Document wDgyr56JELx03R9ERY8OEVxD

Vista Chemical Company loke Charles VCM Plant VCM Plant Rd.r P.O. Box 605 CERTIFIED MAIL #695 154 518 RETURN RECEIPT REQUESTED WasiJake, Louisiana 70669 Phone (318) 494-5000 April 15, 1988 Assistant Attorney General Land & Natural Resources Division U.S. Department of Justice 10th & Constitution Avenue, N.W. Washington, D.C. 20530 .............. ... VBIA T7'~/' --rf.r1 v- Dear Sir: Enclosed is a copy of the quarterly progress report detailing actions taken toward completion of the tasks enumerated in the Compliance and Emission Control Plan. This report covers the period 1-1-88 to 3-31-88 and is the ninth progress report to be issued following the February 7, 1986 inclusion of the Emission Control Plan as an enforceable addendum to the Consent Decree. This letter and the enclosed material is being sent by Conoco Inc. and Vista Chemical Company in accordance with Section V.B. of the Consent Decree entered with the United States District Court for the Western District of Louisiana on August 19, 1985 in Civil Action No. 83-2518 and constitutes the eighth quarterly progress report commencing on the eighth complete calendar quarter after entry of the Plan as an addendum to the Decree. If you have any questions concerning this report contact George Hopkins, Chief Process Engineer, at (318) 494-5062. Sincerely, R. A. Conrad VCM Plant Manager bjr (C4) bcc: WLM CL! JHN GF RAC PEM GEH WPS SVC ERT MGH VVV 000002931 Lake Charles VCM Plant VCM Plant Rd., P.O. Box 605 CERTIFIED MAIL #695 154 517 RETURN RECEIPT REQUESTED V/sstlake, Louisiana 70669 Phone (318) 494-5000 April 15, 1988 Director of Air Pesticides & Toxics U.S. Environmental Protection Agency Region VI 1445 Ross Avenue Dallas, TX 75202-2733 Dear Sir: Enclosed is a copy of the quarterly progress report detailing actions taken toward completion of the tasks enumerated in the Compliance and Emission Control Plan. This report covers the period 1-1-88 to 3-31-88 and is the ninth progress report to be issued following the February 7, 1986 inclusion of the Emission Control Plan as an enforceable addendum to the Consent Decree. This letter and the enclosed material is being sent by Conoco Inc. and Vista Chemical Company in accordance with Section V.B. of the Consent Decree entered with the United States District Court for the Western District of Louisiana on August 19, 1985 in Civil Action No. 83-2518 and constitutes the eighth quarterly progress report commencing on the eighth complete calendar quarter after entry of the Plan as an addendum to the Decree. If you have any questions concerning this report contact George Hopkins, Chief Process Engineer, at (318) 494-5062. Sincerely, R. A. Conrad VCM Plant Manager bjr (C4) vvv 000O2932 Quarterly Progress Report Emission Control Plan 1-1-88 to 3-31-88 I Emission Control Plan Schedule The Emission Control Plan was made an enforceable addendum to the Consent Decree on February 7, 1986. The scheduled completion dates as outlined in the plan (Page 8 of Attachment I) and estimated percent completion to date are as follows: Description a) Definitive Designs for Physical Measures Scheduled Completion Date Completion 8-7-86 100 Actual Completion Date 4-30-86 b) Formal Policies for Administrative Measures 8-7-86 100 8-06-86 c) First Four (4) Hours of 8-7-86 Annual Review Training for Operations & Maintenance Staff 100 8-06-86 d) Eight (8) Hours of Annual 2-7-87 Review Training for Operations & Maintenance Staff 100 1-23-87 e) Mechanical Completion of Physical Measures 4-7-87 100 4-06-87 II. Emission Control Plan Progress All phases of the Emission Control Plan were completed within the scheduled completion dates. The following is a summary of progress for the various phases of the Emission Control Plan: A) Definitive Designs - Physical Measures The development of definitive designs for the Physical Measures outlined in the Emission Control Plan (Attachment I, pages 5-8) was completed on April 30, 1986. This portion of the Emission Control Plan is complete. VVV 000002933 B) Formal Policy - Administrative Measures The development of formal policies for the Administrative Measures outlined in the Emission Control Plan (Attachment I, pages 4-5 and Appendix C) was completed on August 6, 1986. This portion of the Emission Control Plan is complete. C) Annual Review Training As of January 23, 1987, the Operations and Maintenance Departments completed the first eight (8) hours of annual training per employee for the period February 7, 1986 to February 6, 1987. This yearly training schedule was shifted from a February 7 to February 6 basis to a February 1 to January 31 basis as stated in a previous quarterly report dated April 15, 1987. The second year of eight hours annual training for Operations and Maintenance personnel for the period beginning February 1, 1987 was completed by February 1, 1988. Training for the period February 1, 1988 to January 31, 1989 has not yet been initiated for Maintenance personnel while Operations is approximately 12% complete. D) Mechanical Completion - Physical Measures The Physical Measures portion of the Emission Control Plan was completed on April 6, 1987 as stated in a previous quarterly report dated April 15, 1987. Ill. Audit of Administrative and Physical Measures An audit of the VCM Plant Consent Decree Physical and Administrative Measures was conducted on December 1, 1987 by Martin E. Brittain (EPA-Region VI) and William H. Davis, William E. Coltrin, and Claude M. Beasely (LA DEQ) as was reported in a previous quarterly report dated January 15, 1988. VVV 000002934 M 1UDDY ROEMER _^__GQ]fERNOR of ;2Iautstana DEPARTMENT OF ENVIRONMENTAL QUALITY fer* J-a- /* G-iA gjT* received PAUL H. TEMPLET , Ph . D. SECRETARY east* May 17 CERTIFIED MAIL P 247 865 080 Mr. R. A. Conrad Plant Manager, LCVCM Plant Vista Chemical Company Post Office Box 605 Westlake, Louisiana 70669 Dear Mr. Conrads REs Consolidated permit application of April 15, 1988 In order to demonstrate that your plant is in compliance with the property line and beyond National Ambient Air Quality Standards (NAAQS) for Nitrogen Dioxide (NO2) and Total Suspended Particulates, we are requesting that these be modeled for the following time periods: 1. TSP/24-hour and annual 2. NO2 (NOx) annual Also, in order to demonstrate that this facility is in compliance with the DEQ/AQD 1/42 TLV policy at the property line and beyond, we are asking you to model the following, all for 1-hour averaging times: 3. HC1 4. Cl2 5. Vinyl Chloride This modeling should include each source of emissions for each pollutant and preferably should be performed using the current UNAMAP 6 series of ISCST and ISCLT (for NOx, N02) revision #3 in order to account for directional downwash. We further request that vinyl chloride emissions be modeled using this version of ISCLT and a five-year composite Stability Array (STAR) meterological data deck from Lake Charles in order to compare long term off property concentations to acceptable cancer risk levels of 0.138 ug/m^. If the hourly modeling demonstrates that this level is not exceeded, or is exceeded by very little, there will be no need for this long term modeling. OFFICE OF AIR QUALITY AMD NUCLEAR ENERGY P.0. BOX U4096 BATON ROUGE, LOUISIANA 70804 AN EQUAL OPPORTUNITY EMPLOYER uVl/ ,, VV 00002935 Mr. Conrad May 17, 1988 Page 2 Please call if you have any questions. Sincerely, DW/frl cc: Mr. Cliff Janney Doug Walters Air Quality Dispersion Modeling Coordinator Wv 00000?936 TO: Distribution T C-r At. Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles August 24, 1989 NIOSH INVESTIGATION AT THE LCVCM PLANT VIS1A Attached are the employee letter regarding the subject and the NIOSH request sent today. We'll keep you informed on progress. T. G. Grumbles dlj .739 Attachment Distribution: T. H. Huffman, J. A. DeBernardi, R. D. Gamblin, M. S. Reynolds, W. L. McClain-Houston J. Friend-LCCP, J. Ware-LCLAB, R. W. Seymour-Aber, H. D. Garrison-Okc VVV G0G0G2937 i w i r- o -t 5^ 505`? 0003 F02 TO: VCM Plant Employees FROM: date: InfroWk* SUBJECT: Communication R. A. Conrad August 24, 1989 Epidemiological Study - NIOSH VISTA In order to address your concerns over past illnesses and especially the two recent brain tumor occurrences, we have decided to request an independent third party assessment or the situation by the National Institute for Occupational Safety and Health (NIOSH). The National institute for Occupational safety and Health (NIOSH) is a federal agency that conducts research in the areas of occupational safety and health* In the health areas of research, NIOSH conducts Health Hazard Evaluations to investigate workplace health hazards or causes of occupational disease* They do have scientists that specialize in epidemiological studies, such as would be done to look at potential reasons for a specific health effect, such as brain tumors. NIOSH has investigated the relationship between vinyl chloride and brain tumors before. In fact a copy of a study NIOSH completed in 1976 and a soon to be published update of that study are in the literature binder we now have at the plant. Tom Grumbles will officially request a NicSH Health Hazard Evaluation at our plant by early next week* Tom advises that the agency will normally provide feedback on such a request within two to three weeks. At that time they will advise as to their response and timing. We will keep you posted on the dates as they become firm* The additional medical screening issue will be resolved and the results and action steps will be provided to you next week* Thank you for your patience while we continue addressing this very difficult and complex matter. R. A. Conrad br(C) Distribution Dept. Heads Supervisors Bulletin Boards VVV 000002938 V4fci Owned Compony Houston. Texas 77079 (713) 588*3000 CERTIFIED MAIL RETURN RECEIPT REQUESTED August 24, 1989 P.O. 8ox 19029 Houston. Texas 77224 Fax (713) 588*3236 Hazard Evaluations and Technical Assistance Branch Division of Surveillance, Hazard Evaluations and Field Studies NI0SH 4676 Columbia Parkway Cincinnati, Ohio 45226 Dear Sirs: Vista Chemical is requesting a NI0SH Health Hazard Evaluation at it's Vinyl Chloride Monomer production facility in Westlake, Louisiana. This request is being made to investigate the incidence of cancer and particularly brain tumors at this manufacturing location. A plant profile is attached that describes the plant operation and provides details about the plant size and history. The evaluation is being requested as a result of recent events in the current employee population. Two employees have recently been diagnosed as having cancerous brain tumors. According to the information available to us, one employee's tumor was a Glioblastoma Multiforme (astrocytoma) and one was an Adenocarcinoma (metastatic). Both employees have been employed at the plant for more than 15 years. Based on the facts available to us at this time, it appears the two tumors are of a different type and not related in anv wav. However, the occurrence of two brain tumors in a short time has raised employee concerns regarding the relationship between chemical exposures and brain tumors at the plant. For this reason, we believe an independent assessment of the situation would be beneficial. Please contact the undersigned at 713-588-3445 if you have any questions concerning this matter and to provide information concerning the next step to be taken by NI0SH. Sincerely, ------- x__ Thomas G. Grumbles. C.l.H. Environmental Quality Manager di i Enclosures O vw 000002939 TO: Distribution TGG: JCL: MMG: AJO: RF XF: .__________ Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles July 24, 1989 VINYL CHLORIDE AND BRAIN TUMORS VISTA For your information, attached is a copy of a Dow position paper regarding the 1979 study that indicated a possible excess of brain tumors related to VCM exposure. T. G. Grumbles dlj .719 Attachment cc: J. Friend-LCCP, J. Ware-LCLAB, H. D. Garrison-Okc, R. W. Seymour-Aber Distribution: T. H. Huffman, M. S. Reynolds, J. A. DeBernardi, N. Frost, D. Conrad-LCVCM ,VV 0000029* The Society of the Plastics Industry, tnc. 355 Lexington Avenue New York, New York 10017 (212) 573 9400 March 5, 1979 received \m 1 4 1979 plastics business ARc TOj the pvc safety group Gentlemen: Further to my letters of February 16 and 23, 1979 regarding the incidence of brain tumors discovered among Union Carbide workers, 1 am enclosing for your internal use only, a copy of the Dow postion on this subject. For additional information contact John Soghigian of Dow Chemical Company 517/636-3587. Technical Director :GM Attachment VVV 000002941 A joint OSHA-NIOSH investigation, prompted by.a worker complaint in November, 1978, has revealed brain tumors caused the deaths of 9 Union Carbide Texas City workers. This number "would appear to be higher than expected,r at that particular plant. About 455 death certificates from 1962 to 1978 have been examined to date. The agencies have speculated a possible link of vinyl chloride monomer to the tumors. However, both a Union Carbide spokesman and OSHA administrator, Eula Bingham noted there are too many chemicals in use at the plant to reach a correlation at this time. A tenth worker who is still living has been diagnosed as probably having the same form of tumor. The investigation began December 13, 1978, with the preliminary announcement occurring February 15, 1979. OSHA said Union Carbide has been very cooperative. Dow Position (for outside use as needed) What we know about the health of Dow workers exposed to vinyl chloride enables us to conclude that such brain tumors are not a problem in our work force. Also, epidemiological studies on large worker populations in the United States and Great Britain show no correlation between such brain tumoTS and vinyl chloride exposure. VVV 000002942 -2 From our reading of the Texas City situation, it is too early to conclude that the cases, of brain tumors were caused by vinyl chloride monomer. We do not mean to doivnplay the seriousness of current investigations, but we caution against junping to conclusions as to the cause of the deaths. The facts which we have at this time are incomplete, and we are attempting to obtain more information. In addition, we have notified all Dow employees involved with vinyl chloride of the Texas City situation. Dow recently conpleted a mortality study among its vinyl chloride workers at Freeport, Texas which did not show any indication of a similar situation. A similar study completed last year on Dow workers at Plaquemine reached the same conclusion. Specifically, both studies showed no deaths from brain tumors among vinyl chloride workers. -Another Dow mortality study published in 1975, focused on 594 workers exposed to vinyl chloride in Midland, Michigan. Two brain cancer deaths were identified, but these cancers were not believed related to vinyl chloride