Document m6kGpD21QQYdkEZjQ88yawM4

far* A Division of The Society of The PlastTcs industry, Inc. August 13, 1987 Roy T. Gottesman Executive Director 'gAr/r? ivci TO: The VI Health, Safety and Environment Committee RE: Plaquemine, Louisiana Newspaper Article on Vinyl Chloride Effects in Miscarriages I attach a copy of a newspaper article which appeared in the Plaquemine, Louisiana newspaper on Thursday, August 6th, which has been sent to me by Mitch Beaird of Georgia Gulf. Separately,. I have discussed this with Beverly Gholson, an attorney at Georgia Gulf who called me regarding informa tion that we had on this subject. (rhe latest information that we have is contained in the chapter by John Barr in the Encyclopedia of PVC, second edition, pages 252-254, and largely indicates that there is no data which points unambiguously to a relationship between vinyl chloride exposure and reproductive outcome. If your company has any later information regarding vinyl chloride and reproductive outcome, I would appreciate your sending it to my attention as soon as possible. We may want to consider developing a "white paper" on this subject for possible future use. U 8 W o o tn to CD RTG/pmb cc: M.N. Scheck Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (201) 890-9299 j VOLUME t, NO. 12 > FLAQUEMINE, LA. THURSDAY, AUGUST C, Iff7. ; By Kathy Yates Associate Nous Editor An investigation which begin with questions from residents m SL Gabriel hts lead me down a compli ladies that knew, each other, rune had miscarriages and oqe had a live birth." Fontenot explained. cated path from the Department of i He said he had told DHHR environmental Quafey, a division of about - This, : ' and :v continued the -Enviiouiiieatal. Protection . saying/Georgia: Gulf and . BJ7, Agency,'to the LSU Library; in Goodrich have had numerous leaks search of the answers they; re ' and releases ihrougli the years: of quested. Unfortunately, my exper vinyl chloride." . - ! ` .. tise is not hi Chemical Engineering ,. Dr. Robinson at DHHR said or.scientific analysis- Therefore, it is not.my position to offer.the fol- * lowing information as a conclusive ' answer to those 'questions 'being raised m `the community of' St GibricL The information compiled hereinactually is a continuation of - their original questions, Is'it pos- ^le that thc enrisskjns of Hazar- Air Pollutants hum thcchcmi- cal plants in the St .Gabriel area, coaid have,. m -come .way, con tributed to'the-pnscarriagcs, and other medical and health related problems that residents ofthe com munity suffer from? :'r It has been said that rising con cern in the St Gabriel area over.the past few months in relation' to the allegedly higlt rate of miscarriage and stiD births, has prompted inves tigations to be initiated in Various state agencies' and. with a con glomeration of environmentalist groups. -V. v : Congressman Charles "Buddy* Roemer contacted the Attorney that she didn't have the manpower to initiate an investigation as exten- rive as this one, at this time, butthat . she did hovw^er, have some of her - staff trying to compile birth records and statistics from the SL'Gabriel' , .area.,: . ,'Y ,. When ! first began this raves- - tigation I spoke with Kay Gaudet, a pharmacist in St Gabriel, She sup plied dc with -jiames of-some women who she knew had suffered miscarriages and tfiffidut pregnan cies. - She-also told-me-ofthe group of women in the area, the tfco ladies .who were all pregnant at the same - .tine, and nine -had ^uiscatTiages,.that Fontenot-had spoke of,'. She ' added though, thirt these lathes jiff suffered theirijniscaxriages. in .the same - six . to eight month ;time period, between late 1984 and early 1985. Gaudct went on to .