Document qknLR8xnKevLn55dYpDpKVVvE

JAM - Reference Page 14 THURSDAYJ JUPiE 9, 1977 PART II FEDERAL ENERGY ADMINISTRATION V INDUSTRIAL ENERGY CONSERVATION PROGRAM Final Industrial Energy Efficiency Improvement Targets see 1777 20W2: notices FEDERAL ENERGY ADMINISTRATION INDUSTRIAL ENERGY CONSERVATION PROGRAM Final Industrial Energy Efficiency Improvement Targets AGENCY: Federal Energy' Administra tion (FEA). ACTION: Notice. SUMMARY: The Federal Energy Ad ministration (FEA hereby establishes final energy efficiency Improvement tar gets for the 10 most energy-consumptive manufacturing Industries In the United States. The Energy Policy and Conserva tion Act requires FEA to publish these targets In tire Federal Register, together with a statement of the basts arid jus tification for each target. Such state ments are included as appendices to this notice. Within each of the 10 identified in dustries, FEA has identified the corpo rations that (1) consume at least one trillion British thermal milts (Btu's) of energy per year In the United States, and (2) are among the 50 most energy-con sumptive corporations in the industry (41 FR 54977, December 16. 1976). With the establishment of the final energy efficiency Improvement targets, the chief executive officer of each corpo ration Identified by FEA is required by section 375 of the EPCA to report to FEA on the progress made by the corporation toward meeting the target set for the In dustry of which such corporation is a part, unless tire corporation is exempt from mandatory reporting under section 37G<g) of the EPCA. Participation by a corporation In an "adequate voluntary reporting program" is the basis for ex emption. FEA has published critcrta which a voluntary reporting program must meet for a corporation reporting distribution. The first submission of re ports by nonexempt corporations to FEA will be required within four weeks of the publication of the form. Industrial Energy Efficiency Improvement Targets On October 27. 1976, FEA issued lor public comment proposed energy effi ciency improvement targets (41 FR 48169, .November 2, 1976). Public hear ings were held for each proposed target in Washington. D.C., between November 22. 1976, and December 10, 1976. Written comments on the targets were also re ceived by FEA. A discussion of the comments received with regard to a particular Industry 1* contained In each statement of basis and justification that Is appended to this notice, as well as In the target support documents that arc available for public Inspection at the locations and times set forth below. The comments were re EFFECTIVE DATE: Date of Issuance. FOR FURTHER INFORMATION CON TACT: pursuant to it to be exempt under sec tion 376(g) (41 FR 51866. November 24. 1976) and. after publishing for comment a preliminary list (42 FR 15731. March viewed by FEA, the Department of Com merce (DOC), the Energy Research and Development Administration (ERP''. and the contractor which prepared Ramon L. Clllmberg, 12th and Penn 23. 1977), has published a final list of support documents lor FEA. Where sylvania Avenue NW,, Room 307. Old exempt corporations on May 9. 1977 (42 Changes were required In data and analy Post Office Building, Washington. D.C. I-R 23538). sis which affected the final target value, 20461 (202-560-4661). Tlie form to be used by noncxempt they are noted &nd explained In the SUPPLEMENTARY INFORMATION: Part D, Title III of the Energy Policy and Conservation Act, Pub. L. 84-103 (EPCA) (42 U.S.C. 6341-6345), requires that FEA establish a program to promote Increased energy efficiency by American Industry. This program includes the Identification and ranking of the major energy-con sumptive manufacturing Industries, tile corporations was published In the Fed statement of basis and Justification and eral Register for comment on May 4, in the target support documents. 1977 (42 FR 22581), and a public hear-- After consideration of the comments ing was held on May 17.1977. After con and all other Information available to sideration of tlie comments by FSA and FEA. FEA hereby establishes the voluncompletion of the required review ba*the . tary. energy efficiency Improvement tarGeneral Accounting Office, the final idra* v gets tor the 10 most energy-consumptive will be published by FEA In the Federal Industries In the United States as fol Recister and will be made available for lows : establishment of energy efficiency Im provement targets for at least the 10 most energy-consumptive Industries, the Identification of major energy-consum iiunk sir Su. Proposed nt lancet (porcdcu) - Final (percanU Nat tarsal Oflwt ing corporations within those industries for the purpose of determining those which must report progress in Improving energy efficiency, and the establishment of a reporting system that provides for cither the reporting by the identified cor porations of energy efficiency informa tion directly to FEA or, upon exemption, lUttonfciUa ntul Milled product*............. I'rliuiiry uielul Industries................. i`stn>J*uui and eoal products.......--. Rtoue. clay aad class products........ Paper aitii allied products............. Food and kindred products........... Fabricated mtlil products................ TraiuiiurtAUon |Uii>ni*nt................. . Ataclilnrcy sicept oloetrical.............. --. Tettlle mill products....................... . (tat (10) (12) (17) (IT) (It) (24) IIS) (IS) (27) the reporting of such Information Indi rectly through sponsors. The table sets forth the net targets for purchased energy instead of on the basis In accordance with section 373 of the EPCA, FEA has identified the 10 most energy-consumptive industries in the United States (41 PR 12766, March 26, 1976). These industries, described ac cording to the two-digit Standard Indus trial Classification (SIC) Manual pub lished by the Office of Management and Budget, arc as follows: Rankins Indust/p sic N*. Chemicals and allied products... 28 .Primary mcitl Industries..____ u Patnleum and ooai products..,, Stone, day, and rIob products.. 32 Paper and olllod products.----20 Food and kindred products...... -g) Fabricated mcUtl products______ m Traruiwtatloo wiulpmsol.......... IT Machinery, ascept electrical..... U Tactile raill proouets........ ........... 23 each Industry according to the order in which each Industry ranks la energy con sumption, and also includes the proposed target and the offset (from a gross taxget) that reflects the energy require ments of special circumstances. In four Industries--petroleum and coal prod ucts: fabricated metals; machinery ex cept electrical; and transportation equipment--the final net target Is un changed from- the proposed target. In five Industries--fod and kindred prod ucts; textile mill products; chemicals and allied products; stone, day, and glass products: and primary metal In dustries--the final net target Is lower tlian the proposed target. In one Indus try, paper and allied products, the final target shows an Increase over the pro posed target, and the final target has been set on the basis of fossil fuel and of total energy as originally proposed. Basis and Justification for the Targets As required by section 374(a) (1) and (2) of the EPCA each energy efficiency Improvement target Is based on the best available information and is established at the level which represents the maxi mum feasible Improvement In energy efficiency that each Industry can achieve by January 1, 1930, taking Into account considerations of the technological fea sibility and economic practicability of utilising alternative operating proce dures and more energy efficient tech nologies. as discussed below. Each target represents the percentage reduction In energy consumed tier unit of output or activity that can be achieved between calendar year 1972 and January 1, I960. The statement of the basis and justlfica- fEDRAl RIGISTIB, VOL 41, NO, 1 1 I--THURSDAY, JUNt 9, 1977 ;cc 7- 779 -a NOTICES 29661 and available manpower could limit progress la energy conservation. Wblle PEA recognizes the relevance of such limiting factors. It be* lleves that a realistic assessment of what could be