..etc.\ 6.1.4* Sandies should he preserved by refrigeration until . they are ready'for analysis. They should also be v -- protected from sunlight. ,v. Air Samples . . . ------------- /'*<' f 6 2 1 Sampling" sites should be selected which are downwind and in the plume of the atmospheric emissions from the . . plant. Samples should be collected only in areas where local residents or neighboring industries, would b . exposed. Sampling should be conducted over a period . of five days. Sampling sites should be selected in ' "the following array: ona site immediately upwind (A) and one immediately downwind (B) of the plant site; . 4 sites about 0.4 miles from the plant site, one laterally left (C) and one laterally right (D) of the plant site on a line roughly perpendicular to the prevailing wind direction and two (E,F) downwind from the plant site; two sampling sites (G,H) approxi mately 0.5 miles downwind; one sampling site each at distances approximately 0.6 (I), 0.8 (J), 1.0 (S), and 3.0 (L) miles downwind from the plant site. If wind is fish-tailing severely, locate sampling sites G and H approximately 0.5 mile upwind (prevailing wind direction orientation) from the plant. ucc 025828 5 The sites specified are a minimum. Additional sites may be selected contingent upon overriding micro- meteorological considerations that must be determined by the sampler in consultation with the Regional meteorologist. These may be at ground or some elevated level. . .. . Sampling Sites j Prevailing Wind , Direction ' Minimum, Sampling ' Schedule. / Miles Tine ' ' Mon. , ' Wed. Fri. ' 0.8 J . 1800 . 33,1' I.J , X.,L : ' 3.0 ' L All times are dt 30 minutes 6.2.3/ Grab samples are to be taken in 50 ml gas tight syringes. ` , 370 ml "Vacu-Sampler" metal cans, or 12" x 12" capacity v-' Tedlar hags. The "Vacu-Sampler" is evacuated and back- ' filled to pressure of 10" Hg with zero nitrogen (equivalent to 246.6 ml at 760 mm Hg if can is filled at 21C) . A nozzle on top of the can allows a sample J to he taken and sealed until analyzed. Assume perfect gas lavs to estimate volumes* Hypodermic syringes are flushed several times, then the sample is taken and . .......... ayringe is locked and sealed until it is ready to ,, be. analyzed. The Tedlar bag samplers are filled by pulling the walls of the bag apart to suck in the air sample, and then the hag is sealed until the sample is ready to be analyzed. All samples should be protected from the sunlight. 6.2.4. Continuous samples are to be taken in pyrex tubes (approximately, 3/S" O.D. x 18" long) packed with activated coconut shell charcoal (richer Scientific Co., 8-16 mesh). The charcoal is added to the tube UCC 025829 .1 1 t in three 3-inch segments, each separated by a glass /wool plug* The two ends of the packed tubs are also < plugged with glass wool. 3oth ends of the adsorp tion tube are plugged with seruza caps for transit and storage. Flow rate through the tube should be controlled by inserting a Becton-Dickson 27 gage, 3/8" hypodermic . needle through one of the serum caps, and into the end. ' , glass wool plug. . Air is sucked through the tube by v connecting it to. a conventional vacuum pump (the arrangement is similar to that used in the National Air Surveillance Network). Flowrate should.be about . . .200 ml/nin. For each adsorption tube; the flow rat . should be calibrated in the laboratory using a ' standard flow meter before a sample is taken and