-explain that the national average for miscarried pregnancies is 89 for trvery 1000 live births. -She explained that it would take 'St. ' Gabriel 15 .1/2 GeneraTs office adting for an inves years to have 1000 live births, there-1 tigation after lie was made aware of fore St Gabriel exceeded the Na the suspicions ofsome women inSL tional Average in just sixmonths. Gabriel whohad suffered miscar The yramen I spoke with riages and stiD berths.. Willie Fon labeled Vinyl, Chloride. a - 'fetal ' tenot, of the Attorney General's Of- ,toxin\... One woman said, .."Vinyl > .confirmed that he had lent a Chloride causes Spontaneous abor- ' cr to Dr. Sandra Robinson of tion in pregnant women.* - 'Department of Health knd Vinyl chloride is a human carcin Hunan Resources asking than to ogen, is' labeled as an EPA hazard investigate. ous' waste -hnd a `priority to^ic' t "Basically,in 1984,..o..u..t ol flO. (See VINYLCHLORIDE, page aA) G> 3 C" U) O ft* o tn co o .*v TXZ-: VINYL CHLORIDE.i t 4*. from page tA) m ' \'g pofmanv The compound is usually. I wnt to tlie LSU library In In search of facts as to bow encountered as a cooled liquid, yet earch of support for what these ' much of this tone chemical has ac is actually a flammable gas at room -women had told me.. In ,a book tually escaped to the atmosphere in temperature. Vinly chloride is a - called TMutation, Cancer, and Mal recent yean, I went to the main of xilorlcss gas and is basically odor* ; formation*, written by Ernest H.Y. fice'of DEQ to Baton Rouge. I was ess; Yet at it's threshold of human dm and .Walderioo M.Gehcro6o, letection has apkasant .ethereal; xlor, 'similar t that of gasoline i indes.'. ' - .i ' : wider the- tubheading *vmyi chloride*, I found support for their theory. -v- . allowed to examine Set which con- tained information concerning the amounts of vinyl chloride which had been released. Under the direction 1 called -upon Mr. Bill Davis of; )EQ, head f the LESHAP sur- j eillance. (Louisiana Emissions ! - Li .C:i-.1 1 ' t ,>*. ' "An increasedfetal mortality.'wds tandards for Hazardous Air Pol- ; observed for the wives ofMothers itants), this division of the 1 ' who had been exposed to the com- PA/DEQ is the office which 1. pound, and other studies have indi- tsesaes whether or not a particular h -rated an-increased..risk-of:birth sttssion of vinyl chloride was pre- | defects in children ofparentseejud- r_o_u__b_l_e. O__nce an emission is 1 ing in the vacinity ofvinyl chloride seised as either preventable or !. .production' and polymerization Mi-preventable they begin the pro plants," the passage read. as of determining if any action iouM be taken against the violar. Once,the Environmental Qua!- ' ! ; Georgia Gulf, Dow Chemical of Bill Davis, I was given files for Georgia Gulf/Dcw Chemical and B. F.Goodrich. ' ;< ;1 Some ofthc files were incomplete and, others titaply listed a date that an emission occurred without list ing the amount involved. The entire year of. 1984 of the Georgia Gulf surveillance file was riowherc.to be found. 'Therefore, only limited .information concerning that partic ular time period was made available . tome. / Act has been violated, the DEQ ; and ~BJF. Goodrich use vinyl lDavis was successful in obtaining :tt decides what action, if any, i chloride in their production proGes- some, information from another ouk^ie uken against the plant. ; set. Dow produces the chemical st source concerning this-year." could not confirm the, ir selfand sells vinyl to B. F.Goodrich From the availabie^raoords, the )tment by the women 1 spoke r by pipeline, and ships the chemical th concerning vinyl chloride ! by rail also. When shipped by rail, ing a feul toxin or causing spon- - the chemical is a liquid,under pres kous abortion, in , pregnant , sure. - ; mien, he . could only tell me in - Georgia Gulf also -produces 'and to the'subject that the t)EQ pectors, those who go to .the vinyl chloride and sells the chemi- ints to do annual inspections and : cal. They also are a polymerization iodical inspections to determine l plant, producing Polyvinyl chloride - preventability of a particular- . from the vinyl chloride monomer, isston, cannot be women of ' or creating PVC from VCM. I approximate number ' . Of total -pounds of vinyl chloride released from these three plants frorr 1981 until the begining of 1987 added np to 133,097.89 lbs. Sources of these releases varied but most were safety valve releases, pumps and . other ' mal. functioning equipment.'