Document qkr2LnnO15qg8wKGvnXmbMOVG

A Division of The Society of The Plastics Industry, Inc. August 28, 1989 TO: The VI Health, Safety & Environment Committee RE: California Air Resources Board Draft Report on Vinyl Chloride Enclosed is material I received today from Peter de la Cruz relating to the development of a report by the California Air Resources Board outlining "Public Exposure To, Sources, and Emissions of Vinyl Chloride in California". As noted, the comment period on the preliminary draft closes on September 8th; a revised draft will then be developed with a 20-day comment period before the final draft is forwarded to the Scientific Review Panel. If you have separately received this document and filed or plan to file comments, please let me know. As the material I received notes that "landfills are the largest source category of vinyl chloride emissions in California", I have copied the appropriate VI Technical Committee contacts. MNS/pmb enclosure cc: C. Bush J. Krokosky R. Gottesman Meredith N. Scheck Assistant Director SPI-05592 Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (201) 890-9299 vc*cw t. *cu.c* .CAftMft m, nCCKKArt witUAM m. IODCnUAMI. MALCObX O. tatAITMU* WATWC V. ILAC rc**i.cc . vo*4 MAtTlN w. |CC^*C wrt* s. CW4M4 CAOct 4. MHKI| MMIf MA**HA m<NAMAIIA m>cmac. f. o*e* 4vAa*Xn . meev*CAM**M JOHN 4. 0V4CCK #CTC U m w* CJM4 CHdlSTlHCA. mCa6"C* S*iUCY ft. *Ugi**4 UAWACMCC *. MAh4lM Mlm A. itMMOnl (?* A. 4U44CA 4. 4v4lA4WAACTT HOT A5MJTTCO l 9.C 4*CU* A, MltlA* CWV<M 4. 4AQXCN 0'4r0eAo4cCkic4b. M,j.ISoHaOt, ga. masoi C e*CBMSTCia MABClA . SOWAN *ATlCR g. RUSO 3. CAt6 TAwTrc^T MAIK A. ilCvCA* fMt.>CrAMA*CNURM* N4ACO*O"mTTI 4AaiCt*mAcA*ihA< Va.A*/o'tcmc* gtf'wtt a. **< ANMt MQMTCITH clwot sei.it.os SHANNON u CNMAN* SWSAM b ro* HAAS U JTZHO^r CSWIN C. MOwSS* law oeeices Ksiles and Heckman H50 17' STREET. K.W. SUITE lOOO VASHIXOIOM, D.C. 20039 (SOS) 9S6-SOOO August 28, 1989 icjesrtnc STArr Samici, $. frxui*. * . cma*lu v. sscocs. *. o. *04CAT A KaThCWS, Pm. 0, jOhn 9. mooocsman. Pn. o. oar MVTMitc fOLtr gUlTlM ft. AftWCLW l*n. o. (MftlMCC*TCLSCOwauN<CA?lftNft ftMAAwtft f. TgBHCS Tciat TCUCC04C4 (tot) fts.rsss CA4WC ADdftCM ~xetMAa- WSITCS-* 9ISCCT DIAL MWH4e (202) 956-5641 VIA TELECOPIER Meredith M. Scheck The Vinyl Institute Wayne Interchange Plaza II 155 Route 46 West Wayne, New Jersey 07470 Re: CARB Draft Report on Vinyl Chloride Dear Meredith: Enclosed is a cover letter and the executive summary from a preliminary draft report on vinyl chloride being prepared by the California Air Resources Board (CARB). Comments are requested by September 8, 1989. Since the deadline is fast approaching, we may wish to contact CAR3 and determine whether later filed comments will be accepted. I The enclosure is all the materials that I have. I understand that Goodyear sent a copy of this to Goodrich, but I am not sure who at Goodrich received the materials. If the entire document is needed, you or I can obtain it from Ed Nowak at Goodyear (216-796-7417). Please let me know if I can be of any further assistance. CorddiajUy yours, Enclosure cc: Ed Nowak Larry Thomas Robert w. Sherman Lewis R. Freeman, Jr. m,. Peter L. de la Cruz SPI-05593 AUG Z\ 'S3 10:23 FROM r' ODYE AR RSS RM 255 AIR RESOURCES BOARD nvi q jnttfT >.ol OX Ml.* CA *SV3 PROS.002 0*OTO $nrw August 1 1989 i Dear Sir or Madam: Draft Report-on Vlnyl-ChlO-flde As you requested, enclosed for your review and comment is the preliminary draft report on vinyl chloride. f Fublie review of this report includes two comment | periods. The first comment period begins with the mailing of i this report and you have until September 9, 1989 to submit your | written comments to us. The staffs of the Air Resources Board | (ARB) and Department of Health Services (OHS) will review and I respond to all the comments rtctivtd. Your comments and our responses to them will be compiled in Part C of the report and where appropriate, the report will.be revised. The revised report will be mailed out to you and other mnmhnrs nf the public for a second and final review. It will Inc.lude Parts A, 8 and C of the report as wall as an Executive Summary which summarizes Parts A and 8. At this stage, the ARB j and OHS staff will only accept comments on the Executive Summary I and any revisions made to the draft report. A 20 day comment period will be given for your review; comments received, and our . responses will then be incorporated as an addendum to Part C. j After reviewing all public comments, the final draft report along with Part C will then be submitted to the Scientific Review Panel for its review. The Scientific Review Panel has requested that all public comments be directed to the AR8 during these two comment periods. Please note that, in accordance with this process, the Panel will not receive or consider any comments submitted j directly to it, or received by the ARB after the close of each j comment period. SPI-05594 -- * ftUQ 21 'S3 13:23 FROM ' 'DYE AR RES RM 25S PAGE,003 August 1, 1989 In order for your comments to be considered on this version of the report, they must be received by September 8,4919 and submitted to: Mr. Robert 8arha, Chief Toxic Air Contaminant Identificetion Branch Air Resources Board Attn: Vinyl Chloride ?. 