exposures. One subject who had only a three months exposure to low concentrations of vinyl chloride, also had exposures to arsenic in another plant. Dow has previously published data indicating excess cancer in employees exposed to arsenic. The second individual had only a four year exposure prior to his death., a time period generally considered inadequate for cancer to result. The type of brain cancer in each case was not confirmed by autopsy. VVV 000002943 -3- Related Background CXztside studies have also been examined. In Great Britain, a study of over 7,000 workers revealed 2 brain tumors, which was about half the number expected. An epidemiology study on U.S. vinyl chloride (VCM) workers by Equitable Environmental Health, Inc, funded by the Manufacturing Chemists Association, reported "brain tumors were found to be in excess, 12 observed vs. 5.9 expected . . but the incidence was not related to either duration of exposure or to intensity of exposure to VCM." An excess of malignant brain tumors was also reported by NIOSH researchers in a 1976 study of a small worker population. In addition, the NIOSH group claimed to have identified altogether 9 histologically confirmed cases of glioblastoma multiforme (the brain tumor cited in the Texas City deaths) in U.S. workers exposed to vinyl chloride. We are attempting to determine if the Texas City chemical workers were included as part of this survey. Jolm Soghigian 6-3587 w Inorganic Chemicals 2020/MIDIM VVV 000002944 TO: VCM Plant Employees / Interoffice Communication FROM: DATE: SUBJECT: R. A. Conrad October 18, 1989 Request for Epidemiological Study - NIOSH VISTA Attached is the response from the National Institute for Occupational Safety and Health (NIOSH) concerning our request for a health hazard evaluation at our VCM Plant. Essentially, the letter states that they do not believe the tumor incident data would result in a justifiable or meaningful study. The last paragraph of the letter perhaps best states their rationale for not proceeding with a study at this time. By copy of this letter, I am requesting that the VCM Plant Department Heads survey their groups for the interest and further need to have another set of employee meetings with Tom Grumbles and Doctor Drumwright to further discuss the issue and to identify and answer any new questions or concerns that have arisen since the last meeting. Your supervisor will ask you to fill out a copy of the attached survey questionnaire by next Wednesday, October 25. Thank you for your help in this matter. R. A. Conrad br Distribution Bulletin Boards Supervisors Dept. Heads 8UUETW BOARD post !"*& o VVV 000002945 DEPARTMENTOF HEALTH & HUMAN SERVICES Public Health Service Centers for Disease Control National Institute for Occupational Safety & Health Robert A. Taft Laboratories 4676 Columbia Parkway Cincinnati OH 45226-1998 September 29, 1989 HETA 89-356 Mr. Thomas G. Grumbles, C.I.H. Environmental Quality Manager Vista Chemical Company P.0. Box 19029 Houston, Texas 77224 Dear Mr. Grumbles: I am writing in response to your letter of August 24, 1989, requesting a health hazard evaluation at your vinyl chloride monomer {VCM) production facility in Westlake, Louisiana. According to your letter and a subsequent telephone conversation September 5, your request is limited to an evaluation of the occurrence of brain tumors among plant employees. Information supplied by you and by Vista's corporate physician, Dr. J.R. Drumwright, indicated that one current employee has a brain tumor, a glioblastoma. Another reported brain tumor was actually a lung cancer that metastasized (spread) to the brain. In addition, 5 or 6 years ago a former employee had an ependymoma. (Glioblastomas and ependymomas are considered different types of brain tumors, although both arise from neuroglial cells.) Other tumors were reported in a spouse and a child of employees. Finally, there was a case in an employee who worked at the plant prior to the beginning of VCM productior. Eighty to 90 employees are involved in the VCM production process. There is relatively little turnover, and there have been only about 140 employees in VCM production since it began about 20 years ago. In the United States, the age-adjusted incidence of brain tumors (all types) in men is about 6/100,000/year, and the incidence of glioblastoma, the most common type, is about 3/100,000/year. Thus, the occurrence of two primary brain tumors, or even one glioblastoma, in a population of 140 over a 20-year period would appear to be an excess. This, however, is a very crude analysis and would be affected by the age distribution of the workforce and the number of person-years at risk (rather than simply the number of workers). Glioblastomas comprise about half of all adult brain tumors, are more common in men than women, and have a peak incidence at about age 60. Ependymomas, a much less common type of brain tumor, occur about equally in men and women and also have a peak incidence at 50-60 years of age. Assuming that the VCM production workforce at Vista's Westlake plant is mostly men, and that the size of the workforce has been constant, composed of 90 o VVV 000002946 Page 2 - Mr. Thomas G. Grumbles, C.I.H. people at any one time, there have been approximately 1800 person years at risk since VCM production began. The expected incidence of glioblastoma, assuming most of the workforce is now in the 40-60 age range, would be about 5 per 100,000 person-years, yielding about 0.1 expected cases. The expected incidence of ependymoma would be about 0.15 per 100,000 person-years, or 0.003 cases. These expected numbers of cases are only accurate to the extent that the assumptions about the workforce are correct. The actual number of expected cases, for example, is probably less; lower incidence rates would be used in a more rigorous calculation since, in previous years, the workforce was most likely younger than it is now. Also, if there were additional cases in former workers, the difference between the observed and expected numbers of cases would be even greater. Previous studies of workers at facilities that made or used VCM, including one done by NI0SH (Waxweiler RJ, et al. Neoplastic risk among workers exposed to vinyl chloride. Ann NY Acad Sci 1976;271:40-48) and one done for the Chemical Manufacturers Association (CMA) (Wong 0, et al. An update of an epidemiologic study of vinyl chloride workers 1942-1982, final report to Chemical Manufacturers Association. Oakland CA: Environmental Health Associates, 1986, unpublished), which updated earlier CMA-sponsored studies, have indicated an excess of brain cancer, particularly glioblastoma. The CMA study included Vista's Westlake workers and is reportedly being updated again. A recent update of the NI0SH study (Wu W, et al. Cohort and case-control analyses of workers exposed to vinyl chloride: an update. J Occup Med 1989;31:518-523), however, which enlarged the earlier NI0SH study cohort and included more recent mortality information and a more detailed exposure classification, did not find an excess risk of brain cancer attributable to VCM exposure. It is unclear why the previously identified increased incidence of brain cancer was not corroborated by the recent NI0SH study, which had greater statistical power. Perhaps the earlier studies' findings were confounded by other exposures. The anticipated report of the updated CMA study may shed more light on this, but