- .However, idbearing age.. B. F. Goodrich, as mentioned n search ofproof that what these .before redeves its vinyl chloride men had told me was in fact mtiflcally tested and ' proven tewhcrc, I. called Dr. James eman, Iberville Parish Coroner, tman ako could not confirm . He did, however, agree with ns saying that vinly chloride has ft -proven to .c^use angiosar- from-Dow Chemical by pipeline, and they' produce PVC-resin and _ some PVC compound. - ' Their ; polymerization plant produces the ; granular -type resin to be shipped out for the -creation of such products as pipe fitting, construc a, cancer of the liver. Davis had tion , industry electrical fittings, me that this was discovered at wrapping products, such as plastic Goodrich plants in Kentucky, - - "Tap. That part of the PVC resin made into -compound is sold for everytime a plant starts op or shuts down 'ususwally ;large v-emissions, occur, this is also true'of shutting down the boilers for inspections and other operations. ` On some oc- caisions of boiler -shut down, in which the EPA had given their per mission to the plant to conduct the shut down fully aware that chemi cals would be released, a-very large amount of hydrocarbons -'were emitted. . .; . - things such as plastic bottles. (P R&S 040531 --- R&S 040532 "Breaking thk'Ajwa,the incom plete Georgia Guff fifes revealed 96,15689 ft* of vinyl chloride ^kased, Dow Chemical reported . B F Goodrich, which receives it's vinyl chloride from Dow Chemical ^25380 fi&, and B. F. Goodrich - by pipeline, emitted (3,429.1bs,wf totaled 41,687.301*. emitted aver ' VCM -to-'the' atmosphere in the past 51/2 yean. t .1983! These -emissions included-a ' The yean of the most concern to - those' residents in -Si. Gabriel involved in this issue are those of , 1984 and 1983. According'to those .-1 DEQ records : available. !Dow ' . Chemical's total emissions from 1984 and 1983 were 288.00 lbs. From 1984 to .1985 BFGoodrich - emitted 24,61235 lbs. of vinyl chlo- ' ride according to DEQ records.-. Georgia' Gulf, between 1984 and 1985 according to the incomplete . records at DEQ, had a total of v 29,633.48 lbs. of VCM released io the atmosphere... . Georgia Gulfs releases for. that, time period included a 17,760 lb. release .of vinyl chloride -pn November 13.1985.front their PVC plant and 9.142 lbs.' that same day from their VCM' plant These releases also included i 1,900 lb. emission on April 23, '.1985 from' ir VCM plant!' 1 F Goodrich's releases .duringi time period included a 5,400 lb.', release ofvinyl chlorideon January 19,1984 ; and a 3400 hx discharge - 7300 lb. release on October 18 of 1983 and !5,000..!bs.; on December 14, 1983. : :, In the years 1980 and 1981. B F . Goodrich released 11350 lbs. of vinyl chloride, to the atmosphere. In 1983 the U.S. filed suit against B F Goodrich in relation to it's vinyl chloride emissions.- The .company had to . pay approximately $100,000.00 to the state as a result of the^e complaints.; . ,! Georgia Gulfs emissions Tnl986 and part of 1987 total to 5,796 lbs.- . of vinyl emitted. From 1980-1982 the company V released 52397 Jbs.. according lo DEQ records which weni .only as . far-back as 1980. | On .September 20, J985 a pro posed concent. decree .in .United . States vs. Georgia Pacific Corpora* tion was 'lodged with the United States District Court. Middle Dis trict of Louisiana. The .compfaint' filed by the 'U.S! alleged that the Georgia Pacific Corporation vio-. lated the Clean Air Act and the Vinyl Chloride National Emissions . on.January 29,1984.