Document emrOQo6bGG5YwQQ027VQkaq4G

LH&.Jrl m y)\AH /<?7i RECEIVED MAY 1 * 1974 T. L CAREY. EPIDEMIOLOGICAL STUDY OF VINYL CHLORIDE WORKERS Final Report May 3, 1974 Submitted to The Manufacturing Chemists Association 1825 Connecticut Avenue N. W. Washington, D. C. 20009 by Tabershaw/Cooper Associates, Inc. 2180 Milvia Street Berkeley, California 94704 AP00023866 ACKNOWLEDGMENT The research which forms the basis for this report was supported by the voluntary contributions of the following named chemical companies engaged in the synthesis and/or the polymerization of vinyl chloride, and administered in their behalf by the Manufacturing Chemists Association Air Products and Chemicals, Inc. ' Allied Chemical Corporation Borden Chemical Division of Borden, Inc. Continental Oil Company Diamond Shamrock Company The Dow Chemical Company Ethyl Corporation 1 Exxon Chemical Company Firestone Plastics Company B. F. Goodrich Chemical Company The Goodyear Tire and Rubber Company Monsanto Company Olin Corporation PPG Industries, Inc. Shell Chemical Company Stauffer Chemical Company Tenneco Chemicals, Inc. Union Carbide Corporation UNIROYAL, Inc. AP00023867 TABLE OF CONTENTS SECTION I. Summary II. Introduction III. Selection of Study Plants IV. Data Collection V. The Measurement of Exposure VI. Follow-up of Study Population VII. Description of Study Population VIII. Calculation of Risk of Death IX. Analysts X. Discussion XI. Possible Biases in the Calculation of Risk Page 1 2 >3 4 5 6 7 9 11 13 15 REFERENCES 17 LIST OF TABLES 1. Follow-up Status of 8384 Vinyl Chloride Workers 2. Distribution of Months in Exposed Employment by Birth Year, for 7128 Vinyl Chloride Workers with Completed Follow-up 3. Distribution of Months in Exposed Employment by Year in Which Exposure Began, for 7128 Vinyl Chloride Workers with Completed Follow-up 4. Distribution by Months of Exposed Employment and Time Weighted Average Exposure Score, for 7128 Vinyl Chloride Workers with Complete Follow-up 5. Person Years of Observation by Year of Birth and Age for Vinyl Chloride Workers 6. Observed Deaths/Expected Deaths and Standardized Mortality Ratios in Vinyl Chloride Workers AP00023868 7 . Observed Deaths/Expected Deaths and Standardized Mortality Ratios in Vinyl Chloride Workers, by Estimated Level of Exposure 8. Observed Deaths/Expected Deaths and Standardized Mortality Ratios in Vinyl Chloride Workers by Duration-of Exposed Employment 9. Observed Deaths/Expected Deaths and Standardized Mortality Ratios in Vinyl Chloride Workers with Exposure Indices below 1.5, by Duration of Exposed Employment 10. Observed Deaths/Expected Deaths and Standardized Mortality Ratios in Vinyl Chloride Workers with Exposure Indices of 1.5 or Greater, by Duration of Exposed Employment 11. Distribution of Deaths by Exposure Category and by Whether Cause of Death Was Determined, and Correction Factors Used for SMR Calculations 12. Results of Follow-up in Several Occupational Groups 13. Angiosarcoma Deaths in VCM Epidemiology Study Population 14. Other Malignancies (190-199, I.C.D.) in VCM Epidemiology Study Population 15. Malignant Neoplasms of Buccal Cavity and Pharynx (140-148, I.C.D.) in VCM Epidemiology Study Population FIGURE 1. Flow Chart of Follow-up Procedure ATTACHMENTS A. Plant Contact Form B. Plant Background Form C. Job History Form D. Follow-up Letter EPIDEMIOLOGICAL STUDY OF VINYL CHLORIDE WORKERS Final Report - May 2, 1974 I. SUMMARY Eight thousand three hundred and eighty four men who had had at least one year of occupational exposure to vinyl chloride before December ^1, 1972, were followed in a historical prospective mortality study. The major findings of the study are: 1. The overall mortality of the study population was approximately 75 percent of what would be expected in a comparable population of U. S. males. 2. No cause of death showed a statistically significant excess over what would be expected in a comparable U. S. male population. 3. No new deaths identified as angiosarcoma of the liver were found. 4. All previously known Angiosarcoma deaths in the study population during the study period were found as part of the routine study procedure. 5. Cancers of the liver (primarily aiigiosarcoma), respiratory system, brain, and cancers of unknown primary site, as well as lymphosarcoma, occurred more often than expected in those members of the study population with the greatest exposure. Even though the excesses were not statistically significant, the findings warrant further study. 6. Other cancers occurred at lower levels than in the general male population, with the exception of cancers of the buccal cavity and pharynx. There was an excess of tho6e -2- cancers, which however was inversely related to exposure. The explanation for this finding is not apparent. II. INTRODUCTION The study was begun by Tabershaw/Cooper, Associates, Inc. on June 15, 1973, under contract from the Manufacturing Chemists Association. The original eight month period of the contract was later extended by two months, in consideration of logistical problems arising from the number of plants which participated in the study. The objectives of the study are: (1) To compare the mortality of individuals who have worked in vinyl chloride plants with that of the general population; (2) To compare mortality patterns within the population of vinyl chloride workers, based upon estimated occupational exposure; and (3) To compare mortality among vinyl chloride workers with the mor tality of other groups which TCA, Inc. has studied. The study took the form of a historical prospective mortality study. The study population consisted of individuals who had worked for at least one year in a job involving exposure to vinyl chloride before December 31, 1972, and Included retired and terminated as well as active workers. Tor each such worker the date of birth and an employment history were obtained, and the vital status of the workerr as of December 31, 1972, was ascertained. For those found to have died, those death certificates that were available were obtained and the cause of death determined. The observed mortality was compared with that of the United States male population. ^ AP00023871 t -3- III. SELECTION OF STUDY PLANTS The Manufacturing Chemists Association identified 43 United States plants belonging to 19 companies, which either produced vinyl chloride or used it in the production of polyvinyl chloride. The name and address of a responsible liaison person at each company and plant was provided to TCA, Inc. (Attachment A). A brief questionnaire was sent to each plant to obtain an estimate of the exposed population and to find out how far back in time personnel records could be obtained, and to determine whether job histories were available for retired and terminated workers (Attachment B) . All the plants responded. On the basis of the replies, four plants were dropped from the study because they had begun operation after 1968. It was felt that exposures in such plants would be too recent and too brief to provide useful data. Study of one other plant was deferred be cause it had Btopped production of vinyl chloride seven years 'ago, and appeared to present difficulties in identifying an exposed population. In addition, three more plants were excluded from analysis because, when data analysis began, it was found that information from these plants was defective in one of several respects (e.g., no exposure data, no job histories available for terminated employees, etc.). The present report therefore deals with 35 domestic plants involved in either VCM or PVC production, which provided a study population of 8384 individuals. IV. DATA COLLECTION In each plant, data were collected for each worker stated by the plant management to have been employed for at least one year in a Job involving exposure to vinyl chloride. In some plants, particularly those producing the monomer, this determination could be made on the basis o^ job titles. Usually, however, exposure was a function of both job title and the location of the job in the plant, so that the assessment of exposure had to be made on a case-by-case basis by plant officials.