Document x1MnkwaNw8OmrnmyEevQK3w36

To : Dave Penney From: Joe Ledvina Da te: July 13, 1990 Subjec t: VCM Risk Factors Dave , So far I ' ve gotten three responses to my request to the Vinyl concerning the VCM unit King of Occidental sent along the Pennsylvania Air Guideline where they use 2.4 ppb as a fenceline standard. That is 1/420 of the I believe the PEL for VCM is 1 ppm . If I did my math correctly, 2.4 ppb equals approximately 10 ug/m 3 (MW/24.45 * 2.4). Apparently, in Pennsylvania if less than lOug/rrr the facility is considered an The use of for carcinogens seems to be the old way of assessing k. Both and the State of California are usina unit rather than of the PEL to Bob Oubre proximity of Dow -- 10 ug/m'* to F reepor t called to say that the State of for VCM an annual fenceline allowabl impact. He said that Texas will and allow a higher number on a case-by x when Frank Borrelli of Georgia-Gulf in Delaware City, DE provided excerpts from EPA documents that show the VCM unit risk factor _L 4.1 x 10 . A footnote states that oral studies suggest a unit factor of 4.2 x 10 . This is the factor Mississippi is using. If the Mississippi factor is based on oral studies, can we argue that it is inappropriate since the route of exposure is not oral but inha 1ation? This may allow us" t^o~ a---r--g---u--e- xfo--r 471 .1' x 1' 0^ some-way you can check this out? 1 11 pass along any other information I get through the Vinyl cc: TGG, RWS, FGJ VAB.0001154155