EXTERNAL REVIEW
            DRAFT
    HYDROFLUOROCARBONS
            AND
HYDROCHLOROFLUOROCARBONS

        INTERIM REPORT
     U.S. Environmental Protection Agency
       Office of Toxic Substances
        Washington, DC 20460

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             EXTERNAL REVIEW DRAFT
HYDROFLUOROCARBONS AND HYDROCHLOROFLUOROCARBONS


                INTERIM REPORT




               November 15, 1990
     U.S. Environmental Protection Agency
          Office of Toxic Substances
             Washington,  DC  20460

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       I         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
       /                    WASHINGTON, D.C. 20460
                                    I 6 le
                                                           OFF ICE OF
                                                        PESTICIDES AND TOXIC
                                                          SUBSTANCES
Dear Reader:

     The Montreal Protocol,  as  recently amended last June in
London, calls  for a worldwide effort to phase  out the use of all
fully halogenated chlorofluorocarbons  (CFCs),  carbon
tetrachloride, halons,  and methylchloroform.   In addition,  the
new Clean Air  Act Amendments contain similar provisions for
phasing out these substances domestically.   An important key to
phasing out these substances successfully is the development of
functionally similar  substitutes.  An  important key to the latter
process is the development of information that can be used by
chemical manufacturers, processors, equipment  manufacturers,
users, and others to  make near-term decisions  on which
substitutes and technologies to pursue.   To  this end, EPA made a
commitment during the Second International Conference on CFC and
Halon Alternatives held in Washington,  DC (October 1989)  to
prepare interim assessments  on  the most promising substitute
chemicals.

     The attached document represents  EPA's  first effort at
interim assessments of  the hydrochlorofluorocarbons (HCFCs) and
hydrofluorocarbons (HFCs).   As  new information on these
substitutes becomes available,  the assessments will be revised.
EPA is also releasing an interim assessment  on aqueous and
terpene cleaners.  Additional substitutes, such as non-HCFC
refrigerants and semi-aqueous cleaners,  will be considered as
data become available.

     The interim assessments contain available information on the
toxicity of the substitutes  and on potential exposure levels
incurred by workers,  consumers, and the general population from
the manufacture, formulation, and use  of these chemicals.
Because many of these chemicals are not yet  in commerce and are
still undergoing toxicity testing, the assessment rests on
incomplete data and,  therefore, should not be  interpreted as a
final judgment.  Nonetheless, the results of these preliminary
analyses indicate that  HCFCs and HFCs  can be used in a manner
safe to workers, consumers,  and the general population given
appropriate technological changes and  exposure control practices.
                                                            Printed on Recycled Paper

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     In reaching this conclusion, we must emphasize the interim
nature of these assessments  in two respects.  First, as more and
better information becomes available on the toxicity of the
alternatives and their likely exposures, a more definitive
assessment can be conducted.  Second, the data used in these
analyses are, in many cases, limited and assumptions are often
based more on analogy than direct measurement.  As new equipment
is developed that utilizes these chemicals and as work practices
are modified to facilitate use of the substitute chemicals and to
meet the needs of the new Clean Air Act Amendments, exposures are
likely to be reduced.  We urge all companies and workers involved
with the production and use  of CFC substitutes to take reasonable
efforts to ensure that exposures to these chemicals are
controlled while additional  data are being developed.

     We look forward to an increased level of communication with
all parties that are affected by the phaseout of CFCs and other
substances subject to the Protocol.  We hope that these documents
will serve as a good starting point for this dialogue at the
Third International Conference in Baltimore, Maryland (November
27 through 29), as well as in the months ahead.

                              Sincerely,
                               (jfautoL&f
                              Linda J. Fisher
                              Assistant Administrator

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                   TABLE OF CONTENTS
J. .
2.
















3.



















4.
5.




HAZARD ASSESSMENT 	 	
2.1 SUMMARY OF TOXICITY STUDIES 	
2.1.1 SUMMARY OF TOXICITY STUDIES OF HCFC-22 . . .
2.1.2 SUMMARY OF TOXICITY STUDIES OF HCFC-123 . .
2.1.3 SUMMARY OF TOXICITY STUDIES OF HCFC-124 . .
2.1.4 SUMMARY OF TOXICITY STUDIES OF HCFC-141b . .
2.1.5 SUMMARY OF TOXICITY STUDIES OF HCFC-142b . .
2.1.6 SUMMARY OF TOXICITY STUDIES OF HFC-152a . .
2.1.7 SUMMARY OF TOXICITY STUDIES OF HFC-134a . .
2.1.8 SUMMARY OF TOXICITY STUDIES OF HFC-125 . . .
2.2 TOXICOLOGICAL COMPARISON WITH RELATED CHEMICALS . .
2.2.1 CHLORINATED HYDROCARBONS 	
2.2.2 CHLOROFLUOROCARBONS 	
2.2.3 HYDROFLUOROCARBONS AND
HYDROCHLOROFLUOROCARBONS 	
2.3 TESTING STRATEGY 	
2.4 DEGRADATION OF HCFCS AND HFCS 	 	
OCCUPATIONAL EXPOSURE 	
3.1 SURROGATE APPROACH 	
3.2 MODELING 	
3.3 DATA SOURCES 	
3.4 SUMMARY AND CONCLUSIONS 	
3.5 MANUFACTURE 	
3.6 FOAM BLOWING 	
3.6.1 RIGID PUR FOAMS 	
3.6.2 FLEXIBLE PUR FOAMS 	
3.7 COMMERCIAL REFRIGERATION 	
3.7.1 RETAIL FOOD STORAGE 	
3.7.2 COLD STORAGE WAREHOUSES (CSWs) 	 	
3.7.3 CHILLERS 	
3.7.4 INDUSTRIAL PROCESS REFRIGERATION 	
3.7.5 SERVICING 	
3.8 MOBILE AIR-CONDITIONING 	
3.8.1 MANUFACTURING 	
3.8.2 SERVICING 	
3.9 STERILANT CARRIER 	 	
3.10 ELECTRONICS AND METAL CLEANING 	
CONSUMER EXPOSURE 	
GENERAL POPULATION EXPOSURE 	
5.1 ENVIRONMENTAL FATE 	
5.2 ENVIRONMENTAL RELEASE AND EXPOSURE 	
5.2 UNCERTAINTIES IN RELEASE, CONCENTRATION, AND
EXPOSURE ESTIMATES 	
J.
11
13
13
15
17
17
20
21
22
25
25
25
26

27
28
39
36
38
41
43
44
44
49
49
51
52
53
53
53
54
54
56
56
57
58
59
62
65
65
65

67
5.3  OTHER AMBIENT RELEASES	70

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                      1.   EXECUTIVE SUMMARY
BACKGROUND

     Over the past decade, there has been heightened concern
worldwide over the slow but progressive depletion of the Earth's
stratospheric ozone layer, the shield which protects the Earth
from ultraviolet  (UV-B) radiation.  In the 1970s, scientists
hypothesized that chlorine from^hlorofluprocarbons (CFCs) could
destroy stratospheric ozone, thus^increasing the amount of UV-B
radiation reaching the Earth's surface.  Increased UV-B radiation
can lead to increased cases of skin cancers and cataracts and has
been linked to crop, fish, and materials damage.
Bromochlorofluorocarbons  (halons) also destroy stratospheric
ozone, and are believed to do so at a faster rate than CFCs.

     In 1978, the United States banned the use of CFCs in non-
essential aerosols (40 CFR 762) in an effort to halt ozone
depletion.  By 1982, however, the global production of CFCs had
risen, thereby negating the decrease in use that had resulted
from the 1978 aerosol ban in the U. S. and other nations.  Uses
of CFCs include refrigeration, metal and electronics cleaning,
production of insulating foam, mobile air conditioning, and
sterilization.

     Montreal Protocol

     The increase in CFC production prompted officials in the
United Nations Environment Programme (UNEP) to develop and
promote a multilateral response to stratospheric ozone depletion.
These efforts resulted in the development of an international
agreement — the 1985 Vienna Convention To Protect the Ozone
Layer — which provided the framework for the eventual adoption
of the Montreal Protocol on Substances That Deplete the Ozone
Layer.  The Montreal Protocol was signed in 1987, ratified in the
U. S. in 1988, and became effective worldwide on January 1, 1989.
To date, 64 nations, 28 of which are developing countries, have
ratified the Protocol.

     The Montreal Protocol, as initially ratified, requires a
freeze in production and consumption, at 1986 levels, of the
following chemicals:

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      CFC-11         Trichlorofluoromethane
      CFC-12         Dichlorodifluoromethane
      CFC-113        1,1,2-trichloro-l,2,2,-trifluoroethane
      CFC-114        1,2-Dichlorotetrafluoroethane
      CFC-115        Chloropentafluoroethane

 The freeze is to be followed by a phased-in reduction to 80
 percent of 1986 levels beginning in mid-1993 and 50  percent
 beginning in mid-1998.  The Protocol also limits the production
 and consumption to 1986 levels of halons 1211,  1301,  and 2402,
 beginning in 1992.  These reductions are to be  accomplished by
 allocating production and consumption allowances to  firms that
 produced and imported these chemicals in 1986,  based on  their
 1986 levels of activity.

      On August 12, 1988, under the authority of the  Clean Air
 Act, EPA promulgated regulations to implement the reductions
 called for in the Montreal Protocol (53  FR 20566).


      London amendments to the Montreal Protocol

      Scientists measuring stratospheric  ozone have concluded that
 the amount of global ozone in northern hemisphere mid-latitudes
 has decreased 1.7 to 3 percent from 1969 to 1986,  with the lowest
 levels occurring in winter.   This decrease is two to three times
 greater than had been predicted by atmospheric  models.   Several
 extensive scientific investigations also produced evidence that
 CFCs led to decreases in stratospheric ozone during  the  spring
 months in the area over the  Antarctic pole (sometimes called the
 Antarctic ozone "hole").

      Scientists believe that the naturally occurring atmospheric
 concentration of chlorine is 0.7 part per billion (ppb).   When
 the Antarctic ozone hole was first observed in  the mid 1970s, the
 chlorine concentration equalled approximately 2.0 ppb; it is
 currently at 3.0 ppb.   EPA has concluded that levels  of  chlorine
 and bromine in the atmosphere will continue to  increase
measurably despite the reductions in CFCs required by the
Montreal  Protocol.   Concentrations of chlorine  are predicted to
exceed  8  ppb by the year 2075.

      Based on these assessments,  the U.S.  and other Parties to
the Montreal Protocol  determined that further restrictions,
including controls on  other  chlorinated  compounds and an eventual
phaseout  of CFCs,  were warranted.

      In June 1990,  the Parties met again in London to formally
amend the Montreal  Protocol  to  include more stringent provisions.
Under the revised  Protocol:

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     o    all fully halogenated CFCs and carbon tetrachloride
          will be phased-out by 2000,

     o    halons will also be phased-out by 2000 with exemptions
          for essential uses, and

     o    methyl chloroform will be phased-out by 2005.
                                              ^v,
In addition, the Parties issued a non-binding declaration calling
for HCFCs to be used only when other alternatives are not
feasible, with phaseout by 2020 if possible, but no later than
2040.  These restrictions are based on a series of recently
completed scientific, economic, and technological assessments
prepared by the Parties to the Protocol.


     Clean Air Act Amendments

     In November 1990, the Clean Air Act was amended to include a
number of provisions that will eliminate the production of CFCs,
halons, carbon tetrachloride, and methyl chloroform by the turn
of the century.  One key provision requires EPA to set "Lowest
Achievable Emission Levels" for CFCs in the air-conditioning and
refrigeration sectors and prohibits venting of HCFCs in these
sectors within the next two years.  In addition, the new Clean
Air Act requires recycling of all refrigerants in mobile air-
conditioning within the next five years.


INTERIM REPORTS

     To increase the public's knowledge of the potential CFC
replacement chemicals, EPA has been working to characterize the
human health and environmental risks associated with the major
substitutes for CFCs and halons.  In late 1989, EPA released a
draft strategy document, "CFC Substitutes Human Health and
Environmental Effects Program," that outlined the Agency's
approach to this task.  Several offices within EPA, primarily the
Office of Toxic Substances (OTS), the Office of Air and Radiation
(OAR), and the Office of Water (OW), were involved in the
creation of the strategy document.

     A focal point of the strategy was the creation of interim
reports which should help provide the public with an early
indication of the health and environmental impacts of major
chemical alternatives to the ozone depletors.  Chemicals are
selected for assessment in the interim reports based on projected
use volumes and the potential for significant increases in
exposures and releases, rather than because of specific toxicity
problems associated with the chemicals.

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      The interim reports are to be based on data available at the
 time of publication, rather than being comprehensive documents.
 Although the data in the interim reports can be expected to
 change in these fast-moving fields, EPA believes that industry
 and the public should have access to the information as it
 becomes available.  Where data for a particular chemical are not
 available, EPA relies on closely related chemicals and scientific
 judgment to estimate hazard and exposure factors.   EPA will
 prepare future reports as new data on these chemicals become
 available or as other substitutes or exposure scenarios are
 identified.