0. Box 2815 Sacramento, CA 95812 ( If you have any questions concerning the report or the comment procedure, please contact Mr, Richard Corey of the Substance Evaluation Section at (915) 323-8543. I 1 Enclosures cc: Scientific Review Panel Peter 0. Yenturini, Chief Stationary Source Division SPI-05595 PUG 2'1 '83 10*30 FROM r"'ODYEfiR RES RM 25S < PRELIMINARY DRAFT TECHNICAL SUPPORT DOCUMENT mi a PUBLIC EXPOSURE TO, SOURCES, AMD EMISSIONS OF VINYL CHLORIDE IK CALIFORNIA REPORT TO THE AIR RESOURCES BOARD OH VINYL CHLORIDE e .l. PAGE.004 Principal Author Richard Corey Contributing Authors Toa Parker Chris N$uyen Paul Allen Steve Hat Reviewed and Approved by; Joan Oenton, Manager Substance Evaluation Section Robert Barham, Chief Toxic Air Contaminant Identification Branch Peter 0. Yentufinl, Chief Stationary Source Oivision July 1989 SPI-05596 pU<5 '53 10:30 FROM GOODYEAR RES RM 258 PAGE.005 r\ i. INTRODUCTION Part A of this report is an evaluation of vinyl chloride's uses, emission sources, ambient and indoor air concentrations, and population exposure in California. Also included are discussions of the physical properties-and atmospheric persistence of vinyl chloride. California Health and Safety Code Section 39655 states that substances listed by the U.5. Environmental Protection Agency (SPA) as hazardous air pollutants (Section 112 of the Clean Air Act) shall be identified as toxic air contaminants (TACs) by the Air Resources Board (ARS), Therefore, because the EPA has listed vinyl chloride as a hazardous air pollutant, the AR8 is directed by statute to identify vinyl chloride as a TAC. The AR8 is the state agency responsible for the- identification of TACs in their non-pesticidal uses. .The California Health and Safety Code Section 39555 defines a TAC as "an* air pollutant which may cause or contribute to an Increase in mortality or an increase in serious illness, or which may pose a present- or potential hazard to human health." The findings of the Part A report are considered with the health effects findings (Part B report) of the Department of Health Services (OHS) to determine if a compound should be identified as a TAC by the ARB. In 1978, the AR8 adopted an ambient air quality standard for vinyl chloride of 10 ppb for 24-hour average. The standard represented the limit of detection for vinyl chloride at the time it was adopted. Yinyl chloride is an extremely volatile compound that is primarily used for the production of polyvinyl chloride (PYC). PVC is fabricated for use in several products of which many are used by the A-i SPI-05597 AUG '09 10: 33 FROM ODYeflR RES RM 25S PAGS.00S J construction industry. In California, the identified sources of vinyl chloride emissions are landfills, PYC production and fabrication facilities, and sewage treatment plants. Available information indicates that landfills are the largest source category ef vinyl chloride emissions in California. Vinyl chloride has been measured in the ambient air near hazardous waste and municipal waste landfills. Numerous studies have documented the presence of vinyl chloride in the landfill gas of these and other landfills, and have shown that vinyl chloride can be formed in landfills where chlorinated organic compounds have been disposed. Therefore, because disposal of such chlorinated compounds 1$ prevalent, the staff reconmends that all landfills (hazardous and municipal) In the state be regarded as potential vinyl chloride emission sources. In this, report, ambient monitoring data and meteorological data are used with an atmospheric dispersion model to estimate population exposure to vinyl chloride near two California landfills. The modeling results show that people living near these landfills are exposed to elevated levels pf vinyl chloride. The results also imply that people residing near other landfills in the state may be exposed to elevated levels of vinyl.'chloride. In