Document wRO784dX1vj9b9Yqx453kxG6

Tenneco Chernicais A Tcriricco CO".,' iny /l August 30, 1974 | Mr. Sam Orowther Texas Air Quality Services 8520 Shoal Creek Blvd. Austin, Texas 78758 Dear Sam: `j i j This letter and its attachments are intended to briefly summarize some background documents relating to the current concern over Vijnyl Chloride Monomer. We are supplying a second paper dealing with technical . <'--t'' of PVC manufacture, emissions, emission control technologJy, etc. To date, most attention has been given to employee heal tit relatod] prod lews and little to environmental problems. i ! As a general summary, information now available leads to the very! strong, presumption that there is a cause-eflect relationship between prolonged j exposure to high levels oi Vinyl Chloride Monomer and the inciue;i<j:o of angiosarcoma. Valid scientific data on thb health effects are to^ sparse to permit sound statistical correlation; however, a careful analysis of the. information available certainly points to long exposure to ,, 'High ( oncenLration of VCM as a prerequisite to serious health effects; jand conversely, to VCM concentrations in ambient air outside manufacturing planLs being well below level associated with adverse health efiecjls. i i Each of the attachments contain material we, feel will bo useful to| you in your evaluation of the problem. A listing and suminary of c allows: COLOR!TE 008129 Page 2 Mr. Sam Growther Enclosure No. 1-M.C.A. Press Release, "Viny] Ch Lor ide CnronoJ ugly" This paper highlights the M.C.A. involvetiients from 196 7 through] May i JO, 1074. Since most VCM-PVC producers Were and are M.C.A. members, t'n is probably is a fair summation of industry viewpoints and at iVILll'S . In brief, up until the announcement by B. F. Goodrich in January-Eebruary that the death of some employees and former employees was definJ.Le.ly due i to angiosarcoma, there was much more concern about the fire andjexplosion hazards associated with VCM than with its employee health effectjs. Al though animal studies by Dow as early as 1961 pointed to slight damage from exposures down to 100 ppm VCM, other work at Yale llij i vc rs i t y indicated that 500 ppm offered adequate safety for humans and of liei.il f standards published first by AGG1H (1962) and later OSIIA (1971) jset a 500 ppm workplace standard. Animal studies in Italy in the early 1970's reported tumor development in test animals at 250 ppm exposure but not a L 50 ppm. MCA and its member rompanies commissioned an expandot! year-long study in the Onited! SLaLes by Industrial BIO-TEST Labora Lor ies, Inc., results of this study which were released in early 1973. in April, 1974 The preliminary j (after fo lease of the Goodrich report) contained reports of liver cancer in mice nj: exposures 1 down to 50 ppm. Dr. M. L. Kepplinger who directed the animal experiments at BIO-TEST emphasized the unreliability found in correlating, unjmul to human experience. i The industry sponsored TARERSHAW-COOPER survey of VCM-PVC industry employer in 1973-1974 showed an overall death rate 1rom cancer among thosq employees comparable to the U.S. industrial population as a whoLe and less jthan tile general public. There was some suggestion of dose-related increase in in- COLORITE 008130 Rage J Mr. Sam Crowther cidcnee of cancer other Ulan angiosarcoma in the longer exposed workers, I Enclosure No. Shortly after 2 "NIOSH Recommended Occupational the announcement in January, 1974 Safety of the I and llcaljLli Standard? ! death of' the Good rich workers, NIOSH launched an extensive investigation into the matter and published a memorandum recommendation on March 11, 1974. i The key point in the NIOSH recommendation was the rejection of t;.he concept of a threshold limit for VCM in the work place. It would appeal* that the rationale by NIOSH in proposing the "zeri? limit" was the simplistic and extremely conservative one that if there is no proven safe limitj, then the only premissable limit is zero. In addition to the central point of "zero exposure", Lhe NIOSH deporL con tains a Large number of detailed precautions and requirements. Enclosure No. 3-OSHA Temporary Standards i ] OSHA reacted to the NIOSH report by publishing a temporary standard of 50 ppm maximum exposure in the working place on April 5, 1974. An jenLry in the Federal Register on May 10, 1974 carried an announcement of a proposed standard setting a ceiling, at the Limit of detectability. In addition, the proposed permanent standard incorporated many other items contained in the NIOSH recommendation. A public hearing, on the proposed standard was held beginning the week of June 24, 1974 and developed a large mass of testimony, both oral and written. By law, OSHA must promulgate the premanent standard by