      This first interim report focuses on eight
 hydrofluorocarbons (HFCs)  and hydrochlorofluorocarbons (HCFCs) as
 substitutes for the CFCs.   These chemicals are:

      HCFC- 22    Chlorodifluoromethane (CAS # 75-45-6)
      HCFC-123    2,2-Dichloro-l,l,l-trifluoroethane (CAS # 306-
                     83-2)
      HCFC-124    l-Chloro-l,2,2,2-tetrafluoroethane (CAS # 2837-
                     89-0)
      HFC -125    Pentafluoroethane (CAS f 354-33-6)
      HFC -134a   1,1,1,2-Tetrafluoroethane (CAS  #  811-97-2)
      HCFC-141b   l,l-Dichloro-l-fluoroethane (CAS  # 1717-00-6)
      HCFC-142b   l-Chloro-l,l-difluoroethane (CAS  # 75-68-3)
      HFC -152a   1,1-Difluoroethane (CAS # 75-37-6)

      For purposes of this  report,  the term "hazard" refers to the
 potential for human health or environmental effects because of
 the inherent toxicity of a chemical.   "Exposure" addresses
 potential exposures to:  workers who  manufacture,  process,  or use
 HFCs/HCFCs;  the general  population exposed to releases  from
 industrial sites;  and consumers  of products that contain HFCs and
 HCFCs.

      The HFCs and HCFCs  have  a variety of use applications.   The
 major uses addressed in  this  document include: mobile air
 conditioning,  refrigeration,  foam  insulation,  electronics and
 metal cleaning,  and sterilization.  A separate EPA report
 entitled "Aqueous  and Terpene Cleaning Interim Report"  presents
 EPA's assessment of the  aqueous  and terpene cleaners as
 substitutes  for CFC-113  and methyl  chloroform, another  ozone-
 depleting chemical,  in metal  and electronics applications.
 Additional chemical  and  process  alternatives exist for  the CFCs,
 methyl chloroform,  halons, and other  ozone-depleting substances.
 These alternatives warrant a  similar  review,  but due to time
 constraints  and  lack of  information on their use,  they  could  not
be included  in this  report.   EPA will  broaden the  scope of the
next  Interim Report  to include additional  CFC alternatives.   In
the meantime, developers and  users  of  CFC  substitutes should
consider the following:

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o    In developing and using alternatives to the CFCs, care must
     be taken that in solving one problem we do not create
     another.  Any chemical or process that takes a significant
     portion of the market should be capable of being used in a
     safe and environmentally acceptable manner.

o    In general, when making decisions about how to replace the
     ozone-depleting chemicals, EPA encourages industry to first
     consider a preventive approach that will reduce overall use
     of chemicals through toxics use reduction, alternative
     processes, or conservation.  In situations where these
     options do not exist, industry should avoid replacing ozone
     depletors with chemicals that possess known hazards and that
     cannot be used in a safe manner.  EPA also cautions industry
     to be prudent in choosing any chemical for which there is a
     lack of hazard information and encourages those actions
     which would reduce exposure and release to the environment.

     As mentioned above, this interim report is based on
information that is currently available.  In all cases, EPA did
not possess a full data set in terms of hazard and exposure
information for the HFCs and HCFCs.  An industry consortium known
as the Program for Alternative Fluorocarbon Toxicity Testing
(PAFT) is currently involved in conducting a series of toxicity
tests on some of the HFCs and HCFCs which will greatly increase
the amount of information on the possible health effects
associated with the chemicals.  In terms of the exposure
assessment, the lack of actual data on the HFCs and HCFCs is
largely due to the fact that most of these chemicals have not
been used in commerce, and exposure measurements have not been
taken during their actual use.  Where data did not exist, EPA
relied on closely related chemicals and scientific judgment,
where appropriate, to estimate the anticipated exposures and
environmental releases of the HFCs and HCFCs in the given use
scenarios.  EPA will update this assessment when additional
toxicity and exposure data are available.

     Despite its limitations, there are several conclusions that
can be drawn from this preliminary assessment.  These findings
are summarized below.  This information should be provided to
formulators, users, and the workforce handling these substitutes.
OVERALL FINDINGS OF THIS ASSESSMENT

     The interim assessments evaluated the available information
on the toxicity of the substitutes, as well as the potential
exposure levels to workers, consumers, and the general population
from the manufacture, formulation, and use of these chemicals.
Because many of these chemicals are not yet produced or used and
are still undergoing toxicity testing, the assessment necessarily
rests on incomplete data and therefore, should not be interpreted

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 as' a final judgment.  Nonetheless,  the results of these
 preliminary analyses indicate that  HFCs and HCFCs can be used  in
 a manner safe to workers,  consumers,  and the general  population,
 given appropriate technological changes and exposure  control
 practices in some applications.

      In reaching this conclusion, we  must emphasize the interim
 nature of these assessments in two  respects.   First,  as more and
 better information becomes available  on the toxicity  of the
 alternatives and their likely exposures,  a more definitive
 assessment can be conducted.   Second,  the data used in these
 analyses are, in many cases,  limited,  and assumptions are often
 based more on analogy than direct measurement.  As new equipment
 is developed that utilizes these chemicals,  and as work practices
 are modified to facilitate use of the substitute  chemicals and to
 meet the needs of the new  Clean Air Act Amendments to control
 emissions,  exposures are likely to  be reduced.  We urge all
 companies and workers involved with the production and use of  CFC
 substitutes to take reasonable efforts to ensure  that exposures
 to these chemicals are controlled while additional data are being
 developed.

      Following are some general conclusions  regarding toxicity
 and exposure for the HFCs  and HCFCs.

      ToKicitv

      Based  on existing laboratory studies, the  HCFCs  and HFCs, as
 well as  the CFCs,  have generally low  toxicity,  with both classes
 of compounds exhibiting low acute toxicity.  However, compared to
 the  CFCs, a class of compounds generally  recognized as chemically
 inert and biologically inactive, the HCFCs and  HFCs exhibit a
 greater  potential for systemic effects.   In general,  the
 available testing indicates that observed effects,  including
 transient central nervous  system effects, developmental and
 maternal toxicity,  and liver  toxicity,  occur only at  relatively
 high exposure levels in animal studies.   Available
 carcinogenicity studies on three of these substances  do not
 provide  evidence of a carcinogenic potential in humans;
 carcinogenicity studies are ongoing or planned  for four other
 compounds.   Section 2  of this report discusses  compound-specific
 toxicity information.

     Exposure

     To  gain perspective on the potential risks associated with
the use  of  the HFCs  and HCFCs,  the Agency conducted several
assessments to estimate exposures to the  general population
 (primarily  ambient air  releases), consumers, and workers.  The
results  of  these preliminary  analyses  are summarized below by
exposure category.

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     General Population

     The ambient exposure analysis considered releases to all
media, but quantified the fate and transport of emissions to the
ambient air only, the predominant exposure pathway.  The results
of the ambient air analysis indicate that exposure levels
resulting from the manufacture and use of the HFCs and HCFCs will
pose low exposure to the general population.

     Consumer

     The results of the consumer exposure analysis demonstrate
that consumer exposures are expected to be low.  The Agency is
still awaiting ongoing exposure testing that is being performed
by industry to better characterize household emissions from foam
insulation, a large use that the Agency was unable to quantify at
this time.  The consumer assessment will be revised once these
data become available.
                      t

     Occupational

     The Agency estimated exposures in several occupational
settings, including:  chemical manufacturing; foam blowing;
commercial air conditioning and refrigeration; mobile air
conditioner manufacture and service; sterilant carrier use; and
electronic and metal cleaning.  Because most of the CFC
substitutes are not currently used in these sectors, only a
limited amount of occupational exposure data were available.
Therefore, the Agency used the exposure information from existing
CFC applications and modeling techniques to predict HFC and HCFC
exposure levels.  Data limitations precluded consideration of the
extent to which occupational exposures could be reduced by
equipment and technology changes that are required for use with
the CFC substitutes.  Preliminary use-specific exposure results
are presented in Section 3.	

     The Agency recognizes the limitations inherent in the
occupational exposure analysis, in particular the reliance on
existing CFC data to predict exposures for the HCFCs and HFCs.
However, the results of this preliminary analysis can guide
future exposure studies that should be undertaken to better
understand the potential exposures and risks resulting from the
use of the HFCs and HCFCs.

     Traditionally, exposures to the CFCs have been relatively
high, compared to other industrial chemicals, because of the
well-known low biological activity of these compounds.  Since the
HFCs and HCFCs are more reactive biologically, exposure levels
similar to those associated with the CFCs are likely to be
inappropriate in some circumstances.  The results that follow
identify industrial settings in which control strategies,
different from those currently employed, may be needed.

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      The preliminary findings of the occupational  exposure
 analysis indicate that exposures to the HFCs or HCFCs in mobile
 air conditioner manufacture and service and as a sterilant
 carrier are expected to be low when taking into account the
 current understanding of the toxicological characteristics of  the
 CFC substitutes.  The proposed Clean Air Act Amendments will
 require mandatory recycling in mobile air conditioner servicing
 in the long term (next five years), which will further reduce
 exposures.

      Estimated exposures in HFC/HCFC manufacture,  foam blowing,
 commercial  refrigeration servicing, and electrical and metal
 cleaning, could be relatively higher, especially under worst-case
 conditions.  For industrial chillers, as an example,  the modeled
 results indicate significant levels of exposure—both under mid-
 range and worst-case operating conditions.   While  there is
 considerable uncertainty in these exposure estimates,  the
 available data suggest that changes in current workplace
 practices and controls may be needed to ensure that occupational
 exposures in these industrial sectors are reduced.

      Available information indicates that a number of changes
 already under consideration by industry could reduce  exposures.
 In the case of chillers,  for example, the HCFCs are not "drop-in"
 replacements for the existing chemicals (a simplifying assumption
 made in the exposure analysis because of data limitations).  As
 industry develops new equipment for use with these substitutes,
 the need to reduce exposures should be considered.  Again, the
 requirements of the anticipated Clean Air Act Amendments also
 contain several requirements,  such  as mandatory recycling in
 mobile air  conditioner and commercial refrigeration servicing,
 that will further reduce  exposures.   More information is needed
 to better characterize occupational exposures,  including the
 effectiveness of new equipment designs,  controls,  and workplace
 practices in reducing exposure.  Information on potential
 exposures,  releases,  exposure-limiting equipment designs, and
 workplace practices should be made  available to chemical users
 and the workforce.
     Degradation

     This assessment summarizes recent data related to chemical
degradation of the CFC substitutes.  The HFCs and HCFCs are
considered as acceptable substitutes for the CFCs because of
their greater reactivity and, thus, shorter environmental
lifetimes.  This characteristic inevitably makes these chemicals
subject to some degradation in certain uses.

     For example, preliminary laboratory data suggest that under
stress conditions, small quantities of HCFC-123 can degrade to
HCFC-133a and other halogenated compounds of toxicological

                                8

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 concern.  Research to develop better information related to
 degradation under actual use conditions and the employment of
 possible  stabilizers, is underway and will be evaluated as it
 becomes available.  These data will facilitate further analysis
 of  any potential environmental and health impacts.


 ONGOING ACTIVITIES

     This interim report does not present an analysis of the
 risks posed by use of specific CFC substitutes.  However, it does
 provide an initial indication of situations in which exposures—
 if  maintained at levels similar to those observed with the CFCs—
 could be  inappropriate.  These results highlight where additional
 information and control strategies, different from those
 currently employed, could be needed.

     The  Agency is awaiting the receipt of additional exposure
 and toxicity data that can be used for risk characterization
 purposes.  One of the largest activities underway is the conduct
 of  new toxicity testing.  This program, known as the Program for
 Alternate Fluorocarbon Toxicity Testing (PAFT), was initiated
 voluntarily by the CFC producers worldwide to enhance the
 toxicity  database on the substitutes.  EPA has begun to receive
 preliminary results from PAFT; the completion of other tests will
 occur over the next two to three years.  Table 2-3 identifies the
 specific  testing agreement and the schedule for completion of
 these tests.

     Once new exposure and toxicity data are received, EPA will
 refine the information contained in this document.  The Agency
 will continue to address numerous issues, especially those
 related to the interpretation and use of the toxicity testing
 results for risk characterization purposes.  Key issues will
 include the relevance of the effects seen in animals to humans
 and the appropriate methodologies for extrapolating from animal
 studies to human exposures.  In anticipation of this work,
 submission of new data and comments on the information contained
 in  this document will be of great value.


 OUTLINE OF THIS REPORT

     Section 2, Hazard Assessment, presents a summary of EPA's
hazard assessment for the eight HFCs/HCFCs.  The term "hazard"
 refers to the potential for human health or environmental effects
because of the inherent toxicity of a chemical.

     Section 3, Occupational Exposure, examines the processes by
which the HFCs and HCFCs are produced and used, and estimates
potential occupational exposures of workers through inhalation
during manufacture and use of the HFCs and HCFCs.

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     Section 4, Consumer Exposure, presents EPA's estimates of
the likely exposure to consumers from use of products containing
HFCs and HCFCs.

     Section 5, General Population Exposure, presents EPA's
estimates of likely industrial releases of the HFCs and HCFCs
into the environment and discusses exposure to the general
population from these releases.