-OnJune22,' Standard-for Hazardous AirPoIlu* . 1984, they released 2JD00 lbslof tants, by discharging vinyl chloride' S vinyl chloride to the atmosphere V and on August 15,1984 6.8 lbs. with a 7,905 lb! rtlesisfe-bn August 21-of f thai'year. 4n *l985, `they 'emitted '4,800 lbs. 6f VCM.bh May 6: . ,, According to the DEQ records, Dow's .total reported emissions from 1986 up to date total45.50 lbs. ^of VCM emitted to the atmosphere. However,-in 1983 Dow Chemical released 4.42531 lbs. of VCM to the atmosphere according to the records. These emissions included a 300 lb. release on December 4, 1983, 750 lbs, n April 15. arid the from its ethylene dichloride/ vinyl chloride and -polyyinly chloride- facilities. Georgia Gulf now is the owner jof the . plant -.and ' conse quently intervened jn the action to effectuate the injunctive relief sought by the U.S. under Concent Decree. The 'Concent -.Decree required-the plant lo adhere-to a' Remedial Action Plan .and ensure , compliance.-The company had to-, pay $562300.00 in civil penalties to .the U.S. and an additional penalty: Of ..$62300.00 to 'the State , of Louisiana.. - same week on April 18, 3,080 lbs. were released from the plant.' In 1981 and J982 Dow released Vinly chloride is -used as a`vinyl ` monomer in the manufacture of 10,495 lbs, according to the"files. These releases included an 8,925 lb. seon October 22pf4982 and a lb. discharge on August II, if. i B polyvinyl chloride and tber rerint. R According to Mutation.' Cancer ^ . and Malformation. by Ernest H.Y. ., Chu and Walderico M. Gtneroso,' . over 90 percent of vinyl chloride { monomer is usbd in the production I of vinyl chloride homopolymer and i ; copolymer'resins'Used in the build* r tng' and' construction''industries. V The compound is' used in the crea- | Uori ofauch things as'plastics, var- * Btihes. iilk and paper coatings arid . refrigerants. _ ' ;^ f ' "According to the Handbook 0/ Toxic and. `Hazardous Chemicals, byMarshall Sittig, the hazatds of ; vinyl .chloride was ;' riginally ; believed to primarily, concern r workers* employed in- (he eonver[ "iion of VCM to PVC, fvinyl chlo-; r"ride `m'oiio'mef ro ;/pblyvinyl ; chloride) who may.receive a partk! ulariy high exposure of VCM iq certain' operations, or long term 1 exposure to relatively low conceq' tratkrasofVCM in the air al differ* * ent -factory sites! Much-'.larger i . populations are now -believed to be . : potentially at risk, including; pro! duccrs of VCM, people living In the i close proximity to VCM or PVC - producing industries, users ofVCM 1 as propellant in herosol sprays, perPsons in contact with result made * from VCM, consumers offood and beverage products containing - leachable amounts of unreacted ; VCM from PVC packaged.,mate-.' rials (plastics, etc.), and ingestion of ; water containing .unreacted. VCM ,, leached from PVC pipes.-w In 1976 it was.-estimated. 4hat almost one million'pertOnswcre. associated- wjth manufacturing goods'derived fronrpyc.', *'," -. -This ;same . pu blicatiain('ys, "incinerators maybe an additional : source ofainyt chloride emisiivns . since the entrapped .monomer, escapesfollowing incompleteypmbrntion of PVC products,*^ . - According to the-'filial eule* of the. D.EQ Regulations and Proce*. dtires `for Unauthorized >DiSr charges,' which became effective November 19, 1985,'the reportable quantity level for vinyl chloride is one pound. This level is applicable regardless - of t the environmental . medium, (land, air, water, grouod' ater) into which the pollutant is J ischarged.