Document rnX99Z5raRMxEdBvx309903e

*i The Vinyl Institute A Division of The Society of The Plastics Industry, Inc. / c> 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 WV 000005260 Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (201) 890-9299 * .i JOSEPH s, KELt-EP JC40H* H. nCEKKAP wicuam Hi tonCHtlPJ**. ja. np^eOLM o. hppapthub iuthC v. TcaasMce 0. jC* MAPTIW W. JSMM C. Ckt **OvP <, H4>*l| W<J>V *** BCXAMAnA -lEJAtL .; E-A** j hn 'wt>KpieCnVCaNaSss jsnN ouCSK PCTEP k. l. CUvt CHPISTiHE A. MCA6-C* sMiPkev *. ruji**e>*o bAWll&lCC , A, rc* a, *w**la c. *dodLA*JA*"CTT no* aom>ttc& in d.c *'** A, MJI.LA* MfbV'M 4. ftHexCM 0<04( . niKO PRC^CflieK J OAT, -I A. MAMC1 t OKCMfTClNi HAIOA K. COWAM *?*> g. auRO 9 CRA<6 TAV'?rt9T NAB* A. 'CvC*t M*.tCPMAAAWfgA9^i,N9CAO*O<ATTI CATMC*I*< H. MOeMCA *. g*"e* ^tr^RtT 9. Atiao* **' AN( MOKTCITN CLU0t CV>V04 9AANMOA L. 9CNMAA* susax t_ r* na*u u rrznerr CDWiNC MOwtS* law omcfis Keller and Heckman iiSO 17'" STREET. N.W. SUITE IOOO WASHINGTON. .C. 30039 (eos) 5-oo August 28, 1989 VIA TELECOPIER ICjtoririe ~Arr &4PICI I. OiSLCN. p. 6. Cma*lc5 v. aE9CA. *. ft. PO*tRT A. HAtnCWS. P. Q. JOHONLPL.YMUOID/TDMClHRKt ArKjt. tPm. 6, JUSTIN . POwtlL. Pp. . TCkCeOMMUN'CATIONt chaNSlNESIpN.CYu*PNea TCkCX YCLcco*ica c*e>t tp-Tes CASUC ADONCSS "KEkHAN- WPITCP'S 3IRECT OUkk NVP|U (202) 956-5641 Meredith M. scheck The vinyl Institute Wayne Interchange Plaza 155 Route 46 West Wayne, New Jersey 07470 II 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 (CARS). Comments are requested by September 8, 1989. Since the deadline is fast approaching, we may wish to contact CARB and determine whether later filed comments will be accepted. 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, i assistance. Cordially yours, 7ik Enclosure cc: Ed Nowak Larry Thomas Robert W. Sherman Lewis R. Freeman, Jr Peter L. de la Cruz Wv 000005261 AUG 2*1, '09 ,10:29 FROM GOODYEAR RES RM 25S 4TXt| CM14CtHt& AIR RESOURCES BOARD iiei q smti *.. ox mis JA<^^nTO. -* ***** * .4 PAGE.002 Q*ore d*tAtntl4iv August 1, 1989 i j Dear Sir or Madam: Draft Rgt>ort._oj JHnvl ..Ch loj.ld.ft As you requested, enclosed for your review end comment I is the preliminary draft report on vinyl chloride. Public review of this report includes two comment periods. The first comment period begins with the mailing of this report and you have until September 8, 1989 to submit your { written comments to us. The staffs of the Air Resources Board I (ARB) and Department of Health Services (OHS) will review and i respond to all the comments received. Your comments and our I responses to them will be compiled in Part C of the report and where appropriate, the report wlll.be revised. The revised report will be mailed out to you and other j members nf thp public for a second a,nd final review. Tt will I inc.lude Parts A, 8 and C of the report as well as an Executive | Summary which summarizes Parts A and 6. At this stage, the ARB j and DHS staff will only accept comments on the Executive Summary | and any revisions made to the draft report. A 20 day comment I period will be given for your review; comments received.and our . | responses will then be incorporated as an addendum to Part C. | After reviewing all public comments, the final draft report along ; with Part C will then be submitted to the Scientific Review Panel foritsreviev. The Scientific Review Panel has requested that all j . 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. 000005262 g j . 83 -10:23 FROM GOODYEAR RES RM 2SS PAGE.003 .-2 August 1, 1939 In order for your cements to be considered on this version of the report, they must be received by September 3, .1919 end submitted to: Hr. Robert 8arham, Chief Toxic Air Contaminant IdentifIcetion Air Resources Board Attn: Yfnyi Chloride P. 0. Sot 2315 Sacramento, CA 95912 Branch If you have any questions concerning the report or the comment procedure, please contact Hr. Richard Corey of the Substance Evaluation Section at (916) 323*8543. Enclosures cc: Scientific Review Panel Peter 0. Yenturini, Chief Stationary Source Division VVV 000005263 PUS 2'l 1 99 10: 30 FROM GOODYEAR RES rM g56 PRELIMINARY MAfT TECHNICAL SUPPORT DOCUMENT P/RT A PUBLIC EXPOSURE TO, SOURCES, AND EMISSIONS OF VINYL CHLORIDE IN CALIFORNIA REPORT TO THE AIR RESOURCES BOARD OH YINYL CHLORIDE PAGE.004 PriaeipaL Author Richard Corey fcntrjfruHnq AuthPrs Tom Parker Chris Nguyen Paul Alien Steve Hui Reviewed and Approved by.