     More complete assessments of the human health and
ecotoxicity effects of the HFCs and HCFCs can be found in EPA's
support documents.  A list of these support documents and other
references can be found at the end of this report.  Additional
copies of this document and the EPA support documents can be
obtained through:

     TSCA Assistance Information Service
     U.S. Environmental Protection Agency
     Office of Toxic Substances (TS-799)
     Washington, D.C.  20460

     Telephone:     (202)  554-1404

     FAX:           (202)  554-5603
                               10

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                      2.  HAZARD ASSESSMENT

     This section discusses the health hazard information
available for the eight potential CFC substitutes, identifies
data gaps where possible and discusses the Agency testing
strategy for this class of chemicals.  Because of the physical
properties and uses of these chemicals, the main route of human
exposure is through inhalation.

     It should be noted that this section only assesses the
hazard information and does not provide an analysis of risks
posed by use of specific CFC substitutes.  "Hazard" is defined in
this report as the intrinsic toxicity of a substance.  "Risk" is
the probability that a substance will produce harmful effects
under specified conditions under which it is used.  Depending on
the conditions under which it is used, a toxic substance may pose
lower risk than a relatively nontoxic one.

     In general, toxicity studies are designed to dose at levels
that induce some effects.  As a result, it is rare for such
toxicity testing to show no effects at all.  Thus, interpretation
of toxicity testing results must take into account the nature of
the effects observed and the doses at which they occurred.  In
the case of the HFCs and HCFCs, testing was performed at dosage
levels that ranged from 300 ppm to 700,000 ppm, representing a
fraction of the total air volume ranging from 0.03 percent to 70
percent.  Most of the dosage levels used for testing the HFCs and
HCFCs are very high relative to other chemicals that have been
tested.

     Section 2.1 presents a synopsis of currently available
hazard information on five HCFCs (HCFC-22, HCFC-123, HCFC-124,
HCFC-141b, and HCFC-142b) and three HFCs (HFC-152a, HFC-134a, and
HFC-125).  A comprehensive review of available data can be found
in the hazard assessment support document.  To develop an
understanding of the similarities and differences of the hazards
of the HCFCs and HFCs compared to the currently used CFCs, a
brief review of the toxicological profiles of the major CFCs is
provided in Section 2.2.

     Since there is virtually no available health hazard
information of the HCFCs and HFCs in humans, the hazard

                                11

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 evaluation is based mainly on animal toxicity data.  There is
 very limited information available on the pharmacokinetics and
 metabolism of these chemicals.  By analogy to CFCs (as reviewed
 by the World Health Organization, WHO, 1987), the HCFCs and HFCs
 are likely to be readily absorbed by the lungs during inhalation
 exposure.  Most of the chemical that is absorbed is expected to
 be eliminated unchanged in the expired air.  Available data on
 HCFC-22 and HFC-134a indicate that these chemicals are likely to
 undergo very limited metabolism (0.2% and 0.05%, respectively).
 Further evidence for some degree of metabolism comes from the
 finding of a dose-dependent urinary excretion of fluoride in a
 chronic toxicity study with HFC-152a at high exposure
 concentrations (10,000 and 25,000 ppm).  In addition, a
 metabolite common to both HCFC-123 and halothane (2-bromo-2-
 chloro-l,l,l-trifluoroethane) was found bound to rat liver
 proteins following acute exposure to either HCFC-123 or
 halo thane.  Details of the review of the metabolism data can be
 found in the hazard assessment support document.

      The health endpoints discussed in section 2.1 include acute
 toxicity, cardiac sensitization,  neurotoxicity,
 subacute/subchronic/chronic toxicity,  mutagenicity, oncogenicity,
 developmental and reproductive toxicity.   Considerations are
 given to the EPA's Risk Assessment Guidelines in the evaluation
 of these various health endpoints.  In a number of cases,  the
 information presented for some of these endpoints is preliminary
 or incomplete.   Additional toxicity studies are either ongoing or
 being planned for some of these chemicals.   Once additional
 toxicity data are received,  the Agency will be able to provide a
 more complete assessment of the potential adverse effects of
 these chemicals in humans.

      A description of the testing program by the PAFT industry
 consortium is provided in Section 2.3.   The Agency identified
 additional toxicity testing to more fully characterize the
 potential neurotoxicity,  reproductive  toxicity and oncogenicity
 for some of these chemicals.   The Agency has used structure
 activity relationships (SAR)  analysis  as  a predictive tool in
 identifying chemicals with toxicologic concern for additional
 testing needs,  rather than recommending tests for all endpoints
 for all 8 chemicals.   Considerations are  given to the chemical
 reactivity of the compound (i.e.,  the  number of  halogen
 substituents, the position and the kind of  halogen substituents)
 as  well as information available  on metabolism and possible
 mechanisms of action.   PAFT has agreed to sponsor these
 additional toxicity studies as proposed by  the Agency.   Tentative
 dates for the availability of the  results of these toxicity tests
 are also provided in this section.

     These chemicals are not  expected  to  be found in  water at
significant levels  and  therefore are not  likely  to pose risk to
aquatic  organisms.   However,  information  on their potential

                                12

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 aquatic  toxicity can be found in the hazard assessment support
 document.
 2.1  SUMMARY OF TOXICITY STUDIES

 2.1.1  SUMMARY OF TOXICITY STUDIES OF HCFC-22

     HCFC-22 has very low acute toxicity.  Its lethal
 concentration ranges from 277,000 to 300,000 ppm in mice and
 rabbits  (Sakata et al., 81).

     Cardiac sensitization is seen in an epinephrine challenge
 test with HCFC-22 in dogs at a concentration of 50,000 ppm and in
 mice at  400,000 ppm.  No epinephrine-induced cardiac arrhythmias
 were seen in monkeys at concentrations as high as 100,000 ppm
 (series  of studies by Aviado, Smith, Belej, et al., 74; 75).
                      i
     HCFC-22 has been tested in chronic inhalation toxicity
 studies  in rats and mice (Tinston et al., 8la; 81b).  No overt
 toxicity was seen in rats and mice exposed to HCFC-22 up to
 50,000 ppm.  In the rat study, the only reported changes were a
 decrease in  body weight gain in high-dose males, increased body
 weight gains in females of all exposure groups (1000; 10,000; and
 50,000 ppm), and increases in the weights of the liver, kidney,
 adrenal, and pituitary glands in high-dose females.  In the mouse
 study, high-dose animals were reported to be hyperactive.  No
 definition of hyperactivity or scoring criteria were given.  No
 systemic effects were seen in rats and mice at 10,000 ppm.

     Mixed results have been reported in the Salmonella/mammalian
 microsomal assay (Ames assay) with HCFC-22.  In one study, HCFC-
 22 was mutagenic in strain TA1535 (Koops, 77a; Longstaff et al.,
 84).  in another Ames assay, HCFC-22 tested negative (Barsky,
 76).  HCFC-22 was tested in the BHK-21 cellular transformation
 assay (Longstaff et al., 84).  It was reported to be negative;
 however, no  conclusions can be drawn about its activity in this
 test system  since no data were reported to support this claim.
 HCFC-22  did  not induce mutation at the hypoxanthine-guanine-
 phosphoribosyl transferase (HPRT) locus of Chinese hamster ovary
 (CHO) cells  (McCooey, 80).  Two in vivo cytogenetic studies and
 two dominant lethal assays have been conducted.  HCFC-22 induces
 chromosomal  abnormalities in the femoral bone marrow of treated
 rats (Anderson et al., 77b; Anderson and Richardson, 79a) but
 does not appear to induce dominant lethality in treated male mice
 (Anderson et al., 77a; Hodge et al., 79c) and rats (Lee and
 Suzuki,   81), although an erratic response pattern was noted in
mice.

     Although HCFC-22 induces chromosomal aberrations in femoral
bone marrow, it does not appear to induce chromosomal aberrations
 in germ  cells of males as evidenced by the negative dominant

                                13

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 lethal studies.  There is no indication that HCFC-22 induces gene
 mutation in mammalian cells as evidenced by a negative CHO assay.
 On the basis of the data presented, HCFC-22 in all probability
 does not present a mutagenic hazard to man.  No further testing
 for heritable genetic effects is recommended.  Results in the
 cellular transformation assay do not relate to heritable
 mutagenic effects and do not indicate the need for further
 testing.

      Available epidemiological data are inadequate to evaluate
 the carcinogenicity of HCFC-22 in humans.   There is limited
 evidence for the carcinogenicity of HCFC-22 in laboratory
 animals.  HCFC-22 caused small increases in fibrosarcomas (most
 of which involved the salivary glands)  and Zymbal gland tumors in
 male rats at a high concentration (50,000  ppm).   In this study,
 no tumorigenic responses were observed at  lower exposure
 concentrations in male rats (1000 and 10,000 ppm).   Further,  no
 increased incidence of tumors was found in female rats and mice
 of both sexes when exposed to similar concentrations (Tinston et
 al.,  8la; 81b).  HCFC-22 was also tested in another chronic
 inhalation study in rats (Haltoni et al.,  82; 88).   No tumors
 were found at the two dose levels tested (1000 and 5000 ppm).
 This study is considered to be limited because the maximum
 tolerated dose (MTD)  appears not to have been reached.   In a
 limited gavage study where animals were exposed for only one year
 (Longstaff,  82; Longstaff et al.,  84),  HCFC-22  did not induce
 tumors in rats at a dose of 300 mg/kg/day.

      The potential maternal and developmental toxicity of HCFC-22
 has been evaluated in four studies in rats  (Culik et al.,  76;
 Culik and Crowe,  78;  Palmer et al.,  78a) and one study in rabbits
 (Palmer et al., 78b).   No maternal or developmental toxicity was
 observed in the rabbit study at exposure concentrations up to
 50,000 ppm.   However,  HCFC-22 was found to  cause maternal
 toxicity in rats as evidenced by reduced-maternal body weight
 gain  at the highest dose tested (50,000 ppm)  in  the Palmer et al.
 (78a)  study.   In addition,  non-statistically significant and non-
 dose-related increases of eye abnormalities (small  or missing
 eyes)  were found in the fetuses in three rat studies at all doses
 tested (first study -  1000 and 10,000 ppm;  second study - 500,
 1000,  and 20,000 ppm;  third study - 100, 300, and 10,000 ppm).
 Palmer et al.,  (78a) then ran a large study in which there were
 more  than 4000  fetuses from each exposure group.   Increases in
 the same eye abnormalities were seen at all dose levels tested
 (100,  1000 and  50,000  ppm)  but statistical  significance
 (p <  0.05) was  achieved only at the  highest concentration.   This
 large  study  did not examine fetal  abnormalities  other than the
 effects  on the  eye.  Some reviewers  have questioned the
 significance of these  findings because  of the magnitude of this
 effect  in historical controls.   The  Agency  is not yet in
possession of the primary data on  historical  controls.


                                14

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     Except  for the dominant lethal studies cited earlier, the
potential  for  reproductive toxicity of HCFC-22 has not been
studied.
2.1.2  SUMMARY OF TOXICITY STUDIES OF HCFC-123

     HCFC-123 has low acute toxicity.  Its LC^  for acute
inhalation exposure  is between 28,000 and 50,000 ppm in rats
(Hall and Moore, 75; Waritz and Clayton, 66; Coate, 76) and
Chinese hamsters (Darr, 81), and its dermal LD50 is greater than
2 g/kg in rats and rabbits (Brock, 88a; Brock,  88b).  Its
approximate lethal dose in an acute oral study  in rats is 9 g/kg
(Henry and Kaplan, 75).

     HCFC-123 is a mild ocular irritant (Brittelli, 76a) and
produces minimal dermal irritation (Brock, 88c) as demonstrated
in skin and eye irritation studies in rabbits.

     Based on the results of a dermal sensitization study in
guinea pigs  (Goodman and Morrow, 75), HCFC-123  is not a dermal
sensitizer.

     Cardiac sensitization as measured in an epinephrine
challenge test is seen in dogs at concentrations of 20,000 ppm
and greater  (Trochiomowicz and Mullin, 73).  Dogs exposed to
10,000 ppm of HCFC-123 for 5 minutes followed by a challenge dose
of epinephrine showed some increased heart beat (tachycardia) as
well as signs of central nervous system (CNS) depression, but did
not exhibit cardiac  sensitization.

     Signs of CNS depression are consistently seen at
concentrations of HCFC-123 of 5000 ppm and greater in acute,
short-term, and subchronic inhalation studies in rats.

     HCFC-123 has been shown to cause liver toxicity in one
short-term and three subchronic studies in rats and in a single
subchronic study in  dogs.  Pathological changes in the liver were
found in dogs exposed to 10,000 ppm, but not in those exposed to
1000 ppm (Crowe, 78).  In rats, the observed liver effects were
not consistent across the studies.  Significant dose-related
increases in liver weights were reported in all subchronic
studies (Crowe, 78;  Industrial Biotest Laboratory, 77c; Malley,
90) at doses ranging from 500 to 10,000 ppm and from 5000 to
20,000 ppm in a 4-week study (Kelly, 89).  However, mild
pathological changes were only found in one study (Industrial
Biotest Laboratory,  77c).  The preliminary results of the 12
month sacrifice from an ongoing chronic study in rats showed
liver weight changes at 5000 ppm but not at lower doses (300 and
1000 ppm).  A full characterization of the potential for liver
effects will be developed following the receipt of the results of
the ongoing chronic  study.

                                15

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      HCFC-123 has been tested in vitro in the
 Salmonella/mammalian microsomal assay (Barsky and Butterworth,
 76; Callander, 89) and in vivo in the micronucleus assay (Muller
 and Hofmann, 88).  Both assays were negative.  There is no
 evidence to suggest that HCFC-123 induces either gene or
 chromosomal mutations and hence no reason to suspect that it
 might be a germ cell mutagen.  No further testing for heritable
 genetic effects is recommended.