- Data were collected for as far back in time as complete records were kept. In most cases this covered the entire history of the plant. In others, records were kept for a fixed period such as a decade. In a few, records were kept for different periods, depending on whether the worker had died on the job or had left employment. > In the latter case it was necessary to exercise care in defining the period for which study data were to be collected. For example, if a plant kept records for five years on those who left employment, but kept them indefinitely for those who died on the job, no termination could be in cluded in the study unless it occurred within the last five years. Data from the earlier period would be biased for the purpose of this study, since a worker had to die to be in the records for the earlier period. The policy therefore was to determine how long each kind of record was kept (quit, discharged, retired and alive, retired and deceased, died while employed) and to define the study period as the shortest of these. One problem which arose in the PVC plants resulted from the fact that a worker could transfer within the plant from exposed to non-exposed jobs. Therefore, even though the number of workers in exposed jobs at a given -5- time may have been a small proportion of the total work force, it was necessary to search every worker's record to find those who might in the past have had over a year's experience in exposed jobs. Several of the PVC plants undertook to conduct this search themselves. As a result, plant data were collected in two ways. In some plants, a TCA, Inc., team visited the establishment, copied the records designated by management as representing exposed workers, and obtained sufficiently detailed exposure estimates to produce a job history. In others, the plants were provided by TCA, Inc. with standard forms which they filled out for workers whom they identified as exposed. Three basic forms were used, depending on whether the worker was known to be alive, known to be dead, or was of unknown status. In all three cases a work history with estimated exposure was recorded, the differences being in the ancillary data required. Attachment C shows such a form for workers known to...be dead . Approximately 5000 of the study population came from plants visited by TCA, Inc., while the remainder came from plants which had filled out the forms themselves. V. THE MEASUREMENT OF EXPOSURE The job history forms (Attachment C) were originally designed in the expectation that vinyl chloride exposure on each job could be quantified in parts per million. This proved generally to be impossible. However, industrial hygiene and safety personnel in each plant were able to identity certain jobs and locations as involving the highest exposures in the plant, and to classify other exposures as medium or low relative to the "high" represented by the Jobs with the greatest exposure. Therefore, the attempt -6- to obtain objective exposure data was abandoned, and each exposed job in the worker's history was scored 1, 2, or 3 to indicate low, medium or high estimated exposure, This gross classification has two major failings, as a result of the subjective nature of the estimates. The first is that the scores represent estimated relative exposure within a given plant. It is therefore possible that, in objective terms, a "high" score in one plant corresponds to a "medium" or even "low" score in another. The second is that exposures in most plants have tended to decrease over time, so that a worker with long service may have had jobs in the remote past which involved "low" exposure relative to other jobs at that time, but which might be "high" in comparison with current exposures in the same job. This subjective classification is therefore of questionable validity in characterizing the exposure of a given worker. For epidemiological purposes, however, those who have high scores can reasonably be expected, on the average, to have had the greatest exposure, while those with low scores will have had the least, even though the true exposure in each group may vary considerably from person to person. The estimated exposure history of each worker was summarized by calculat ing An Exposure Index (El) . This was done by multiplying the number of months on each job by the exposure score, totalling these overall exposed jobs, and dividing by the total number of months of exposure. VI. FOLLOW-UP OF STUDY POPULATION A follow-up procedure was instituted for those who had left employment and whose vital status could not be determined at the local plant. A portion of the terminations was traced by mail, using a form letter sent to the last AP00023875 -7- known address. Attachment D shows such a letter. If the letter was re turned as undeliverable, the procedure shown in Figure 1 was used to obtain a current address. The remainder of the terminations was traced through a retail credit bureau. The latter was also done for a portion of those who could not\ be found by the mail follow-up. ' Approximately 5500 of the study population came from plants in which direct mail follow up was employed. In the remainder of the population follow-ups was by retail credit bureau. There was no significant difference between the success rates of the two methodologies. Table 1 shows the vital status of the study population as of December 31, 1972.. Follow-up is 85 percent complete, although follow-up data were still being received at the time the files were closed for this report. Of the 352 workers known to be dead, death certificates have been received for all but 24. The mortality calculations in the succeeding sections of this report are based only on those workers who were successfully traced, which is equivalent to assuming that mortality among those not found is the same as among those who were found. In order to examine the reasonableness of this assumption, the differences between those found and not found are examined briefly as part of the following section. VII. DESCRIPTION OF STUDY POPULATION Table 2 shows the distribution of those successfully traced, by year of birth and number of months of exposure. The median birth year was 1931 (compared with 1920 for those not found) and the median duration of employ ment in an exposed job was 80 months (44 months in those not found). The 5 -8- shortest exposures occur in both the oldest men, most of whoseworking life was over when vinyl chloride came into general use, and the youngest men, whose date of hire was closer to the closing date of the study. Although nearly half of the study population had less than 60 months of exposed employment, there were nevertheless 855 workers with 20 years or more exposure, and 1641 with 15 years or more. ' Table 3 shows the distribution by duration of exposure and the year in which exposure began. The median year in which exposure began was 1962 (versus 1953 for those not found) . Notice that almost half the study population first entered exposed employment in the decade 1960-69. This reflects the fact that a great many plants first began vinyl chloride operations in that decade and means that these workers have not been followed for any substantial length of time after their exposure occurred. Table 4 shows the relationship between duration of exposure and Exposure Index (El). The median El is 1.44 (1.75 for those not found). There does not appear to be a close relationship between the El and the duration of exposure, that is, workers with a higher El do not differ substantially in duration of exposure from chose with a lower El. One implication is that in assessing the relationship between mortality and exposure, both duration and level of exposure should be examined separate ly, as well as in combination. The' data shown above for those not found indicates that they were born (and began their exposure) about 10 years before the group on which follow-up was complete, and had about half the duration of employment with a slightly higher El. Typically, their employment in an exposed job ended before 1960. The bulk of these workers came from older plants from AP00023877 -9- which data were collected late in the study. Although there appears to be nothing very unusual about this group in terms of work history and exposure, it is nevertheless true that their exposures took place further back in time than that of the group success fully traced. It is therefore possible that their mortality, after a substantial latent period, might show a somewhat different pattern of mortality from the traced group. VIII. CALCULATION OF RISK OF DEATH The usual method of describing the risk of death in a study of this kind is to express the number of deaths which actually occurred as a percentage of the number which would have been expected in a comparable male population observed over the same age and time intervals. This statistic is called the Standardized Mortality Ratio (SMR). In order to calculate the number of expected deaths it is first necessary to calculate the number of years for which each worker was observed, and to classify these years of observation by the age intervals into which they fell and the birth date of the worker. Table 5 shows such a calculation for the 7128 vinyl chloride workers on whom follow-up was complete. This group represents 77,846 person-years of observation. For example, the table shows that for workers born in the years 1925-29, there were 2725 person-years of observation in the age interval 30-34, and an easy calculation show's that these person-years were lived in a period whose midpoint was about 1960. Therefore, the number of deaths to be expected in this cell of the table is the number of deaths occurring in 1960 among 2725 males aged 30-34 in a comparable non-exposed population. -10- In the present study the U. S. male population was used as the standard of comparison, and the age-specific U. S. male death rates for the appropriate ages and years were applied to the corresponding cells of Table 5 to obtain the expected deaths.