achieved by Industrial establish* menu hM been made. In particular PEA recognizes that the priority position of energy-conservation Investments relative to other uses of capital may differ from com* pany to company as well as over time with an Individual company. Industrial commcnters seem uniformly concerned that the component goals which were aggregated as an industry-wide target would be applied Indiscriminately to their own Industries or companies. The PEA Is only charged with setting a voluntary target for an SIC code Industry. The component goals are not directly, applicable to either component industries or individual com panies. B. fowl larpet*. After the proposed net target was published for comment, PEA Initiated a further review of the underlying data with particular regard to the Impact of special circumstances. As a result of this review the initial estimates of energy usage for the nine major' four-digit classifications were modified and the estimated energy con sumption required to meet special circum stances wav determined. Special circum stances applicable to SIC 20 were found to include the following: 1. Energy consumption required by measures to comply with mandated environ mental and occupational safety and health regulations. 2. Energy consumption related to nondtscretlonary changes In the quality of raw materials. 3. Energy consumption related to changes in product mix caused by outside sources. The following table illustrates the data on 1980 energy usage and the allocation of energy for special circumstances for the four-digit classifications. Aimitelisrd rate of energy utage by SIC 21 on Jan.1,1980 (ftt quads) 10" Bfu With 1972 energy usage and manage ment ................. ________ 4. BO With maximum feasible energy (gross) conservation (but not consideration of special circumstances)__________ _ 3.09 For energy conservation (offset), in cluding energy requirements for environmental systems, changes In product ml*, etc_______________ _______ . ]3 With maximum feasible energy (aeti conservation, including energy re quirements for environmental eye- terms changes in product mix, etc__4. 12 The following Is the energy efficiency Im provement target set by PEA for SIC 28: Final c*t hint let of Ciicrgv <-'>>isuuip!i'in ly industry compiinotl Cla- Name IfdO ttk-rev UMign Knnrey required --.................-- .................. byitwdat With 1072 With 1880 cireurastaoero irelioolocv taehnoioar cron (10" llui'i) uou biu'il <lO" Uiu iJ 3812 Alkalies and chlorine............... .. ......................... ........ 2813 Industrial saws....... ........................................... ...... >14 Itvirvanlr uietnr-nlj........ .................................................. >19 In'IuMrial tnurtnnk'climiieaU. u.*.e............................ >21 Plastics. syni Utile resin.*, etc.......................................... 2822 Kyruhetir rubber................................................................ 2S25 CeDulwic Bianmadc fibers.................................... 2824 Rjmilinic arcHiiic fillers, ex crllutuair.................. . 2M PbarmarruticaU............................................................. 2841 fiomfi. delewn!*. tie....._____________ 2842 RpoHahr. droning, poiUlilng, sanitation......... ......... 2K43 Kurile active s|v-ih*. tie.............__________ ... 'A+4 Perfume* cosmetic* etc........... ........................... . 2841 Paints, cunlshm, larmiers, etc................................. 34) Hum and wood chemical*.............................. .. 2844 Cyclic (eenl lar) erutles, ere........................................ 3*49 Industrial organic chemical* n.e.c................................ 2073 Nitrocenrous fcrtilUnri......................................... 'A74 l'lio*plide li-rillltm.......... ............................. .. 2S75 Ferilllxer*. mliing only._____ _____--...___ --t---. 2R7V Poslleklcs and agiVuhural chemical, ........ 2SV2 Kcpliwirre.............................................. ...... ...........i'-*2KO Priming ink.......................... ............................................. 2MS Carbon black........... .............. ............... .......................... 2S99 Chemicals and chemicals prcieiralin, n.f.e............... Totals (rMtulvd) 4.0 111.(1 VJ.O LM.O M. (J 75.4 48.0 273. 0 M7.fl <9.7 14.3 i7.0 11.9 VJ.l U.6 294.0 i. 674.0 >3.41 107.0 15.7 4J 4 17.0 ta.i n, 3 a*L 4 at 2 r.suao 219.0 I0LO JU.O 549.0 i`iao 92.5 50.7 2110 111.0 49.2 11.M 14.4 10.6 2.1.7 8.9 235,0 1,383.0 310.0 128.0 31.6 40.7 14.3 44. H 2.K 37.0 94.1 i.wo.o 7 <1 X 211 J 3 t 5 7 J <1 <1 <1 1 <1 4 U 23 l 4 l I <t * i 130 SIC-SS, chcmicnlt and allied producti--irtHol and revised energy efficiency goals by intimity and subclass Percent Oross target (based on maximum energy efficiency achievable without consideration of special clrcum- sLnnccs or conditions of the Indus try) ------------ 17 Offset (required for special Industry circumstance* and conditions)____ 3 Net target (based on maximum energy efficiency achievable with considera tion of special circumstances and conditions) ______________________ Appendix E: Statement op Basis and Justi fication poa the Enerct EmciENcr Im provement Taucct for SIC 29--Petroleum and Coal Products L INDUSTRT DESCRUTTON AND ENERCY BASE The petroleum and eoal products industry Is made up of companies engaged In refining petroleum, manufacturing paving and roof ing materials, and compounding lubricating oils and greases from purchased materials. This Industry Is Identified as Standard In dustrial Classification (SIC) 29. The Industry may be further divided Into five four-digit SIC product classifications which are listed below with the figures on energy consump tion by each classification for the 1972 base year: SIC component nsm Ox' (iVTCdat) Rovised goals (poreent) a* Oo . 2813 ADcalln and chlorine__________________ _____ _________-- 2813 Industrial [tvs________ _______________________ _---------- 2816 Inorganic pigments........ ......................_________ __ _______ 2819 Industrial Inorganic chemicals, sot alsewbw rlavrlftel 2821 Plasties, (ynlhstie rtsin* tU___ ................------ -------- gyntfasUc rubber.........--------------- ..------------------- 2623 CeOulosle man-made Oban--------------------- ------------------------ 2824 Bynthetle erganie fiber* u cellolode---------------------- 28JI Biological products... ___ _________------ 2833 MeiHdiud elwrolcal* *nd botanical*...--.-- 2834 Pharmaceutical preparations_____ ........ ......--------------- 241 Soap, detergent* ate---------- --------------------------- ........... 2842 Specialty, cleaning, polialilng. sanitation_______________ __ 2843 Surface active agents, ate...__________________ __________ 2944 Perfumes, cosmetics, ale..______________ ____ ............ 2851 Paints, varnishes, locnuen, etc................ .............. 2861 Onm and wood ehemlcals.-- 2SAS Cyclic (cool Ur) erudes. otc.----....-------------- ------------... 2809 Industrial organ!e chemicals, not elsewbart olawUM-- 2873 Nitrogeneous fcnlllzen............................................................... 2874 Pbosphatte fcrlllltcn....... ................ -- ~.............. ...................... 2875 FerUiiter*, mltlng only..........-------- ---------------------------- -------- -2879 Prrt(d<J* and agricultural chemicals, not aleewbere --------------------- ---------- ........... 2841 Adhesives sad sealants............................................................... 2842 Explosives...........................................-......................................... 2S93 Printing Ink.........................................._...........................----.. 2895 Carbon black.... ............ ........... ... .............. --............................ 2899 Chemicals and chemical preparation, not abewbera dossified________ ________ _____________ _______________ Total 28......................... _...............................................- as Ll L4 ai 17.1 24. S 10.1 22.7 <) <`) <*) 19.* ILt 13.7 U.3 its 11.8 i&i i&. 17. e iai jas 22.4 IS. 2 10.0 70.2 9. S' 39.4 tt 15. 