should he verified again in the laboratory after >1 ' the, sample is taken. ; The adsorption efficiency of the carbon should he ` ,. V . verified in the laboratory by preparing a 3 ppm v/v --VCM mixture in air in the 36" x 36" Tedlar bag and drawing this through the adsorption tuba. Flow ....... ;.'rates -through the tube should be verified before /' ' .:/ and after the expeiiiaent.,,",. . -/ - AH collections should be made with the adsorption rjr. ... tubes protected from light - either by wrapping with foil or enclosure in a box. ;' /v.--';' /Each segment of the adsorption sample is worked 1 up separately by etching the tube in the middle of each 3" section with a file, successively breaking each segment and spilling the contents into measured " / . volumes of, carbon disUlfids in glass stoppered test tubes. - The additions should be effected cautiously ` f :r 1 * . , ` and with cooling in an ice bath since the interaction ... of activated charcoal with carbon disulfide is exothermic. A 2 micro liter aliquot of the super natant solution should be injected on the Gas Chrcm. supported FFAP column for estimation of .the adsorbed ,TCM. Successive analyses of the three adsorption tube segments will indicate the amount of break-through of VCM through the adsorbent The sane procedure should 'be used icr taking. samples in the field. 02&  6.2.5*: Record the temperature and atmospheric pressure at vhich the samples are taken. 6.2.6 (See page 7a), 1 Calibration ,7.1. Calibration for Analysis of Gas samples. ' *' ' * * ',, ' ' . 7.1.1. Record ambient temperature and atmospheric pressure. - > 7.1.2. .Prepare dilutions of 50, 1.0, 0.2 ppm (v/v) of vinyl ` chloride in zero nitrogen by diluting standard VC gas , mixture (50 ppm in zero air) with appropriate volumes ' ; ' of nitrogen. Dilutions may be made using Tedlar bags and gas tight syringes. 7.1.3. Inject 1 ml aliquots of the calibration samples into '.v .a G.C. equipped with a Carbowax - 1500 (on Carbopak A) ` \'-j: packed column and an FID detector. Use zero nitrogen / ` as the carrier gas at a flow rate of 60 ml/min. * Operate the inlet and the column at room temperature. v.7'?-.. / ' " ' i/l . * ' 7.1.4. Prepare a calibration curve. Repeat dilutions and G.C. ` ^v-:' .injections until calibration curves are reproducible. . t- 7.1.5. Assume the perfect gas laws to be applicable. .7*2. - Calibration for Analysis of Water Samples..^. .-T ' V ." 7.2.1. Prepare a stock solution of 10 ppm vinyl chloride by' bubbling a slow stream of standard vinyl chloride gas ... - mixture (50 ppm) into a septum-sealed vial which has been . ,.\T v:>' completely filled with carbon tetrachloride. During this 7 . . period, the vial system should provide for free exhaust ' . of the nitrogen dilution gas. If a supply of reagent 7C is available it may be used in place of the standard `V/. - VC gas mixture. . 7.2.2. Determine the concentration of the stock solution by . G.C. analysis using a FRAP on Gas Chrom Q packed column and FID detector. Operate the G.C. with zero nitrogen carrier gas at a flow rate of 60 ml/min. inlet tempera ture of 150C, end a column temperature of 62C,, The stock solution concentration should be determine. comparison to Hpuroprinin dilutions of V.C. in nit;u~.m; zero gas. 7.2.3. Prepare dilutions of V.C. in carbon tetrachloride solu tion at concentrations of 2,' 1.0, and 0.2 ppm UCC 025831 \ ., . septum sealed vials which are completely filled with. known amounts of carbon tetrachloride. ,7.2.4. Inject 2 microliter aliquots of carbon tetrachloride calibration samples into G.C. equipped as described ... _ : in 7.2.2. .7,2.5. Prepare a calibration curve. Repeat dilutions and , G.C. injections until calibration curves are ' ''reproducible. '.,;- 8. Procedure . 