* This was done for all causes of death together, and for each of the 35 causes for which detailed mortality rates are published oh a national basis (omitting such causes as breast cancer, congenital malformations, and diseases of infancy). Table 6 shows observed and expected deaths, and the SMR, for each of these causes for the total study group. In calculating the SMR's for specific causes, the 24 deaths for which no certificates were found were assumed to have the same cause distribution as those for which certificates were available. In the standard population, each SMR would be equal to 100. Therefore, the statistical significance of the deviation of each SMR in the study population from the expected value of 100 was tested. A single asterisk indicates those SMR's which differed significantly from 100 at the 5 percent level, that is, which had a probability of .05 or less of occurring by chance. A double asterisk indicates those which were significant at the 1 percent level. SMR's based.on fewer than 5 observed 2 cases were not tested for significance. The practical interpretation of these statistical statements will be examined below. Each diagonal in Table 5 corresponds to experience centered around a given year. For the first three diagonals (from left to-right) 1950 rates were used; for the next-three, 1955, 1959 and 1965 rates were used; for the last two, 1967 rates were used. Large-sample tests of significance were derived from: C.hiang, C. "Standard error of the age-adjusted death rate," Vital Statistics Special Reports, 47 (1961) pp 275-285. A I 0( -11- Table 7 shows the same SMR's for workers with an Exposure Index below 1.5 versus those at 1.5 or above. The dividing point of 1.5 represents a level halfway between "low" and "medium." Table 8 shows similar results for workers with less than 5 years exposure versus those with 5 years or more. In order to examine the possible interaction between duration and level of exposure, the study population was divided into 4 groups on the basis of both El (low vs high) and duration of exposure (short vs long) using the same dichotomization as Tables 7 and 8. Table 9 shows the results for short versus long exposure in the low El group, and Table 10 shows the same comparison in the high El group. In each of the above tables, deaths for which certificates had not been received were assumed to be distributed as a uniform percentage of all causes. The cause specific SMR's were therefore adjusted upward by a percentage which varied in each subgroup. Table II shows the distri bution of uncertified deaths in each group, and the resulting percentage by which the cause specific SMR's were increased. IX. ANALYSIS The overall mortality of the study population is statistically significantly lower than that of the U. S. male population. There were 352 observed deaths compared with 467 expected, for an SMR of 75. Table 6 shows that no specific cause of death was statistically signi ficantly greater than expected. Several, particularly heart disease, accidents and "other diseases" not detailed in the tables, were significantly below their expected values. -12- When the study population Is divided according to length and duration of exposure (Tables 7 and 8) and combinations of these measurements (Tables 9 and 10) three major patterns emerge. For malignant neoplasms as a whole, the SMR increases with increasing exposure, whether measured by level, duration, or both. In the high ex posure group with 5 years or more exposure (Table 10) there are 36 observed cases and 26.11 expected. For cardiovascular - renal diseases as a group, there are also increases in the SMR with increasing exposure, but the number of observed cases remain leBS than expected, the differences being statistically significant in all groups except the high exposure, long duration group in Table 'll. For all other causes, there are no consistent relationships with exposure Within the malignant neoplasms, the largest (although not statistically) significant SMR is in cancers of the buccal cavity and pharynx, with 5 observed, 2.84 expected, and an SMR of 189. However, Tables 7 to 10 show that all these cases have Exposure Indexes below 1.5, and 4 out of the 5 have less than 5 years exposure. Cancer of the digestive system shows no excess in the study population as a whole. However, in those workers with Exposure Indexes of 1.5 or higher, there are 12 observed cases where 9.14 are expected (table 7). In the'subgroup of the above workers with 5 years or more exposure, there are 11 observed cases and 7.47 expected. Respiratory cancer shows a slight excess in the total group, and a similar pattern for different exposure categories, with 13 observed versus 10.28 expected when the Exposure Index is 1.5 or higher, and 12 observed versus 8.50 expected when, in addition, the duration of exposure is 5 years -13- or more. Malignant neoplasms of other and unspecified sites show an excess in the total group, and an increase with both level and duration of exposure (Tables 7 and 8). The relationship with exposure is more pronounced, since those with exposures of less than 5 years have fewer cases than expected. The lymphosarcomas, although occurring at about the expected rate when the whole group is considered, are concentrated almost entirely in the high exposure long duration group. In that category there are 4 cases observed and 1.84 expected. Cancers of the genital and urinary organs, and leukemia, have fewer cases than expected. The number of cases is too small to examine any trends. X. DISCUSSION The favorable overall mortality of the study population is a phenomenon commonly observed in working populations. Studies of several occupational groups have shown that, even if there is an occupational hazard which greatly increases the risk of death from a particular cause, the overall mortality may well be favorable. Table 12 shows the SMR's obtained in a number of recent studies of other occupational groups. Although for technical reasons these SMR's are not strictly comparable, the overall mortality in the present study is clearly favorable. SMR's which are higher than expected may be worthy of attention even if they are not statistically significant. This is especially true in the present study since the number of deaths from many causes is quite small, and even a relatively high SKR may not reach statistical significance. If, in addition, a particular cause shows a consistent pattern of increase with exposure or estimated exposure, the findings are particularly >* AP00023882 -14- inter es ting. By these criteria, mortality from digestive cancer, respiratory cancer, cancer of other and unspecified sites, and lymphosarcoma, appear to be related to exposure as estimated in this study. In view of the association between vinyl chloride exposure and^angiosarcoma of the liver, the digestive cancers were examined further to see what contribution angiosarcoma made to the observed mortality pattern. Of the 19 digestive cancers, 7 were liver cancers, of which two were angiosarcomas according to the death Certificate. However, among angiosarcoma deaths in vinyl chloride workers identified by other investigators, there were 6 which occurred in the present study population during the study period. They were all found in the course of the study, but 4 were listed on the death certificate as due to causes other than angiosarcoma. Table 1-3 shears* these dccth" vitV. the- death certificate If there had been no angiosarcomas, Table 13 shows that the total number of digestive cancers in the high exposure