4 *L4 a: 4.1 2.2 ia? 12.1 ia 19.1 90.6 16.0 14.0 U.0 10.0 1U8 10.4 114 IS. 6 1S.0 tao 22.1 14.1 0.4 30.1 9.1 38.4 rr.t iti ii.i 6.9 6.3 at 17.T * *n.i 1*6 *20.7 34. T 19.1 . 1A6 It 7 10.9 1*2 11.4 30.1 17.4 30.9 213 3*1 32. J 1*0 33.1 16.3 41.6 30.7 16.6 i Ox-a net goal which Includes merry roTUired toe en?troameaul ryitcroj and chant la prodartkm mix; Qo a cross goal with no consideration lor offsetliog circamsUnoes, Estimates that were modified by additional estimates and data. yjtimates that had been modified by additional dates and aaalyaea. Not ebswbara elMsIOtd. aic Industry vnaocy Prrernl eeruraraed eftetal 10" HWs 2011 3941 352 2992 3990 PtUoUui* refinery....................2,031.30 Psrloc mix snd bWk..._ 25.07 Ajphiit fells ead eoatincs.. taortoatlns ells sad crsasM. 19.3 a40 Froduets ef petroleum and 4l._ ....................................... 7.M l Totals.. ................... *99*63 98.0 .9 .0 .3 .3 100.0 The. following paragraphs Indicate the significant products that are Included In wu'b of the SIC categories. 810 2911, petroleum refining, comprises establishments primarily engaged In produc ing gasoline, kerosene, distillate fuel oils, residual fuel oils, lubricants, and other prod ucts from crude petroleum and tts fractiona tion products by use of straight distillation of crude oil, redlstUlatlon of Intermediate products eo produced, plus further cracking of heavy molecules and by other processes. SIC 2951, paving mixtures and blocks, com prises establishments primarily engaged in manufacturing asphalt and tar paving mix tures, and paving blocks made of asphalt, ercosoted wood, and various composition* of asphalt or tar with other materials. 610 2052. asphalt felts and coatings, com prises Industries engaged tn manufacturing FEOEJAl (EGISTEK, VOL 42, NO. Ill--THURSDAY, JUNE 9. 1977 see 2-1779 34 RECEIVED SEP :-R 1977 COMMENTS OF THIS ENVIRONMENTAL DEFENSE FUND ON THE PROPOSED AMENDMENTS TO THE FINAL EMISSION STANDARD FOR v VINYL Cll 1,0f<lI1E . - (42 Perioral Register 28154, Judo 2, 1977) On October 21, 1976 (41 Fed. Hey. 46560), pursuant to $112 of the Clean Air Act as amended, the Administrator promulgated National Emission standards for the hazardous air pollutant vinyl chloride. On November )9, 1976 the Environmental Defense Fund (EOF) filed a petition in the U.5. Court of Appeals for the D.C. Circuit for review of these standards. As part of a settlement which led EDf and FPA to move to dismiss the review petition on March 24, 1977, the amendments under consideration were piopor.cd. The proposed amendments represent a true compromise .................. between what EOF could have pressed for in court and the existing standard. Section 112 of the Clean Air Act requires that emission standards for hazardous air pollutants, sudh as f vinyl chloride, be set "at a level which Jn the judgment <>( the Administrator provides on ample margin of safety to protect the public health from such hazardous 'air pollutants." It clearly requires a health-linked, not a tuchnology-bascd standard. Yet, inconsistent with the statutory requirement, the original standards were based on what EPA believed industry could accomplish with best available technology. In the Standard Support and Environmental Impact Statement, EPA BFA - EOF claims that the proposed vinyl chloride regulations cons tute a less stringent standard than it could have insisted u| from the court in the litigation which it instituted. Accua EDF could not have pressed the court to change the original regulations to set an immediate zero emission limitation.' T1 court Is only empowered to decide whether EPA's regulations arbitrary and capricious. At best' from EDF's standpoint EPA could have decided that the first ruelmaklng was arbitrary at not in accordance with 112 of the Clean Air-Act. Such- a ru' would have voided the regulation, and.EPA could then, If it chose, have begun another public rulemaking proceeding1 in-wh: it would presumably be an Impartial arbiter.of comments from concerned. As it stands, however, the proposed standard is-t result of coercion by one party with a particularpoint- of vi and acquiescence by the EPA (It seems significant to note tha EPA has never allowed such an unseemly settlement where -Indus has in the first instance filed a court challenge to a.regula promulgated by ..EPA.). In effect the proposed regulation in t Instance has l n dictated by a private party, and this is cc traryfto the Clean Air Act which has delegated impartial ,rule makinp, authority exclusively to EPA .: recognised that vinyl chloride is an "apparent non-threshold pollutant'' which creates a risk to public health at. all levels, had the case gone to trial, 01' would have taken the position that S112 required a zero emission standard, the only standard adequate to provide the required margin of safety for n nunthreshold pollutant. Instead, EOF settled for a compromi:;^ which establishes a goal of zero emissions and requires industry to move one step closer to that goal. The new standard would not require the installation of completely new technology. Industry is not being asked to scrap existing technology. The revised limits can be achieved through the improved operation of existing technology permitting full amortization of the industry'u investment in tfontrol tech nology. This should be viewed in contrast with the proposal of the New Jersey Commission on the Incidence of Cancer that any industry emitting one of some seventeen substances reduce emissions to zero or stop producing. Not only will there be.vy, no shut-downs required by these amendments, but the industry, will be able to continue its growth under this compromise. The Society of the Plastics Industry, Inc. (Sri] has attempted to portray this settlement as some sort of private agreement between EFA and EOF to promulgate a revised emission standard, largely because they were excluded from the settle ment negotiations. There is no legal requirement that an intervenor In a ease bo permitted to participate in settlement see -1 782 s \ KJ -3- negotiations. Industry searched for such a Legal precedent but was unable to find one. Industry has now had ample oppor tunity to comment on the proposed amendmOnts at a meeting from which EDF was excluded, a public hearing, and through written comments. It should lie noted that EDF was also excluded from the industry-EPA sessions which led to promulgation of the original standard. It should also.be noted that despite industry's exclusion from settlement negotiations, F.DF's attorney kept industry well Informed of the outline of the proposed settlement at all stages. . Finally, if r;pI and its members arc unsuccessful in persuading EPA to revise the pro posed standards before promulgation, they can always petition the Court of Appeals for review of the standards. _ At SPI's request, a public hearing was held by EPA on July 19, 1977 to receive public views and suggestions on the proposed amendments. PDF would like to address the major \ T . points in opposition to the proposal raised by SP1 at that " hearing. The primary areas of interest seemed to be: (1} fh" absence of new data since the existing standard was promul-' gated to Justify a revision of that standard, (2) the offset policy, (3) the cost of compliance, and (4) the degree of Improvement resulting from the amendments. In addition some inapposite comments were made concerning the energy consequences of certain emission reductions. EDF believes these amendments are sound, representing.progress toward EPA's goal of zero emissions, and urges their promulgation. UFA - While EDF's claim that industry will have the opportunity to challenge in court any final rulemaking which may result from the proposal in question is true, because of Che way @112 'is drafted anyone opposing the proposed rule bears a heavy burden of showing with particularity in the rulemaking proceedings why the proposed regulation is improper. Zn short it is anomalous Chat EDF, a single group purporting to represent the public Interest, has not only avoided this burden in its litigation of the original regulations through a settlement agreement with EPA but also it has been able to shift