      No information on the oncogenic potential of HCFC-123 is
 available.  An oncogenicity/chronic toxicity study on HCFC-123 in
 rats is underway.  EPA has received some information from the 12-
 month sacrifice as mentioned above.  The terminal sacrifice will
 occur in January 1991.  A full report of the results is expected
 in early 1993.

      The maternal and developmental toxicity of HCFC-123  has been
 evaluated in a range-finding and a final inhalation study in
 rabbits (Bio/dynamics, 89a;  89b)  and two inhalation studies in
 rats (Culik and Kelly, 76; Industrial Bio-Test,  77).   The final
 rabbit study provides evidence of maternal toxicity following
 exposure to doses as low as 500 ppm of HCFC-123  as demonstrated
 by significant reductions in food consumption and body weight
 gain.   There was  no statistically significant evidence of
 developmental toxicity in the final study at doses as high as
 5000 ppm.   However,  higher doses were used in the range-finding
 study.   This study showed dose-related decreases in litter size
 and fetal  body weight (10,000 ppm or greater).

      Maternal toxicity was also reported in two  rat studies.  A
 significant reduction in maternal weight gain was seen in the
 study by Industrial  Bio-Test (77)  when pregnant  dams  were exposed
 to  5000  ppm (only dose tested)  of HCFC-123.   In  the second study
 (Culik and Kelly,  76),  pregnant dams exposed-to  HCFC-123  at
 10,000 ppm (only  dose tested)  showed clinical signs of anesthetic
 effects.   No conclusive evidence of developmental toxicity was
 reported,  but both rat studies are considered inadequate  for
 hazard assessment.   This is  because both studies suffer from a
 number of  deficiencies including the use of a single  dose,  a
 small number of animals,  and an inadequate assessment of  fetal
parameters (e.g.,  fetal  body weight,  visceral examination).

     Data  from a  2-generation reproductive effects study  on HCFC-
 123 and data  from developmental toxicity studies on HCFC-124, a
structurally  similar compound,  will  be used to better define the
potential  for developmental  toxicity of  HCFC-123.

     HCFC-123  will be tested in a  2-generation reproductive
effects study.
                                16

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2.1.3  SUMMARY OF TOXICITY STUDIES OF HCFC-124

     HCFC-124 has very low acute toxicity.  Its LCj0 for acute
inhalation exposure in rats ranges from 230,000 to greater than
360,000 ppm  (Hazleton, 76; Kelly, 90).

     Cardiac sensitization was seen in an epinephrine challenge
test in dogs at concentrations of 25,000 ppm and greater (Mullin,
76).  No effect was observed at 10,000 ppm.

     Signs of CNS depression have been seen in acute and subacute
studies of HCFC-124 at concentrations greater than 50,000 ppm.

     HCFC-124 has been shown to cause absolute and relative liver
weight changes in rats in a subchronic study (Industrial Biotest
Laboratory, 77a).  In this study, liver weight changes were seen
at 1000 and 5000 ppm. i HCFC-124 is being tested in another 90-day
subchronic study in rats at 5000, 15,000, and 50,000 ppm.  The
results of this study should be available for evaluation in mid
1991.  The results of this study will be incorporated to more
fully evaluate the potential for liver effects of HCFC-124.

     HCFC-124 tested negative in the Ames assay (Barsky, 76;
Litton Bionetics, 76) and did not induce micronuclei in an
inhalation micronucleus assay in mice (Rickard, 90).  There is no
evidence to suggest that it induces either gene or chromosomal
mutations and hence no reason to suspect that it might be a germ
cell mutagen.  No further testing  for heritable genetic effects
is recommended.

     No information on the oncogenic potential of HCFC-124 is
currently available.  PAFT plans to conduct an
oncogenicity/chronic toxicity study on HCFC-124 in hamsters.

     HCFC-124 has not been adequately tested for developmental
toxicity.  In the only available study (Industrial Biotest
Laboratory, 77b), exposure of pregnant rats to 5000 ppm of HCFC-
124 (only dose tested) produced a significant increase in
resorptions.  PAFT has scheduled developmental toxicity studies
in rats and rabbits.

     HCFC-124 has not been tested for reproductive toxicity.  The
results of the 2-generation reproductive effects study on HCFC-
123 will be used to evaluate the need for further assessment of
this end effect for HCFC-124.
2.1.4  SUMMARY OF TOXICITY STUDIES OF HCFC-141b

     HCFC-141b has low acute toxicity in inhalation, oral, and
dermal studies.  Its LC^ for inhalation exposure is
approximately 60,000 ppm (Doleba-Crowe, 77b; Hardy et al., 89a).

                                17

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 No effects were seen in oral studies at 5000 mg/kg or in dermal
 studies at 2000 mg/kg (Sarver, 88; Liggett et al., 89; Gardner,
 88; Brock, 89b).

      HCFC-141b is a mild to moderate eye irritant and produces
 nil to minimal skin irritation (Brock,  88d; Liggett,  88a; Brock,
 89a; Liggett, 88b).

      In a study designed to detect epinephrine-induced cardiac
 sensitization in dogs (Mullin, 77), a marked response was seen at
 concentrations of 5000 to 20,000 ppm.  No response was noted at
 2500 ppm.  In a second study (Hardy et  al., 89b),  epinephrine-
 induced cardiac arrhythmias were induced at concentrations
 ranging from 9000 to 21,000 ppm in dogs and from 3000 to 10,000
 ppm in monkeys.

      HCFC-141b was tested for dermal sensitization in 20 female
 albino guinea pigs (Kynoch and Parcel1,  88).   No evidence of
 delayed contact hypersensitivity was found.

      Cage-side observations of transient CNS  depression (effects
 occurring only during exposure)  were noted at 3200 ppm and
 greater in rats and 4200 ppm and greater in rabbits in
 developmental toxicity studies.   Because these results could be
 indicative of neurotoxicity,  the PAFT testing program for HCFC-
 141b (and HCFC-123)  will closely examine the  effects  of CNS
 depression through more careful testing of these effects (e.g.,
 functional,  rather than cage-side observations).

      Although exposure to 20,000 ppm of HCFC-141b  in  a subchronic
 study in rats resulted in lower body weights,  decreased food
 consumption,  decreased responsiveness to stimuli,  and increased
 levels of serum cholesterol,  these effects were not accompanied
 by  either gross or histopathological changes  (Yano et al., 89;
 Landry et al.,  89).   Thus,  the overall  systemic toxicity of  HCFC-
 14lb appears  to be low.

      HCFC-141b  gave mixed results in the Ames  assay.   It was
 positive in strain TA1535 in  two studies (Hodson-Walker and  May,
 88b;  Russell, 77)  and negative in one study (May,  89).   No
 explanation for the differences  in test  results is available.
 HCFC-l4lb does  not induce chromosomal aberrations  in  cultured
 human lymphocytes  (Hodson-Walker,  90b).   It does,  however, induce
 aberrations in  cultured  Chinese  hamster  ovary  (CHO) cells
 (Hodson-Walker,  90a).  This is  in agreement with an earlier
 report (Bootman et al.,  88c)  in  which HCFC-141b was also positive
 in CHO cells in culture.  However,  this  ability to induce
 chromosomal effect in vitro is not noted when  HCFC-141b is tested
 in vivo.   HCFC-141b  has  been  tested twice in the mouse
micronucleus assay (Bootman et al.,  88a;  Vlachos,  88).   It was
negative  in both assays.  HCFC-141b was  also negative in the E.
coli  assay for  DNA damage in  bacterial cells  (Hodson-Walker  and

                                18

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Hay, 88a) and the in vitro assay for gene mutation at the H6PRT
locus in Chinese hamster V79 cells  (Bootman et al., 88b).

     Given the entire set of test results for HCFC-141b, it is
concluded that in spite of the positive response in CHO cells and
the mixed results in the Ames assay, HCFC-141b in all probability
does not present a mutagenic hazard to exposed individuals.  The
available mutagenicity data also do not indicate a concern for
possible carcinogenicity of this compound because currently
available data indicate that genotoxicity test results do not
correlate well with rodent carcinogenicity test results for this
class of compounds.

     There is no information on the carcinogenicity of HCFC-141b.
As discussed in the hazard assessment support document, SAR
analysis indicates a low oncogenicity potential for HCFC-141b.
An oncogenicity/chronic toxicity study on HCFC-141b in rats is
underway.
                       i i
     HCFC-141b was tested for developmental toxicity in both rats
and rabbits and found to cause developmental effects only at high
dose levels.  In the rat study (Hughes et al., 88), there were
clinical signs of transient CNS depression during exposure at all
dose levels (3200, 8000, and 20,000 ppm).  However, the observed
transient CNS depression was accompanied by changes in body-
weight gain and food consumption only at the highest dose tested.
Although statistical analyses were not performed on maternal
parameters, dams exposed to 20,000 ppm exhibited an 8% reduction
in mean body weight and a 44% increase in water consumption.
Developmental toxicity was evident after exposure to 20,000 ppm
of HCFC-141b as demonstrated by a significant increase in
resorptions and a significant decrease in litter size and fetal
body weight.  In addition, fetuses exposed to 20,000 ppm had
increased frequencies of edema, spaces between the bodywall and
the organs, subcutaneous hemorrhages, supernumerary liver lobes,
and delays in ossification of certain skeletal elements;
statistical analyses were not performed.

     In the rabbit study (Hughes et al., 89), there were no
statistically significant differences in food consumption or
maternal body weight between treated and control groups at any
dose level (1400, 4200, and 12,600 ppm).  There were clinical
signs of transient CNS depression during exposure at the mid- and
high dose levels.  There was no evidence of developmental
toxicity at any dose level.

     HCFC-141b has not yet been tested for reproductive toxicity.
PAFT is scheduled to test HCFC-141b in a 2-generation
reproductive effects study.
                                19

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 2.1.5  SUMMARY OF TOXICITY STUDIES OF HCFC-142b

      HCFC-142b has very low acute toxicity.   Its LCj0 for 30
 minutes of exposure is greater than 300,000  ppm (Lester and
 Greenberg, 50).

      HCFC-142b produced only mild irritation when tested in
 rabbits (Brittelli, 76b).

      Epinephrine-induced cardiac arrhythmias were observed in
 dogs exposed to HCFC-142b at 50,000 ppm (Mullin, 69a).   No
 effects were noted in monkeys and mice at concentrations up to
 100,000 ppm.  Noise-induced cardiac sensitization (via  release of
 endogenous epinephrine)  was reported in dogs during a 30 second
 simultaneous inhalation exposure to 800,000  ppm of HCFC-142b
 (Mullin, 70).

      HCFC-142b has not been tested for neurotoxicity.   An acute
 study (Lester and Greenberg,  50)  demonstrated signs of
 neurotoxicity at very high concentrations (loss of postural
 reflexes at 200,000 ppm; loss of righting reflex at 250,000 ppm;
 loss of corneal reflex at 300,000 ppm).

      The results of a subacute (Moore,  76a)  and a subchronic
 study (Kelly,  76)  of HCFC-142b indicate low  systemic toxicity.
 No effects were seen at any dose level  tested (high dose = 10,000
 ppm in 90-day study in rats and male dogs; high dose =  20,000 ppm
 in 2-week study in male rats).

      Results of a chronic  inhalation study (Seckar et al.,  86)
 support the findings of low systemic toxicity of HCFC-142b in the
 subacute and subchronic studies.   No treatment-related  toxic
 effects were noted in an inhalation study in rats at doses up to
 20,000 ppm.

      HCFC-142b was mutagenic  in the Ames assay (Jagannath,  77;
 Longstaff and  McGregor,  78; Longstaff et al.,  84).   As  discussed
 in the hazard  assessment support document, HCFC-142b gave a weak
 positive response  when tested for its ability to induce
 chromosomal  aberrations  in the  bone marrow of male rats
 (Pennwalt,  80a).   HCFC-142b is  considered to be without effect in
 a  dominant lethal  assay  in rats (Pennwalt, 8Ob).

      HCFC-142b was also  tested  in both the BHK-21 (Longstaff et
 al.,  84)  and the Balb/3T3  systems (Matheson,  78).   No conclusions
 can  be drawn about the activity of this  compound in either of
 these test systems although HCFC-142b was reportedly positive in
 the  BHK-21 system.

      Although  HCFC-142b  was positive in  the  Salmonella  assay and
 is a  weak  inducer  of chromosomal  aberrations in femoral bone
marrow,  it does not appear to induce chromosomal  aberrations in

                                20

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germ cells of males as evidenced by a negative dominant lethal
study.  On the basis of the data presented, there is no evidence
to suggest that HCFC-142b presents a mutagenic hazard to man.  No
further testing for heritable genetic effects is recommended.
Results in cellular transformation assays do not relate to
heritable mutagenic events and do not indicate the need for
further testing.

     In a two-year inhalation study in rats on HCFC-142b (Seckar
et al., 86), no statistically significant increase of tumor
incidences were reported for any dose level (highest dose tested
= 20,000 ppm).  The maximum tolerated dose (MTD) might not have
been reached in this study.  However, HCFC-142b is not expected
to be oncogenic because of the negative test results combined
with SAR analysis that indicates a low oncogenicity potential for
HCFC-142b.