group would have dropped to 8, and the number with high exposure and 5 years or more exposure would have dropped to 2, so that the mortality pattern in thi3 cause group is due entirely to angiosarcoma. The other cause group worth further investigation is cancer of other and unspecified sites, both because it is a heterogeneous category and because it 6eems, unlike the other cancerB, to be more related to duration than to level of exposures. Table 14 shows a list of the specific causes included in this category, which is essentially brain cancer and generalized cancer with primary site AP00023883 -15- unknown, About 40 percent of the observed deaths were due to brain cancer. In the general male population, about 22 percent of this category is due to brain cancer, 60 that not only is the mortality from this cause excessive, but brain cancer is overrepresented. The possibility exists based on the lack of specificity of some of the listed causes that some of the brain cancers were not primary, but metastases from another unidentified site such as the lung. The cancers of the buccal cavity and pharynx are difficult to explain because of their occurrence in the low exposure - short exposure group. It is possible that this is a chance occurrence, or that exposures to other substances were involved. XI. POSSIBLE BIASES IN THE CALCULATION OF RISK There are three areas in which bias could have entered the calculation of the above SMR's. The first is the choice of the U. S. male population as a standard. The second is the absence of 15 percent of the population who were not found. The third is the discovery, as the study ended, of a group of 1500 workers whose exposures occurred up to 35 years ago, and who are not included in the study group. The choice of the U. S. male population was-not entirely appropriate. The study population was concentrated almost entirely in the Eastern half of the United States, whose normal mortality is slightly higher than that of the whole country. This implies that the correct expected values should have been slightly higher than the ones which were used, and the corresponding SMR's slightly lower. This has no practical significance except for those malignancies in which the SMR's were above 100. However, regional differences in mortality from those causes is such that these SMR's would have been at most 1.5 to 3 percent lower, with no substantive difference in the results. !! -1(.- The workers who could not be traced may conceivably contain a dispropor tionate number of deaths, which could increase the overall SMR. It appears un likely that the distribution of causes would be substantially different. How ever, without actual data in hand, the possibility cannot be ruled out that either some new causes of death might become significant, or that some of the relationships found in this study might be diluted. The same comments apply even more to the group of 1500 workers discovered too late to be included in the study group, since they would provide data in precisely the area (very long exposure and long latency) in which the present study is relatively weak. AP00023885 References: Archer, VE, Wagoner, JK, Lundin, FE, Jr: Cancer mortality among uranium mill workers. J Occup Med 15:11-14, 1973. Enterline, PE, DeCoufle, P, Henderson, V: Mortality in relation to occupational exposure in the asbestos industry. J- Occup Med 14:897-903, 1972. Enterline, PE, Kendrick, MA: Asbestos-dust exposures at various levels and mortality. Arch Environ Health 15:181-186, 1967. Hammond, EC,. Selikoff, IJ: Relation of cigarette smoking to risk of death of asbestos-associated disease among insulation workers in the United States. Symposium on Biological effects of Asbestos, Lyon, October 2-5, 1972, paper M6. Lloyd, JW, Ciocco, A: Long-term mortality study of steelworkers; methodology. J Occup Med 11:229-310, 1969. Lundin, FE, Jr., Lloyd, JW, Smith, EM, Archer, VE, Holaday, DE: Mortality of uranium miners in relation to radiation exposure, hard-rock mining and cigarette smoking--1950 through September 1967 . Health Physics 16:571-578, 1969. Redmond, CK, Ciocco, A, Lloyd, JW, Rush, HW: Long-term mortality study of steelworkers~VI. Mortality from Malignant Neoplasms among coke oven workers. J Occup Med 14:621--629, 1972. Tabershaw, XR, Cooper, WC, Balzer, JL: A Labor-management occupational health service in a construction industry. Arch Environ Health 21:784-788, 1970. APOOO Table l Follow-up Status of 8384 Vinyl ChlorLde Workers Number Percent Total 8384 100.0 Alive Dead 6776 80.8 352 4.2 Unknown 1256 15.0 \ Death Certificates Rec'd. Not Rec'd. 328 24 92.7 7.3 April 15, 1974 AP00023887 D is tr ib u tio n o f Months In Exposed Employment by B ir th Y ear, fo r 7128 V in y l C h lo rid e Workers w ith Completed F ollow -up <rc>*r u <CL. AP00023888 D is tr ib u tio n o f Months in Exposed Employment by Year in Which Exposure Began, fo r 7128 V in y l C h lo rid e W orkers w ith Completed F o llo w -u p g <N O 0 CM M c c 3 r-4 m Mf cn o vO m os cn O' cn m m i O o cn 4J M O' 3 Os v> cm Oi ao H^ CM U-4 o O' v) cn JS CM U1 co .o. 00 X r-< cn c-s ^ cn CM \D r^ cm fs 00 CM CM ^ r-4 in cn H vO o m CM n v tn so oo n* O' r-* os cn m CO r-< H 05 O' OS 1 f-< cn H VO CM cn v-t sj cn rs cm Os un <* 1 CM o VO sO Os rx r-4 cm tn os *o m m o n oo h in vO r-4 m ps. rx Os V h CM H flj u 0 H a X T3 CO 0) 4J PU to CO o iJ to in co cm co in n so h O os cn rs oo CM H h>. O' os O' C7S 1-- n vj m o n ii *i O oooo cn Mf m vo r> Os O' os os os "1 1--< t-J fM t-4 to U 0 (-> AP00023889 D is tr ib u tio n by Months o f Exposed Employment and Exposure Index fo r 7128 V in y l C h lo rid e Workers w ith Complete F o llo w -u p U nknow n ON ON co rn on r-4 -d o vD n Os m CO i o o co 0> u 3 Os <A <7\ O 04 0- l Xo 04 o to ON C m 4J 04 Ci oo 32 co H ON r-. 1 o 04 H ON pH 1 o VO CO H OI On co CM O' On to in CM h* On CM CM m v> to vO O 00 co VO GO n tr O ON Nt CM r- ON VO m ^4 cm n* r-< \D H vO ON f--i mc m O in vD h~ CM On V -^ r-^ CM r ! U O H 04 W 9X W 0) O "O a. c XM W cm r^. ON co in ro oo sf co CO CM r 11 r-% c 5 o t +c o in c H3 u O H AP00023890 Person Years o f O bservation by Year o f B ir th and Age f o r V in y l C h lo rid e W orkers A p r il 15, 1974 HOlCOT> sOMITNf* *xf--xti r--4 co m MJ" ITJ ON <o--nt< <OTn co i 1 ^ < CCOMvj CM om*- oh- *OOM-N*f S-rOHo3N- NvrrO-xfi cmo CoOMN CCi--MMi C0O0N in On O*c<o-N< <cO-oHn CfOCxMON m mr*. crxo CM rCrxxO co 0o0 2rOHoN cOHoN CmO--MN1 OCOMnn h 0cM0f C--Mi __fax r--< . &*-* 0 -s* vC3OM*3 cN0Oo0 scrOx n in rx CrinMx CCCMOO iCfnxM CM nCCTOO> ro ro vO 00 OVsCMN* ^COr-Mnt in 1-- oCO ooON r-4 CCOO *4 CM CVrxM? CM CM om ro rx 0co0 vrcx> JS in On uH ON On r-4 0CO0 2 d OcoN m cn cn mO \mO0O 1-4 st CoM e4 CsCOMO oo fx CM CM O sj- O rO.--HN4 Or-| n *- o t~x4 VO CM co xnCOMt rx vODN C0OM0 r-4 nCCOMM r-4 Hrinx NCNOOO ed CO CM m o oon < IS ^ H in in n M3 Mf r--4 r4 CrsM CMmMf c 1r-x4 NCrxOM CNOO en CCoMMn vO O xf on on f-4 r-4 CM NO -4 n orx CM CO <o cn NO co CO rx CM mOn OONn 00 CO r-< r-4 iornx m vl> in in co vinn CM OCM rx r-4 r-4 ^4 r4 COOOn sOfn qo --4 _| rx 4 <o mro CC3O0 rrxx vCOM CO CM ioonoo ooCOon CM --4 CCMM mCO CO o CM m Oooop So03o0 COMN H<r CM CCMO mr--4 o t--4 m AP00023891 OBSERVED DEATHS/EXPECTED DEATHS AMD STANDARDIZED MORTALIT T RATIO S IN V IN Y L CHLORIDE WORKERS `"l-SMR's a d ju s te d fo r deaths w ith cause unknown. See T able 11. s ig n ific a n t at 51 le v e l. S ig n ific a n t at IT le v e l. AP00023892 OBSERVED DEATHS/EX PECTED DEATHS AND S. jM R D IZ E D M ORTALITY RATIOS I S V IN Y L CHLORIDE WORKERS BY ESTIMATED LEVEL OF EXPOSURE AP00023893 SMR's a d ju s te d f o r deaths w ith cause unknown. `s ig n ific a n t a t 5X le v e l. " S ig n ific a n t at IX le v e l. See T a b le I I . OBSERVED DEATHS/EXPECTED DEATHS *ND STANttiRDIZED MORTALITY RATIOS IN VINYL CHLORIDE WORKERS BY DURATION 0? EXPOSED EMPLOYMENT SMR's a d ju s te d f o r d e a th s w it h cause unknow n. See T able 11. S ig n ific a n t a t 5L le v e l. *S lg n ifle a n t at IX le ve l. o> to X. B O. s0 K0 cs ox so o> V ^01 tt , OO^^NNf'5O'O<-N`^NnScoHcvOOfNn*i-->co0^'Cy3O0y'rONnOhOOOcmOo'NOosMOOOOsoO^nntoo00 --nsssss32si"as^2s"5 f*- VO CO .................................. CO I o ^v w' *0 O N O o mv --* c^> * cm n 1-1 m in to to it2onO'MOB' ^NnONMrtONOO*N-< OrO-4 fi4C> <nt c-o *3 OO2!S'?'0e'eClo5",iiO5'oOnOOrt>oci"C intn o- c o nt s r^o'\o<nsooooN cm a-i on m * r* vc cm ocn^NnooN-j^NeoCM^^HfsOj woonHOCHHOHjo.^ioH in > CN CN *0 ** w> SO **s CM OS o Os tA 1 U7 k i iM r> CM md 1 <N Os st o Os CM tr tn Os t M o CM Os to < .' CO ^* AJ s <Oo CO Va 0- sO 00 to 73 <9 f-4 H 75 44 Sm;Sw o c C 75 ab t 1 4) o ^4 H AJ AJ to ^s w ttttoooo9*41 ruO0o9-ii si4> H0 O S/ O H X4UU334 (.