Document gb4qkyq9Gj1Lqw8OqzzGX1RRN

r\ i U Aks?oi& 9Oilnio 4-4-:>i - C31501 June 23, 1995 Ms Lillian J Kelly Hazardous Waste Toxicology Section MS-241 California Environmental Protection Agency 601 North 7th Street Sacramento, CA 94234-7320 Dear Ms Kelly: Re: January 27. 199S, Lillian J Kelly. M.P.H. Letter to Haa Shah. Ph. D. This letter is in response to Dr Shah's request that The Goodyear Tire & Rubber Company clarify an issue raised in the above referenced letter. (See attached). In your letter, you had inquired about clarification of information in a 1977 article published in the Journal of the National Cancer Institute. "Angiosarcoma of the Liver". This information referenced ambient emissions of vinyl chloride monomer for a factory located approximately 1,700 feet from a residence being as high as 92,800 parts per million in 1975. As a matter of information it would be essentially impossible for such an ambient concentration approaching 10% by volume of vinyl chloride to ever occur in the air. Never theless, Goodyear's records were searched and, as expected, there were no ambient monitoring results found at the referenced high level. To the contrary, fcncclinc monitoring data obtained for Goodyear's Niagara Falls, New York plant in 1975 indicated that vinyl chloride was typically non-detectable. Additionally, during the 1970's, Goodyear was not the only company operating a PVC . manufacturing plant in the Niagara Falls, New York area. Goodyear believes that the referenced ambient air value must be in error and strongly urges that the State of California not utilize this data in their health risk assessment of exposure to vinyl chloride. It is not scientifically sound to use information that is not substantiated and apparently not correct. BFG 002091 JlwN-- ij' eJC rnul'i lUKJJJ ro tielkJiidb i"'5-*4i i r. 05 Ms Lillian J Kelly Hazardous Waste Toxicology Section MS-241 California Environmental Protection Agency June 23, 1995 Page Two Attached, for your information is a April 5. 199(6?), Jack D Lauber, P. E. Letter to Lillian J Kelly, The Goodyear Tire & Rubber Company strongly supports Mr Lauber's comments. If I may be any further service, please contact me. M W Smith s5m6a23 Attachments (2) Section Manager, Chemical Information Systems & Regulator}' Affairs TOTAL P.03 BFG 002092 New York Start* Dtpsrtmem of Environmental Conservation SO WoH Am*, Alban*, MmtVmk 122^4 TtUpMnm: ft 467-7000 Pwn.lt* Fa* N t* 0 , CwOatt. 76/1 F--.-ir ( g*J-,a h'*/>/6 *i36- AL<Z p Mlcftaaf 0- loitt Canminionv April 5, 1996 Ml Ultiaa J. Xdty HiMfttom Wiote Tojocoiogy Section MS'241 fblifnrma Environmental Protection Agency 601 North 7th Stmt P.G. Box 942732 Sacramento, CA 94234*7320 Dear Ms. JCcOy: Thu U in reply to your March 14, 1995 letter to me and to a previous telephone cMiventdeQ. You had inquired about dariffcatioc of tafbnitftkn in a 1977 article p*KAw* in the Journal of National Cancer 1/isMute, 'Angnaaroom of the liver," an epidemiological survey by Brady, et ai, that was eo-anthorad by an author of the NYSDOH. Thii mfomatioo allegedly discussed emission* of vinyl chloride monomer at approximate!)' 1,700 feet from a residence being as togh as 92*800 pgnm in 1975- 1 have checked with our Bureau of Air Quality Surveillance and Region 9 staff. Then ere no records or reports of such toxic ambtttt floonhoriBf results that we can find relating to previous ambient studies of vinyl chloride in Niagara Falls near the Goodyear Chemical Company. However, such gross emiuioos appear to be a typographical error or nusinterprstation of eoiissiofl data. It would be virtually impossible for such concentrations approaching 10% by volume oi vinyl chloride to ever occur in the ambient air, I have experience in the xnanufteture of polyvinyl chloride (PVC) from vinyl chloride monomer, which is the process operated by Goodyear at Niagara Falls, New Vud. During the mid~1970*s the U.S. EPA was developing the vinyl chloride NESHAF, and at that dine there, was a fair degree of control of vinyl chloride monomer from the Gondyaax facility. Several yean later, t baUeve the vinyl chloride fmirpqni were largely in compliance with the NESHaP* and cootroUad vo about 10 ppm ct the source as per foe terms of this regulation.. In reality, there should be very few process emittioa sources of vinyl chloride from such a facility except lor a few PVC product stripping fcrfities that could have had emission* above rht NESHAPa standards in 1975. However, it is BFG 002093 m f>g# 2 of 2 inconceivable that such could ever produce vinyl chloride chat would ever exceed several ppm >n the ambient air on an unoontxoQed baria. Conaeqoeatiy, irdonsatooo you quoted from rim previous erode appeua u be in cite, hziupi, PVC ctniaiOB aeasatcncxt values wen mud: analier, such as fit&ogzamitoi&c me mther than ppm. It would be imprudent to quote tins apparently incorrect infbrmadoi your health studies acd evalueriova of tbit toxic air firmtamings. Sincerely* fee* D, Laaber> P. Cfiief, Toebaotogy Aamunent Seerioo Bureau of Application Review and Penn&u&g Dfrisca of Air Resource* ec: J. Biggins B. Borneo P.Uvte T. Cullen F John P. Galvin S, Cufaoer