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