     HCFC-l42b has not been adequately evaluated for
developmental toxicity.  It has only been tested in one species,
rats.  The two existing studies in rats are considered limited.
No maternal toxicity was seen in these studies.  In one study,
there is suggestive evidence of developmental toxicity (pre-
implantation loss) at 1,000 and 10,000 ppm (Culik and Kelly,
76b).  The other study provided only suggestive evidence of
developmental toxicity when tested at 2000 and 10,000 ppm (Damske
et al., 78).

     Except for the dominant lethal study cited earlier, the
potential for reproductive toxicity of HCFC-142b has not been
studied.
2.1.6  SUMMARY OF TOXICITY STUDIES OF HFC-152a

     HFC-152a has very low acute toxicity.  Lethal concentrations
range from 383,000 to 500,000 ppm depending on the length of
exposure  (Moore, 75; Lester and Greenberg, 50; Limperos and Zapp,
51).  Test animals showed lack of coordination, labored
breathing, unresponsiveness to sound, and dose-responsive
narcosis at concentratibns of 175,000 ppm and greater.

     HFC-152a is a weak cardiac sensitizer.  Epinephrine-induced
cardiac arrhythmias were seen at 150,000 ppm but not at 50,000
ppm in dogs (Mullin, 69b).  No effect on the cardiovascular
system of monkeys and dogs was seen at concentrations up to
200,000 ppm in the absence of an epinephrine challenge dose.
Rats did have arrhythmias at concentrations of 50,000 ppm and
greater, but rats are not considered to be a good model for
evaluating the cardiotoxicity of halogenated hydrocarbons in
humans (from a series of studies by Aviado, Smith, Belej et al.,
74; 75).


                                21

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      Signs of CNS depression have been noted in acute inhalation
 studies in rats at high concentrations (175,000 ppm and greater)
 (Moore, 75; Lester and Greenberg, 50; Linperos and Zapp, 51).   In
 a 2-week study (Moore, 76b), narcosis and unresponsiveness to
 sound were noted at 100,000 ppm.

      Results of a chronic study in rats (McAlack,  82)  indicate
 that HFC-152a has low systemic toxicity.   At 25,000 ppm, animals
 had symptoms that were indicative of a mild reversible alteration
 in the renal structure of males and females and a  slight
 interference in renal function in females.  There  was also an
 increased incidence of swollen ears, ocular/nasal  discharge and
 wet/stained perinea in both males and females,  and an increased
 incidence of wet/stained body and face in females.  These
 symptoms may be indicative of chronic low level irritation or
 stress.  No effects were seen at 10,000 ppm.

      HFC-152a was negative when tested in the Ames assay (Koops,
 77b).  No conclusions can be drawn about  the activity of HFC-152a
 in the Drosophila melanogaster sex-linked recessive lethal (SRL)
 assay (Foltz and Fuerst,  74; Garrett and  Fuerst, 74)  because the
 available information is inadequate to draw conclusions.   There
 is no evidence to indicate a concern that HFC-152a may induce
 heritable effects in man.  No further testing for  heritable
 genetic effects is recommended.

      HFC-152a was non-carcinogenic in a 2-year inhalation study
 in rats with a high dose of 25,000 ppm (McAlack, 82).

      No statistically significant evidence of maternal or
 developmental toxicity was seen in a study of HFC-152a in rats
 (Culik and Kelly,  80).   There was a dose-related trend in the
 incidence of two skeletal anomalies.   Although  this finding is
 suggestive of developmental toxicity,  it  should be noted that  no
 statistically significant effects were seen at  50,000  ppm.   HFC-
 152a  has not been tested in a second species.

      HFC-152a has not been tested for reproductive toxicity.


 2.1.7   SUMMARY OF TOXICITY STUDIES OF HFC-134a

     HFC-134a has  very  low acute toxicity.  Lethal concentrations
 range  from 567,000 to 750,000 ppm in rats  (Silber  and  Kennedy,
 79a; Rissolo and  Zapp,  67).

     The cardiac  sensitization potential of HFC-134a was
 evaluated in a standard epinephrine challenge test (Mullin and
Hartgrove,  79).  HFC-134a is  a weak cardiac sensitizer.
Epinephrine-induced  cardiac arrhythmias were seen  at doses  of
75,000 ppm and greater  in dogs.   No response was noted at 50,000
ppm.

                                22

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     Signs of transient CNS depression have been seen in acute
 studies  (Silber and Kennedy, 79a; Rissolo and Zapp, 67) and in a
 developmental toxicity study (Lu and Staples, 81) at 100,000 ppm
 in rats.  In a 90-day inhalation study on HFC-134a (Hext, 89),
 female rats exhibited decreased brain weights at 10,000 and
 49,500 ppm which were not dose related (2.77 and 2.63%,
 respectively).  This statistically significant change was not
 accompanied by either positive histopathological findings
 following the usual staining of brain and peripheral nervous
 system  (PNS) sample tissue or by transient CNS depression.  Four-
 week recovery animals from the subchronic study and 12-month
 sacrifice animals from an ongoing chronic study showed no similar
 decrease in brain weight.  Four-week recovery animals from the
 subchronic study were negative for all histopathological
 findings.  While EPA agrees that the available histologic reports
 were negative, adequate details of the evaluation were not
 provided as to which brain regions were examined.  EPA is
 awaiting more specific information from ongoing studies to fully
 evaluate the potential neurotoxicity of this compound.

     In subacute studies (14 days and 28 days) in rats (Silber
 and Kennedy, 79b; Riley et al., 79), the only pathological
 changes noted were in the lung indicative of focal interstitial
 pneumonitis after exposure to 50,000 or 100,000 ppm of HFC-134a.
 Some changes in organ weights (liver, kidney, gonad) were seen in
 the 28-day study at 50,000 ppm.  Increased liver weight was also
 seen at 10,000 ppm in males.  None of the organ weight changes
 were associated with altered gross or microscopic pathology.

     Other than the brain weight changes noted above, little or
 no systemic toxicity was observed in rats following inhalation
 exposure for 13 weeks to HFC-134a (Hext, 89).  Body weight and
 organ weight changes and changes in urine, blood biochemistry,
 and hematology parameters were observed but were not dose-related
 or consistent with time.

     HFC-134a was tested three times for its ability to induce
 gene mutation in the Ames assay (unpublished study submitted to
 EPA, 76; Taylor, 78; Callander and Priestley, 90).  Results were
 consistently negative.  HFC-134a was also nonmutagenic when
 tested in an assay for micronucleus formation in the femoral bone
marrow of treated mice (Muller and Hofmann, 89) and appears to be
negative in the dominant lethal assay (Hodge et al., 79a).  The
results of the chromosomal aberrations assay are inconclusive
 (Anderson and Richardson, 79b).  In addition, HFC-134a did not
 induce unscheduled DNA synthesis (UDS) in rat hepatocytes in vivo
 (Trueman, 90).  There is no evidence to suggest that HFC-134a
 induces either gene or chromosomal mutations and hence no reason
to suspect that it may induce heritable effects in man.  No
further testing for heritable genetic effects is recommended.


                               23

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      HFC-134a did not induce tumors in a limited oral bioassay
 (animals were exposed for only one year)  (Longstaff et al.,  84);
 however, this study is inadequate to assess the oncogenic
 potential of HFC-134a because of the short duration of exposure
 and the use of only one dose level.  SAR analysis for HFC-l34a
 predicts a low potential for oncogenic activity because fluorine
 generally has lower biological activity than other halogens.
 PAFT is conducting a chronic inhalation study in rats.

      Three inhalation studies have been conducted on the
 potential maternal/developmental toxicity of HFC-134a?  two were
 conducted in rats (Lu and Staples, 81; Hodge et al.,  79b)  and one
 in rabbits (Wickramaratne, 89a; 89b).   One rat study with a  small
 sample size (n = 7 or 14) demonstrated maternal toxicity after
 exposure to 100,000 ppm (reduced response to noise stimuli,
 uncoordinated movements)  or 300,000 ppm (significant reduction in
 food consumption and body weight gain, no response to noise
 stimuli, severe tremors,  uncoordinated movements)  of HFC-134a.
 Developmental toxicity was also evident after exposure to 300,000
 ppm of HFC-134a as demonstrated by a significant reduction in
 fetal body weight and a significant increase in the incidence of
 several skeletal variations.   No statistically significant
 effects were seen at 30,000 ppm.   The second rat study,  which
 used a much larger sample size (n = 29 to 30),  provided no
 statistically significant evidence of maternal toxicity after
 exposure to doses as high as 50,000 ppm of HFC-134a.
 Developmental toxicity was evident after exposure to 50,000 ppm
 as demonstrated by a significant reduction in fetal body weight
 and a significant increase in the incidence of several  skeletal
 variations.

      In the rabbit study,  maternal toxicity was evident after
 exposure to 10,000 ppm or more as demonstrated by a statistically
 significant reduction in  food consumption and body weight gain.
 Developmental toxicity was also evident after exposure  to 10,000
 ppm or 40,000 ppm.   Exposure  to 10,000 ppm or more resulted in a
 statistically significant dose-related increase in the  fetal
 incidence,  but not the litter incidence,  of unossified  7th lumbar
 transverse  processes.

      There  was a dose-related increase in the incidence of
 gaseous distention of the stomach.  Although the incidence at
 40,000  ppm  (12.7%)  was only slightly outside the range  for
 historical  controls (2.3  - 11.5%),  the difference when  evaluated
 by  number of  fetuses was  statistically significant.   When
 evaluated by  numbers of litters,  this  statistical  change is not
 apparent.  This effect was seen in 7/23,  7/18,  7/21,  and 9/23
 litters in the control, 1400,  4200, and 12,600  ppm groups,
 respectively.   Gaseous distention can  be  caused by gasping air.
 The reason(s)  for the increase is unclear but could be  indicative
 of non-random  handling of  the animals  or  lung problems.  No
maternal  or developmental  effects were seen at  2500 ppm.

                                24

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     HFC-134a has not been tested for reproductive toxicity.
Decreased gonad weights were noted in a 28-day study at the
highest dose tested  (50,000 ppm) (Riley et al., 79); however, the
significance of this finding is unclear because no effect on the
gonads (either pathological or weight changes) was noted in the
subchronic study  (Hext, 89) at similar dose levels.

2.1.8  SUMMARY OF TOXICITY STUDIES OF HFC-125

     HFC-125 has very low acute toxicity.  Its LC^ via
inhalation is reported to be 700,000 ppm (Vogelsberg, 90).

     No other toxicity data on HFC-125 are available.  The
potential for adverse effects from exposure to HFC-125 can be
evaluated by drawing on an analogy between HFC-125 and HFC-134a.
Details of these studies are presented in the review of HFC-134a.
2.2  TOXICOLOGICAL COMPARISON WITH RELATED CHEMICALS

     A direct comparison of chlorinated hydrocarbons, CFCs and
HCFC/HFCs provides a meaningful and useful basis for evaluating
the HCFCs as a physicochemically-related class of compounds and
for developing (1) individual hazard assessments and (2) a
strategy of identifying individual toxicity testing requirements.
A detailed discussion of the toxicity of chlorinated hydrocarbons
and CFCs is beyond the scope of this report; however, some
generalization in regard to biological effects of each of these
groups of compounds can be made based on SAR analysis.  In
general, effects from chlorinated hydrocarbons occur at lower
levels and are more severe than are seen with either CFCs or
HFCs/HCFCs.
2.2.1  CHLORINATED HYDROCARBONS

     The short chain saturated chlorinated hydrocarbons are
important solvents and feedstocks.

     Overall, this class of compounds is of low acute toxicity.
High concentrations may produce renal and hepatic dysfunction and
pulmonary irritation.  Most chemicals in this class are moderate
cardiac sensitizers and are known to produce CNS depression.  The
liver is often a target organ for chronic toxicity.

     Depending on the degree of halogenation, stereochemical
considerations, and metabolism to genotoxic intermediates, some
compounds in this class are genotoxic, mutagenic and/or
carcinogenic.  The predictive power of mutagenicity tests for
these compounds is limited.


                               25

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 2.2.2  CHLOROFLUOROCARBONS

      The following section provides a description of toxicity
 data for CFC-11, CFC-12, and CFC-113.  These three compounds are
 the most significant chlorofluorocarbons in current use,  from the
 point of view of production as well as widespread use.  This
 class of compounds came into commercial production at a time when
 toxicological testing requirements were limited by today's
 standards.  Thus, many of the available studies may not be
 adequate to fully characterize important endpoints.  However,
 under the conditions of human exposure, no striking examples of
 chronic toxicity have emerged.  The data support a broad
 comparison for a variety of toxic effects of the major  CFCs  with
 the chlorinated hydrocarbons.  In general,  it can be shown that
 the CFCs are less toxic.

      Both CFC-11 and CFC-12 have relatively low acute toxicity
 (inhalation LC50 is greater than 100,000 ppm in animals).
 Alterations in both pulmonary compliance and resistance have been
 observed in humans following exposure to CFC-11 and CFC-12
 (Clayton,  67).  In comparison to the chlorinated hydrocarbons,
 the CFCs exhibit generally lower acute toxicity.