H. Sanrinnatn L. Stiller J. Schreiber T; Gcatfie Dr. A Star*, NYSDOH BFG 002094 TOTAL P.03 California Environmental Protection Agency OFFICE OF ENVIRONMENTAL HEALTH HAZARD ASSESSMENT January 27,1995 State of California Pete Wilson. Covmvtr Has Shah, Ph.D. Chemical Manufacturers Association 2501 M Street NW Washington D.C., 20037 Dear Dr. Shah: Thank you for your phone cail yesterday, following-up on a copy of a letter from this Office dated September 19,1994 to Francoise Drion, M.D., Association of Plastics Manufacturers in Europe, regarding the worldwide registry of cases of liver angiosarcoma from occupational exposure to vinyl chloride. As explained in the letter, the Office of Environmental Health Hazard Association (OEHHA) is completing a health risk assessment of exposure to vinyl chloride in a residential community immediately adjacent to a closed hazardous waste landfill. Enclosed, as you requested, is a copy of the November 1990 interim health risk assessment of the landfill, and the October 1990 proposed identification of vinyl chloride as a Toxic Air Contaminant in California. In December 1990, the Air Resources Board adopted the unit risk value for vinyl chloride recommended in the October report (20 x 10"4 [ppb]"1). In July 1991, Governor Wilson created the California Environmental Protection Agency (Cai/EPA). The Hazardous Waste Toxicology Section, which prepared the interim health risk assessment, and the Air Toxicology and Epidemiology Section, which prepared the Toxic Air Contaminant report were transferred from the Department of Health Services to OEHHA in Cal/EPA. You mentioned the Chemical Manufacturers Association nine-member panel of manufacturers of vinyl chloride in the United States. I would like to take this opportunity to ask if any of the manufacturers could provide clarification regarding the New York resident diagnosed with liver angiosarcoma reported by Brady etai, in "Angiosarcoma of the Liver. An Epidemiologic Survey", Journal of the National Cancer institute. 1977, 59(5): 1383-11385. The authors state "Of possible importance is the fact that the ambient emissions of VC monomer for the factory located approximately 1,700 feet from foe residence of patient #10 were as high as 92,800 parts per million in 1975." I am looking forward to receiving the articles and information you are sending, and to further discussions with you. Sincerely, Enclosure Lillian J. Kelly, M.P.H. Associate Hazardous Materials Specialist Hazardous Waste Toxicology Section 601 North 7th Street P.O. Box 942732 Sacramento. CA 94234-7320 (916)324-7572 Printed on recycled piper BFG 002095 California Environmental Protection Agency OFFICE OF ENVIRONMENTAL HEALTH HAZARD ASSESSMENT January 27, 1995 State of California Pete Wilson, Govenw Has Shah, Ph.D. Chemical Manufacturers Association 2501 M Street NW Washington D.C., 20037 Dear Dr. Shah: Thank you for your phone call yesterday, following-up on a copy of a letter from this Office dated September 19, 1994 to Francoise Drion, M.D., Association of Plastics Manufacturers in Europe, regarding the worldwide registry of cases of liver angiosarcoma from occupational exposure to vinyl chloride. As explained in the letter, the Office of Environmental Health Hazard Association (OEHHA) is completing a health risk assessment of exposure to vinyl chloride in a residential community immediately adjacent to a closed hazardous waste landfill. Enclosed, as you requested, is a copy of the November 1990 interim health risk assessment of the landfill, and the October 1990 proposed identification of vinyl chloride as a Toxic Air Contaminant in California. In December 1990, the Air Resources Board adopted the unit risk value for vinyl chloride recommended in the October report (20 x 10'5 [ppb]*1). In July 1991, Governor Wilson created the California Environmental Protection Agency (Cal/EPA). The Hazardous Waste Toxicology Section, which prepared the interim health risk assessment, and the Air Toxicology and Epidemiology Section, which prepared the Toxic Air Contaminant report, were transferred from the Department of Health Services to OEHHA in Cal/EPA. You mentioned the Chemical Manufacturers Association nine-member panel of manufacturers of vinyl chloride in the United States. I would like to take this opportunity to ask if any of the manufacturers could provide clarification regarding the New York resident diagnosed with liver angiosarcoma reported by Brady etal., in "Angiosarcoma of the Liver: An Epidemiologic Survey", Journal of the National Cancer Institute. 1977, 59(5): 1383-11385. The authors state "Of possible importance is the fact that the ambient emissions of VC monomer for the factory located approximately 1,700 feet from the residence of patient #10 were as high as 92,800 parts per million in 1975." I am looking forward to receiving the articles and information you are sending, and to further discussions with you. Sincerely, Enclosure Lillian J. Kelly, M.P.H. Associate Hazardous Materials Specialist Hazardous Waste Toxicology Section 601 North 7th Street P.O. Box 942732 Sacramento. CA 94234-7320 (9(6)324-7572 ^ Primed on recycled paper BFG 002096