Document zdr47oyvb9Vp4B7veOdx7a6BB

TELECOPY COVER SHEET -*> Thia will be a tranamiaaion of 7 page* including this cover sheet. To ___3 C S CA^kzj- pPCompany ____ T \ G Phone Ho.: <P|2.) H/W " 37 Type of Machine; P / Few Hi: From >Cmv.cyvN.C2 . Chemical Manufacturers Association 2501 M Street, N. W. Waahington, DC 20037 Senders Direct Dial: Senders Name: Panafax MV1200 Phona No.: 202Z88.7-12.3_7 (Automatic) DEX 700 Phone No.: 202/887-1248 (Manual) SL 063043 2 It Is hoped that the above has clarified any concerns you nay have " .d on the OAOPS support for the ndtli t i anal testing of 1,1-Di chi oroethy ! ane 1-.section 4 ( a 1 i 1) (A ) of the "Toxic Substances Control Act. Sincerely yours, cc: C. Glasgow K. Schell G, Timm R. Northrop Nancy B. Pate, D.V.M. Project Officer Pollutant Assessment Branch SL 063044 A . 2S- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 1 5 JW RECEIVED ,,, a Dr, Robert It, Romano Associate Director, Special Programs Chemical Manufacturers Association 2S01 M Street, NW Washington, DC 20037 Dear Or. Romano: Your letter of March 20, 1937 concerning the OAQPS support of the Proposed Test Rule for 1,1-nichloroethylene reveals a need for some clarification in several areas. First, additional testing will clearly improve the data base for risk assessment. The weight of evidence supporting the current risk estimate is inadequate to support regulation under the Clean Air Act at this time. The proposed testing, conducted using appropriate protocol, will strengthen tne case one way or the other. Second, we are not supporting a test rule for 1,1-Dichioroethylene principally because of the State initiative program. Rather, we are saying that in the event that, the results of the proposed testing strengthens the case for not developing Federal regulations, it will assist State and local agencies in helping to Identify any potential high risk sources of 1,1 fli chi oroethylene for further evaluation. As you may he aware, the identification and evaluation of high risk point sources Is one of the elements of the multi-year development plans that the states are required to submit as a part of the Agency's Air Toxic's Strategy. In short, the proposed testing helps fill an existing data gap with respect to the quality of the evidence implicating 1,1-Dichioroethyleno as a carcinogen as well as assisting in defining the potency if it is a carcinogen. In referencing the Federal toxic air pollutant assessment program and the State initiative proyram, we are only establishing that there exists regulatory programs that will benefit from answers to such questions. The emission and exposure information that you provided Is appreciated. However, as you are aware, the Human Exposure Model requires significantly more data, including the location of each emissions source, netpre it can be executed. Si 63045