      Cardiotoxicity has been studied in greatest detail with both
 CFC-11 and CFC-12.   Both compounds have been observed to  produce
 an increase in heart rate and decrease in blood pressure  in
 monkeys (at 50,000 ppm), arrhythmias,  and increases in  vagal-
 heart acetylcholinesterase activity in an isolated preparation
 (Young and Parker,  75;  Doherty and Aviado,  75).   Many of  the
 observed effects can be blocked by treatment with a beta-
 adrenergic blocker.   It was also noted that CFC-11 sensitizes
 cardiac muscle to the effects of epinephrine, while CFC-12
 exhibits either minor sensitization potential or no effect on
 epinephrine activation  of cardiac muscle.   These are effects
 common to  halogenated hydrocarbons.

      In terms  of hepatotoxicity,  CFC-12  has been studied  in  both
 continuous (90-day)  and repeated exposures  (8h/5  days/6 weeks)  at
 4000  ppm in rats, monkeys,  rabbits,  and guinea pigs.  Following
 both  continuous and  repeated exposures at very low concentrations
 (100  ppm),  only the  guinea pigs exhibited extensive liver damage.
 However, the fact that  no liver pathology was noted in  any of the
 other species,  taken together with the authors'  acknowledgement
 that  the guinea pig  has an inherent susceptibility in continuous
 exposure studies suggest that these agents,  unlike the
 chlorinated hydrocarbons,  are not directly  hepatotoxic, and  that
 the guinea  pig response appears to be  an allergic response
 (Prendergast et al.,  67;  Maltoni et al.,  88).

      As  reported by  WHO (89),  CFC-11,  CFC-12  and  CFC-113  have
been  tested for developmental  toxicity.   In addition, CFC-12  and
CFC-113 were tested  for reproductive effects.  Although some  of

                                26

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these studies may be limited by today's standards and thus not
all results are conclusive, none of the studies showed evidence
of reproductive or developmental toxicity.  Therefore, it appears
that CFCs would have low potential for toxicity in this category.

     CFC-12 has been studied for potential neurotoxicity.  In
humans, motor skills were affected (20,000 ppm); in rats,
anesthetic effects were observed at 400,000 ppm (Azar et al.,
72).  These findings indicate the apparent anesthetic effect that
has been observed throughout with CFCs, HFCs, and HCFCs  (see
below).  Epidemiological evaluation of the human exposure
experience reveals no associated neurotoxicity or behavioral
effects with chronic exposure to general anesthetics, but no
systematic testing of this endpoint has been done in animals.

     With regards to carcinogenicity, chronic inhalation studies
with either CFC-ll or CFC-12 (at 5000 ppm) were conducted in both
rats and mice and reported no significant incidence of tumors
(Prendergast et al., 67; Maltoni et al., 88).  This is a low
dose, not likely to be a maximum tolerated dose (MTD).  Long-term
oral carcinogenicity studies of CFC-ll and CFC-12 have given
negative results (WHO, 89).  CFC-113 was evaluated in a chronic
study at a well-defined MTD of 20,000 ppm and also produced no
increased tumor incidence (Wood, 85).

     CFC-ll and CFC-12 are negative for mutagenicity in the Ames
assay with and without activation in TA98, TA1538, TA100, and
TA1535 strains (Longstaff et al., 84).  There are no chromosomal
damage studies for these compounds.  It should be noted that many
mutagenicity assays provide inconsistent data and poor
reproducibility with a variety of halogenated hydrocarbons.


2.2.3  HYDROFLDOROCARBONS AND HYDROCHLOROFLUOROCARBONS

     HCFCs and HFCs share common physicochemical features, and
toxicity tests produce similar qualitative results.  While actual
data gaps are apparent, extrapolation within the matrix is
possible and affords a rational basis for developing a toxicity
testing strategy.  Several general observations are evident for
HCFCs and HFCs.

     All appear to be of low acute toxicity and are generally
significantly less acutely toxic than either the halogenated
hydrocarbons or the CFCs.  Only HCFC-123 and HCFC-141b exhibit
LC50's in the 50,000 ppm range.  All others range from 100,000 to
700,000 ppm.

     All HCFCs appear to be weak cardiac-sensitizers (with
epinephrine) as described for CFCs.
                                27

-------
      Two chemicals induce some effects on the liver.   Both HCFC-
 123 and HCFC-124 cause liver weight changes but only HCFC-123  has
 been found to cause some pathological changes at high exposure
 levels (10,000 ppm in dogs).  The HCFCs are, thus,  similar to  the
 CFCs and exhibit little marked potential for frank  liver
 toxicity, unlike the chlorinated hydrocarbons.

      Some of the HCFCs and HFCs cause maternal toxicity as
 evidenced by a decrease in food consumption and body weight gain.
 Developmental effects are also seen at dosages that equal  or are
 greater than the maternally toxic dose.  A consideration of SAR
 and available data for compounds such as dibromochloropropane,
 halothane, and HCFC-133a suggest the reproductive system as a
 potential target for HCFCs.  The class of HCFCs,  thus appear to
 have a somewhat greater potential for reproductive  and
 developmental toxicity than do the CFCs.

      Like the chlorinated hydrocarbons and CFCs,  all  HCFCs and
 HFCs appear to cause CNS depression much like the general
 anesthetics.  At the present time, they have not been adequately
 studied in animals.

      There is not an abundance of carcinogenicity data on  the
 HFCs or HCFCs.  The available carcinogenicity data  on three
 compounds (HCFC-22,  HFC-152a,  and HCFC-142b)  do not provide
 evidence of a significant carcinogenic potential in humans
 although some studies are limited.  SAR analysis suggests  a low
 carcinogenic potential for HFCs and some HCFCs (e.g.,  HCFC-141b
 and HCFC-142b).

      It should be noted again that many mutagenicity  assays
 provide inconsistent data and poor reproducibility  with this
 class of compounds.   While the HCFCs are sometimes  positive in
 the Ames assay,  HFCs are all negative in the Ames assays.
 Because of the same  technical  difficulties a general  comparison
 with the CFCs is not easily made.   No clear picture emerges from
 the results of the available genotoxicity assays.
2.3  TESTING STRATEGY

      After all of the currently available animal studies were
reviewed, the Agency developed a testing strategy to fill data
gaps.  Instead of testing all compounds for all possible adverse
effects, analogies between individual chemicals are used to
address some toxicological endpoints.

     The CFC producers initiated the Program for Alternative
Fluorocarbon Toxicity Testing (PAFT) in 1983 to develop a
comprehensive, common toxicology data base to support the
manufacture, introduction and use of alternatives by

                                28

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manufacturers internationally.  This is the first time that an
industry, representing companies from around the world, has
voluntarily joined to evaluate the toxicology of limited
production or research chemicals.  The status of the PAFT testing
program is presented in Table 2-1.  Table 2-2 lists the
participating PAFT companies.  The program is divided into three
parts.  PAFT I is investigating and reviewing the toxicology of
HCFC-123 and HFC-134a; PAFT II, HCFC-141b; PAFT III, HCFC-124 and
HFC-125.

     In designing the PAFT programs factors considered were
safety, an urgent need for toxicology information, availability
of the compounds in amounts sufficient to sustain long-term
tests, the economic future of these alternatives, and the
availability of space for inhalation studies in qualified
toxicology laboratories.  Additionally, consideration was given
to the testing requirements in the United States, Europe, and the
Far East.

     The program integrates past and present toxicological
information to enable an evaluation of health effects including
elements of acute, subchronic, developmental and chronic
inhalation studies, genotoxicity studies, oncogenicity studies
and environmental studies.  Most of the tests in PAFT I and PAFT
II, excluding the chronic studies, have been completed and work
is underway on the PAFT III program.

     PAFT studies in progress and schedules for completion are
listed in Table 2-3.  Studies already submitted to the Agency are
listed in Table 2-4.

     EPA evaluated the PAFT testing program and identified
additional testing needs for neurotoxicity and reproductive
toxicity,  EPA also asked for a change in the oncogenicity
testing program for HCFC-123 and HCFC-124.
                                29

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                TABLE 2-1 STATUS OF TESTING PROGRAM
HCFC-
22
"Acute
"CSens
"Neuro
8Subchr
"Muta
8Onco
"Devel
aRepro
T
T
NT
T
T
T
T
NT
HCFC-
123
T
T
P
T
T
O
*T
P
HCFC-
124
T
T
NT
O
T
P
O
NT
HCFC-
14 Ib
T
T
O
T
T
O
T
P
HCFC-
142b
T
T
NT
T
T
T
«T
NT
HFC-
152a
T
T
NT
T
T
T
"T
NT
HFC-
134a
T
T
NT
T
T
O
T
NT
HFC-
125
T
NT
NT
P
P
NT
P
NT
As  discussed  in Section  2.3, testing for neurotoxicity and
reproductive  effects will be conducted on two compounds, HCFC-123
and HCFC-141b.  The need for testing additional compounds will be
evaluated when the results of these studies are available.

T = tested  for this endpoint; NT = not tested for this endpoint;
P = testing planned for  this endpoint; O = testing ongoing for
this endpoint

a Acute = acute toxicity; CSens = cardiac sensitization;  Neuro =
neurotoxicity; Subchr =  subchronic toxicity; Muta = mutagenicity;
Onco = oncogenicity in at least one species; Devel =
developmental toxicity in two species; Repro = 2-generation
reproductive  effects study

b HCFC-22 has been tested for oncogenicity in rats and mice

c tested in rats and rabbits,  test results inconclusive in rats.
The results from the reproductive effects study in rats will be
used to determine the need for further testing for developmental
toxicity in rats.

d tested in one species only,  test results inconclusive.   The
potential for developmental toxicity for HCFC-142b can be
evaluated by comparison to that of HCFC-141b.

e tested in one species only.   The potential  for developmental
toxicity for HFC-152a can be evaluated by comparison to that of
HFC-134a.
                                30

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                    TABLE 2-2  PAFT COMPANIES
1.     AKZO Chemical                      Holland

2.     Allied-Signal                      USA

3.     Asahi Glass                        Japan

4.     ATO Chem, NA                       USA

5.     ATO Chem, SA                       France

6.     Central Glass                      Japan

7.     Daikin                             Japan

8.     Du Pont                            USA

9.     Hoechst                            Germany

10.    ICI                                England

11.    Kali Chemi                         Germany

12.    Montefluos                         Italy

13.    Rhone-Poulenc ISC Div.             France

14.    Showa Denko                        Japan

15.    Solvay & CIE                       Belgium

16.    Ulsan Chemical                     Korea
       Neurotoxicity testing is needed for this class of
compounds because signs of CNS depression are consistently seen
in the available studies (acute, subacute, subchronic, and
developmental toxicity studies).  EPA selected HCFC-123 and HCFC-
14Ib for neurotoxicity testing because they are the most acutely
toxic of the eight compounds, and signs of CNS depression were
seen at lower exposure levels in the existing studies for these
two compounds than for the other compounds.  In addition to the
effects noted in animal studies with various HCFC compounds, the
support for neurotoxicity for this class of compounds is also
based on human evidence suggesting possible impairment of psycho-
motor and cognitive performance associated with inhalation
exposure to CFC-11 (trichlorofluoromethane), CFC-12 (dichlorodi-
fluoromethane), and CFC-113 (l,2,2-trichloro-l,l,2-tri-
fluoromethane) (as reviewed by WHO, 1987).

                                31

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        EPA considers it necessary for HCFC-123  to be tested in  a
 2-generation reproductive effects study.   Positive findings of
 reproductive effects in HCFC-133a assays,  similarities  evident  by
 SAR analysis, and suggestive results in existing developmental
 toxicity studies prompt this decision. To fully characterize the
 potential reproductive hazards of the class of  HCFCs, EPA also
 designates HCFC-141b to be tested for this effect.

        As discussed in the hazard assessment support document,
 SAR analysis identified HCFC-123  and HCFC-124 as having the
 greatest potential for oncogenic  activity.   In  order to account
 for differences in species sensitivity, HCFC-123 and HCFC-124
 will be tested for oncogenicity in different species.
 Genotoxicity test results do not  correlate well with rodent
 carcinogenicity test results for  this class of  compounds.
 Therefore,  additional genotoxicity testing is not expected to
 contribute to an understanding of the carcinogenic potential of
 these compounds.

        EPA will reevaluate any additional  testing needs,  if
 necessary,  based on its analysis  of the entire  testing  package.