given the relatively few cases of brain cancer among Westlake workers, a study limited to that facility would resolve neither the issue of whether VCM exposure increases the risk of brain cancer nor the question of whether the brain tumors there are work-related. There is no way to determine whether a small cluster of an uncommon, but not rare, tumor is more than a chance occurrence, especially in the absence of a known association between an exposure and the tumor. VVV 000002947 O Page 3 - Mr. Thomas G. Grumbles, C.I.H. This letter constitutes our official response to your request for a health hazard evaluation. It should be posted in a prominent place accessible to affected employees for a period of 30 days. Should there be any additional questions, I can be reached at (513) 341-4386. I would be happy to talk with any employee or any company or employee representative. Sincerely yours. Mitchell Singal, M.Ct/, M.P.H. Chief Medical Section Hazard Evaluations and Technical Assistance Branch Division of Surveillance, Hazard Evaluations, and Field Studies o VVV 000002948 TO; VCM Plant Employees from; DATE; fnttrofflo CommvnkaMon SUBJECT* R- A. Conrad August 1.65, 1989 Toxicity Studies VISTA A toxicity reference book will be made available Wednesday, August 16 at the Main Office. It will contain 21 different papers, studies and reports on epidemiological and toxicity data for VCM and EDO as well as some general studies for the Chemical Industry in Louisiana. Also, a set of file folders containing two (2) copies of each report has been prepared. The reference book will be available for review at the office. It contains an index of papers and a copy of each. An employee may check out a copy of any of the reports he would like to read in detail. We ask that an employee take only one copy at a time and return it the next day so that other employees will have timely access. Contact either George Shirley or Betty Rogers for assistance. Attached is a copy of the index of papers. While each paper usually has a summary, much of the data is very technical in nature and is not easy reading. However, I'm sure we can get needed clarification or interpretation of terminology or meaning by checking with Tom Grumbles or Dr. Drumwright. The reference book and checkout papers will be available by noon, Wednesday, August 16, 1989. Tom Grumbles has advised that possibly one or two more papers may be available. We will add them to the package when received. R. A. Conrad br(2) Distribution Dept. Heads Supervisors Bulletin Boards VVV 000002949 INDEX OFTOXICOLOGICAL PAPERS PAGE-NQ. VCM No. 1 VCM No. 2 VCM No. 3 VCM No. 4 VCM No. 5 VCM No. 6 VCM No. 7 VCM No. 6 A No. 9 VCM No. i0 VCM No. 11 VCM No. 12 VCM No. 13 EDO No. 1 General No. 1 General No. 2 IT Effects of Exposure to Vinyl Chloride: An Assessment of the Evidence Cohort & Case-Control Analyses of Workers Exposed to Vinyl Chloride An Update Vinyl Chloride - Draft Toxicological Profile Final Report on Epidemiologic Study of Vinyl Chloride Workers Occupational Exposure & Brain Tumors Excess Lung Cancer Risk in a Synthetic Chemicals Plant Proportional Mortality Among Vinyl Chloride Workers Mortality & Cancer Morbidity in a Group of Swedish VCM and PVC Production Workers A Mortality Study of Vinyl Chloride Monomer Workers Employed In the United Kingdom in 1940-1974 incidence of Cancer Among Vinyl Chloride & Polyvinyl Chloride Workers Mortality Experience of Workers In a Vinyl Chloride Monomer Production Plant Neoplastic Risk Among Workers Exposed to Vinyl Chloride Mortality Study of Workers In the Manufacture erf Vinyl Chloride and Its Polymers Toxicological Profile for 1,2- Dtehloroethane (EDC) - Draft Occupational Risk Factors For Brain Tumors A Cohort Mortality Study of Petrochemical Workers SPUflCE Richard Doll Various U.S. Public Health Chemical Mfg. Association (CMA) Andrew Moss Waxweiler. et ai Monson, et al Byren, et al Jones, et al Heldass, et al Buffier, et al Waxwelier, et ai Tabershaw, et al Clement Associates Thomas, et al Austin, et al O&EE April 13, 1987 December. 1986 November. 1987 October, 1986 1985 October, 1981 June, 1975 October, 1976 1968 1984 March, 1979 1975 1974 December, 1988 1986 April, 1983 VVV 0000029 PER TITLE Mortality From Brain Tumor & Other Causes In a Cohort of Petrochemical Workers Brain Tumors in the Chemical Industry A Case - Control Study of Chemical Exposures & Brain Tumors In Petrochemical Workers Mortality Experience of a Cohort of Louisiana Chemical Workers A Review of Cancer Epidemiology in Louisiana SOURCE Waxwelier. et al Setifoff, et al Austin, et al Olsen, et al ENSR DATE January, 1dd3 1965 April, 1983 January, 1989 March, 1989 Wv 000002951 VISTA Vista Chemical Company Vista Polymers Inc. Report of a Possible Adverse Effect To Health or the Environment If you think a chemical substance or mixture has caused an adverse human effect, identify that substance and describe how affected. If you think the environment (for example, the air, water, soil, animals, or plants) has been adversely affected by one of the facility's chemical substances or mixtures, identify the substance (if known) and the affected plant and/or animal or contaiminated area of the environment. If you cannot identify the suspected chemical substance or mixture, identify the product, material, or item believed to be the cause of the adverse effect or describe the process or operation or the effluent, emission, or discharge from the facility that you think has caused the adverse effect. -cp. ^ 0/1.---- &'U******^g& f, ^ jCy (^td/loe rn, Stf,/LUrV J7Z, Name of Reporter ^Printea) J Send Completed Form To: 77 &/?uM&L<rs t-f-oosTojJ jp~-rJu, POSH vW/o/?^ Date orReport >96z- /yy? Date Aaverse Enect Occurea ^ VVV 000002952 TO: Distribution CONFIDENTIAL Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles August 10, 1989 VISTA DRAFT TEXT FOR EMPLOYEE LETTER ON THE NIOSH HHE AND NEUROLOGICAL EXAMINATION EXPLANATION Attached is text that can be sued in the letter to employees to notify them of our decision to ask NIOSH for a HHE and to provide a neurological examination. This text would be the body of a Conrad letter to employees. Any questions or comments on the factual part should be addressed to me. I've attached JRD's original and my redraft on the medical screening information. Conrad should draft the employee letter and send to THH and me for review. The final letter will be copied to Friend, Ware, Seymour and Garrison. A c-"----------- T. G. Grumbles tmp Distribution: THH, JAD, MSR, WLM, NCF Dick Conrad VVV 000002953 NIQSH HHE EXPLANATION The National Institute for Occupational Safety and Health (NIOSH) is a federal agency that conducts research in the areas of occupational safety and health. In the health areas of research, NIOSH conducts Health Hazard Evaluations to investigate workplace health hazards or causes of occupational disease. They do have scientists that specialize in epidemiological studies, such as would be done to look at potential reasons for a specific health effect, such as brain tumors. NIOSH has investigated the relationship between vinyl chloride and brain tumors before. In fact a copy of a study NIOSH completed in 1976 and a soon to be published update of that study are in the literature binder we now have at the plant. VVV 000002954 TGG Revision of JRD Information Brain tumors present clinical signs and symptoms including headache, altered mental status, progressive loss of function