< 0 s r* CO *4H o C w m4 B n aj Sw/ U 44 <0 B n 4) a ^ i S n n a X to n C c n UU <Q B 0 r< > 0u o uxtuotuos ^0> 0AfJl O H O ^ 7fBl3) E J0S n 75 * 0 4MJ UMU U UO C in v 44 0. *H B U CN O u 60 O B *r4 JS ^ O CM 3 w 44 0 U AJ *H *04 J3 M E 73 V< M 0 O 0 - " - - B nBnEEn Bn Ein S4i AJ . <^s. O sD V) V) J Qne)n44ia <oslr4WCwM su> roOi. o. bo. op ao. o cb -ao<* 4p4 01 C 44 C V 04 C 44 75 C C04 004 AJ AJ AJ U AJ AJ <0 G(ot an e e ^04 AJ <c9 C *tHo tco M c 60 M cc 00 to m cto a 0 01 0 HHH HH 3 3S5SS.S to *J q w to 4J to jz t DO UO Nn #i fnl Mu N<r N m 0 44 *H0 C h4) 73 ''e0 s-' Ot!Co 3o aV M BH AJ 44 4) U c u0 44>44) 75 AWJ * *H n MO*it '-- W (4A4 wAJ 73 4) *9J) aCj rU-4 oa siMm * Ui e --o4 Xu s^4 0 V> 04) <OT4 AJ Aa 44 703 e4) 73 AJ W00 JC n 4' Mvitj 0 00 0*4) 75 0 ~>r4 H c44 0 w4C> $ u< ` 0 u Q. O 4e4 CO c44 7MV9 <*4 3735 +u0DM4. c0 upB4 6 oC e00 e& 0B0 U*M>d0cNc04d 70<34 A045B(A4J <A4 0 u0u-4 to Oi w 7vACC0a0H34J44. 3" |0 4J in vom0 iMou 7e3 7o0C5 75 #-s 44 J-*N v4Cwa) /voninoi nio 75 -4 <t AW0J 446J) OV*4 HH 303 -0W40 tO 00 _< AA00B0HJJ 0 44 . v0wo << AoJ* w G 44 44 > 7O3 HvA 0 0) AJ *(J9 O U a. IM O no) 73 4) AJ <C4 So>4 fBtj >s 7*M3 *J 44 U *h a o4 0(J 0 C 09 44 O oto ^S m O CsSi 't-o'OI o r>. os M Os AJ * <r 73 'M 44 **4 4) r> so 70B5 0 A0 > 0 0 M 73 <OH nun * i* j- uw4 oi q do ma noE J3 aj 4> U u jz u u 44 uo CL uo QtMj UWo4( atBs VB>,)HH<4OJ *d-<M>3 ows 44 W (J 44 7434 u 7^5 *ori JOJUC *t3UoH vOB< 0) U AO>i UO-i ^(9 >I> Sg I 2 AP00023894 OBSERVED I IITHS/EXPECTE3 DEATHS ID STAHDARpIZED MORTALITY RnTIOS IH VINYL CHLORIDE WORKERS .TTH EXPOSURE INDICES BELOW 1,5, BY DURATION OF EXPOSED EMPLOYMENT AP00023895 SMR's a d ju s te d to r det s w ith cause unknown. See ta b le 11 S ig n ific a n t a t 5% leve S ig n ifica n t at IX le\ IOBSERVED DEA S/EXPECTED DEATHS ND STANDARDIZED MORTALITY RATIOS IN V IN Y L CHLORIDE WORKERS W IT EXPOSURE IN D IC E S OF 1 . 5 OR GREATER. BY DURATION OP EXPOSED EMPLOYMENT I Il-SMR's a d ju s te d fo r deaths r lt h cause unknown. See T able * S Ig n lfic a n t a t 5% le v e l. **S lg n iflc a n t at IX le v e l. AP00023896 D is trib u tio n o f Deaths by Exposure C ategory arid by W hether Cause o f Death Was D e te rm in e d , and C o rre c tio n F a c to rs Used f o r SMR C a lc u la tio n s QJ >4 3O in in to o> vO 0 At 1-^ CL r4 -< X Al X) w in CM rj O u o m vO co cn o 00 m lO H in JZ Al CM 3 4J dc n o X lA vO CM oo QJ c M o *p4 c> n4 CM cn c cn M V Xi QJ eJ QJ UU o 0a w in vO V vO CO 00 m d* VO to 4J a V t# TJ X ow QJ u 0) 0) o3 u J= w 3 4J 0 to a to CL o O AJ X cl z: ua X Wc o CO QJ to j_t o E h-4 V HH d" a-h co m CM CM CM avf oo vO in CA ah o Csl X 0) m ri * 3 --1 H* At QJ U 3 wo m CL 1-4 XV W a** vO --< m d- H ^4 m Ah CO vO CM CO a-. r"4 00 *H h to K r--4 0 CM CO vT cn 4J m CM CM O cn m Ah H c po in ? e QJ o .x in e d 3 2C 3 (0 o qj QJ tn H 33 T--4 < tf_l)j o QJ tn d QJ Ll uc H 1_> c pi 0) S u CO u QJ c PL ^4 0) oCot03nO) QcnJ ALtO00Jni)0 <u30 3cj coo utd O r3XcC u0 M-4 0 c tCnO ju=in 5 tQnJ 30) o JjO=j u0 U-f O C3L QCo> *3 tao *ocJ *oa d3o * 4c<3dJd HItQLoCQJn-JJOll eud LQJi X0o3ton)g QUJ 3X0toCn)L .0dd3x 33 hdh! tn JutZn *QtQdJ jz *333 Ah 1 cm tn AP00023897 Table 12 Results of Follow-up in Several Occupational Groups Study Population Number Years of SMR Observed Observation All causes Reference Asbestos building product workers Asbestos friction material workers 12,402 1951-1963 7,510 II Enterline 6 89 Kendrick, 1967 > Enterline 89 Kendrick, 1967 Asbestos textile plant workers 1,843 II Enterline 6 121 Kendrick, 1967 Cotton textile workers 6,281 It - 88 Enterline Kendrick, 1967 White underground uranium miners 3,414 1950-1967 Lundin et al, 159 1969 Steelworkers 59,072 1953-1961 82 Lloyd Ciocco, 1969 Asbestos insulation workers > -20 years 250 1946-1965 Tabershaw et al, 140 1970 Coke oven workers 4,661 1951-1966 98 Richmond et al, 1972 Asbestos maintenance service, etc. 438 1941-1969 Enterline et 124 al, 1972 Asbestos insulation workers > 20 years 370 1963-1971 Hammond 198 Selikoff, 1972 Asbestos insulation workers 17,800 1967-1971 Hammond 136 Selikoff, 1972 Uranium mill workers 662 1950-1967 99 Archer et al, 1973 Lead smelter workers 2,352 1946-1970 107 TCA, Inc., unpublished Lead battery plant workers 4,680 1946-1970 99 TCA, Inc., unpublished Petroleum refinery workers 18,916 1962-1971 68 TCA, Inc., unpublished May 3, 1974 AP00023898 A n g io s a rc o m a D e a th s i n VCM E p id e m io lo g y S tu d y P o p u la tio n me in Va) . o f>t)s 4) 0>V>)* I 3 l CO fSt)K 01 JA ft) ft) > > c ft) ft) 0) >w o l-l ft) > (0 r-4 ft). CO 44 3o eft O CO *H 0) O Jft Ui u v4 O Outo o Xa. w <n O CM to X W (ft o <n w 2 C o^ U Vi (ft f-( (X 0) O0 XX 14 S^ 0 iM ^u 44 to oo a G o) wc "d C 0) 0) 4) <ft MX CO CM V4 CJ > *4 *4 44 O ft) .) O 4-J u S3 xv 0 ft) 0) uo Cft 0) oo *4 r4 60 w C < m i-4 MX >-, eft XM *r4 ou a. 1-4 MX U ft) ft) > W **4 3 -4 -4 >r4 U4 0 O 44 U U ft) 0) u >B *r4 B J o eft ft) >0 *4 U CO U CO eft <0 to EO W *o 60 c (ft XM B <0 xv to ft) C U a s4 cd d MX 4J eft 0) 0 3 4J Mf a X (0 MX E eft eft * Cft u 4J U 4J o ft) ft) *c E > CJ u *4 eft *4 oe *-m i-4 'a 0) a) U4 u eft 43 *d 4 o U* CeOn CM u ft) > r4 i-4 eft - ft) o UG 3 *r4 ^4 o *t4 )4 eft eft U4 ft) u v4 u U$ CO p a* -h ft) SC au, MHl CM juC QCftOJ VA Cft ft) 2 O vO CMOT * CCOA CmM en o ss o > m m m m M3 CO c \o r o CM CM r*- m m 43J mT o- m r- CO m 0CO0 r>* \ cr in <ua AP00023899 0 o 0 a o a >s a 3 Xto o a. w 6 > -sr rH 0 ft) w H A o L4 * O' Or4' 1 c O' v> ft) t4 O c <0 r--re6H4t0 X Li ft) JLZJ o 5s w a o 0) u >> - o d O) o 5ft)s c o OM 0 C ft) >N ft) c *>r4 os 0 ft) to 0 3 0 o6 c 0* r-l y ft) 0 5 X> LI 0 <0 E O e 0) r0--4 e <y 7<aW3>t -B b t(n0l aofts) 5s H 4 -< 7w3 rn-fl St X t0? ft) u a CO a) o > AHJ > eft OE c r(4ft a) v)' E 4J onftsj) 0 -u co en 000 ueft *h 2 ^0 6 X cn 0i-t (ft X u(ft JO o1 E ft) '*CWO' /-s r-l . Hw-l or4 UM >, e o rl L> u 2E 0 0 0 ft) *or4 O E>c r4 O ft) C Xu uu U a (4 V(ohft/ 73 0 ^0o aoi 0u Lf 0 (ft m 0O 3B 4J U T-l E O E Cu A X (0 0 *T-I eft *0H 0 73 f0t) 0 B 14 A ft) X a. w wcm (Lfti X Uft) Q) o llWi ft) r4 1 4J 0 0 bHo u>s r-l 0 -4 E^ r ft) 0W S ft) O X! u CL >t (n o 0 p 6o U J0 (ft < c o <n ft) 00 o0 u A ft) Xu H (0 U4 o u o TO r--ft)1 o E (ft 00 0 rl 4 u o P uft) O0 u < Eu VoM r4 4J -4 3 E 0 Ho *4 <ft X 0rl r4 to Li /*\ O Sw 30 B *0r4 0r-0l 0W Li A <""S (ft O E 'CwM' iJ 0 0 0 OO f-r44 0 E r Li O B L0I 0r4 uCIS A (ft ft) (0 L0J (ft 40J a) E uX C 0 u r4 0> rA4 r-4 0 5 00 E M 0rl 0 L L O0 Es y, 4J 73 H *0r4 0 U 0 L -C AH Carcinom atosis 753s O o cwd O ft) 239 o fwt) o 0X vO bl 00 to o X mO O' VO >0 vO CTi <}* CM 5769 52 xU: 0ft) A u c0n0 0 qj OO : soof m VA O<r o X G <orv-r. 3 CM O vO vO o O' rr*> o O' CM m cs CO O O o 00 Cf Ml- O' O r-l vO fs. o S c CM cs r-> l>H AP00023900 (0 CL 0 O 4) c xj > t < CO V) u .4 0 0 XJ B G H Vi cn C. x w o XJ 1-1 Vi (0 00 <0 H CO CO B Vi o -G e 4) 1-1 iJ 4) >4 a to Vi 0) u co i-l O CO C XJ X oG u 4) CO lx u O > eo *9 rt i-C C u o xj B 4) *-1 XJ 3U U cO JG rl XJ U 4> U u /-N CO co <o -C XJ CL x; m r-X CO V. XJ V4 4-4 V/ a> >N CO * G Vi CO rO w ** i-C 4J Vi TJ XJ 1X >1 CO CO V 63 AS <0 o u 1-4 Q CO <u V> CM >% -w* B B XJ U l4 U Vi a O 2 to *o 0 O CO CO u B 1-1 V XJ M aj CO Vi o JC 03 a CO y. u O <9 5 o CO Vi o a. e CO n-< 0 a 0 H vX Cu (0 o u c CO >> o a >N a; CM a i-i V J4 CO CO Oi >-j o V^ Vi W X, o 3 0) etf i4 5 CO 4) N 1 Vi V 4) CO tu 6 44 i-t i4 V( o Cu c 3 <0 (0 'rX O CO c CO *w o XJ u 41 (0 CO Vi G CO O CO iX XJ B u Ci Vi 6 f** 1>X 41 w r4 XJ T3 41 4J 4) XJ 0 XJ *) ft) G i4 XJ CO 3 H CO 3 u0 *H O ft) U XJ aj G CO iX c 4J 3 (0 4) cr O C/3 t jj G s E 0 T3 X *o CO AaJ 44 i4 O6 Vi ecC AJ CO EU 0 41 <v c T3 to ox c >v o 3 J3 Vi a fO QJ g u XJ A) 1-X u CO ts i4 U XJ <--* cd CO CO G XJ u O CO 1-1 E CO XJ r-* 2XJ i4 4J u Xow a 4J c -W (0 E oC E a> XJ J v/ *3 G CO 3 i4 CO ft) o XJ XJ v4 (0 CO E 0 >1 Gu H CO uE V. 1-C 3 Vi &4 y-v XJ G O so-/ CA 4) i-C U<- 00 i4 *4 -3- H S3 4) Vi r--X A) ja JG CO H XJ o ft> to O W HO CM to o s pXCJ CO a; Q r> XJ \D co < 0 z vD *> MJ* TJ CNJ 3 CO XJ to rN o> 1-4 S)vO o tA GO CM o o to tn CO n r^ st H40 vO \Q CA -4 f-4 o> VO VO NO fA CO CO r>* hi Mf lA rO-Ni lA U cl < AP00023901 M a lig n a n t Neoplasms o f B uccal C avity and Pharynx (140-148, I.C .D .) in VCM E pidem iology S tudy P o p u la tio n A p r il 15, 1974 X CO ex. uo c 4 oc a to c CO rl <0 CO 9 to to ``s ao 44 (0 *> 44 Vi a 6 X -cH -O >w ij g^ to O O6 O lA (0 U a ^d w a. u *a id O (0 -rl 1-1 g id a to ^ *e9 u "O 9 O td g id O be X X B r**< B5 C9 u w o^ d d c^ C r-4 H 9 e h *u 0 ou c Uo 4o4 *"64 Vi g 5 zzz a w o a. x ov u W OCO X V) X 1 o H 1--4 CO 9 a. o gc o 9 CO n H u iM 44 X Vi 4J s CO H 44 Vai Vi X 4o4 4oJ .11 X 9 X Vl r4 E 9 c aa 4J 44 -r4 44 -1 44 /*> CO u v4 E E o c o E 4J E <44 44 c v_4 c wy 9 60 u E 9 E -I O 9H > c 9 >r4 H *r4 r4 E U 4J V* k 4-1 i^ C o Vi U l4 a. *h 1 X o 0 f4 44 V< e CM 6 .9 ii 9 9 << 1 X 44 E 00 V44 O 4O4 c -4 ^4 JZ C N u o i4 44 00 e o Vi C u u o u x Vi CO U u oS /--s jC G # C i4 a f-i i *o <4 UO o 9 60 M U Sg4 60 e u 4J u X' J3 U c *4 t-4 9 Vi 44 (3 |4 ^4 ^4 9. *4 0 CJ g U n4 Vr o w e O 44 9 a w 44 0 o M E 44 > 44 *9 H *4 9 44 I 9 Vi Vi 44 r*4 9* X 4J ^4 r-4 a 44 CO 15 c VO CM CU Q vXOT) m m 0) < r> vo o Ss CO Xo *9 494 on W --4 CO --4 c vO CoO X AP00023902 AP00023903 Manufacturing Chemists Association VCM Epidemiology Study Parent. Corporation Plant Designation Address Telephone _}~e*t TABERSHAW-COOPER ASSOCIATES' CONTACT FOR SUBJECT STUDY: Name Title Mailing Address Street Address (please identify with sufficient precision to serve as a taxi-driver's instruction) Telephone _J_____ )__ Signed Name Title Company Address Telephone ( ATTACHMENT A ext. AP00023904 Tabershaw-Cooper Associates, Inc. 2180 Milvia St., Suite 104 Berkeley, California 94704. Manufacturing Chemists Association VCM Epidemiological Study Plant No. \ 1. When did this plant begin work involving vinyl chloride? 