October 1974. COLOR!TE 008131 Page 4 Mr. Sam Crowther Enclosure No. 4-"K.PA Press Release iug.ird.ing jg -Inno 1 : , IS /4 l belweon Mr. Russell E. Train and senior executives ol VCM- PYC_p if od uc inc. companjes". EPA took an early interest in the matter and set up a commit Lee |ileaded ] by Mr. GLen Schweitzer, Director of Toxic Substance, EPA, to investigate the problem and report back to the Administrator. MCA arranged a briefing seminar for various EPA officers, primarily Mr. Schweitzer's committee, by its member VCM-PVC producer companies in early April, 1974. EPA followed that up with an elaborate ques tjionaire to all PVC producers in May. A smaller number of PVC producers, Tenneco being one, were invited to meet individually with an EPA task fotree in Durham, North Carolina. EPA also carried out a limited field sampling program during Muyj, 19 74 in the vicinity of one PVC plant in each of the EPA regions. Now Jersey was the Region 11 sample. Tennefio, FlemingLon, l j j ^I Mr. Train summed up the EPA position during the June 11 meeting tj>y saying that there is no scientific evidence to indicate an imminent heajth hazard to people living in the vicinity of PVC plants, but prudence dictated reasonable steps to promptly reduce emissions to the lowest Jevej. Mr. Train touched on the monitoring programs to say that 95% of tjhe ambient air samples showed concentrations of less than 1 ppm VCM. Enclosure No, 5-Tcnneco Testimony, OSHA Hearing, June 25, 1974 i j j Tenneco in testimony during the hearing opposed the "zero dectablfe" limit on the grounds that it is not technically feasible and as an aitqrnaLe, COLOR!TE 008132 Page 5 Mr. Sam Crowther , | proposed a step-down reduction of the maximum limiL to 40 ppm wijlh a ppm IVA by October 5, 1974, a 25 ppm ceiling by October b, I9j7/F, with the addition of a 10 ppm TWA average by October 5, 197(1. Tcmiecj.) es- i tinuLed a capital cost in excess oi $10,000,000 with added annuajL operating' costs amounting to millions of dollars to reach Lhe goals. Miscellaneous Items, Not Documented I. Recent EPA Actions In Lhe course of a visit by representatives of the EPA Industrial Studies Branch to Tcnneco Burlington, New Jersey on August 22, 1974, fjlr. Leslie ! Evans made these points concerning probable EPA actions: j A. His industrial studies group will recommend that EPA declare VCM a "hazard substance" in order to allow the agency greater ifreedom of action in setting standards. B. So far, the investigation lias not shown VCM to present, a slerious heal hazard to the general public outside PVC producer's planLs. C. EPA will not be os rigid in their position as OSHA has been, and will give much more weight to economic considerations. D. EPA will probably seL an allowable .ambient air concenLratibn. E. EPA rule making will probably take at least six months and possibly i more than a year. ' i E. EPA is greatly concerned about the lack of definitive healpi effect data on which to base a standard. i i C. EPA believes it is Sensible lor a PVc plant to reduce VCM ((missions U less than IX of Lhe monomer charged with 0.117,. being near (ille minimum limit possible wiLh available technology. COLORITE 008133 Page b Mr. Son Crowther J . He.iilh Effects Summary There is unfortunately liLtle available data actually relating employee exposure to VCM lo employee health. Dow is the only company known to have Long term records which can be used to correlate exposure with health effect. in testimony at the June 25, 1974 OSHA bearing, Dow reported that their data showed some increase in medical ab normalities in workers exposed to VCM levels above 200 ppm but none Lo workers exposed to levels below that figure. ' In this same hearing testimony regarding 13 cases of angiosarcomji iden tified among employees of U.S. PVC plants showed that seven were employed at one plant, three at a second, two at a third and one at the fourth. All of these plants were more than 20 years old and were built prior to the development of many now current engineering standards. Whi !<) there is no record of VCM levels in these plants in the ]940's and 1950's, the best estimate based on employee's memories of odor levels is that levels exceeded 250 ppm and in some cases, may have exceeded 1000 ppm. Dow pre sented actual data showing time weighted averages os high as 38o and ex cursions up to 4000 ppm in the very early years. As a conirasL to those early conditions, our data, and Lhat of mu|s L other I PVC producers show that exposure levels on a time weighted averag|e are now below 50 ppm in allexcept a few instances, 1 j ! I hope this information will be useful Lo you. If we can assist further, please call on us. Yours very truly, J i ! ` TENNECO CHEMICALS, INC. j e '7 0. Or, W. P. Anderson ! j COLORITE 008134