or neurologic deficit and convulsions or seizures. These same signs and symptoms can also be produced by various degenerative diseases, chronic cardiovascular problems and various toxic states-including medication. A neurological evaluation/examination is performed to look for specific objective signs or findings and to attempt to localize the problem within the nervous system. Symptoms of problems experienced by the patient help the doctor to look at specific areas and identify potential causes. The diagnostic evaluation of a patient depends largely on his/her clinical history, cooperation, and ability to provide useful information to the doctor. In addition to the clinical history, the doctor conducts a neurologic examination. This examination usually addresses five major areas: Mental status, Cranial nerves, Motor function, Sensation, and Reflexes. Specific tests are used to determine normal or abnormal functions of these areas. Based on information obtained from the clinical history and neurological examination more specific tests may be requested - including dye studies, Electroencephalograms (EEG), Skull X-rays, CT Scans, or MRIs. These tests will help localize the problem and aid in determining treatment. Frequently, surgical procedures, biopsies, etc. are necessary to establish an absolute diagnosis. TO: Distribution Irttoroffic* Communication FROM: DATE: SUBJ: T. G. Grumbles October 5, 1989 NIOSH RESPONSE TO OUR HHE REQUEST Attached is NIOSH's official response hazard evaluation at the LCVCM plant. not going to do an investigation. to our request for a health The bottom line is they are The letter is somewhat confusing but I believe a fair summary is that larger studies have failed to confirm an association, and studying a small population will not provide any definitive answers regarding causation. With this response and the ongoing neurological evaluations, I believe we have completed the current outstanding action items. At this time, we need to decide what our next step is. For example is it useful for Dr. Drumwright and I to do another series of employee meetings? Please let me know your thoughts on what we should do next. Distribution: N. Frost, W. L. McClain, Drumwright, R. D. Gamblin TT ~ff. / Huffman t / fr,' j, r. R. A. Conrad-LCVCM Attachment WV 00000295 DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service Centers for Disease Control National Institute for Occupational Safety & Health Robert A. Taft Laboratories 4676 Columbia Parkway Cincinnati OH 45226*1998 September 29, 1989 HETA 89-356 Mr. Thomas G. Grumbles, C.I.H. Environmental Quality Manager Vista Chemical Company P.0. Box 19029 Houston, Texas 77224 Dear Mr. Grumbles: I am writing in response to your letter of August 24, 1989, requesting a health hazard evaluation at your vinyl chloride monomer (VCM) production facility in Westlake, Louisiana. According to your letter and a subsequent telephone conversation September 5, your request is limited to an evaluation of the occurrence of brain tumors among plant employees. Information supplied by you and by Vista's corporate physician. Dr. J.R. Drumwright, indicated that one current employee has a brain tumor, a glioblastoma. Another reported brain tumor was actually a lung cancer that metastasized (spread) to the brain. In addition, 5 or 6 years ago a former employee had an ependymoma. (Glioblastomas and ependymomas are considered different types of brain tumors, although both arise from neuroglial cells.) Other tumors were reported in a spouse and a child of employees. Finally, there was a case in an employee who worked at the plant prior to the beginning of VCM production. Eighty to 90 employees are involved in the VCM production process. There is relatively little turnover, and there have been only about 140 employees in VCM production since it began about 20 years ago. In the United States, the age-adjusted incidence of brain tumors (all types) in men is about 6/100,000/year, and the incidence of glioblastoma, the most common type, is about 3/100,000/year. Thus, the occurrence of two primary brain tumors, or even one glioblastoma, in a population of 140 over a 20-year period would appear to be an excess. This, however, is a very crude analysis and would be affected by the age distribution of the workforce and the number of person-years at risk (rather than simply the number of workers). Glioblastomas comprise about half of all adult brain tumors, are more common in men than women, and have a peak incidence at about age 60. Ependymomas, a much less common type of brain tumor, occur about equally in men and women and also have a peak incidence at 50-60 years of age. Assuming that the VCM production workforce at Vista's Westlake plant is mostly men, and that the size of the workforce has been constant, composed of 90 vvv OOOOG2957 Page 2 - Mr. Thomas G. Grumbles, C.I.H. people at any one time, there have been approximately 1800 person years at risk since VCM production began. The expected incidence of glioblastoma, assuming most of the workforce is now in the 40-60 age range, would be about 5 per 100,000 person-years, yielding about 0.1 expected cases. The expected incidence of ependymoma would be about 0.15 per 100,000 person-years, or 0.003 cases. These expected numbers of cases are only accurate to the extent that the assumptions about the workforce are correct. The actual number of expected cases, for example, is probably less; lower incidence rates would be used in a more rigorous calculation since, in previous years, the workforce was most likely younger than it is now. Also, if there were additional cases in former workers, the difference between the observed and expected numbers of cases would be even greater. Previous studies of workers at facilities that made or used VCM, including one done by NI0SH (Waxweiler RJ, et al. Neoplastic risk among workers exposed to vinyl chloride. Ann NY Acad Sci 1976;271:40-48) and one done for the Chemical Manufacturers Association (CMA) (Wong 0, et al. An update of an epidemiologic study of vinyl chloride workers 1942-1982, final report to Chemical Manufacturers Association. Oakland CA: Environmental Health Associates, 1986, unpublished), which updated earlier CMA-sponsored studies, have indicated an excess of brain cancer, particularly glioblastoma. The CMA study included Vista`s Westlake workers and is reportedly being updated again. A recent update of the NI0SH study (Wu W, et al. Cohort and case-control analyses of workers exposed to vinyl chloride: an update. J Occup Med 1989;31:518-523), however, which enlarged the earlier NI0SH study cohort and included more recent mortality information and a more detailed exposure classification, did not find an excess risk of brain cancer attributable to VCM exposure. It is unclear why the previously identified increased incidence of brain cancer was not corroborated by the recent NI0SH study, which had greater statistical power. Perhaps the earlier studies* findings were confounded by other exposures. The anticipated report of the updated CMA study may shed more light on this, but given the relatively few cases of brain cancer among Westlake workers, a study limited to that facility would resolve neither the issue of whether VCM exposure increases the risk of brain cancer nor the question of whether the brain tumors there are work-related. There is no way to determine whether a small cluster of an uncommon, but not rare, tumor is more than a chance occurrence, especially in the absence of a known association between an exposure and the tumor. wv 000002958 Page 3 - Mr. Thomas G, Grumbles, C.I.H. This letter constitutes our official response to your request for a health hazard evaluation. It should be posted in a prominent place accessible to affected employees for a period of 30 days. Should there be any additional questions, I can be reached at (513) 841-4386. I would be happy to talk with any employee or any company or employee representative. Sincerely yours. 