2. What is the approximate size of the current work force, exclusive of secretarial and office personnel? 3. Approximately how many of these are employed in jobs in volving some exposure to vinyl chloride? 4. Please answer the appropriate one of the following questions about your retirement plan. a. No retirement plan b. Voluntary plan, begun in c. Required of all employees, begun in d. Now required, formerly voluntary. Voluntary plan begun in Required plan begun in Remarks:__________ '______________________________________________ 5. Please answer the applicable questions below about retention of records. How long are personnel records kept a. for those who retired but were not covered by a retirement plan? b. for those who retired under a retirement plan and have died? c. for those who quit or were discharged? d. for those who died while employed? ATTACHMENT B AP00023905 Tabershav-Cooper Associates, Inc. page 2 6. Do the personnel records which are retained contain a record of job titles and dates of job title changes for the Individual concerned? 7. Please list the job titles in the current work force which involve some exposure to vinyl chloride. ATTACHMENT B (cont.) AP00023906 VCM EpldemioLogical Study - Individual Work History Form B - Workers known to have died (please attach copy of death certificate) 1. Date of birth 2. Date hired ' 3. Date of death 4. Place of death Status at time of death: 5. Employed ________________ 6. Retired (give date) 'i 7. Terminated (give date) 8. If death certificate is not available, please give name of worker so that death certificate can be obtained. No contact will be made with relatives or attending physician. * Job no. Job history with estimated exposure Title l. ______________ from ______ to __________ 2 from to __________ 3 ______________ from ______ to __________ 4 from to ' 5 from 6 7. to _________ from to ______ . from to Check estimated exposure in ppm 450 50-199 200-500 >500 ATTACHMENT C AP00023907  tatqepshauj/coapep associates inc. 2180 Milvia Sired, Bcikeley, California 94704. Telephone (415) 845-3355 We are a research firm concerned with the health of workers in industry in the United States. We have been asked to study certain occupations in order to determine the health of men who have at one time or another worked in these occupations. To accomplish this we need to know if those men we are interested in were alive on December 31, 1972. For any of the men who died on or before that date, we need to know the place and date of death. With these facts, we can compare the health statistics of our men with the general population. To assist us, can you provide information regarding the person whose name appears below? A stamped, addressed return envelope is enclosed for your reply. Needless to say, any information you give us is strictly confidential. Thanks for your cooperation and assistance with this project. Sincerely, W. Clark Cooper, N.D. Name: Date of birth: Was above named man alive as of 12/31/72? If deceased prior to 12/31/72: Date of death Place of death (city and state) ATTACHMENT D AP00023908 The following is the status of the VC1 Abatement projects: y 1. REGULATED AREA The fencing of the regulated area is complete except for three personnel gates. Shipment of these gates has slipped and are rescheduled for installation in June. 2. PERSONNEL MONITORING Personnel In the Resin Plant were monitored on April 9, 14, and 22, 1975. Of the 39 operators monitored, nine had exposures exceeding 1 PPM as follows: Castleberry Timmons (Utility) Henson (Utility) Copeland Draffen (Utility) MacDonald Coleman (Utility) Hurst (Utility) Overbey 3.1 PPM 2.6 PPM 4.5 PPM 1.8 PPM 7.1 PPM 3.1 PPM 1.4 PPM 1.3 PPM 2.2 PPM All utility operators in the above list spent some time in reactors and were wearing fresh air masks. The Compound Plant operators were monitored on 27 March 1975 and all results were less than 0.1 PPM. These operators are on a quarterly monitoring schedule. 3. SOLVENT CLEANING A CE has been submitted for solvent storage, piping, etc. for Calvert City. 4. STRIPPER PROJECT A CE has been submitted for the addition of three post strippers and automation. 5. FRSH AIR HAVEN The control panel has been enclosed to use as a fresh air haven. This project is complete and will not be included in future reports. RECEIVED MAY 9 - 1975 T- cJiJREX AP00023909 / \ cdftk "T^uxtucti- and C6emica& * ___ \ INC. ; iV INTEROFFICE MEMORANDUM Date 26 February 1975 Rf?<n C. f ^h^r-r^EPA Meeting - Durham, N. C. 25 February 1975_____________ To Prom T. .L. Carey J* T. Barr cc: A. R. Adams R. C. Burnham A. J. Diglio R. Fleming ----' U -OfjvT,- (Location, Organization, or Department) i (Location, Of9*nizatiori, or Department) 1 R. E. Jones - Pensacola J. D. Kramer - Calvert City T. J. Medovich - S. Brunswick E. A. Primeau - Pensacola J. T. Sebastianelli E. Steck - Calvert City H. L. Watson SUMMARY 1. The Standards Group has sent to Washington recommendations to declare vinyl chloride a hazardous air pollutant and to proceed with setting a standard under Section 112 of the Clean Air Act. 2. A meeting of NAPTAC is scheduled for 25-26 March in Washington to con sider the proposed action. 3. The proposed standard will limit emissions at some sources on the basis of production rates and from others at a maximum concentration of 10 ppm. Control methods are similar to, but more strict than those discussed In my report of the 7 January visit. Surveillance methods are not fixed at this time. 4. Vinyl chloride in water will be limited to a maximum of 0.0043 lb/100 lb. PVC produced. 5. Proposed sampling methods include the headspace method for resins and the gas bag method for air. 6. Industry representatives presented their conments on the questions asked by EPA. (3201 AP00023910 T. L. Carey 2 - 26 February 1975 7. Several specific comments or pieces of information are to be prepared for use by the group, and a meeting will be held 21 March to prepare for the NAPTAC presentati on. REPORT The special subcommittee of the EPA/SPI committee met with EPA personnel in Durham, N. C., on 25 February to discuss activities related to the proposed stan dards on vinyl chloride emissions. The agenda prepared by EPA and a list of participants are attached and the numbering of the agenda is followed in this report. Mr. Don Goodwin, head of the Engineering Standards and Emissions Division, chaired the meeting. 