* Joan Oenton, Manager Substance Evaluation Section Robert Barham* Chief Toiic Air Contaminant Identification Branch Peter 0. Yenturinl, Chief Stationary Source Division July 1589 VVV 000005264 0UQ ZA *e9 10J30 FROM 800DYERR RES RM 255 * ft PftGE.005 DRAFT 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 35655 states that substances listed by the U.S. Environmental Protection Agency (EPA) as hatardous air pollutants (Section 112 of the Clean Air Act) shall be identified as toiic air contaminants (TACs) by the Air Resources Board (ARS). Therefore, because the EPA has listed vinyl chloride as a hazardous air pollutant, the AfiB Is directed by statute to Identify vinyl chloride ts a TAC. The AR9 is the state agency responsible for the fdentification of TACs in their non-pesticldal uses. .The California Health and Safety Code Section 33555 defines a TAC is "an* air pollutant vhich may cause or contribute to an increase in mortality or an Increase in serious illness, or vhich may pose a present- or potential hazard to human health." The findings of the Part A report are considered vith the health effects findings (Part S report) of the Department of Health Services (OHS) to determine if a compound should be identified as a TAC by the ARB. In 1973* the AR8 adopted an ambient air duality standard for vinyl chloride of 1C ppb for a 24-hour average. The standard represented the limit of detection for vinyl chloride at the time it was adopted. Vinyl chloride is an extremely volatile compound that is primarily used for the production of polyvinyl chloride (PVC). PYC Is fabricated for use in several products of vhich toany are used by the A-i VVV 000005265 ttUG Z\ '89. 10:30 FROM GOODYEAR RES RM 256 PAGE.086 J construction industry. In California, the identified sources of vinyl chloride emissions are lendfllls, PYC production and fabrication facilities, and sewage treatment plants. Available information indicates that landfills are the largest source category of vinyl chloride emissions in California, Yfnyl 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 i$ prevalent, the staff recommends 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 of 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 eipcsure, this report also evaluates indoor air exposure to vinyl chloride. Based on limited monitoring data, indoor air exposure to vinyl chloride Is probably hot 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 vinyl 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 times greater than the corresponding ambient concentrations. \ i { i j I \ ii i i A-2 vvv 0000Q5266 i .AUG 21 ' 89 10:31 FROM GOODYEAR RES RM 256 \ \ PAGE.007 no * O ii i Prepared by: California Department of Health Services i Principal Editor: Koman Cravirr, Ph.D., HTH, Staff Toxicologist Revleved by: George V. Alexeeff, Ph.D. Michael J. Lipaetc, tt.D. Douglas N. Cox, Ph.D. (California Public Health Foundation) Based in part on vork subnittted by: Carla C. Christensen and C. Tucker Helae*, Biological and Environmental Chemistry Department, SRI International, 333 Ravensvood Avenue, Menlo Park, California 94025, Under Contract 85*86$?$ (045A) and by: Deborah Crady. M.P.H. School of Medicine, University of California, San Francisco, and Allan Saith, W.D., PH.D. University of California, Berkeley WV 000005267 ' % j 'f f t AUG 21 '89 ,10! 31 FROM GOODYEAR R5 RM Z5B t PAGE.008 .