-This is the limit-fbc . . DEQ has act forsbe plants to ii^pqrt - ^n emission..! :7*. r. v- Vy. 4% Aim found ini ChemicBffatards txpptwc bruits in sir hstkd in the ; <f*be Workplmct,,*QvtrjQcasesof Handbook of Toxic and Hazard- og^hemkals," the federal stand-' a^Por exposure to. vinjl chloride t btiosaroomajnfthciitpfJmvfhccD i_ported Among -^viayl.Akisridc . polymerisation workers ja the Uni- acts a limit of I part per million over | ted States and nine other nations. in 8 hour period, and a ceiling of5 ppm averaged over i period not exceeding K minutes. --- - The chemical is absorbed both thr ugh inhilation , and akin !. Became this tumor is extremely rare, the occurrence* of these cases under, similar occupational condi- f, tjons'strongly suggests:a casual relationship to some phase of vinyl absorption.-' ` * chloride production! Clinical fea- \v According to the Handbook of, ! tunes of seven patients with the car Toxit.-and Hazardous jpb/emicals- cinoma varied from no signs or medical-disorders associated with . ' symptoms -to .weakness.:pleuritic vinyl chloride include: acrobsteoly- t. pain.-abdominal pain, weight loss, s. Raynaud's phenomenon, ami clerodermatous skin changes. Chronic exposure may also cause hepatic damage. ' i Vinyl chloride is regarded as a human carcinogen .- ' apd.a cause *ofangiosarcoma ofthe liver. Excess cancer of the, lung- and lymphatic . and nervous system! has also been ' reported. ^xperimental evidence of tumor induction in a-Variety'Of organs, induding.liver,-lung, brain 1 and kidneys, as well as nonmalig- ' nant aherations such as fibrosis and connective'`tissue deterioration . ate the multisystem oncogenic toxicologic.'effects of Vinly ride. * , In agreement a. book, called. Chemical Hazards of:the Work place by Nick H. Proctor, PHD, toxicologist and James p., Hughs, MD explains that then; is an increased incidence of malignant tumors, acroosteolysts, Raynaud*; .`gastrointestinal bleeding, and Jhepatosplenomegaly; liver function' - abnormalities were-.present in all subjects -.but without a consistent pattern. .In addition to.the malig nant tumors,, four-cases of nonma- lignant; hepatic disease character. ired by portal fibrosis and porfal ; -hypertension have been attributed t - to .Vinyl chloride exposure." i Continuing in. this publication. the authorJists symptoms and signs 'of exposure as-'weakness pleuritic . ^ '.pain, abdominal pain, anorexia. ( weight loss, gastrointestinal bleed ing; hepatomegaly, .splenomegaly; \ . Raynaud's syndrome, lesions in the distal -phalanges of the hands; cen tral nervous system depression.' "Numerous publications . snp. ported this fact, that vinyl chloride exposure causes cancer of the liver ` pr angiosarcoma, including a pasr. sage' jn -Mutations, . Cancer ,and syndrome, :.scerodertna,' thrombo cytopenia,' circulatory -disturban ces, and Unpaired -liver- function; very high concentrations cause cen tral nervous system depression, . associated with the intake ofvar ied amounts of vinyl chloride.,. .'Radiologic"findings in patients with acroosteolysis included lytic lesions in the distal phalanges ofthe hands, in the styloid processes of the ulna and radius; and'/in the Malformation which listed a key event in which workers in numer' pus countries showed an increased - incidence of angiosarcoma. . . Angiosarcoma is a very rare dis order of the liver. I have also found evidence .that vinyl chloride expo sure'clearly produces gene muta tions and.primary DNA dahiage. -Reference was made to problems in genetics and chromosomal defects in-relation to exposure.. sacroiliac joints.-Of 20 autoclaive. ' DHHR has not yet compiled any workers ; with exposure io Vinyl Statistics that they would release on chloride, 16 had thrombocytope nia, seven had splenomegaly, six had hepat megaly, 14.had fibrosis of the liver capsule and four had u of acroosteolyus in one study flpis same publication. : . t.he birth rate in the St. GabriaJ area. I-am presently awaiting those ~ ! statistics along with statistics, on incidences of cancers 'and other | . related material. from an area hospital. * - . * "The passages made reference to numerous other disorders found in workeis-of VCM plants, including -vac uudywfclch kaw"2Joaei ol acrooateolytu, - {degeneration Nnf -/*+ terminal phalanges).:-. ; ? i. According to -.Tom .