addition to estimating ambient air exposure, this report also evaluates indoor air exposure to vinyl chloride. Based on limited monitoring data, indoor air exposure to vinyl chloride is probably not significant for the majority of the population. However, for people residing near landfills, inhalation of Indoor air may represent the most significant source of vinyl chloride erposure. This is because Ytnyl chloride can migrate underground from landfills and accumulate in nearby structures. The concentrations of vinyl chloride measured in homes located near landfills have been reported to be several time* greater than the corresponding ambient concentrations. j 1 I j I i A-2 SPI-05598 I .AUG 21 '09 12:31 FROM GOODYEAR RS RM 253 PAGE.00? Prepared by: California Departaent of Health Services Principal Editor: Horaan Cravit2, Ph.D.. XPH. Staff Toxicologist Revieved by: George V. Alexoeff, Fh.D. Michael J. Lipaettt, M.D. Douglas H. Cox, Ph.D. (California Publie Health Foundation) Based In part on vork subnittted by: Carla C. Christensen and C. Tucker Heines, Biological and Enritonaental Cheaistry Departaent, SRI International, 333 Ravenrvood Avenue, Renlo Park, California 94025, Under Contract 85*86676 <045A) and by: Deborah Grady, M.D., K.P.H. School of Radioine. University of California, San Franciacd, and Allan Saich, tf.D.. PH.D. University of California, Berkeley SPI-05599 AUG 21 39 13:31 FROM GOODYEAR RES R(1 25S PAGE.009 1.0 Executive.Suawaty Vinyl chloride Is s shore-chain halogenated hydrocarbon used predominantly in the manufacture of polyvinyl chloride and various packaging and com true cion produce*. Vinyl chloride ha* a very lev degree of acute toxielty, with evo-hour inhalation LDjg values ranging froa 27,419 ppa in alee to 236,215 ppa in rabbits and guinea pigs. Exposure to high concentrations can lead to narcosis, cardiovascular and respiratory irregularity, convulsions, cyanosis and daath. Several husan deaths have been attributed to occupational . exposure co very high level* of vinyl chloride. Autopsies of these patients revealed congestion of the liver, spleen and kidney*. Acute toxicity syoptoas are choughs to occur above 100 ppa. Chronic exposure of worker* to vinyl' chloride ha* been shown to lead co "vinyl chloride disease", characterized by occupational aero-osteolysis, vasospasm of the hand* siailar to Raynaud's syndroae, darsaeleis, circulatory and central nervous eyetea alterations, thrombocytopenia. splenoaegaly and changes in liver function. Sight symptom* conponly reported by workers exposed to vinyl chloride (including dissiness, headaches and nausea) were observed even at dose levels below SO ppa. Vinyl chloride ha* been shown to induce cancer in animals in utero^ but has not been shown to cause any the* reproductive or 1-t SPI-05600 AUG. 21 '89 10132 FROM GOODYEAR RES RM 25S PAGE.009 n P ^ >' developaencal effects in rats. mice and rabbis*, Epidemiologic studies of families of vinyl chloride vorkers or communities having vinyl chloride processing facilities suggested tha possibility of an increased incidence of birth defects and spontaneous abortion* among people *c risk; however, subsequent review* of chase studies have concluded that lh*X9__ is--Inadequate__aydeoga _to link gnyirqwsnCAl .gr taaemal--exposure go vinvl chloride Vith Mrrfr defects or spontaneous abortions in huaana. The noncarcinogenie affects occur at concentrations near or above -10 ppar which Is greater than four orders of magnitude above possible general ambient levels in California (0.5 ppb). The noncarcinogenie effects also occur at concentrecions greater chan 3 orders of magnitude above the highest concentrations measured near landfills <10 ppb). Consequently, MS... staff do not expect; nonearcinogenic adverse health affects ta occur frt>..c.H.gt..qji chronic axnosuree to vinvl chloride in ambient air. The International Agency for Research on Cancer, CIARO. the United States Environmental. _ Protection Agencv (,CFAl_and_the California Deaartmanc of Health Services (CDHS1 have identified-Vlnvl chloride as a ehemtcal for vhlch _ there___is sufficient--vjflKft--,gf carcinogenicity In both-humane and experimental animals. Chronic Inhalation and., oral exposure* of rats, alee and hamsters to vtsyl chloride have been associated vith an increased incidence of malignant and benign tumors at several sites including the liver, lung, mammary gland and the nervous system. In humans. ; ` 1-2 SPI-05601 flUG S'! '39 10*32 FROM GOODYEAR RES RM 256 PAGE.010 epidemiological studies f occupationally exposed workers have linked vinyl chloride exposure to development of s rare cancer, liver anjiosaroeae, and have suggested a relationship between exposure and lung and brain cancer*. Although pharmacokinetic studies in huaans exposed to vinyl chloride are rare. Liaised evidence indicate* that, fallowing inhalation of low level* of vinyl chloride <3 to 24 ppm), up to 71% (with e seen value of 42%) of the given dose may be absorbed. Vinyl chloride absorption appear* to depend on its metabolism, which is a dose-dependent, saturable process. 