this burden to those parties opposing the new regulations which It has dictated to CPA.;-; ;!" ;; lit f *.I see 1793 I I so i -4- . I- Absence of New Data The moat prevalent comment by Industry h;is been, "How could KPA change the vinyl chloride standards when no r.cw information has been developed?" There are several responses to this. First, EDF believes the original standards did not ,. comply with the law,* 5112 of the Clean Air Act, and so no new information is required to amend the standard to bring it in closer compliance with the law. Second, some signi- . . .. ileant test data was either not available at promulgation or, as with Dr. Ccsarc Maltoni's latest experiments, only became available shortly l>cforc promulgation, not allowing time for full consideration. EDF would like to rctraco and update the state of medical knowledge concerning vinyl chloride which, under the Clean Air Act, is to serve as the basis for EPA's regulatory actions. It should be noted that no data, developed either before or after promulgation of the existing standard, indicates that . any level of exposure to vinyl chloride but zero ppm is snfeV In 1970 Profosr.or Viola presented the results of a pilot experiment which showed that rats exposed to extremely high concentrations of vinyl chloride (30,000 ppm) developed tumors 1/ and carcinomas. Four years later the D.F. Coodrleh Company provided the first report, based on employee deaths from angiosarcoma (liver eancor), which confirmed that vinyl chloride was a human carcinogen, fflgnificontly, net all of HLK - Basis? Not so. HLK - Which? Must be specific. KLK - Evidence? In fact, all did -JZ O c *< O' u i. uu 3 a .zU .c. j o LO .. PON. <c0 H O DO a u3 8s o su X -5 s 5* u VUl 8 Co Oo $ oc .= V**I Col w e. cou \ a z I see 2-1784 ULK - What? There i r: also evidence; which i r.tli e-tt'.-n nngiorwncona is .... HLK - Whac kind? not the only health rink ij^r.oei a t oil with vinyl chloride. 21* : * !v 'd : .! 'i:1!- f - Anyinani.conn .nerved nr; n 'murkor disease," its rarity allow- iny a causal connection with vinyl chloride to ho easily drawn. Studies also point l.o vinyl chloride as tlm cavisal agort in the development of eaiu:er of the lung, the lymf.hal os, And the 4/ central nervous syston iii: well ar. the liver." In addition..................... CDK - Reference 4 should be checked for accuracy and Interpretation. A review of the report by Infante was written by Dr. McMahon for SPI and is attached. Dr. Peter Infante, currently with hlOSll, has observed an excess. . HLK - His papers have been discredited by CDC. rate of serious liirth defects (teratoiiei^csis) in residents in 5/ Ohio counties with plant:; emitkiny vinyl. chJorido. Mso, .. mutagenicity was J.ndJ call'd in studies hy Dr. F, rtnScrren of! NIKim, on tins effect of vinyl chloride On Salmonella -- liver micironoRU syuLcm?;. A liigher-lhan-ncirnial rate of r-til 11>i ri;hs and miscarriage:; amony the wives; of vinyl chloride worker-; and CER - While many of the VCM references at higher dose levels may be very valid, some of the low-doset short-time exposure data needs to be seriously evaluated for accuracy in the conclusions. This should especially be noted on the basis of the poorly designed Infante study noted in the literature (P.F. Infante, Oncogenic and Mutagenii Risks in Communities with Polyvinyl Chloride Production Facilities, 1975, ANN. N.Y. ACAD. SCIENCES, 49-57. a high incidence of abnormal chronosomes amony the workers / themselves have heen observed. v 'Some iimifni.ini- i-f:i data wan made public just as EPA w,u^. ; . HLK promulgating tho original standard and may not have been fully .. HLK considered. Other data not available at the time the regulations; HLK Not so - This paper shown to have been speculative. Let EPA so state What? were promulgated has come to light and serves as an additional basis for EPA to amend the existing standard to refloct the health rink poned hy lower level:; of vinyl chloride. Each group. .HLK - Source? of tests indicates vinyl chloride induces cancer at extremely low concentrations. Professor Viola first noted these effects 1/ at 30,000 ppm. iiy Juno ot 1P74, Dr. Cesare Malloni, in the NJ see 1 785 experiments which originally established the link between vinyl chloride ond cancer, reported that angiosarcoma had Keen produced in rodents by inhalation of as little as 50 ppm in V air. Just as the original vinyl chloride regulations wore promuloated, hr. Maltoni reported Llic induction of mammary ...... n/ carcinomas in rodents at levels of 1 ppm. Mi of this data -- was at least available to EPA prior to promulgation, though there was probably not enough time for EPA to fully consider Or. tlaltoni'u data. Completely new data lias since become available from teste performed by Professor K. Italoyanova at ... . the Institutcof Hygiene and nutrition in Sofia, Hnlgnrla. Professor Kaloyanovn found that vinyl chloride exposure ot 1 ppm 9/ induced carcinomas in both rats and mice. JUther than pointing toward the existence of a thresh,old for harmful effects, each test with vinyl chloride indicates that almost any level of exposure contributes to the development of cancer. The addition of the new scientific evidence fucthojj. justifies the amendment of the existing standard. It might t even be said EPA has a duty under the law to amend the existing { standard to reduce the level of vinyl chloride to which the . . .. public is exposed, based on evidence which continues to indi cate vinyl chloride is a non-threshold carcinogen. II. Offset Policy Under tho proposed amendments, hofrnre an existing plant ... could expand or n now plant locate nn.tr an existing site. of what one ca Consider reliable data when testing is'perform on a bacterial system versus a mammalian study..' . In reference, maimalian studies, certainly the unpublished vork of Dr'.j'Malcoi who reported the induction of mammary carcinoma-in rodentis'at levels of 1 ppm, is important. However, more data must-be obt. utilizing mammalian species at other selected dose-timfe -concen trations. Additional information must also be elicited.on the species papulation from which experimental animals are selectee in order to rule out an unusually sensitive species'. ' 1' *'t, ' | _ .. . CDK - The data generated by Dr. Maltoni and Dr. Kaloyanova are,:' cited as memos, not published reports, As such these data represent prellmlary results from Incomplete studies.' Appropriate consideration and meaningful evaluation of. these observations await completion of the experimental work'and.' publication of final reports. Preliminary results of ex-' perlments do not constitute scientific evidence. ! ;> ;i !:; ! . I HLK - Just the opposite - A dose effect relation is seen i' CER - There is no reason to believe from any of the studies of either recent or past origin that a dose-time response does not exist. As a scientist, one cannot generally consider it prudent hot to assume that there is "no threshold" for chemical carcinogens. In fact, it is most likely there is a threshold below; which the body is able to handle small amounts of vinyl chloride without adverse effects. Obviously if this is the case, there is;no-i EWS - Awkward reason to believe that carcinogens pose a'thres to human health at slightly higher exposure , lev over a relatively brief period of time. ro see -1 7 8 6 -u- rcriuctiona would have to bo achieved so there would be no net increase in total vinyl chloride emissions. This offset policy is necessary because, as FPA recognized in the back- 10/ ground documents, an emission standard by its very nature cannot: prevent the total amount of vinyl chloride relented from a particular facility from increasing over time should there bo expansion or a new plant built. About <.6 million n/ people live within five miles of existing plants and would not be adequately protected if no thought were given to overall levela of exposure. A clustering of large plants on the name . site could triple or even quadruple the ambient air concentra tion produced by just one plant. Another objective is to provide an incentive for industry to develop new technology, which