2 Mitchell Singal, Chief Medical Section Hazard Evaluations and Technical Assistance Branch Division of Surveillance, Hazard Evaluations, and Field Studies vvv 000002959 /J { if / VVV 000002960 VISTA Vista Chemical Company Vista Polymers Inc. Report of a Possible Adverse Effect To Health or the Environment If you think a chemical substance or mixture has caused an adverse human effect, identify that substance and describe how affected. If you think the environment (for example, the air, water, soil, animals, or plants) has been adversely affected by one of the facility's chemical substances or mixtures, identify the substance (if known) and the affected plant and/or animal or contaiminated area of the environment. If you cannot identify the suspected chemical substance or mixture, identify the product, material, or item believed to be the cause of the adverse effect or describe the process or operation or the effluent, emission, or discharge from the facility that you think has caused the adverse effect. O 4...... JmI/v-- 4. /V#*} DjQ+J To 7t c . ?rc-r S'T^TlCft} /( v rtc /'//> c*zs-tr Z/fj TcsufLC "To i/c. f fOC. Ar TWts PLaot s ssoaj-*/#/*- ///* /? gfA TT - Signature of Reporter C. Name of Reporter ^Printed) Send Completed Form To: j 7'7~ /***? Date of Report J3-/7^ 7 ---- frcscST Date Aaverse Effect Occured VVV 000002961 What Vista intends to do Vista Chemical recognizes and un derstands the concern felt by our em ployees and their families. The company continues to evaluate the literature and participate in industry groups concerned with the health ef fects of exposure to chemicals used or manufactured in our plants. In addition, the company is investi gating new non-invasive testing meas ures which could be used to detect ab normalities. As we move forward, we'll keep em ployees informed of our progress. VISIA Facts About... VV 000002962 VISIA Vista Chemical Company Lake Charles VCM Plant Brain tumors and chemical exposure VVV 000002963 What studies show about brain tumors The scientific literature and study re sults present conflicting evidence in re gard to the association of brain tumors and vinyl chloride monomer. Some studies have indicated a possi ble association between brain tumors and VCM. Others have shown no asso ciation at all. In the studies which indicated a pos sible association, the number of tumors occuring in studied workers was com pared to the number of cases known to occur in the general population. While the number of tumors among the work ers was higher than those occurring among the population at large, the dif ference was small enough that one could not say for sure whether the dif ference was caused by worker exposure to VCM. The information on exposure to ethy lene dichloride and carbon tetrachloride does not indicate an association be tween these chemicals and brain tu mors. What are the symptoms of brain tumors? For brain tumors, clinical findings or symptoms are variable. Headaches seldom are the first indi cators of the presence of a brain tumor. Other symptoms such as convulsions or seizures are probably the more common signs. Intense headaches accompanied by vomiting, visual disturbances, (blurring or seeing double), weakness and/or trouble with coordination should be thoroughly investigated by a physician. Also keep in mind that brain tumors may result from other causes as well. For example, certain forms of lung can cer may spread to the brain or other lo cations in the body. Good health habits, taking part in Vista's health testing program and peri odic visits to your own physician are important to stay ahead of any physical condition that could adversely affect you. Tests that can detect brain tumors There are a number of specific diagnotic tests which can be used to de termine the presence of a brain tumor. These tests include CAT scans, MRIs (magnetic resonance imaging), skull x-rays, injection of dyes, or com binations of these and other tech niques. However, most of these are invasive tests which carry some risks of their own. For instance, CAT scans involve exposure to more radiation than a nor mal chest x-ray and should not be un dertaken lightly. In addition, the multi-phasic testing offered by Vista is designed to provide broad screening, not specific diagnos tic tests. Vista's exam uses questionnaires and interviews to obtain good employ ee medical histories. These histories, used to determine signs and symptoms of potential health problems, are ex tremely important because problems are usually detectable before actual physical findings are. When screening evaluations indicate problems, more intensive diagnostic procedures may be recommended. for employees of Vista Chemical Company's Lake Charles VCM Plant in response to employee questions at the July 14 meetings Q. What will Vista do if another brain tumor place in an accessible location at the plant. It is antic is found? A. We will continue to communicate with you re garding what we are currently doing in response to the recent employee health problems and concerns. ipated this should be completed in early August with additions made as papers are received. Dr. Drumwright is actively pursuing the issue of medical screening for brain tumors. We believe our current efforts are the right ones to ad dress the present situation. Another brain tumor in the near term would certainly add emphasis to our ef Q. Based on the potential inaccuracies of death certificates, how can epidemiological forts. However, it must be stressed that the recent studies be accurate? brain tumors are not known to be related in terms of A. Many epidemiological studies are based on mor type or origin. tality (death rate) from a disease. This is done for Q. Have we talked to other vinyl plants? several reasons, but in general, deaths are well de fined, consistently recorded, and the records are typi A. Dr. Jack Drumwright, Vista Medical Manager, is cally available. In many cases, mortality studies are discussing current health events with other chemical the only feasible type of study to do, especially for company medical directors to determine if other chronic diseases with long latency periods, such as chemical companies are experiencing any brain tumor cancer. incidents, how they were discovered and what was However, the cause of death on death certificates is done to respond to them. Vista also belongs to the indicative of a judgment on primary cause of death Vinyl Institute and the Chemical Manufacturers Asso and may or may not list complicating factors at the ciation. Those are industry groups that sponsor stud- time of death, such as brain tumors. This may result jf workers and promote safety and health practic in an underestimation of a particular cause, or an es in the industry. Any pertinent information overestimation, such as a brain tumor that was due to obtained will be shared with employees. a lung cancer