                             TABLE 2-3
         PAFT STUDIES IN PROGRESS, SCHEDULED OR CURRENTLY
          UNDER DEVELOPMENT AS PROVIDED BY  PAFT  ON 8/23/90

 PAFT I

 HCFC-123
        Chronic Study Initiated                   Jan. 1989
                      Terminal Sacrifice           Jan. 1991
                      Final Report                1st quarter 1993

        Inhalation Reproduction Study
                      Tentative Start             Jan. 1991
                      Tentative Completion
                      of In-Life                  Mar. 1991
                      Final Report                1st quarter 1993

        Neurotoxicology  Evaluation
                      Tentative Start             Jan. 1991
                      Terminal Sacrifice           Apr. 1991
                      Final  Report                1st quarter 1993

HFC-l34a
       Chronic Study  Initiated                   Oct. 1989
                      Terminal  Sacrifice           Nov. 1991
                      Final Report                4th quarter 1993
                                32

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                         TABLE 2-3 (cont)
PAFT II

HCFC-141b
       Chronic Study Initiated                   Jan. 1990
                     Terminal Sacrifice          Jan. 1992
                     Final Report                1st quarter 1994

       Inhalation Reproduction Study
                     Tentative Start             Jan. 1991
                     Tentative Completion
                     of In-Life                  Mar. 1992
                     Final Report                1st quarter 1993

       Neurotoxicology Evaluation
                     Initiated                   Jan. 1990
                     In-Life Completion          June 1990
                     Final Report                1st quarter 1991

PAFT III

HCFC-124
       Subchronic Inhalation
                     Study Initiated             May 1990
                     In-Life Completion          Aug. 1990
                     Final Report                2nd quarter 1991

       Rat Teratology
                     Study Initiated             May 1990
                     In-Life Completion          Aug. 1990
                     Final Report                2nd quarter 1991

       Rabbit Teratology
                     Tentative Start             Jan. 1991
                     In-Life Completion          Feb. 1991
                     Final Report                2nd quarter 1992

       Chronic Study Dates not yet determined

HFC-125              No studies have been placed yet.
                     Identification of a source for the test
                     compound is completed.  Completion of a
                     subchronic inhalation and two species
                     teratology is estimated by 4th quarter 1992.
                     HFC-125 will also be tested in a battery of
                     mutagenicity assays.
                                33

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            TABLE 2-4   PAFT STUDIES SUBMITTED TO EPA
PAFT I
       HCFC-123      An Inhalation Range-Finding study to
                     Evaluate the Toxicity of CFC 123 in the
                     Pregnant Rabbit

                     Primary Dermal Irritation Study with HCFC
                     123 in Rabbits

                     Acute Dermal Toxicity Study of HCFC 123 in
                     Rabbits

                     Acute Dermal Toxicity Study of HCFC 123 in
                     Rats

                     An Inhalation Developmental Toxicity Study
                     in Rabbits with HCFC 123

                     A 4-Week Inhalation Study with HCFC 123 in
                     Rats

                     HCFC 123:   Ames Assay using Strains TA98,
                     100, 1535, 1537,  1538 with and without
                     Metabolic Activation

                     Haskell Laboratory Report "Subchronic-
                     Inhalation Toxicity:  90-Day Study with HCFC
                     123 in Rats"

                     HCFC 123 Micronucleus Test in Male and
                     Female NMRI Mice after Inhalation

      HFC-134a      HFC 134a - Embryotoxicity Inhalation Study
                     in the Rabbit

                     HFC 134a:   Teratogenicity Inhalation Study
                     in the Rabbit

                     HFC 134a:   90-Day Inhalation Toxicity Study
                     in the Rat

                     HFC 134a - Teratogenicity Study in the Rat
                     (Comments  only)

                     HFC 134a:   In vivo Micronucleus Assay
                     Conducted  by Hoechst

                     HFC 134a - An Evaluation Using the
                     Salmonella Mutagenicity Assay (CTL/P/2422)
                               34

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                        TABLE 2-4  (cont)
                     HFC 134a Assessment for the Induction of
                     Unscheduled DNA Synthesis in Rat Hepatocyte
                     In vivo

                     HFC 134a:  An Evaluation in the In vivo
                     Cytogenetic Assay in Human Lymphocytes

PAFT II
       HCFC-14lb     Skin Irritation in Rabbits of HFC 14Ib

                     Primary Eye Irritation Study with HFC 14Ib
                     in Rabbits

                     Acute Oral Toxicity Study with HFC 14Ib in
                     Male Rats

                     Acute Dermal Toxicity Study of HFC 14Ib in
                     Rabbits

                     House Bone Marrow Micronucleus Assay of HFC
                     14 Ib

                     Irritant Effects on the Rabbit Eye of 4874-
                     89 (HFC 141b)

                     Irritant Effects on Rabbit Skin of 4874-89
                     (HFC 141b)

                     Acute Dermal Toxicity to Rats of 4874-89
                     (HFC 14 Ib)

                     HFC 14Ib:  2-Week Inhalation Toxicity Study
                     in the Rat

                     PWC 4874-789 Acute Inhalation Toxicity Study
                     in Rats ($-Hour Exposure)

                     1,1-Dichloro-l-fluoroethane:  4-Week
                     Inhalation Toxicity Study with Fischer 344
                     Rats

                     1,l-Dichloro-1-fluoroethane:  13-Week
                     Inhalation Toxicity Study with Fischer 344
                     Rats

                     Delayed contact Hypersensitivity in the
                     Guinea Pig with 4874-89 (HFC 141b)
                               35

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                         TABLE 2-4  (cent)
                      HCFC-141b - Assessment of Mutagenic
                      Potential in Amino-Acid Auxotrophs of
                      Salmonella typhimurium and £.  coli including
                      the First Amendment

                      A Study of the Effect of HCFC  141b on the
                      Pregnancy of a Rat

                      A Study of the Effect of HCFC  14Ib on the
                      Pregnancy of the Rabbit

                      Acute Oral Toxicity to Rats of PWC 4874-89

                      Acute Inhalation Toxicity of FC141b in Rats

                      Acute Dermal Toxicity of FC 14Ib  in Rats

                      Acute Oral Toxicity Studies of FC 14Ib in
                      Rats

                      HCFC 14Ib:   Cardiac Sensitization in Monkeys
                      and Dogs

                      HCFC 14Ib:   Final Report - Preliminary
                      Pharmacokinetics

                      Determination of Acute Toxicity of HCFC 14Ib
                      to Daphnia magna

                      Determination of Acute Toxicity of HCFC 14Ib
                      to Brachydanio rerio

                      Exposure of Cultured Human Lymphocytes to
                      Vapors of HCFC 14Ib

                      Effects of HCFC 14Ib on Chromosome of
                      Culture Chinese Hamster Ovary  Cells
2.4  DEGRADATION OF HCFCS AND HFCS

       The HCFCs and HFCs are considered as acceptable
substitutes for the CFCs because of their greater reactivity and,
thus, shorter environmental lifetimes.  This characteristic would
tent to make these chemicals subject to some degradation in
certain uses.  Industry has provided EPA with the results of a
review of published and unpublished information on the
decomposition of HCFCs and HFCs.  This information suggests that

                                36

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HCFC-123 can decompose to HCFC-133a depending on such factors as
temperature, the presence of metals, the presence of organic
materials  (such as oil), and pH.  other halogenated hydrocarbons,
including halogenated butenes, were also reported.

       A variety of toxicity studies of HCFC-133a were run in the
1970s  (see hazard assessment support document, Appendix A).
HCFC-133a was found to be toxic and industry dropped their
interest in the compound as a commercial product.  HCFC-133a was
carcinogenic in a rat study where 300 mg/kg/day was administered
orally for one year (Longstaff et al., 84).  Animals were held
until week 125 and then examined.  HCFC-133a has also been tested
in a series of dominant lethal assays in mice (Hodge et al., 79d;
80; Kilmartin et al., 80).  HCFC-133a caused reduced fertility
and sperm abnormalities at 100 ppm and greater.

       There are great uncertainties regarding the levels of
HCFC-133a that would form under actual conditions of use and
storage.  Most of the currently available data were generated
under stress conditions.  Industry has provided EPA with
screening test results designed to examine the compatibility of
HCFC-123 with various materials present in large refrigeration
systems, rigid foams, and solvent applications.  Some of these
conditions probably exceed those that would be encountered in
practice, and, in general, it was under these conditions that the
highest levels of HCFC-133a were found as breakdown products.

       Research to develop better information related to
degradation under actual use conditions and the employment of
possible stabilizers, is underway and will be evaluated as it
becomes available.   In particular, tests are being conducted to
determine the extent to which decomposition products form over
longer periods of time during use.  The potential for adverse
health effects from exposure to HCFC-133a and other decomposition
products will be evaluated when potential exposures are
characterized.
                                37

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                    3.  OCCUPATIONAL EXPOSURE

       This section characterizes potential occupational
exposures resulting from routine use of the eight HFCs and HCFCs.
Potential exposures resulting from accidental releases of
HFC/HCFCs are not addressed in this document.  Although numerous
other chemicals and/or alternative technologies having the
potential for replacing CFCs have been identified, an assessment
of these alternatives is beyond the scope of this document.  The
information presented in this report is contained in a draft
document titled, "Occupational Exposure and Environmental Release
Data for Chloroflourocarbons (CFCs) and their Substitutes. (PEI,
1990) .

       The following occupational exposure scenarios are
addressed in this section: manufacture, foam blowing,
refrigeration, mobile air-conditioning, sterilant carrier, and
metal and electronics cleaning.  As can be seen from Table 3-1,
these scenarios correspond to uses that account for the great
majority of CFC consumption.  Table 3-2 provides a summary of
potential uses for the eight HFCs and HCFCs as described in
recent United Nations Environment Programme (UNEP) documents.

       Occupational exposure assessments require information on:
the populations exposed; worker activities leading to exposure;
routes of exposure; and the frequency, duration, and levels of
exposure.  Providing there is a complete and representative set
of information, a comprehensive exposure assessment would relate
worker activities to exposures and present the range and the
distribution of monitoring data.  In the case of the above HFCs
and HCFCs (except for manufacturing and to a limited extent for
certain foam blowing operations) there were no personal
monitoring data available to characterize potential exposures,
primarily because these chemicals are not currently in
significant commercial use.
                                38

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      TABLE 3-1  EXISTING CFC U.S. CONSUMPTION SUMMARY, 1985
USE
Foam blowing
Refrigeration (1)
Mobile air
conditioning
Sterilant
carrier
Electronics and
Metal Cleaning
Aerosol Use
TOTAL
CFC consumption, million kilograms
CFC-11
68
8
None
None

None
4
80
CFC-12
16
47
44
22

None
8
137
CFC-113
None
None
None
None

69
Unknown
69
CFC-114
3.5
0.5
None
None

None
Unknown
4.0
CFC-115
None
5
None
None

None
None
5
Source:
Note:
       EPA,  89a

(1)   Refrigeration includes both commercial refrigeration
       and air conditioning
                                39

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                 TABLE  3-2   LIKELY  HCFC AND HFC  SUBSTITUTES FOR CFG USES
USE
Foam
blowing
Refriger-
ation (1)
Mobile air
conditioning
Sterilant
carrier
Electronics
Metal Clean
HCFC22
X
X
X


HCFC123
X
X

X
X
HCFC124

X
X
X
X
HFCJ.25

X



HFC134a

X
X


HCFC141b
X
X

X
X
HCFC142b
X
X
X


HFC1523

X
X


       An "X" indicates the HCFC or HFC may possibly be a CFC substitute for the use
noted.  A blank space indicates no information was found indicating that this HCFC or HFC
may be a CFC substitute for the use noted.
Sources:      UNEP, 89a; UNEP, 89b; UNEP, 89c; UNEP, 89d.
Note:
        (1) Refrigeration includes both commercial refrigeration
       and air conditioning

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        Two techniques were used to estimate the range of possible
 exposure levels:  a surrogate approach,  based on existing  CFC
 personal inhalation monitoring data,  and modeling.   For each of
 these analytical approaches,  both mid-range and outerbound
 occupational exposures were estimated based on available
 information, including information on the existing  CFCs.   Mid-
 range exposures are presented to provide a sense of what likely
 or average exposures may potentially  be.   The Agency has a high
 degree of confidence that potential exposures are likely to be
 less than the outerbound level presented; there is  more
 uncertainty in the estimates  of the mid-range values.   The two
 techniques used to estimate exposure  are discussed  below,
 followed by a summary of key  data sources used in these analyses.


 3.1  SURROGATE APPROACH

        Data on the existing CFCs offer some promise as surrogate
 information to assess potential exposures to the substitutes
 because of the similarities in their  use patterns as well  as
 their physical/chemical properties relative to the  HFCs and
 HCFCs.   Some physical and chemical properties of the HFCs  and
 HCFCs are presented in Table  3-3.

        The use of existing CFC exposure  data as a surrogate
 method for quantifying exposures to the HFCs/HCFCs  has several
 important limitations that must be noted:

 o       First,  only a limited  amount of data was found  on the
        existing CFCs and it may not be representative  of typical
        workplace exposures.   A significant proportion  of the data
        was collected by NIOSH in response to complaints.
        Therefore,  there may be some biases associated  with this
        data.

 o       Second,  since the HFCs and HCFCs will not be "drop-in"
        substitutes in most cases,  industry will need to design
        new equipment.   The higher cost of the substitutes  and
        anticipated State and  Federal  regulations, such as  the
        Amendments  to the Clean Air Act, will move industry
        towards  developing new equipment that will minimize
        releases of HFC/HCFCs  to the workplace and the
        environment.   Because  EPA does not possess actual data
       which show  the effect  of potential  technological changes
        on the actual  workplace exposures,  reductions could not be
        quantified  in  the surrogate  approach.

o      Third, the  exposures to the  substitutes,  (particularly the
       outerbound  exposures) may effectively be  reduced if
       threshold limit values  (TLVs)  or other recommended  or
       required exposure limits  are established which  are below
       those currently in place  for the existing CFCs.