* * i \t\ r i i 1.0 Executive .Summary Vinyl chloride is a short-chain halogenaced hydrocarbon used predominantly in the manufacture of polyvinyl chloride end various packaging end construction produces. Vinyl chloride has very lev degree of scut* toxieley, vith tvo-hour inhalation LD^q value* ranging from 27,419 ppm in alee to 236,215 ppm in rabbits and guinea pigs. Exposure to high concentrations can lead to narcosis, cardiovascular and respiratory irregularity, convulsions, cyanosis and death. Several human deaths have been attributed to occupational , exposure to very high levels of vinyl chloride. Autopsies of these patients revealed congestion of the liver, . spleen and kidneys. Acute toxicity symptoms are thought to occur above 100 ppm. Chronic exposure of workers to vinyl' chloride has been shown to lead to "vinyl chloride disease", characterized by occupational aero-osteolysis, vasospasm of the hands similar to Raynaud's syndrome, dermatitis, circulatory and central nervous system alterations, thrombocytopenia, splenomegaly and changes in liver function. Eight symptoms coassonly reported by workers exposed to vinyl chloride (including dizziness, headaches and nausea) were observed even at dose levels below 50 ppa. Vinyl chloride has been shown to induce cancer In animals iQ uttro., Vut has not been shown Co cause any other reproductive or 1*1 VVV 000005268 es 10)32 FROtt GOODYEAR RES Rtt 25S f .1 PAGE.009 UKn d a rii 5 developmental affects in rats, mice and rabbits. Epidemiologic studies of families of vinyl chloride workers or communities having vinyl chloride processing facilities suggested the possibility of an Increased incidence of birth defects and spontaneous abortions among people at risk; however, subsequent review* of these studies have concluded that h*fl__ li__ inadequate evidence _to_ link snYixqamental -r__ paternal--irmar*__ to defects_or_ spontaneous ahortlons-jin human*. chloride vjth, birth The noncarcinogenic effects occur at concentrations near or above 10 ppa, which is greater than four orders of magnitude above possible general ambient levels in California (0.5 ppb). The noncarcinogenic effects also occur at concentrations greater than 3 orders of magnitude above the highest concentrations measured near landfills <10 ppb). Consequently, &w,S_ staff __do not _earoecg none arc Ino.gsn.ic adverse health__ affects__ to occur froaJacute op chronic exposures to vlnvl. chloride in amb-ienr-air. lh___International Agency for Research on Cancer (IARO. the United States. STr^XQTutitaL:..^ __ Agency fEPA1_a.nd the California Department o,f Heal th Service* <'CDnSt) have Identified.vinyl chloride as a chemical for which there _JLs_ sufficient evidence of car.clnorenieitv in._be_thjiura*n* and experimental animals. Chronie inhalation and. oral exposures of rats, mice and hamsters to vinyl chloride have been associated with an increased incidence of malignant and benign rumors at several sites including the liver, lung, mammary gland and the nervous system. In humans, ; 1-2 VVV 000005^69 Z\ 89 1032 FROM SOODYEftR RES RM 256 PAGE.610 4' i epidemiological studies of occupationally exposed workers have linked vinyl chloride exposure so development of e sere cancer, liver angiosarcoma, and have suggested a relationship between exposure and lung and brain cancers* Although pharaacekinetie studies in buaaos exposed to vinyl chloride are rare, limited evidence indicates that, following inhalation of lev level* of vinyl chloride <3 to 24 ppa), up to 71% (with a mean value of *%) of the given dose may be absorbed. Vinyl chloride absorption appears to depend on Its metabolism, which is dose-dependent, saturable process. Due to saturation of the enzyme systems responsible for the metabolism of vinyl chloride (cytochrome P-450 and ` alcohol dehydrogenase), exposure to concentrations above approximately 250 ppm will not necessarily lead to an Increasing incidence of euaor development. Metabolism of vinyl chloride leads to formation of chloroethylene oxide and chloroa.ce taldehyde, tvo reactive Intermediates which undergo covalent binding to cellular aacroaolecules and are thought to be responsible for the toxic effects of vinyl chloride. These and other metabolites nay be further metabolized and excreted in the urine. Unmetabellstd vinyl chloride is eliminated primarily in exhaled air. Vinyl chloride ..is mutagenic in both prokaryotic and eukaryotic test systems, with significantly greater genotoxiclty seen after metabolic activation. SRS staff _have found __r>o evidence..of a ggrcinOEenle threshold, level__ and because--vinyl ,chloride. . 