metastasizing (spreading) to the brain. The result of any epidemiological study must be Q. Will Vista study our group, the LCVCM viewed wiJi caution based on these potential prob Plant? A. We are currently attempting to review the medi lems, and efforts made to be as thorough and accurate as possible when reviewing records. cal and health records for employees and past em ployees known or suspected to have had cancer. Em ployees at the plant are providing us names and Dr. Q. We don't care about studies with thou sands of workers. Why don't you study us? Drumwright is attempting to find their records. This A. A study of only the VCM plant, or even the may be difficult because some records are with Cono VCM plant and our PVC plants, would involve a very co and others may be held by private physicians. The small population and the results would probably not matter of medical confidentiality and potential need be conclusive. Studies done to determine the relation for releases to obtain the information may slow the ship of a disease or cause of death must have an ade process. quate sample size to assure that any differences, or The plant population was included in the CMA excess, seen in death rates or disease rates, are not study, which is in the literature binder available at the random occurrences, but are truly different from what plant. At this time, no decision has been made re the normal, or unexposed population would have. garding further studies. The reason for this is explained by two fundamen tal statistical concepts that define the needed sample Q. How long will it take to answer our ques size (population studied) and power of the study, tions? A. We cannot tell you exactly how long it will take taaddress and resolve all of the issues raised by the ] at employee health problems. Addressing your which is the probability of detecting a real difference in disease rates. The smaller the population studied, the less chance you have of detecting truly different disease or death rates. concerns and resolving the issues is a priority item with plant management and Houston staff. We have ordered relevant scientific papers not in our files to 1 (more) WV 000002964 Q. What do we know about EDC/TARS expo sure effects? A. Quite a lot is known about EDC short and long term exposure effects. Detailed information is availa- to you through your plants hazard communication program and the Material Safety Data Sheets (MSDS). A summary follows. EDC is a central nervous system depressant and causes damage to the liver and kidneys. Short-term exposure to high concentrations of EDC is character ized by anesthetic effects as well as by headaches, dizziness, nausea and vomiting, weakness, trembling and stomach cramps. Severe exposure causes coma and death from respiratory and circulatory failure. Animal studies, mostly in mice and rats, have estab lished carcinogenic effects in rodents. EDC may be absorbed through the lungs, skin and gastrointestinal tract with resulting liver and kidney damage. Q. Can EDC and TARS be carried home on my clothes? A. Yes, under some conditions. Avoid contact with EDC by wearing protective gear and remove soiled clothing that is contaminated with ethylene dichloride (EDC). EDC is volatile at room temperatures and will evaporate rapidly. EDC does not remain in the air for very long. There is, however, a higher poten tial for significant amounts of EDC to remain in im pregnable surfaces such as shoe leather. That is why certain types of composition shoe soles are perced for plant workers. EDC has a very distinct odor at low levels. Many people smell it at 3 ppm or less. It's odor is a good warning property. Contami nated clothing should be properly stored until cleaned or destroyed, which will depend on the situation. Shoes with contaminated uppers should always be de stroyed. The danger with "TARS" is very similar although TARS are heavier in nature and may evaporate more slowly. The potential for TARS contaminated cloth ing to cause chemical bums or slowly release vapors into a storage area is even greater than that for EDC. Contaminated clothing should be professionally cleaned or destroyed, depending on the situation. Q. Can't one molecule of a carcinogen cause cancer? A. This question cannot be answered with a simple yes or no. There is much scientific debate over what level or dose of exposure to a carcinogen will result in cancer. Most toxic chemicals have a threshold level below which no effects are known to occur, or their effects are reversible. This is based on our knowl edge of how the body "handles" the chemical and the way the toxic effect occurs. lowever, we do not know as much about the way carcinogens cause cancer, and cannot say for sure if a threshold exists, or if one exposure can cause cancer. There is clear evidence that the potential for cancer to occur is reduced when overall exposure is reduced. Q. A film shown in 1972 said glioblastomas were a result of VCM exposure. Has this changed? A. We cannot find the film mentioned in the em ployee meeting. Before 1974, there was little, if any, information available regarding the chronic human health effects of vinyl chloride. Even in the 1974-76 period, when VCM became strictly regulated, the in formation available was mostly about the incidence of liver cancers, specifically angiosarcomas. Brain tumors, or glioblastomas, have been found in various studies of vinyl chloride exposed workers. The evidence showing the relationship between VCM and these tumors is conflicting. Q. Haven't more than 100 angiosarcomas been found in workers exposed to PVC and VCM? A. There is a worldwide angiosarcoma register kept. On this register there are currently 138 cases that have been reported. Thirty-eight of those are from the United States. Conoco Chemicals and Vista had none to report. Q. What about HCI and chlorine effects? A. Detailed information regarding the health effects of these chemicals can be found in your plant's hazard communication program. In summary, both of these chemicals are severe ir ritants to the eyes, skin, and upper respiratory tract. Irreversible tissue damage can occur as a result of short exposure to high concentrations. The strong ir ritant properties serve as a good warning and, in gen eral, prevent long-term exposures. Many people can detect the odor of chlorine and HCI at levels below 0.5 ppm. Long-term or repeated exposure to chlorine and HCI may cause corrosion of the teeth, chronic irrita tion of the skin, and chronic lung damage. Q. Are EDC releases and exposures reported to OSHA? A. No. There is no specific requirement to report EDC releases or exposures to OSHA. The VCM stan dard requires reporting "emergency exposures", under certain conditions, to OSHA but there is no such rule for EDC. If five or more people are hospitalized as a result of EDC exposures during an emergency, a report to OSHA is required. Q. Why don't you document high EDC expo sures like you do VCM exposures? A. We do not document EDC exposures exceeding (more) VVV 000002965 the permissible exposure limit with a letter to the em ployee as we do for VCM. However, it is routine for the plant to investigate over-exposures and emergen cy releases for all chemicals, including EDC. EDC <oosure records are maintained in the same manner /CM exposure records. As a result of the company's investigations, infor mation is developed and kept regarding those people that had high exposure