will be rewarded by permitting expansion and new construction. The offset policy also represents a compromise. An i alternative approach could have been a no growth policy within- a given radius. ROF, however, felt this war. an unreasonable / position and did not pursuo it, though we believe it could have been legally supported. It should be emphasized that this "trade-off* approach is not new. KPA has already developed a similur policy for ................. regulating new construction in areas which have not yet , 11/ attained the primary air quality standards. In both eases, the objective is the came* no inefbase in ambient levels of "j ' - ] EWS - By avoiding being specific, EDF manages to create an impression that growth or expansion could or might create an unhealthy - . situation. ' }:>. ' EWS - This is inconsistent with EDF*s zero-risk to health position'. Offset permits continutation of something less than zeroiemlsslr which EDG contend it necessary to protect health. EWS - It new having been in effect for less than a year. Its ' results are not yet known. see -o- a pollutant which presents a health threat at existing levels. SPI suggests that applying this policy to a single chemical would be substantially different without saying irv what ways. Ffir feels the major difference, that this policy involves a single, confirmed human carcinogen, offers more support than . . even non-complying air quality regions for pollutants which arc not necessarily carcinogenic. As a first ctep in implementing this trade-off approach, . a facility which planned to expand would have to calculate, the total emissions from the existing operation. If the existing plant were not already in compliance with the present standard, the total emission figure would have to be adjusted to reflect pcrmissablc emissions from the existing -fociliV.y once it is in compliance. If, however, the emissions from the plant arc below the emission limit applicable to it, the pro posed rules would glvo tho source credit if it maintains its . T . emi'ssion levels at tho time a new plant is added or expansion', undertaken. It is through early compliance and continued ' reductions that additional capacity can be added in a given ' geographic area. Of course, degradation from levels for which credit was given will erase the credit and prevent expansion or new construction. A major source of cmlnnions from controlled vinyl chloride and polyvinyl chloride plants arc fugitive emissions. The original standards require either .'Specific omission limits or 'V !*-'. EWS - Implies a no threshold effect. EWS - (Comment on entire paragraph) If a new facility Is the'.same size as the existing one and yet emissions from the; old .plus new cannot exceed the old, is this hot ultimately goings to ' lead to zero emissions? 'ni: viii'- M see -1 7 8 9 see 1789 r bJ I -jo- . I ' i: !v 1 . the use of certain technology to control these sources, deductions in fugitive emissions will offer n means of earning credit under the offset policy in the same way reductions in other areas would. Two methods of calculating credit would lie available to each plant. If a baseline level for fugitive emissions could he measured or estimated, assuming compliance with existing standards, any demonstrated reduction could be used as credit under the offset policy. Deference should be given to industry'ti estimates of fugitive emissions because of the great Incentive to be accurate, A low estimate would nindcr future expansion and a high estimate of emissions would be harmful publicly. Alternatively, the operator of a plant should be able to isolate a particular source or sources of fugitive emissions, demonstrate that they comply with existing standards, measure or estimate emissions from them, and pro-jr coed to reduce those emissions. Any such reduction would, to transformed into credit. '/' Fugitive emissions have become the primary source of- ... emissions from vinyl chloride plants. Yet EPA has been unable to tackle tho technical problem of how these can be further reduced. One of the principle benefits of the offset policy will be to force industry to address the problem of how to control fugitive emissions. Any technical innovation will be rewarded by permitting further expansion, it is likely, in EWS - Are fugitive emissions consistent from one time tb:ahotheir? -i doubt It. ' i: . ' EWS - (Comment on entire paragraph) Great reliance on the'"graphite" approach. ; EWS - Has this been established? ) to . .v o - .. n-.-.e'-7==' 3 -<J o"-3 M to U m c . ' h o ' 'i\ r~t W4 U i-l W 3 <0 0, >\ 3 eg .a > a) OVA c o . 4- 3 "H T3 CSV oau U o c >N w X u tg D. 41 O6 T3 eg ~a c u, eg a ux w ogo iH JZ o <-i a C T3 U H 41 <g u 4' C C U w tj _ C. -J JO u o Xo c c f; o A U ' X 3 V3 0 O <j Ol 3 VI X o 3o *1 vu u < % V 1% u c o %V id *t -vi jj u G c a eg zti u 4 l4J O (0 tx 6 <g -h c 41 3 > <g h X -H tn j= U ClO U 0 O 9 9 C. a 9 M > O see 2-179C see -1 7? i -12- III. Cost of Compliance SPI attempts to make cost a central issue, even though the statute Cl*A operates under requires* reyulat ions based on protection of health and not cost and technology concerns. To say that Congress did not intend $112 to force plants to clo.se, as SPI contends, docs not necessarily imply no economic burdens should be placed on industry. In fact, industry has offered no cost estimates, possibly because the proposed amendments were designed to make use of existing technology and equipment for the most part, making additional costs minimal. in their July 19, 1977 statement, f.i'I estimated that vinyl chloride emissions will be reduced by 0.1 lb/hr for typical suspension plants and 0.02 lb/lir for typical dispersion resin plants, citing Table 4.3 of the Standard Support Document. SPI goes on in a footnote to mention that the Table reforred to does not actually use those figures. . f The footnote indicates the Table actually lists emissions as' ' zero (in which ease no new controls would be required and so the cost would be zero as well)- He do not sec either figure supported by the Table, in fact, the Table suggests a minimum of 4.4 lb/hr and a maximum of 7 lb/hr subject to further reductions. These figures would suggest that instead of costing $12.20 per pound of vinyl chloride removed per $10,000 expended, it would only bo $.C1 maximum. These are both nice, but meaningless figures. The only relevant figure is the ro '* . -n- increasc in the cost per pound of polyvinyl chloride. An additional expenditure of $10,000 in a typical size poly vinyl chloride plant only represents seven onc-thour.andthn of o cent increase in the; cost per pound of producing vinyl 13/ chloride. In the post, the plenties indnn'.ry lion demon strated its ability, in complying with emission regulations, to pose on costs without any significant economic harm to the industry. There is every reason to believe this will be the case with these regulations. Without any support, Mr. Holbrook of Sl'I states; I hat the cost of building n new plant, required by the offset policy if existing cmiusinnn cannot: be reduced, will be $10 million greater than expanding output at an existing pl.'ini. This figure might contain unnecessarily negative assumptions, such as locating plants in isolated areas ar. opposed to existing industrial parks where non-plastic industries arc located. This difference could result in exaggerated shipping costs and omission of additional economics. In the aboonci of further documentation ami comparison of costs, these figures' arc without value, for instance, an investment of considerably less than $10 million in control technology may be able to reduce existing emissions enough to add the additional capacity needed under the offset policy. ID n n -14- IV.Energy ConaumpLion EOF has taken an active role in the problems; of energy.............. supply, supporting conservation anti increased efficiency as methods of assuring a continuous supply of energy in the future/ He are somewhat confuted by SPI's use of l.he I'Lfi industrial 14/ energy efficiuncy targets as .in excuse for not adoptin') ; ! control technology for the oy.yohlorination process;. FEA officials wo have spoken to indicate it was never IT.A's intent. to restrict EPA's ability to impose health protective emission requirements on industry. The reporting form used to determine industry's progress toward the targets oven separates changes in energy consumption due to government requirements so firms will not bear any onu;i for excels energy coiiSuinpt iqii required 15/ for compliance. Even more important is the fact that f'.'