8.1. '* Water Sample Analysis "i. - tV 8.1.i. Untreated water samples (1-5 microliter aliquots) .. .. .are injected directly into the G.C. 8.1.2. A .% FFAP on "Gas Chrom <Qn packed column is ns d. _;t . , Nitrogen zero gas is used as the carrier gas at a : ;' flow rate of 60 ml/min. Inlet temperature is set at 150C. The column is operated isothermally at" ;' 62G. . Detection is by FID. : ' 8.1.3. Report concentration of VC in sample in mg/l. 8.2. ` Sludge .and Scum Samples It' ^ .n *; 8.2.1. Extract 5 grams of sludge or scum sample with 100 ml of tetrahydrofuran (THF).: Analyze THF extract in the - same manner used for water samples in 8.1. If VC con-. , .centrations are too high, make appropriate dilutions . . of the THF extracts. " . >. ! 8.2.2. Report concentration of V.C. in.sample in mg V.C./g of sample. 7 ' 8.3. Air Sample Analysis 8.3.1. Grab sanpi.es. . 8.3.1.1. Use a 0.4$ Carbovax 1500 on Carbo-Pak A packed column. Use nitrogen zero gas as . the carrier gas with a flow rate of 60 al/mln. Operate the column.and inlet at room temperature. Use a flame ionization detector.. ucc 025833 ' `1 ..h'. ^ v; -f \" ` . UNITED STATES ENVIRONMENTAL PROTECTION AUtiVoV "' ' r V. . Southeast Environmental Research Laboratory Athens, Georgia 30601 . , J SUBJECT: 'i M ; | FROM: i ; Determination of Vinyl Chloride " Monomer in Aquatic Effluents Alfred d. Thruston,' Jr. /?0Q. Analytical Chemistry Branch ^ ,_' ' DATE: April 24, 1974 ' ` 1 TO: - Arthur W. Garrison '** ' ' -'-'"tV, `-'V ' /'; .. ' -.-t ,| Analytical Chemistry Branch." . -. :VV'* : - "v;j/Vy: V-i:**H^R0:DUCT?9H. ' 'Cr v:,. >; This technical assistance' project was undertaken at- the j request-of Dr..*Henry.~Enos .-in his memo of March. 15, 1974. on.. ' i ` "The Availability of an Analytical Method for Vinyl Chloride -' -in Water." , s-*1'^ ! j4. ;!.** -V * .V *' *',** V: r-. S Ut M.MaAR, Y J `'i-.'V ' A'method for preparation of quantitative standard ! V;y solutions of vinyl chioride monomer (VCM) in.carbon tetra-,. . -j- i -i.V;. chloride was developed. Two gas chromatographic techniques - - | I-:: to quantitatively determine VCM. in aquatic samples were i -,V tested. They are based on: (1) direct aqueous injection, and < '" (2) carbon tetrachloride extraction, Both methods were ' tested on effluent samples from a vinyl chloride plant and .- V/- shown to be reproducible and'quantitative at the mg/1 levels. - . .. Water , samples containing vinyl chloride. should he * *' . ..v>. collected by completely: filling a- glass bottle and sealed . V.,,;:: with a teflon-lined cap. Samples should be immediately. .'V.;VJr-.. refrigerated. and kept , cold during shipping and storage. Quan-, ;';V titative standards should be prepared gravimetrically.. .. W?, Direct'aqueous injection GC is the best method' for screening ; . ,V>;: samples for mg/1 levels of vinyl chloride. Extraction methods * *. '.-** W' should be used to analyse samples containing'yg/1 amounts of -. -y ; .-: vinyl "chloride. Gas chromatography-mass spectrometry is t vV-T valuable for confirmation of the presence of vinyl chloride.' Headspace- gas-sampling is suggested as- an alternate screening . 