1. He opened the meeting by stating that the final "package" for NAPTAC was almost ready and that the impact and health effects sections would be com plete in about two weeks. This will be presented to NAPTAC on 25-26 March in Washington. (Note the date change). The proposed regulation Is expected to be published In late June, with a public hearing following within 30 days and final promulgation by the end of the year. He forbade discussion on the decision on Section 111 vs. 112, or on health effects, on the basis that this would not the proper group for those subjects. A meeting for this purpose could be arranged later, but Ruckelshaus should handle this. 2. Item no. 2 on the agenda was a report by Ms. Susan Wyatt on current monitor ing nearplants. Each test site at B. F. Goodrich, Louisville; Conoco, Aberdeen; and Shell, Narco; has 15 samples taking 24-hour integrated samples by the carbon tube method. One site has a Bendix FID operating on a 2.5 minute cycle and reporting hourly averages, and all sites have a meteorology station. The 24-hour samples are taken twice a week, and they have T5 from each plant. The highest reading reported so far was 10 ppm., found between two storage tanks at Shell. Shell confirmed the high concentration but could not relate it to an unusual condition. The next highest reading was 1.42, also inside a plant. Most of the readings have been below 0.04 ppm. The 50 hourly averages had 4 above 1 ppm. This program is scheduled to continue until April, but may be extended. A similar program has just been started at 5 fabricators; Ford at Mt. Clements, Congoleum Nair, Reynolds at Richmond, Sylvania at Warren, Pa., and Charlotte Pipe and Foundry at Monroe, N. C. These each have 4 of the 24-hour samplers. No data are available. They are concerned that the recent reduction in production will affect the results of this study. We will get a copy of this test protocol. AP00023911 T. L. Carey - 3- 26 February 1975 3. The writer discussed the problems with using a material balance as the only method to control emissions, and presented the SRI proposal for a combination of process check points, ambient monitoring, emergency reports, and long term material balances, tailored for each process, as a preferred method for determining compliance. Comments by EPA personnel generally supported the opinion that material balance was not satisfactory alone. This and the other presentations generally followed the outline agreed on at the meetings in New York on 11 February and Washington 18 february. 4. Les Evans stated that his source of information had been from the Section 114 reports of last year, follow-up questionaires to about 15 companies, and visits to 12 plants (those which he considered well-controlled). He has talked to Calgon, Chemical Design, Vulcan, Houdry and IGCI. He proposes best available control techniques in the following areas: Fuqative leaks Seals - double mechanical or canned pumps. Maintenance - purge with nitrogen or steam before opening any system. Institute a formal leak patrol reporting system. Car loading - purge to control equipment, use magnetic level Indicator. Leaking Reliefs - Add rupture disks and tell-tales. Sampling - use closed loop manifold. He would not estimate at this time the permissible emissions in this category. Reactor entry With installation of a gasholder, equipment purge, either water or solvent reactor cleaning, and reformulation of recipes to reduce fouling losses from this source can be reduced to a maximum permissible rate of 0.1 lb/100 lb. of PVC. Emergency Reactor Discharges Additional instrumentation and control, including shortstop, plus vent connections to the gasholder and emergency power will eliminate this source, and no discharge will be permitted. Recovery Vent Use of solvent or carbon systems, Incineration, or refrigeration AP00023912 T. L. Carey -4- 26 February 1975 should reduce this stream to a proposed maximum of 10 ppm. Blend Tanks and downstream Proper stripping will be required, and plants will be allowed a loss of no more than 400 ppm. monomer in resin as measured by the difference from the stripper exit to shipped resin. Composite analyses of each grade will bp used. Any monomer measured from or destroyed in exit gases could be credited. Aqueous streams Flow and concentration of each stream must be measured and controlled before going to an open system so that total exit levels are below 0.0043 Ib./lOO lb. of PVC. He still believes that there are feasible methods of treating dilute air streams to recover monomer, but did admit that these were not demonstrated. 5. It was stated that most, but not all suspension, bulk, solution, and latex products can now be stripped to 400 ppm., dry solids basis. Dispersion ... resins cannot be reduced below 2000 ppm., on some types only, and with significant productivity loss. It was estimated that 2 - 2.5 years would be needed to equip all suspension plants, and 4-5 years for dispersion plants, to achieve these levels at full rates. Goodwin said he was not worried about productivity losses. 6. It was stated that Industry did not believe that incineration, carbon absorption, or solvent adsorption would be suitable except on a very limited number of small concentrated streams. 7. It was stated that recycle of drier exhaust was not feasible because of corrosion, heater fouling, and energy costs, and that reduction of drier exhaust flow would not effect monomer emissions.. 8. Mr. Bill Grimly presented the information in the attachment titled "VC Source Test Method Background". He favors the .qas bag for air samples and is Inclined toward the BFG Perkin Elmer headspace method for resin analyses. He was told that this latter method was not proven for slurries, copolymers, and emulsions. We asked that we not be restricted to one method, and were told that EPA would specify the standard or referee procedure. 9. Mr. Bill Hamilton presented the preliminary cost estimates for control systems given in attached Table I. These are for their "typical" 150W Ib/yr. plant using 5M gal. reactors. Net costs are based on a value of lOi/lb. for monomer, and the figures reflect his estimate of a 5% overall Increase in efficiency of the plant with controls. Objections were raised to most of his numbers. AP00023913 T. L. Carey 5 - 26-February 1975 10. Ms. Wyatt presented the attached chart of impact effects from the proposed control devices. The first four were given as small in actual impact, and she stated that solvent cleaning was undesirable because of all the associ ated problems. She did say these estimates are preliminary, and can be improved. Energy cost for prolonged stripping was given as 50% more than the present standard procedure at 170F. Incineration was estimated to increase total energy consumption by 50% in a suspension plant and 400% In a dispersion plant, and still leave 10 ppm in the effluent. They admitted incineration probably was not practical, and that their data on carbon absorption are inadequate for proper evaluation. The solid waste impact is expected to be quite' high. 11. It was stated that true fugatlve emissions amounted to no more than 10% of unaccountable monomer and that a good preventative maintenance program with intensive personnel retraining were more effective than any other single item in reducing emissions. Industry generally is well along on the EPA list in response to OSHA. 12. It was recommended that specific equipment or methods should not be required, but used as found suitable. Each of the listed types has some proper applications, but is not universally applicable. 13. It developed that this referred to pumps, filters, etc., so it was stated that, with time, arrangements can be made to return this to the recovery system. 14. Analytical methods have been exchanged with EPA. 15. Union Carbide admitted to three runaway dispersion batches in the last 6 months due to relaxed cleaning schedules, and BFG spoke of "several"lost batches at Louisville recently because of reformulation experiments aimed at reduced fouling. It was predicted that little further advance would be made in this area. Emergencies beyond the scope of realistic protective systems always will occur. Connections to common vents or a gasholder for relief valves were stated to be unsafer. The two representatives of monomer producers met later with Evans and Goodwin. In summary they were told that fugative emissions would be placed on the same basis as at PVC plants (as yet unspecified) and that all process vents will be limited to 10 ppm. The industry group met later and agreed that the dispersion area required Immediate attention. Representatives of this business will meet 3 March to prepare more AP00023914 T. 1. Carey - 6- 26 February 1975 Information for EPA and try to arrange a meeting at Durham 10 March for discus sion. i Meanwhile, the committee will: try to obtain more data on the Connecticut cases, if it can be made available; prepare comments on the proposed water standard; comment on the control costs; and meet on 21 March to prepare a statement to be made at NAPTAC. JTBrfm Attachments AP00023915 TABLE I NET COST OF CONTROL DEVICES Source Fugative Reactor Recovery Vent and Slurry Drier, bulk area Total Device Several Gasholder1 Carbon bed^ Improved Stripping Cost $M 226 824 220 368 1,637 Without Monomer Credit i Net Annual Cost WYr. 4/Lb. 204 0.14 (489) (0.33) ( 29) (0.02) 94 (220) 0.06 (0;15) 530 0.35 !93M ft.3, 10,000 lb. capacity. ^Gas flow 60 acfm, enclosed blend tanks with small nitrogen purge. JTB 2/26/75 AP00023916 -A--G--E--N---D--A- , EPA and SF1 Heating - The Control of Vinyl Chloride Emissions from Polyvinyl Chloride Plants February 25, 1975 Durham, North Carolina 1. PVC Regulation Work Schedule HPA 2. PVC Ambient Monitoring Program EPA 3. Recognizing that source sampling to monitor total emissions from PVC plants is difficult to impossible - Discuss techniques of using plant material balances to determine emissions. (Sampling techniques, manpowerrequirements, accuracy, etc.) - SPI 4. Current Status of PVC regulation. EPA 5. Technical feasibility of reducing the vinyl chloride content of SPI the PVC resin from the stripper to 400 ppm dry basis. 