.h guidelines apply to an entire Industry. SPI attempts to apply .. these to a single process within only a segment of that industry. This misses the point of the targets, which is to give industry the choice of how to achieve increased efficiencies. A minor increase in energy use from ono process simply docs not justify discording the standard. SPI's comments also present unsup- ( ported figures indicating the energy required for control of the oxychlorinntion process is greater than KPA originally estimated. Yet, in the preamble to the proposed amendment.';, EPA states that the adoption of a recycling and oxygen feed system eliminates the supplemental feed problem. This is because JAM ' -1- ; '|.!l. . 1 The EDF has apparently no_t read or does not .understand r'theiguidi lines Issued by Che FEA/see FR 29642 (1977// attached'/..hThe/; efficiency goals are set not only on a general Industry basis. (chemical) but also by subclass. In the SPI testimony:the'; targ< for the entire chemical industry was cited. If we ; look. linjmore detail, we find that the target for SOC 2869 (the class which: includes VCM) is 15.9% after allowing 1.5% for environmental-an; other government regulatory actions. It is obvious that^the EDI could single out any specific process and claim [that its1 lihcrea? energy consumption can be counterbalanced by some other process with even greater improvements. The improvements envisidned by increased energy consumption must Justify the increases iri enerj requirements and it is the position of SPI that they'do'not;. JAM The EDF also has not understood the comments relative to;the in crease in energy requirements to meet a 5 ppm emission limit fen the oxychlorination reactor. The SPI testimony (also that of Shell's) stated that the operation of an oxygen-recycle technolc system requires a 72 Increase in energy over that'of the.EPA's typical air feed oxychlorination plant. This matter wasjdiscus with EPA at the June meeting In Durham (which is part of.the public record). The EPA stated at that time that;they had 'not realized this and would Investigate the matter further. '\iln fsci the EPA has discussed this further with Shell (and. perhaps ;othei on at least two occassions. These telephone discussions; 'are al: part of the public record. The SPI testimony was simply, pointit out that, in the support document for the original'standardj the EPA rejected the use of incineration to control' the..oxychiorinai vent because it required an Increase of 62 in energy consumptior Since oxygen-recycle technology requires an even.greater'Amount energy, we fail to see the rational for the proposal. , -vi .; The EPA Is simple incorrect in its preamble statement . that the oxygen-recycle t inology does not require additional energy. 1793 tn n n -15- tlic effluent gas stream would be wore concentrated using (lie technology to he installed in new plants, requiring less energy to reduce emissions. v. . V^V. K:;'1 1 V. negreo of Emission deductions nut-' believes the degree of emission reductions resell ing ... from the proposed amernliiiciits is significant enough to justify their promulgation. but the actual extent of reduced emissions which result from the proposed amendments is less important than the fact that they represent progress toward EFA's goal of zero emissions -- the only level adequately protective of ..... human health. SPI maintains inconsistent positions in its prepared statement for the July 19 bearing on the quantity of emissions reduced. On one hand, it :.s recognized that even with the ..................... existing standard, DC purification and VCM formation plants will have emissions of 2. f lb/hr excluding any emissions .i^rom the oxyehlorination process or fugitive emissions. Oy levering allowable emissions from 10 to 5 ppm, a 1.25 lb/hr rcductioh would result. Yet 51*1 then goes on to say any reduction under the proposed amendments would come solely front improved con| trols on the oxyehlorination process. This ignores the 1.25 lh/hr reduction attributable to ocher parts of the process. SPI also .. suggests that there only be a 10 ppra limit on tha oxyehlorination process. Tho 0.9 lb/hr reduction from 10 to 5 ppm limit, which this would preclude, if. not insignificant, hlao considering " ' l [ l-i 1 ''i - ; JAM - Again EDF'has failed to review the data as presented: by 'ISPA.' has claimed, in its proposed regulation, that >th'ere:'wili;|be a emission reduction of VCM from new typical size oxychlorinati plants of 11.6 lb/hr. Using the data presented by EPA`in its Support Document, it can be seen that this reduction; will. con. solely from the proposed new standard from oxyehlorination ve EWS - Again EDF assumes no threshold. :i JAM - On the other hand, EPA has also proposed that the allowable emissions from other sources in a VCM plant be, reduced by'-50% Again, from the Support Document, the data shows that this is meaningless proposal because the EPA has stated that'there an (zero) emissions from these other sources. What!-SPI- attdmptec point out Is that the EPA's table showing "zero'1; from "these ot sources is not precisely correct and that the emissions may b( about 2.5 lbs/hr. With the proposed ,50X reduction, a miximum 1.25 lbs/hr might be realized and that this figure is \ihsignil leant. i` |.: . i; | , 1 i; - JAM - Nowhere in the SPI testimony was it suggested chat -a 110, >ppm 11 be adopted for oxyehlorination vents. SPI simply pointed; out that the EPA has published data In its original support .docume showing the impact of.a 10 ppm limit. The EDF's statement tha 0.9 lb/hr reduction is "not insignificant" demonstrates -that t have little unc^>-standing of how to measure impact. . a1! CO 1 see 17^4 -16- the substantial reduction required to reach 10 ppm, it docs not seem unduly difficult, especially at the design stage, to adapt the technology to a lower limit. Industry has expressed a great deal of concern over ihc offset policy a.-; a means of reducing community exposure to vinyl chloride. In its July 10 comments, SP1 chose to focus attention on the impact, of the policy on annual ambient levels from vinyl chloride plants at distances of five miles. (Despite repeated requests, DDK has not received n copy of the dispersion study conducted by Dames and Moore. That study conspicuously does not consider the uffcct of a single plant - expansion which probably causes a greater increase in ambient levels than certain combinations of plants.) Scientific analysis of the processor cancer indicates that even carcinogens . . 11LK at low doses, with levels in parts per billion, may pose a 16/ health risk and thu3 constitute a legitimate concern of ...... . 'ty- . .. HLK EPA. It should be recognised that by examining annual levels,^, instead of shorter time periods, and distances of five miles, instead of closer to the plant, a "host case,* from industry's s point of view, is described. Figures in the Standard Support Statement demonstrate for those same five mile levels, sub stantially hlghor levels will he found at shorter distances with a tremendous difference between short-term and annual ambient levels even for plants complying with the existing standard. Theue figures demonstrate the value of reducing existing emissions, -17- ,f. I i; as done by the proposed amendments, and the need for an offset policy to prevent the increase, especially of chert-term levels, caused by expansion of an existing plant or construction of r'. V. : -^1' i r ;. ! , .