'TV,- 'method.. , - - - -* ^ / -'.ri:-'..v*', METHOD ^ -.... " , ; --Eq--u--i-p*--me nt- . ::-,1v. r- .. . - r-ir: yy.--- . `-Tv..- - -R'-.t-: .V' .: '-;V *; .*'*: } :: ; ' '-. V" 1. Vinyl chloride - lecture bottle size (Matheson or ... ... _ /equivalent) r. . ..... . /.: ; 2. Carbon tetrachloride (CCl^) - GC grade : '. V^y. .. 'V- - 3. 2 ml and 25 ml serum vials with teflon-coated rubber ; - septa ire':, y yy:. ' v 's ' * ' ^ ? *i~*vi*-...... - ... ;......,,ucc 025835 o..'J .* 4. 10 and' ICO yl syringes . 'i'- ` 5. 1 ml gas syringe * .''. '` 6. Gas chromatograph with flame ionization detector/ tempera-1 1 . ture` programmed column oveni and a one millivolt recorder* hi ' analytical Parameters N I ' * ,, ' ` 1.Column s Packing - ` 1' * V-* * ' ' ** i* *" ':**. * \ *' `V *' * .**' */ **,: *. - * ` ' * " Column Temperature . - . /'v: C"*` *' - v.*V. * ,** * '1 'i *,-*,'* '^i 1 * '* -***-*--m** r-V; . H ` . - ;* . vt r- - t. ,v. v 1 4# # ** /. . .> . 1 !i1 , ! * - v,,, 1/8" OD x S' long SS or glass filled with 10% FFA? on 80/100 / chrcmosorb Vf-AW ` j; - Isothermal at 60 C. until VCM ``. / elutes (50 seconds) , then raise temperature to 16 0 C. at! ,30/ min. until water or solvent-is '^' eluted.;` ` -yy'^y-.v ;i:-*>? - Chart Speed - ;vi>.: t 1/2"'. per minute. . - //:./.. ; \ <* . -- _* / i ' Samole Preservatiioonn. -./".V-i.'/rV'-. f/V'-.r./v::*'nhh'/P"' * / y /.;;; - ; ^-r^-'Sr './//V /`i'`.X` 7 Store water samples in the refrigerator in glass bottles' ' with teflon-lined screw tops.. Particulate matter should be \ !- = .'-:i: allowed to settle. - For convenient replicate sampling, several ``4- 4/tubing end in a beaker of water. Adjust the lecture bottle valve1 !j '...to give a'steady flow of gas as indicated by the bubbles. Pierce :V: ; the tubing 1 inch frbm the valve with a 1 ml gas syringe. 1 Flush -'i;the syringe twice and then v/ithdraw 800 yl of VCH (approximately ' T-/ 2 mg) . Inject the VCH slowly into the CCI4 in the serum vial. '" * Care should be taken not to pull any CCI4 solution into the syringe v;hen removing the syringe from the septum. Shake the vial vigorously for one. minutev Reweigh the vial -and' calculate the--concentra- ' tioh' o'f VCM ` (approximately'80'ng/y'l) . Recap'^he vial with, an unpierceu septu:n or transfer to a bottle closed with a teflon- lined screw cap. (The CCI4 attacks the septum rubber once the teflon liner is pierced.) Dilute this stock solution to give working standards.' Two ml serum vials/ which hold- about 1.8 ml.- . - - :'..ii-ji-jL j .--i1 .. ^ 1 . *- ' v ` 4 i *,* , I 1{ * . f * * ' Ft V - * *V. . ` ; ./ ^4 * . . fc.**.* * ucc 025836 to the neck (calibrate), make good containers for. the diluted standards. For example: aliquots of 90, 45, and 23 yl (ICO yl syringe) diluted to 1.8 ml make 4, 2, and 1 ng/yl solutions. These solutions must be prepared fresh daily if the septa are pierced. .. Analysis ` r A. Direct Aqueous Injection - Inject, the sample (2 to 3 yl) directly into the GC. The sensitivity of this technique, depends on the condition of the GC. For example, on '../.three different GC`s, 50% full scale chart deflection (FSCD) at the most sensitive attenuation corresponded to: ' (1) 20 ng, (2) 4 ng, and (3) 0.5 ng of VCM. On insfcru- . ; ment (1) with a 2 yl direct aqueous injection, the lower . ., limit of detection. (10% FSCD) was 2 mg/1, while on instrument (3) the limit was 0.05 