during any emergency. Q. Can different people get different can cers from the same exposure to the same chemical due to individual differences? A. Yes. Every individual has a distinct biochemical make-up. These individual biochemical differences can result in different responses to toxic chemicals or other stresses. Individual susceptibility can also vary due to such things as genetics, race, diet and age. Q. Do studies look at the total number of employees exposed or total number of em ployees at the plant? A. Each study is done differently. However, in gen eral epidemiological studies attempt to look at ex posed populations and not all employees at a plant site using that chemical. The vinyl chloride studies that are available have looked at various plant popula tions and generally attempted to include only exposed or potentially exposed workers. Q. Do the chemicals here, VCM and EDC, have a cumulative effect? A. VCM and EDC are metabolized by the body and eliminated through various routes. They are not known to accumulate in body tissues the way lead does, and exert effects as a result of remaining in the body. o Since Ross & Fogleman are the reason this meeting will there be a study of their work habits? A. If we decide to do further studies of the LCVCM plant employees, this may be a pan of the study. At this time that decision hasn't been made. We do know that in the early 70's, the exposures at the plant due to general work practices were higher than they are today. Q. Are two brain tumors in a short-time in a small group like ours indicative of a prob lem? A. We don't believe so, especially not when they are of different types. Also, both are found in the general population and are a "common type". Q. Did Mr. Fogleman have any apparent signs/symptoms from the van exam? A. Several health problems were noted in the last exam, but were believed to be unrelated to his brain tumor. However, it is believed that his cancer was a rapidly growing one which developed since the last van exam. Q. Is Vista looking at any other tests be sides Cat Scans? A. Yes. However, there are no known direct screening methods to detect brain tumors. There are tests available that measure central nervous system dysfunction which may indirectly indicate a brain tu mor. We are evaluating the usefulness of the availa ble tests. Q. Are there brain tumors at Oklahoma City and Aberdeen? A. One has been seen at Aberdeen in the past. This tumor did not originate in the brain but spread from another site. This tumor occurred prior to 1984. Q. What about the causes of death among children of employees? Will you look at those? A. We will look at all data presented to us if appro priate releases are also provided for these family members. Q. What are the types of cancer Ross & Fo gleman had? A. According to the information available to us Ross' cancer was Glioblastoma Multiforme (astrocy toma) and Fogleman's was Adenocarcinoma (meta static). Q. Would the problem Dan Ross had showup on the van chest X-Ray? A. No. Q. Will you get more info on Ross & Fogle man? A. We hope to, but this depends on the employees' Q. Did Dan Ross' cancer spread from an wishes and approval. other site? A Medical information available to us does not indi ct any spreading. Q. Why isn't a Cat Scan part of a routine physical for us? A. The Cat Scan is not a routine screening test. It is a very specific diagnostic test ordered after consulta tion with the appropriate physician and based on 3 symptoms and medical findings. (more) Wv 000002966 Q. What are possible signs and symptoms of a brain tumor? A. The location of the tumor within the central ner vous system) and its biologic behavior determine the v the patient's signs and symptoms are presented. .ien a tumor grows slowly in a "silent" area of the brain, it may first cause a headache, nausea, vomiting, alteration in personality or changes in the level of consciousness due to increased intracranial pressure. A tumor within the speech or motor areas may cause general weakness, or dysphasia, long before other signs or symptoms are present. Q. When used as a follow-up to signs and symptoms, can Cat Scans always detect tu mors? A. CT scanning provides the ability to visualize the central nervous system and possibly the early di agnosis of tumors. The addition of IV or IT contrast material has increased the detection of hidden tumors. Tissue diagnosis of intracranial tumors is required before beginning therapy. Despite the increased sen sitivity of current imaging techniques, many diseases - including tumors - may not be detected by this meth od. Q. Does cigarette smoking cause brain tu mors? A. There is no confirmed link between cigarette r 'king and primary brain tumors. However, cigar<_ - smoking is well known to contribute to lung can cer which can frequently spread to the brain. Also, cigarette smokers in general have a higher susceptibil ity to many diseases. Q. Why do Vista blood results use higher normals for comparison? A. Ranges used for comparison are guidelines only, and vary between laboratories due to different instru ments, methods, etc. It's important to remember that the normal ranges developed and reported by any la boratory are scientifically developed and reviewed by independent accrediting organizations. Also the nor mal ranges are based on data from different popula tions and regional differences may be seen. Q. Why do the van testing results take so long to get? A. Vista's medical department is notified immedi ately of any significant abnormalities found in the test results. Dr. Drumwright then notifies employees. The full report is generally provided to the employ ee at the time of the hands-on portion of the exam. However, if an individual wants his prior to that time, h she can be provided with the report when it is t. . available from Health Examinetics. This is usu ally a 4-6 week time-frame. TO: Tom Grumbles FROM: DATE: Interoffice Communication SUBJECT: J. R. Drumwright, M. D. April 19, 1990 8 (C) ALLEGATION - LCVCM - 1989 VIS1A The following summary is provided for the 8 (c) file for the alleged brain tumor problems at Vista's VCM plant in Westlake, La. R. A. Conrad, Plant Manager, drafted a letter to VCM Plant employees on September 1, 1989 in which he outlined the criteria for "company sponsored medical screening for brain tumors". (Basically any LCVCM employee who had worked in the vinyl industry for at least 10 years was "eligible".) A three month period (9/8/89-12/8/89) was identified for those who were eligible and elected to have the neurological evaluation/examination performed. A total of eleven LCVCM employees elected to have the examination with Dr. Gerald R. Litel, Neurosurgeon, Lake Charles, La. at a cost of $300.00 per individual (total cost: $3300.00). Because of medical history data presented to Dr. Litel, three employees underwent additional tests, e.g. Cat Scan, MRI studies. Costs connected with these additional procedures were handled by the individual's group health insurance plan. Conclusion: No evidence of any active intercranial injury or disease process was detected for any of the eleven employees who elected to have the additional medical/neurosurgical evaluation. Dr. Litel reviewed his findings and recommendations with each of the eleven employees, provided copies of his report for each to Vista Medical for review and filing in the respective employee's cc: JRD/LCVCM 8 (c) File vvv 000002966