0ue eo saturation of the enzyme systems responsible for the metabolism of vinyl ohloride (cytochrome P-450 and ' alcohol dehydrogenase), exposure co concentration* above appsoxisacely 2SO ppa will not necessarily lead to an increasing incidence of tumor development, Metabolism of vinyl chloride leads to formation of chloroethylene oxide and chloroacetaldehyde, two ~ reactive Intermediates which undergo covalent binding to cellular Bacromoleeules and are thought to be responsible for the toxic effects of vinyl chloride. These and other metabolites may be further metabolized and excreted la. ehe . urine. Unmetabolized vinyl chloride is eliminated primarily la exhaled air. Vinyl chloride..!* autagemic in both prokaryotic and eukaryotic test systems, with significantly greater genoeoxieity seen after metabolic activation. DBS staff have found no evidence-tf-h garcinoeenle threshold level and 'because, vinyl--shl.9fi<*f. _U 1-3 gpi-05602 AUG 21 '89 10=33 FROM GOODYEAR RES RM 255 r PASS.01l 1 autagsnic. the staff Tecomcnda that vinvl -chloride be as riot having a threshold for carcinogenicity. A 3 _< .KAS1'*, Svr*l sniasl carcinogenicity and huaan epidemiological studies of occupationally exposed workers have bean analyzed for risk assessment purposes. Although aeeual exposure levels era not known, exposure estimates have been usad co evaluate the Vaxweiior ec al. (1975) stud/ of vinyl chloride workers.. Sasad on these estimates. OKS staff has caloulated that a lifetime exposure to 0.4S5 ppb eight result In an incremental Individual cancer risk of 1 x 10*(assuming liver, brain and lung cancer are all related co vinyl chloride exposure). This yields a risk estlaats of 2.1 x 10"6/ppb. la the ease that only liver cancer is assumed to ba linked to exposure, a llfeciae exposure to 1.0 ppb aay. be expected to result la a risk of 1.0 x 10*. Due to inadequate exposure date, follow-up tine end ocher methodological*problems, DK3 staff suggest that Che huaaa risk estimates be used only for comparative purposes. Evaluation of aniael experiments by the linearized multistage model yields s range of human risks spanning froo 1.5.x 10'Vpph to 3.9 x 10*V??b> vith most estimating a risk of between ,* .3 10 and 10 /ppb. Evaluation of aniaal tuaorlgeuleity data indicates chat vinyl chloride's carcinogenic potency Is dependant on sex, tuaor sice and age of exposure. Taking these factors into account. DBS staff believe ehat the human risk estimates are consistent with those obtained for laboratory animats. The staff of DHS recommends that the aniaal data be ueed to evaluate the risks resulting froa vinyl chloride exposure, fonsecucntlv. the 1.4 SPI-05603 AUS 21 '39 10:33 FROM GOODYEAR RES RM 25S PAGE.012 Ai range of risks, estimated__ from__ analyseS___fti. animal studies and recommended bv DHS -far__ regulatory--purpose* lie between 3.9 x 10`Vppb and 1.8 x 10~*/asb> Vinyl chloride has noc baaa detected In chs ambient air of California (limit of detection -0.5 ppb) except at certain *hot spots". Air Resources Soard (AR3) staff has aonitoted vinyl chloride emissions from the IRK hazardous vasts site in Vest Covina and the Oil landfill in Honterey Park. Estimates of peak exposure concentration* for maximally exposed receptors range from 2 to 10 ppb at the BKX landfill and from 0.6 to 9 ppb ac the 01Z sice. Air Resources Soard staff has estimated than be eve an 17,000 and 151,000 individuals aay be exposed to 1 ppb at the BKX site. A lifetime exposure of 131,000 residents to 1 ppb would be associated vleh an upper bound estimate of 0.5 to 236 excess cancer cases. The calculations represent the upper range of plausible excess cancer risk: the actual risk,, which cannot ba calculated, aay be insignificant. Based on the finding of vinyl chloride-induced carcinogenicity and the results of the risk assessment, 0K9 et^fff finds thae vinvl chloride is an air pollutant which. mav_ cause. _or contribute to. n increase in mortality or an Increase in serious illness. or vhlch mav pose a, present or potential haritrd to human hfc&IriaJU SPI-05604