mg/1. " . B. . Extraction with CCI4 - Carbon tetrachloride quantitatively extracts VCM. from water. If a sample contains too. little" ; '.VCM for-direct aqueous-injection, .CCI4 concentration techniques may be used. *- ; Add 5, 10, or 500 ml of settled sample- - depending on the ; concentration of VCM - to "a 15 ml stoppered centrifug : <. tube or a 500 ml separatory funnel containing 1.0 ml -CCI4. - Stopper, shake for. 1 minute, allow -the layers to . separate, and inject 2 yl of the CCI4 layer into the GC. / Recovery at the mg/1 Level'LT/.?t^Zgr'i;.`XV."'*?*'.? ^' ~ ' ' Aliquots of 1, 2, and 3 ml of ah effluent sample "containing 7.1 mg/1 VCM (as measured by direct aqueous injection), were each extracted with .1. ml CCI4. The aqueous.and CCI4 layers from each.extraction were'analyzed by GC. : As shown in Table.!,, the concentrations, of VCM in the CCI4 layers indicates essen- . tially complete recovery. .'t . i. v . 4 > V ; Table * 1/ . CCI4 Recovery- at 7.1 mg/1 VCM_ Level, _ . , . . , * * * t,% Ratio : > ' ....CCI4 Layer--/ V V .; ~ '- Aqueous' Layer Sample:CC14' ng VCM* .. mg/1. in Sample ..... ng va-i isi 2:1 * t- * 3:1' : 17.' .;-- 35 , . ; .55 ; ...-v''/ -^7.3- ` ; '* ' <1- ; *; ; ,r, - .<1 '. ' '' <i * Calculated by comparison of .GC peak height with that of standard VCM iinn CCCC1l4^. C* . *** ' '.'-S^? s. : iV' 'A.` ,* ; ;* l; i Ij - y- . - -;4.i ucc 025837 Recovery at the iig/1 level , . *..' A` sample, which, analyzed 3.7.mgA VCM by direct aqueous injection, was diluted from 1 ml to 500 ml with tap water (7.4 yg/1 VCM). The 500 ml was extracted with 1 ml CC14 - . 74% of the VCM v.Tas recovered (5.5 ugA) . Another sample that analyzed 0.19 mgA VCM by direct aqueous injection was diluted 1 ml to 100 with tap water (1.9 ug/1) * The 100 ml was extracted with 1 ml CC14 and 84% of the VCM was recovered (1.6 yg/1). ' Analysis of Industrial Effluent Samples Pour aqueous samples from three stations at a plastics* manufacturing plant were analyzed by both techniques: , .'.'.y. ; ' - . ' " :. *' 0468- V , - clarifier scum removal system discharge 0465 and 0472 - primary clarifier discharge (two different ..V.,; days) 0463 - ` ; plant storm sewer . . -. ..m * . _ mm.i . ` `*t . * Results are shown in. Tab5ilee 2. . .* . '** '`;7:v;,v*v - *" .** 1 , *'-*'* . - Tabie 2.,: VCM in Aqueous Industrial Effluent Samples. i. '5* . >. j* ' . v*4 . ^ . . :. - >* ' '* . * 1^**. j.- V* *' * ' ** Sample Direct Sample ;:1,';Tnjection A '' mg ; Extraction with CCI4 xatro Sanple:CCl4 - *`mgA 0468* . - -*.* t , 9.3- . . ,, :. ._l:l'l y-v 6B- 04 65::. . 2.8' 'V/*'*; : ;-rv-y w-.yy-; ., 0472 ' *. *:><; :2.8'.VV'--'* 0463 `'i'libV'" P2. * * r.. , V4'v - * *, ..-.i...'.: . : i'V'"- ' ' **^*^V`* .-/li*-* - r. ij! #' *2.,' ,* .. : '-.3:1 :* ;-'.i *. :* : : : v'- 'V : tt\ ' l.\ .1 *.4V* - v 3:1. ..'y^;3.o'V'; ; * 2.9 :. v. -'r'^^wvv; ' 50 sit!, ; ,, r.T;0.2 . .-V-y iv-y . v ,->: % `J \*.'1 ' . i' ; - ' v* y-,v *3. * V*. * ` a;........ * . ` - / * ' . * * * #* <-. ,. . . /. *: .1>. ^ .y *' '* .= * . .* * .. *. ` , -i . # '*' J _ * * v '= : ' *C'V"` 1 K.yy-'y;.yyr ; *.-: *.*"*. p . ' > V * . . 4 * **r *. t.*. rk->!* * - k. *v- * v# . 11 ;* , * . , t f <*r `i j, r * r . ** * *r,. : *. *** * *p4**V*;. . ** *f\fe '*/ ** . v ^. . - ' , , " - . '* 1 ...................... ** :* : v.1. * ** `' f * * . : y -- '* *#fc***', F * i, ' ' ,`*,1 i t* ;V)I -; '4 ** i* ' ,**. * ^/ i\. '*" f .'. i*<* -T V: * ' *'' \* *- Ss . '1' ' .