6. Compliance schedules for installation of stripping systems at existing plants. Use of Incineration, solvent ebsorpion, and/ or carbon adsorption to reduce the vinyl chloride concentration of the dryer exhaust to less than 10 ppm. (Cost, capability.) SPI 7. Quantify the reduction in dryer exhaust gas volume that can be achieved by using fluidised bed dryers, flash dryers, and/or by recycling the dryer exhaust after removing the water and vinyl chloride. Discuss the factors that would control the rate at which these techniques can be installed. SPI 8. Source sampling and analytical procedures for PVC*. 9. Preliminary cost estimates of controlling PVC plant emissions. EPA EPA 10. Environmental impact of PVC plant regulation. EPA 11. Status of installation of control equipment to restrict fugitive emissions in response to OSHA regulations. SPI 12. Use of canned pumps, or double mechanical seals on pump, agitator, and compressor seals to reduce fugitive emissions. SPI AP00023917 AGENDA EPA and SPI Meeting February 25, 1975 Page 2 13. Feasibility of purging all vinyl chloride to the monomer recovery system or to a carbon adsorber; incinerator or flare before opening process equipment for maintenance and inspection. 14. Sampling and analysis techniques to determine the vinyl chloride content of the resin after stripping. 15. Use of alarm systems and shortstop to eliminate reactor pressure relief valve discharges or to eliminate such discharges by venting the reactor contents to a gasholder. SPI SPI SPI C c* * AP00023918 _i Roster 2-25-75 Meeting on Vinyl Chloride Don R. Goodwin George W. Walsh G.W. Daigre W.W. Madden J.T. Barr Jos. E. Hadley R.W. Laundrie W.C. Holbrook D.A. Scholes R.H. Wheeler L.B. Evans Chuck Kleeberg Bill Hamilton Bill Vatavuk Susan Wyatt Jack Farmer Bill Grimley Albert J. Beveridge ~1 Gary H. Baise _J Jim Durham Stan Cuffe Director, ESED EPA , ESED Dow Chemical, Plaquemine, La. Firestone Plastics Co. > Air Products & Chemicals SPI General Counsel General Tire B.F. Goodrich Chem. Co. Hooker Chemicals & Plastic3 Union Carbide Corp. EPA, ESED EPA, ESED EPA, SASD EPA, SASD EPA, .ESED/SDB EPA, ESED/SDB EPA, ESED/EMB Ruckelshaus, Beveridge & Fairbanks Washington, D.C. EPA, ESED/ISB EPA, ESED/ISB 11 i i r .* I AP00023919 e 0363000dV S*tS c. m <U o. t5 N.. <- $ ir\ i i ! K- S t; cn *sr* -J LU H- CO Ur >CO- -o ^ c< =o -1 o i< C Z3 3o JQ J LU -O M CO -CJ HCJ- 3< IT , 2 QJ UM (/) ro o r- CL <c CL gr z: 0> 4- LiJ lA <M SI o 3: Ons oj C o E o co O? +4 iU CJ> <0 Q. o r- +4 +fO4 P- *Ola3O! "OIO M6 U f-- c o r-r Qi u3 h- I-- ::: co oO >co- <>u oc --to I- *r- o P W L cnn*pM- +cJ oEo LL U4 CJ C. 4C-D5 rsr Eo) ^5- +C-> o> >> "O CO O 0) -G CD LA CfO 3 CD CL 0) > fS LA ->D0 OS- O) 4-> *4- C CO3 COJ i- 4-5 cCn O C *r- +C1J C>J fcO fO OJ U> O r-- OC CO O *3 c QJ > >> Q. O i- C_ i. S- -r- O. 3 C f-- 4-> t--I CO CO c o 4- 4-> C CL Q) S~ 5* O r-- t/j O -O CO < c o H3 4J i_ l j (U 0 0-0 g .= -a r- -M 3 O T- L. C3 U oc ro c. S- cu C0) -G JO -Q f 44 3 O -r- i- cs u H-4 UO Co 44 C Q. ou 4&3- Oo <3*5 i VC SOURCE TEST METHOD BACKGROUND For stack sampling purposes, vinyl chloride (CH2 = CHC1, molecular weight 62.50} must be assumed to exist in conjunction with other hydro carbons, both chlorinated and otherwise. Accordingly, the accepted method for VC (vinyl chloride) analysis has consisted of first separatIng the VC from other hydrocarbons, followed by measuring the quantity of VC with a flame ionization detector. However, between various groups concerned with measuring VC, non-uniformity In procedures was found to exist in the following areas: (1) sample collection, (2) Introduction of sample to gas chromatograph, (3) chromatographic column and associated operating parameters, and (4) chromatograph calibration. Two of the approaches for VC sample collection involved an evacuated flask for grab samples and tubes containing activated charcoal for an integrated sample. Since it was established that a two-hour average concentration was desired, the integrated sample approach offered a greater advantage over the grab sample approach because emission fluctua tions due to process variations would be automatically averaged. In addition, the integrated approach naturally minimizes the number of samples that need to be analyzed. Upon investigating the activated charcoal sampling tubes, it was found that they were basically designed for sampling ambient concentration levels of VC. Since source effluent concentrations are expected to be higher, there was the uncertainty Involved with predicting sample breakthrough or when the sample should be terminated. In addition, the amount of charcoal that would be required for some sources would be excessive for a two-hour sampling period. - -rr~ --r---------------- -- ~ ' | AP00023921 In view of these deficiencies, it was decided that collection of the sample in Tedlar bags might be a better approach. To check the flexibility of this approach ?. study of VC stability, or deterioration in Tedlar bags in the presence of various process-associated gases was undertaken.^ The study showed no significant deterioration of VC over a period of 48 hours. Consequently the integrated bag technique was deemed suitable. Introduction of a collected gas sample to a gas chromatograph can be done either through use of a gas-tight syringe or an automated sample loop. The latter approach was selected since it has less possi bility of leakage and provides a more reproducible sample volume. Several columns, used by the various groups, are mentioned in the literature as being suitable for the separation of VC from other gases; most notable among them have been Carbopak A2 and Chromosorb 102. 3 Carbopak A is the more sensitive of the two; however, the VC elution time is not as great as with the Chromosorb 102. For this reason Chromosorb 102 was selected for further study. A program was under taken to establish whether various hydrocarbons that were known to be associated with VC in stack emissions interferred with the VC peak from 4 the Chromosorb column. The study revealed no such problems. Further more, analysis of actual source samples of the peak reported as VC with this column by two qualitative techniques, spectroscopy and elec- 5 tron capture, indicated the peak was only VC. It should be noted that selection of Chromosorb 102 does not mean that Carbopak A or some other column(s) may not work equally well. AP00023922 Calibration has been accomplished by two techniques, the most common being the dilution of 99+" VC with nitrogen into a series of lower concentrations in Tedlar bags. The second technique utilizes a set of cylinder standards. Both techniques have been found to pro duce acceptable results and will be included in the reference method. Based on the study of VC stability in Tedlar bags, possible inter ferences by various process associated gases, and calibration methods, and as a result of a field study and tests conducted at a source of vinyl chloride, Method 104 was prepared for determining compliance with new source performance standards. This method is essentially the same as used for the data gathering process for setting the standards. Leak tests for the flexible bags and calibration procedures to Insure accuracy, precision, and reliability are also specified. v5 I: V'l I '; ! '- . AP00023923 REFERENCES 1. "Evaluation of a Collection and Analytical Procedure for Vinyl Chloride in Air," by G.D. Clayton and Associates. December 13, 1974. EPA Contract No. 68-02-1408, Task Order Mo. 2. EPA Report Mo. 75-VCL-l. i 2. "Vinyl Chloride Monitoring Near the B.F. Goodrich Chemical Company in Louisville, Kentucky." Region IV, U.S. Environmental Pro tection Agency, Surveillance and Analysis Division, Athens, Georgia. June 24, 1974. 3. "The Evaluation of Airborne Concentrations of Vinyl Chloride," Richard R. Keenan, G.D. Clayton & Associates, 1974. 4. Same as 1 5. EPA Report No. 75-VCL-2 AP00023924