- Ballcsger, . director -of the State Center for Health Statistics, in 1982 IbeniDe , Parish avenged slightly over tfe state avenge for still births. Bom ' the yean 19&3-1986 Iberville, was slightly tinder the state avenge for still births, and in >1986 none of . those cases reported came from St. j: Gabriel - According to those women 1 ! , spoke within St Gabriel ipstances ; ' of miscarriage and still births are __ higher than Ballenger's frgurcs indi- 1;. cate. One of.these women said that - from 1983 to 1985 out of 17 preg- i nandes there were 15 miscarriages ' and ooc live birth. r * ' ` Several of the women went on to | have children later but-had to have 1 progesterone (a. female, hormone) supplements during their pregnan cies following their..miscarriages. | None of these "women had any instances of.this type of complies- * tions with childbearing iritheirfam- ? ' ily histories. 1. ' ' ' ' If this isindeed fact, we may find *. reasoning -behind .these occurrcn- ; ces, -and-that reasoning may not , necessarily be those chemical emis sions between the. years of 1983-85. The evidence 1 mentioned briefly .; before . concerning / genetic . and chromosonal -damage after expo sure has opened up another field of investigation. -The -question of the ". generation before this one's expo- ; sure ritiw ~ irises! Their parents. many of which lived .in the -area ' f .years ago-when limits set oh vinyl chloride- and other .hydrocarbon emissions were not as strict as they are now; could possibly be the ones who's intake was too great. This theory t will try to support with more research, but to begin I quote from Mhiatlon, Cancer and j Malformations, - 'Only dominant | mutations and certain chromo- | somal defects- will have clinical effects in the first generation. The pefsistance of mutations depends upon the biologic fitness of the phenotype.' If-.carriers of a given mutation have no offspring because of lethality or infertility, the muta tion will only persist for one genera tion. Mutations of the heteroZygoic ` type will be-similar to that of nor mals.' Such -mutations will persist for many generations.' I'* In addition to the informati n I presented in this article,1! have, doc-' smented .evidence of releases of Chlorine and other hydrocarbons " and theireffects on the human body '--and the -environment -which 1 will ; _ present with further research at a J3 ffo (/) o C* O Ul CO CO -rtas ooo-S Ck '&&f><2/raJx OX4-ic,(e. Zl V: v::i . The Department of Emiroomen- Ul Quality has in progress a -fact finding nrisrionto provide answers to a posable fink between allcga- tions of mkcairiagcs-and stinbirths in the St Gabriel and -the environ ment. i*. . 7 . '- . The DBQ staff has pot together a comprehensive plan to provide os with a variety of information winch we can share with DHHR," Martha Madden,- Secretary of DEQ said. The 'Department: of .Health and Homan Resources, working in con junction with federal Centers..Ibr Disease Control, is the lead agencey ;; . ; :t. 'V-tl.-.y.? .l.iu., '..'if ..''.-.I Q ihe . investigation :i ~> into .-the problem in St GabrieL v->'- >... The DEQ plan calls for informa tion from six different aieas.':These indnde: v :.v - yJL An inventory of . chemical -products and by-products produced in the SL Gabriel area, , , . v V. Z A study of arridcntal spills and ..releases over the past fiveyean, - 3. A .retrospective j .study of baseline data on-air and water quality,--. - 4.; Groundwater testing of monitariqg wells, - 5. Tests ofdrinking water sources and ::; - '*' 6. Conduct soil and surface water ; "We - have been working on .`answers to the many :qocttions raked by -this incident in St Gabriel,* Madden ooododed. ,*Be assured DEQ : k .well in the forefront in its doty to help DHHR solve thk problem.* R&S 040534