* ' ;' UCC 025838 '.><* r'i -* h .. A * i"' V: ;V- . t'l; 'aL. .^V _>. M .* ' ./ *v V... -S ', ` ! , ` . . , wX > A / * .Alternative Analytical Technicrues for VCM ' A. Other .Columns for Direct Aqueous Injection - Columns 1/8" ID x 2* long packed with Chrcmasorb 102 or 1/8" . ID x 8' long packed with 0.4% Carbowax 1500 on Carbopack A have also been shown to give good results for VCM by Don Brown of the Chemical Service 3ranch, Surveillance and Analysis Division, Region IV, EPA. 3. Headspace Screening - This technique (also developed by Don Brown) is a sensitive and fast screening procedure, and is semi-quantitative if standardized. Fill a 2 ml . .. serum vial to half capacity with the aqueous sample, cap, and place in a 40 C oven or v;ater bath.. The VCM will equilibrate between the liquid and headspace gas. Withdraw 500 yl of the headspace gas with a 1 ml gas syringe and inject into the GC. After about 10 injec- v*';., . tions at 60 C, raise the column temperature to 160 to remove water, vapor from the columns s' Confirmation by Gas Chromatography - Mass Spectrometry 1* ^ . i.m 1` ' ` s*> The presence of-vinyl chloride is indicated by thre .3.. :- V prominent ions in the mass spectrum: the vinyl ion at m/e 27, . ' -"$f: :,:.the molecular ion at m/e 62,and.the chlorine isotope molecular . . . h- '`.j --'ion at m/e 64. The ion abundance at m/e 62 and m/e 64 niust be ; ''approximately 3:1, corresponding to the natural abundance of `Jr,: 1 - the chlorine.isotopes.' * t #:. # `i * * > ,*s ** >* *< * i',* ** \ ^ i .i " ** " ?,,*> ' ;.-v ! The presence of 6.2 mg/1 VCM in sample 8463 was easily . .confirmed on a Finnigan 1015 GC/MS System. Good spectra . . were obtained using either a 2 yl direct aqueous injection or ' , '2 yl of CCI4 extract. To test the sensitivity of GC/MS to VCM,'. w*' , ,-v .' "the CCI4 extract of this sample was diluted to successively . -:;r. ' , * V lower concentrations and analyzed. 1 Acceptable spectra were ;Y'Y,,. obtained with 0.14 ng of VCM injected into the'GC --this would. * v-". ..... ... ............... . :: l'l#. ' . mL: ; . 'jV ..'/<%#. \ * *.* | . rfj ?..,* ,* r-- . -w x* ucc 025839 rj i ETA QUESTIONS FOR SPI (SOCIETY OF PLASTICS INDUSTRY) 1. list of top 50-100 PVC produces by sales volume 2. list of top 50-100 PVC products by volume of plastic In product 3. amounts of unreacted monomer In above products 4. list of PVC compounding plants by name, location, # employees, polymer used, products line, quantities produced 5. list of PVC fabrication plants by name, location, 9 empolyees, polymer used, fabrication methods utilised, quantities produced 6. - levels ofVCM In plants in 4. and 5. by plant area and detection method utilized 7. levels of VCM beyond the plants and detection method (a) used 8. .levels of VCM in water effluents 9. decomposition products from various Incineration conditions for PVC and quantities of PVC Involved 10. amounts of VC leaching out of landfills and total amount PVC burled to date 11. toxicity of PVC resin and products 12. epidemiology studies of workers 13. population within square mile of plants 14. substitutes for VC and PVC n 15. Future PVC markets New products New(workerslfor old'products 16. Additives used In PVC products UCC 025840 1 5/23/74 CC TO: N. H. Ketcham H. R. Guest R. G. Lilley J. b. Carvajal A. B. Steele N. b. Zutty M. E. Eisenhour D. L. Engle G. J. Hanks, Jr. 511 511 514 514 NYO-28 NYO-32 515 515 511 ucc 025841