1*3 WV 00000*5270 ftUG 2"! * 83 10:33 FROM GOODYEAR RES RM 25 i ft. PAGE.011 autagenic. the.-_.ce*g TscofflwafMis than v-I-nvl ^hley<<S fcft eflMl^y>rf as nor havlEg_.a threshold. .for, carcinogenicity Several animal carcinogenicity and human epidemiological studies of ecupationally exposed workers have been analyzed for risk assessment purposes. Although actual exposure levels ere act krovn, exposure estimates have been used to evaluate the Vaxweiler at al. (1976) study of vinyl chloride workers. Based on these estimates, DHS staff has calculated chat a lifetime exposure to 0.465 ppb eight result In an incremental individual eartcer risk of 1 x 10'6(assuming liver, brain and lung cancer are all related to vinyl chloride exposure). This yields a risk estimate of 2.1 x 10'/ppb. la Che ease that only liver cancer is assumed to be linked to exposure, a lifetime exposure to 1.0 ppb may be expected to result la a risk of 1.0 x 10', Due to inadequate exposure data, follow-up time and ocher methodological problems, DHS staff suggest that the human risk estimates be used only for comparative purposes. Evaluation of anlaal experiments by the linearized multistage model yields a range of human risks spanning from 1.6.x 10'Vppb to 19 x 10'Vppb, vich most estimating a risk of between 10'4 and 10**/ppb. Evaluation of animal euaorigenlcity data indicates chat vinyl chloride's carcinogenic potency Is dependent on sex, tumor site and age of exposure. Taking these factors into account, P3S staff believe chat the human risk estimates are consistent with those obtained for laboratory animals. The staff of DHS recommends that the animal data be used to evaluate the risks resulting frost vinyl chloride exposure, Conseouetitlv^the VVV 000005271 1*4 RUG 2 ; >69 10:33 FROM GOODYEAR RES RM 256 * -lk.l PAGE.012 DRAi rangft----fif__risk_.*-tln!ated___fzsa----maly.f.Ca----ft- aninsai *7^ recommended bv PHS -for regulatory--nuraoses H__ bAtMn 3.9 * Ifll^/ppb and 1,8 x 10~*/p?b. Vinyl chloride has nor been detected In the ambient air of California (limit of detection - 0.5 ppb) except at certain "hot spots". Air Resources Board (ARB) staff has monitored vinyl chloride amissions from the BKK hazardous vaste site in West Covina and the Oil landfill in Konterey Park. Estimates of peak exposure concentrations for maximally exposed receptors range from 2 to 10 ppb at the BKX landfill and from 0.6 to 9 ppb at the Olt site. Air Resources Board staff has astinsted that betveen 17,000 and 151,000 individuals say be exposed to 1 ppb at the BKX site. & lifetime exposure of 131,000 residents to 1 ppb vould be associated vith 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 be calculated, aay be insignificant. Based on the finding of vinyl chloride-induced carcinogenicity and Che results of the risk assessment, PHS staffl fifrda__ that vtcvl chloride is. an air Pollutant Which tnav causa or contribute - tor _ anIncrease In mortality or an increase In serious ,,,g vhloh ,nay jmopentiffl hfrffflrd.g9,hrtr> VVV 000005272 . h. . f The Vinyl Institute A Division of The Society of The Plastics industry, Inc. July 27, 1989 TO: The VI Health, Safety & Environment Committee RE: Proposed clean Air Legislation: Listing of Vinyl Chloride and Polwinvl Chloride As you may be aware, legislation introduced in the Congress (S.816, HR2585) to amend the Clean Air Act contains a "Prevention cf Sudden, Accidental Releases" provision. The proposed legislation directs the EPA Administrator to promulgate a list of not less than 50 substances "which may, as a result of sudden events, be released in concentrations that may reasonably be anticipated to cause acute adverse health effects in humans". The proposed legislation then directs that the list shall include 28 specified chemicals, including polwinvl chloride and vinyl chloride. As a result of contracts made with congressional staff by Margaret Rogers (SPI's Director of Federal Government Affairs) we learned that the