<; i. ' -''nil i;2 : a new plant. EPA'o ambient level estimates, based on disper t ' ' j: ' , ' k sion modeling for a large polyvinyl chloride suspension/ .................. EWS - Models are notoriously inaccurate. Any modelling -data should b< 17/ checked against actual measurements. . ikik ; dispersion plant arc: 1 Time Concentration 5-minuta avcr.igc maxima 24-hour average maxima annual overage maxima 12 ppm 0.6B ppm 90 ppb Other modeling done by EPA at greater distances to determine ........ JAM - The data given in Table 6-3, 6-4, 6-5, and 6-6 of;the "Support Document" (which .is that used by EDF) shows the maximum at-one the maximum ambient levels produced by a cluster of four ethylene given point VCM concentration for the .various' types' at. VCM' or; P' dichloridc - vinyl chloride and polyvinyl chloride plants plants and has nothing to do with the average exposure of`piersoi living within five miles of a plant. '| k complying with the existing sLandnrd produced the following 18/ If_one wishes to use EPA data,' the model which EDF should have looked at is that contained.in thb'7|: figures: "Quantitative Risk Assessment" document (December Time Concentration 1975). This report shows for uncontrolled plants that persons livinR as close as 1300 feet rrom a typical PVC plant,. the;annu< 5-minute average maxima . 24-hour average maxima annual average maxima 3.1 ppm 0.59 ppm 99 ppb average exposure level is about 300 parts per billion (ppb): Tl living five miles from this plant have an average annual expoaui of 4 ppb, with an overall average for all persons living irithin These figures strikingly demonstrate that for the. annual five miles of 17 ppb. For plants controlled to the existlriR' ambient levels in the parts per billion range cited by SPI-, standard, the average annual exposure of all persons livingjwitt five miles of a plant is about 2 ppb. These exposure'ievels art short-term levels in the parts per million range could occur. far from the OSHA allowables that the EDF testimony should |t>e dj In fact, for plants complying with the existing standard it missed for its lack of candor. i is possible that ambient air concentrations will exceed the Furthermore, the EDF has missed the point of the SPI testimony i which was to challenge the validity of the results of the;EPA's maximum allowable uccup.ition.il exposure established by the calculations in the "Risk Assessment" document. 'The Dames''and F Occupational Safety and Health Adminiutration (OSHA) of a S ppm 19/ ceiling averaged over a fifteen minute period. study shows that the annual average VCM concentration within fiv miles of a controlled typical PVC suspension or dispersion plant was less than 0.25 ppb rather than the 2 ppb cited by EPA'!, Also the SPI testimon' 'ffered data (again in Dames and Moore report) that the proposed standard would have less than a 0.1 b effect i the average annual concentration within the five mile radius;. The EPA ha9 failed to evaluate this Impact. (See additional comments t top of page 18.) see -1 7 9 6 -m There j rs reason Lo believe cmcinogcnr: pose n threat Lo human health at slightly higher exposure levels over a rein- .. tivcly brief period of line. This in significant I'oc.uitc .... control of point source!:, whose emii-.'jioiui are to he reduced hy ouc-h.-ilf under the proposed ;unvndt<*nts, )an, according lo 20/ F.PA, a disproportionately large impact on reducing short term ambient levels. The table:; above ckiwmil riiUi the likeli hood of high short-l enn /irnbiunt levels even when annual Koeu.e ui t-no s. u uxion people living within mile jradius' of VCM and PVC plants .would be decreased more -than elghf jfoid'rr1 fBy; June of 1975, EPA had completed extensive-surveys of jviriylj.'chibrid concentrations in air surrounding three different plant'fcomplpxes. Findings were that concentration levels were below' those 'contem plated by the EPA standard before implementation of the -controls required by the existing standard. Considering this, it'1 would see unreasonable to propose tighter standards especially !wlthout va. showing of need before the existing standard was fully.implemented and its effectiveness measured. ... i- .JAM - The EDF raises the question regarding the effect of short .term'. exposure to higher levels of VCM. I will leave comment'on this, to the medical group. What the EDF has done, however,' is mix !:: "apples and oranges" by citing data from the "Support-Document" - in an attempt to rebut the SPI testimony concerning the average exposure of persons living within five miles of VCM-PVC plants: . EWS - What is the source of this allegation? ambient levels arc much lower, lienee, if short-term exposure to n carcinogen pones a risk, the significance in terms o' protecting health of any reductions under the proposed amend ment u is greater than in,me number:i might indicate. |_ That a greater threat may c::ist from short-term exposure t to somewhat higher ambient levels of vinyl chloride is con sistent with current theories of chemical carcinogenesis. 21/ One Lhcory proposes that cancer in induced in a single cell. ^. , This so-called "one-hit" model implies that the total dusogo ^ ; nnd not the length of exposure determiner, whether cancer will- I be induced. Thu:; a single exposure to vinyl chloride could conceivably cause cancer in the population surrounding vinyl .. y | chloride plants. Another theory, known an the multi-hit or multistage' model, suggests that a single cell must undergo n 22/ serious of changes before it can generate a tumor. Thin theory Also suggests that exposure to slightly higher concen HLK Only a theory, and not a good one at that. . Some carcinogens , i' , at one concentration are essential for life, at a second - '.'p ex: CDK - References 21--25 should be checked for accuracy and interpretation. The first sentence of the first paragraph on this page (18) should be referenced. The discussion of theories of chemical carcino genesis is selective, incomplete and cursory. Again, references 21-23 should be checked in order to determine accuracy and appropriate interpretation. tration::, even of short duration, may pose it threat,. The work M SLC 1797 -19- * *. i 23/ o Crump, et al. ties this all together by showing l-hat most models of carcinogenesis will have a linear dose-response relation at low doses, assuming there -are already carcinogens present which act in conjunction with the specific carcinogen under study. Hy combining those theories, an interesting conclusion is reached: shorl-Lorin exposure to a chemical carcinogen ut slightly hiciher levels than arc normally present presents a potentially sign! iicant .risk of cancer. Ars the Standard Support Document points out, this in just the typo of exposure which will be most affected by the proposed amendments. Scientific evidence for other carcinogens demonstrate ft ... that the risk of actually developing cancer following only u brief exposure is very real. In the case of asbestos, woi Iters who were exposed for only one month showed substantially 24/ increased rates of lung cancer. Persons living outside ' T . a'sbcjtos plants, with low level exposures for only seven yenrsj or less, developed mesothelioma, nn extremely rare cancer"/ 25/ associated with asbestos exposure. The risks of short term and low dose exposure to a carcinogen are not. just ' theoretical, and constitute a substantial basis for regulation, especially since $112 requires protection be given with an nmplc margin of safety from just these types of threats to CER - health. *Wynder, Ernst L, M.D. and Gorl, GioB., M.D., "Contribution of the Environment to Cancer Incidence: An Epidemiologic Exercise," Journal of the National Oncer Institute, April, 1977.' **Fraumeni, Joseph F., Jr., Persons at High Risk of Cancer: An Approach to Cancer Etiology and Control, Academic Press, Inc., New York,-1975. HLK - Hot so. CDK - The first sentence of this paragraph should be referenced. HLK - Not VCM. CER - Statements such as, "the risk of actually developing cancer following only a brief (environmental) exposure (to a carcinc Is very real," cannot be proven and reveal a lack of;under standing concerning delineation of persons in high-risk cane* groups. From a review of multiple literature sources,' the sc called "environment" is implicated in a large percentage of cancers. This "environment" appears to include