list of chemicals is drawn from information contained in an about-to-be finalized EPA contractors report "Acute Hazardous Events Data Base" (contractor: Industrial Economics, Inc., Cambridge, Massachusetts). I have reviewed all the data entries for both vinyl chloride and polyvinyl chloride. Charts summarizing the information are enclosed. Briefly, the PVC data base is a "fire events" data base, made up entirely of submissions to the New Jersey Office of Fire Safety. On July 18th, Margaret arranged a meeting with EPA staff responsible for this project. Several SPI staff participated (including me), as well as Laurie Micciche of Occidental's Washington office. As a result of that meeting, two things were promised: 1. A letter to EPA with suggestions for language to be incorporated on the contractor's final report clarifying the data base and its use. 2. I promised a letter to EPA staff addressing the information on the data base, as it relates to PVC. I will, of course, forward that letter to you. Wayne Interchange Plaza U 755 Route 46 Wesf Wayne, NJ 074 70 (207) 890-9299 OO0OQ5273 Information in this report has already been quoted from during legislative hearings. As this issue will be debated throughout the legislative consideration of amendments to the Clean Air Act, any information you have on specific events in which your company is listed would be useful. It goes without saying that all activity will be carefully coordinated with CMA. The current legislative status is that Congress will be adjourned August 4th-September 6th. If you have any questions, please call. MNS/pmb cc: L. Micciche, Occidental M. Rogers, SPI G. Lefebvre, BFGoodrich -M-A/%t VVV 000005274 POLYVINYL CHLORIDE VVV 000005275 K v a e u n t.in n r. V/-M /hO M ic a H iiltlior f ir e , ox|i. lin m lilo n T o w n tili1 1>, N.f I'VC, liy ilrn j'o n 0 0 yon c y m iltlc , Jil.yrcno H.l? EPA ACUTE HAZARDOUS EVENTS DATA BASE VINYL CHLORIDE CATEGORY DATE COMPANY CAUSE SOURCE Deaths 5 1/12/64 Thompson Chemical Human error, reactor MMA vessel l 5/13/86 BFGoodrich Equipment failure, NJ2 Petricktown leaking reactor Tniuries 2 7/3/83 Formosa Plastics Railcar equipment fail.. NRC 8 9/19/80 Great American Tank overheating NTP 1 2/2/84 CE Casting Loading NRC 5* 9/28/82 11. Central Gulf RR Driver drinking NTP 3* 7/26/80 11. Central Gulf RR Derail NTP Evacuations workers* workers 36* Workers 4,000* Workers Workers Workers 300* 4/19/83 Union Carbide 5/16/83 PPG Westlake 9/9/81 Shell Oil 5/5/80 Keysor 6/9/85 Cottonbelt RR 2/16/82 Consolidated RR 6/10/85 Union Carbide 10/14/82 Conoco 2/26/80 Consolidated Rail Rupture disk failure Equipment failure Derail Fire/exp. Derail Derail equipment fail. Rail valve leak Open valve Derail NRC NRC NTP LAT UPI NJ2 NRC NRC APR ouantitv 1/5/81 LaPorte Chemical 7/2/82 LaPorte Chemical 5/5/83 LaPorte Chemical 4/16/85 LaPorte Chemical 12/9/83 Dow, Freeport 12/18/83; Conoco (MS) 2/15/83 Conoco, Aberdeen 8/27/83 Conoco, Aberdeen 10/31/84 Air Products, Ky. 12/9/83 Dow, Texas 5/21/85 Air Products 9/23/84 Hercules 8/13/85 Air Products, Ky. 3/29/86 Air Products, Ky. 3/17/86 PPG, La. 8/5/82 Conoco 6/9/82 Conoco 5/22/82 Georgia Pacific 373 upset reactor TXA 1500 equipment failure TXA 2000 human error TXA 392 equipment failure TXA 22500 equipment failure NRC 229 human error NRC 2200 overheat valve NRC 4000 equipment failure NRC 275 equipment failure NRC 3000 unknown TXA 300 equipment failure NRC 8500 human error NRC 45900 gasket failure NRC 200 equipment failure NRC 155 equipment failure NRC 133 overpressure NRC 885 equipment failure NRC 12090 reactor overheat NRC VVV 000005276 < ^ t 5/25/82 2/3/82 1/23/84 4/24/85 Dow Chemical Georgia Pacific Conoco, Aberdeen Vista Polymers 4000 equipment failure 250 equipment failure 300 equipment failure 650 valve open NRC NRC NRC NRC Legend: * Chemicals in addition to vinyl chloride listed. Sources Searched: APR NRC NTP LAT MMA UPI Associated Press National Response Center New Orleans Times Picayunne Los Angeles Times March and LcLennon United Press International 1980*1986 1983-1986 1980-1986 1980-1986 1956-1984 1980-1985 VVV OOOQG5277 r