all elements Influencing cancer incidence originating wholely or largely outside the body. Thus, many authors have concluded that "environment cancers" are Induced or. related to-our personal habits and lifestyle as well as things beyond our personal control. The leading known causes of cancer in the United St are clearly extrinsic. Tobacco and alcohol use and nutrition factors appear to be important contributors to."environment cancers," accounting for well over half of all cancer deaths* One must also consider the ten percent plus of all cancer cas^ which apparent!v have heraditary factors**. Only if these things are cor' dered can a sensative approach to cancer' etiology and control be reached. \<S I see 1798 -20- l?Kpo$ure to even sm.il] Joses of vinyl chloride must b<* viewed in context. First, individual responses to carcinogens vary and there may Ins people, who will be susceptible to carcinogens at low levels, lienee, even a slight reduction in vinyl chloride levels could reduce the incidence of cancer. Also, l.'PA cannot ignore the fact that people avc subjected (o many other chemical exposures, such as to polychlorinated .............. biphenyls (PCRs). ll.jJf of the U.5. population is believed to have accumulated 1-3 ppm of I'Clls in their fatty tissues............... These compounds arc similar to DPT and ether chlorinated pesticides. Their metabolism activates specific liver enzyme systems, enabling the liver to more readily metabolize such chemicals as vinyl chloride. The presence of Tens and certain pesticido residues in our bodies may render us tnorc susceptible to cancer from a given dose of vinyl chloride than otherwise would be predicted. There may be other additive effects of A carcinogens which again would moke low dose exposure, or ' higher dose exposures over a short-term, more dangerous than 26/ they would initially seem. .......................................... i VII. Availability of Interim Emission Limits ' EOF recognizee that some plants may experience particular difficulties in meeting the standards under the proposed amend ments. EPA has also recognized this and has included a relief valvo. A particular plant which, denpite a full effort, in unable to comply may request an interim emission limit lower CDK - The discussion on this page argues for an investigation^ jo chemical interaction, potentiation and enzyne'induction. I'.j.'; (all needed) but does not argue for long-term inhalation!^'1 tests of low levels of vinyl chloride as might be-expected from the first sentence. HLK - Also tobacco. HLK - Not VCH. 1 '>i . ! HLK - Very Speculative. i'My. K) -1 7 9 9 1300 ! I rO tnn (:i 21- Lhnn that required by the proposed amendments. Plants are given one and one-half years to determine how they will comply. This is a reasonable amount of time to develop projections as to whether compliance will, he possible, before installation of equipment begins. EDI' hcliovus specific criteria would not be appropriate for granting interim limits because the Adminis trator will be considering problems applicable to n specific plant. He assume plant operators will have no difficulty ............................ obtaining such interim lin.it?; if, even with their best effort;;, EWS - Is It safe to make such an assumption. Can EDF speak] authoritatively for EPA and other activist groups?. compliance will be impossible. Issuing an interim limit will have an important impact on tbc surrounding community. It is therefore extremely important that at least a public meeting be held ta enable ......................... interested citizens and groups to present their position and EWS - This seems inconsistent with the above assumption. . challenge, where appropriate, industry's basis for an interim limit. Of course, confidential and proprietary information!, need not be revealed. EPA has an ample record of protecting such information. There is no reason not to have the nog-, confidential information subject to public discussion. Contrary , . . EWS *- Is the public an authority on health and control matters1 to s to SPI's belief, there are many responsible citizens, environ nothing about technology and economics. ;J : mental and civic groups, which could contribute to such a process and possibly even aid industry by suggesting alternative processes and procedures, lust as RDF has done with reaped; to .... suggesting the ozonc-UV process as an alternative control EWS - Had EDF adequately demonstrated this technology? ' Or is'it Just a gleam in Houston Research's eye. ; technology. _ -22- EOF has been extremely disappointed with the stance industry has taken in trying to reduce the levels of vinyl chloride, a human carcinogen, released into the environment. The flexibility of the interim emission standard in these proposed amendments points out the real purpose of the amendments -- to have industry, with tremendous technological expertise at Its disposal, try harder. Only with their expertise and cooperation can EJ'A's goal of zero emissions ever he achieved. VIII. Conclusions EOF supports the proposed amendments to the national Emission Standard for vinyl chloride. As we have pointed out the initially mandated reductions simply do not go far enough toward compliance with the law. These proposed amendments represent an important first step towards achieving EPA's goal of aero emissions and may have a significant effect in'^' protecting public health by reducing short-term exposure to. higher doses which the current standard allows. The proponed amendments will also result. in a substantial reduction in x emissions from new sources which must comply with the reduced emission levels before operation is permitted. Finally, and perhaps most important, the offset policy should encourage the development of technology which will ultimately permit a substantial reduction in fugitive emissions from existing sources, an well as preventing residents of areas surroundin'* ;; FT EWS Zero emissions Is unattainable In practice bartlnR a': complete shut-down. . I';-': hJ I see 1801 c h lo rid e tw o o r th re e tim e s th o s e o f ju s t a s in g le c o n tro lle d .% hl_l_ 1B02 > oo 24 Q -> C|< sc g>- 9> C ."5 21- 8l2 e5 it --o VTM Om ec <w -J! -C c= -< n u < *c H OiH 4J cfr. s 2--i c. e\h -> O 5 c!2 hi! eu 0H 2 > C ^ r!- of IA *! O Q. S IAJX iio r. 0s > 99 s -1 n c. a ux s%[b% !!> Tjfs cl. e j. cl- rio ol--< If U. xj ci *5(2 Sji 5a !*j =!* J2C5 jj{ai wlcj - c. ur y hu2 <a x -* ~Sj2 .516 0<VI u > M- * K - is. rj w (/! co O- Li 2 V2 --uC u0v *> ^ 0 vs U CJ cu C w3 ic) *O EE to X C ,M O f M <U M o = 0 -u M (A <3 M c C *o U 5. Z -5 CilO H 5 it _ C < U V< >-- E -O OC U o -i *W O 1 %. C -MtOO e e oo -- u --< r-h -u y a r- qee h w n y ~i o wo e.S'n . no O '> * Vi Z - O 6. L. Jj * C c > H fl J J .S'} O c -H -- U --( u OH 3 9 c = a.^1 L. < .} VI U CC 1- C "S o E c e o l- - a u O u (J ul q : U 3 3- g a -< h >, E u a * C v > n -< =Ca e> S?>2 J ^!h Ee ' uS 9~ s^ii 2I bLu 2-1303 -25- 14. 42 Fed. Beg. 2960 (1577). 15. 4 2 Fed. Reg. 32831 (Juno 20, 1977). 16. r..S. Crump, ct al., Fundamental Carcinogenic Processes and Their Implications Cor l,ow nose Risk Assessment, j6 CANCUIJ RESEARCH 29/3-2979 "tf97tT^ 17. Standard Support and environmental Impact Statonmnt, supra note 10, Tobies C- 'S', 6-4, . 10. Ibid., Table 6-6. 19. 39 Fed. Bog. 35090 (1974). 20. Standard Support and Environmental Impact Statement, supra note it), at 6-20, 6-21. 21. N. Arley and N. Iverson, On the; Mechanism of Experimental . Carcinoeenesis. 31 ACTA PXYliOb. MICHOlllAL. SCAMI).`T54-f7T Tf6T5) -------- 22. C.C. Drown, Mathematical Aspects of Pose-Aasponsc Studies in Cardnugenosis - Tlie Concept of ThreshofiTtTI 53To;,iCOrX)GV 23. K.S. Crump, et ol., supra note 16. 24. I.J. Solikoff, Asbestos Disease in the United States, 4 REV. FR. MAI.. RES!*; 7-5-T (lJ'JiTI 25. - Environmental Defense Fund, Petition for Emergency Action *$', Under 5303 of the Clean Air Act to Abate Asbestos Pollution;, in Montgomery County, Maryland, pp. 7-0 (May 10, 1977). ./ 26. R. Preussmann, Chemical Carcinogens in the Human Environment; Problems and Quantitative Aspects, 33 ONCOLOGY 51, 57 (1976). KJ I see 1S04