                                41

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  TABLE 3-3  SELECTED PHYSICAL CHARACTERISTICS OF THE HFCs/HCFCs
Characteristics
HCFC-22
HCFC-123
HCFC-124
HFC-125
Formula
Appearance
Odor
Physical State
Molecular Weight
CHC1F2
colorless
ethereal
gas
87
Vapor Pressure, nonHg 10,995
Boiling Point, "C
Water Solubility"
-40.8
0.300
CF3CHC12
colorless
ethereal
liquid
153
688
27.9
0.39
CF3CHC1F
colorless
odorless
gas
137
3155
-10.2
1.71
CF3CHF2
colorless
ethereal
gas
120
9309b
-48.5
0.094
                       TABLE  4-3 continued
Characteristics
 HFC-134a  HCFC-141b
             HCFC-142b
              HFC-152a
Formula
Appearance
Odor
Physical State
Molecular Weight       102
Vapor Pressure, mmHg   4965
Boiling Point,  *C     -26.5
Water Solubility"      0.15
 CF3CH2F    CC12FCH3
 colorless colorless
 ethereal  ethereal
   gas      liquid
             117
             517
            32.0
            0.5b
                         CHF2CH3
 CC1F2CH3
 colorless  colorless
 ethereal     faint
   gas
   101
   2260
  -9.8
               0.5
  gas
   66
  4018
 -25.8
   1.7
8 Water solubility in lb/100 Ib 1^0  at 25'C.
b Estimated by a duPont representative.
Source: Modified from PEI,  1990.
                                42

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 3.2  MODELING

        The modeling technique used in this assessment has  been
 used in the past by EPA to develop risk management decisions.
 The model chosen uses a mass balance approach coupled with
 assumptions regarding the size and duration of releases, room
 size, and the extent of ventilation to estimate worker exposures
 in enclosed spaces.  Engineering judgment was used to estimate
 typical ranges and distributions of possible values of the model
 input variables.  A Monte Carlo selection technique was used to
 calculate corresponding distributions of potential exposures.

        In this analysis, modeling was used to estimate potential
 worker inhalation exposures to CFC substitutes during manufacture
 and servicing of commercial refrigeration and air conditioning
 systems and also during the charging and servicing of mobile air
 conditioners.  The model used requires estimates of five key
 parameters.  The distributions of possible values for two  of
 these parameters,  air exchange rate,  and mixing factor were
 assumed to be the same for each exposure scenario modeled.   The
 distribution of possible values for the remaining three
 parameters; room volume, duration of release and emission  mass
 were varied depending on the exposure scenario being evaluated.
 The ranges of values chosen for the air exchange rates and mixing
 factors assumed are given below.


        Model Input Parameter                  Range

        Air exchange rate(air changes/hour)     1-10

        Mixing Factor(dimensionless)          0.3  - 1.0


 These ranges of model  input parameters are believed to be
 representative of  current industrial ventilation practices.  The
 ranges of  possible values for the other three model input
 parameters are given in Sections  3.7  and 3.8.

        There is considerable uncertainty whether the modeled
 exposures  are truly representative of  future CFC substitute
 exposures.   This uncertainty originates predominantly  in
 assumptions  used for model  input  variable values such  as amounts
 of CFC  substitutes released into  the workplace and  ventilation
 rates of enclosed  spaces where exposures occur.   In addition,  the
 extent  to  which future  differences in  work practices and
 equipment  design will reduce substitute exposures is unknown.
Attempts were made to recognize the potential exposure reduction
 of CFC  substitute  recycling and release prohibitions in the
modeling used to estimate the  occupational  exposures.
                                43

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 3.3  DATA SOURCES

       The major sources of data on occupational exposure cited
 in the PEI report include:

 o      A database maintained by the Occupational Safety
       and Health Administration (OSHA) which contains
       records on 1400 chemicals regulated by OSHA and
       monitored (mostly for enforcement purposes) since
       1981.

 o      Information from National Institute of Occupational
       Safety and Health (NIOSH) studies such as Health
       Hazard Evaluations  (HHEs) and Industry Wide Surveys
       (IWSs).

 o      Information voluntarily submitted to the EPA in
       conjunction with responses to requests for
       information under Section 114 of the Clean Air Act.

 o      Information voluntarily submitted to the Agency by
       manufacturers and users of CFCs and their
       substitutes during the development and review of
       this document.

 o      Modeling techniques which were used to predict
       potential exposure levels in the absence of data.

       The above data sources only contained data on exposures
 through inhalation.  It should be noted that the majority of the
 personal inhalation monitoring data were taken in response to
 complaints and the extent that they accurately characterize
 potential exposures without any biases is not known.  Therefore
 there is no way of knowing whether these data are truly
 representative of actual CFC exposures.  This uncertainty is
 further compounded by the use of existing CFC data as surrogates
 for CFC substitutes for many exposure scenarios.

       No data on dermal exposure were found.  However, the high
volatility of CFCs and many of the substitutes are expected to
 significantly limit any dermal exposure.  For this reason, dermal
 exposures are not addressed in this analysis.


 3.4  SUMMARY AMD CONCLUSIONS

       Tables 3-4 and 3-5 summarize the results of this
preliminary assessment which are described in more detail in the
 following sections by end use.  The results presented here rely
heavily on the limited data set for existing CFCs.
                                44

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           TABLE 3-«:  ESTIMATED POTENTIAL WORKPLACE EXPOSURES FOR CFC SUBSTITUTES
                       FOR SCENARIOS WHERE MONITORING DATA IS AVAILABLE(I)

SCENARIO
MANUFACTURE
FOAM BLOWING
Rigid
Flexible
STERILANT CARRIER
ELECTRONICS CLEANING
METAL CLEANING
UIIUDCB nc
SITES
<11
<85
<144
6,000
6,700(4)
12,200(4)
NUMBER 0
PER SITE
50-145
2-10
2-10
5
3
3
F WORKERS
TOTAL
550 TO 1600
170-850
268-1440
30,000
20.100
36,600
8 HR-TWA INHALA1
Mid- range (ppm)
10
20
5

20
10
ION EXPOSURE
Outer-bound (ppm)
100
500
55
3(2)
1000
1000
15 MINUTE PEAK EXPOSURES
(PPM)
<1000
<5000
<550
15(3)
<10,000
<10,000
NOTES

1.  Dermal exposure* are expected to be minimal for each scenario.
2.  Exposure was based on PEL for Ethylene Oxide.
3.  10 minute exposure.
4.  The number of sites assumed to be the same as the number of operating units.

-------
                         TABLE 1-5:  ESTIMATED POTENTIAL WORKPLACE EXPOSURES (1,2) FOR CFC SUBSTITUTES
                                     BASED ON MODELLING TECHNIQUES
SCENARIO

REFRIGERATION SERVICING (3,7)
Retail Food Storage
Cotd Storage Warehouses
Chillers
Industrial Process Coolers (5)
MOBILE AIR-CONDITIONING (4)
Manufacture
Servicing
	
	
IHMRFR OF
SITES
.... 	

305,000(6)
76,000(6)
25,000(6)
>1, 000,000(6)

64
329.000
	
NUMBER (
PER SITE
... — ....

1-2
1-2
1-2
1-2

20
1-5
	
	
IF WORKERS
..... 	
TOTAL

1220-2440
300-600
100-200
8500-25000

1280
329,000 -
1,654,000
8 NR-TUA INHAU
Mid- range (ppm)
	
20
20
66
14(8)

S3
7
IT I ON EXPOSURES
Outer-bound (ppm)
	
71
48
171
42(8)

105
21
	
15 MINUTE PEAK EXPOSURES
(PPM)

497
325
1179
313(8)

158
26
	 	
NOTES

1.  Denial exposures are expected to be minimal for each scenario.
2.  Emission masses for servicing scenarios take into account recycling required by 1990 Clean Air Act
3.  Refrigeration exposures were based on modelling using HCFC-22 as a model compound except  for chillers which
    used HCFC-123
4.  Mobile air-conditioning exposures Mere based on modeling using HFC-134a as a model compound.
5.  This scenario includes ict machines, skating rinks, and chemical plant and refinery process coolers.
6.  The number of sites was assumed to be the same as the number of services per year.
7.  Refrigeration includes both coamercial refrigeration and air conditioning.
8.  These estimates are for servicing of medium sized ice-machines which make up the bulk of  this category.

-------
        Additional data characterizing actual  HFC/HCFC use  and
 exposures would improve this assessment.   Exposure monitoring
 studies of actual worker activities associated with the use  of
 HFCs/HCFCs are particularly needed to reduce  the uncertainties
 associated with the current exposure characterization.  There are
 several important issues that must be considered when developing
 plans for monitoring studies to gain additional  data-.  To  ensure
 that monitoring data collected is representative of actual
 potential exposures, the variables that affect the measured
 exposures should be characterized and known to be  within the
 bounds of what may reasonably be expected to  occur in actual
 practice.  The major variables that are expected to affect
 exposures include:

 o      Worker activities and work practices.

 o      Quantities and rates of HFC/HCFC used  and potentially
        released.

 o      Technologies and equipment used.

 o      Engineering controls that limit exposures such as
        ventilation rates.

 o      Personal protective  equipment.

 o      Physical/chemical properties such  as vapor  pressures  and
        molecular  weights.   If existing CFCs are  used to simulate
        the HFCs and HCFCs,  then they should have properties  that
        are similar.

 o      Concerns regarding the relatively  greater toxicity  of the
        substitutes.

 Plans  for obtaining monitoring data must  also  address the  issue
 of how many measurements are necessary to fill the perceived data
 gaps.   EPA would  like the opportunity to  meet with industry  to
 discuss specific  monitoring protocols  before any data are
 collected.
3.5  MANUFACTURE

       HFCs and HCFCs will be manufactured by chlorinating and/or
fluorinating volatile chlorinated solvents in continuously
operating, contained systems.

       Because manufacturing plans are still being developed by
industry, the potential number of manufacturing sites and
production volumes for the eight HFCs and HCFCs are unknown.
Based on the average plant capacity data for the existing CFCs,
an average daily throughput for a CFC substitute may be 32,200

                                47

-------
kg/site-day.  It is assumed that the potential total number of
manufacturing sites will be similar to the number used to
manufacturing current CFCs, which is 11.  This number probably
overstates the future markets for HFCs/HCFCs, given their
relatively high costs and the availability of other non-HFC/HCFC
substitutes.

       No information was found on the number of workers
potentially exposed at existing or substitute CFC manufacturing
sites.  It is estimated that 50 to 145 workers per site could be
exposed.  Therefore, the total number of workers exposed is
estimated at 550 to 1600.

       Workers could potentially be exposed during quality
control sampling, packaging and shipping, and maintenance
activities.  Workers may be exposed for up to 8 hours per day,
250 days per year.
                      I
       Workers at CFC manufacturing facilities typically do not
use personal protective equipment (PPE) to limit inhalation of
CFCs under normal operating conditions.  However, the use of
toxic gases such as chlorine in the CFC manufacturing process
requires a substantial amount of engineering controls that
effectively limit exposure to those chemicals.  In some
instances, these controls also serve to limit exposure to CFCs.

       Occupational exposures to HFCs and HCFCs are expected to
be similar to the existing CFCs because of their similar physical
and chemical properties.  Personal monitoring data found for
CFCs, HFCs, and HCFCs (8-hour TWA) are displayed in Table 3-6.
It is not known whether this data set is representative of all
CFC or CFC substitute manufacturing operations.  However, it is
believed that outerbound 8-hour TWA exposures to the HFCs and
HCFCs can be expected to be below 100 ppm, if controls that are
commonly found in existing CFC manufacturing environments are
used.  The geometric mean of 8-hour exposure data currently
available indicate that mid-range exposures could be less than 10
ppm.

       No short-term exposure data for the CFCs, HFCs, or HCFCs
were found.  EPA investigations into occupational exposures to
other volatile chlorinated compounds during use in metal and
electronics cleaning and dry cleaning operations indicate that
15-minute ceiling exposures can be an order of magnitude greater
than 8-hour data.  Based on these data, outerbound short-term
exposures are estimated to be less than 1000 ppm.  There is a
high degree of uncertainty in this estimate due to the difference
in activities that may result in peak exposures.
                                48

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 TABLE 3-6  PERSONAL INHALATION MONITORING DATA (8  HOUR TWA) FOR
     THE MANUFACTURE OF CFCS, HFCS, AND HCFC8
CFC
CFC-11
CFC-12
CFC-113
CFC-115
HCFC-22
HCFC-123
HCFC-141b
HCFC-142b
HFC-152a
No. of
sites
2
1
2
1
2
1
1
1
1
No. of
samples
29
25
15
12
18
5
6
6
3
Range Geo. Mean Data
ppm ppm Sources
0.7
0.1
0.1
0.1
- 90.7
-159.0
-108.0
- 34.0
0.01- 11.0
0.2
0.1
0.1

-10.8
- 2.7
- 3.7
1.5
6.4
3.3
5.0
0.9
0.6
0.9
0.5
0.5

NIOSH
114 letter
NIOSH
NIOSH
114 letter
NIOSH
NIOSH
114 letter
114 letter
114 letter
114 letter
NIOSH
3.6   FOAM BLOWING

        Currently,  CFC-11  and CFC-12 are used as blowing agents in
the manufacture  of rigid  and flexible polyurethane  (FOR) foams.
CFC-11, CFC-12,  CFC-113,  and CFC-114 are also used as blowing
agents  in the production  of other foams such as phenolic,
polypropylene, polyethylene, PVC, and polystyrene foams.  Foam
production processes using HCFCs are expected to be
technologically  similar to those that currently use existing
CFCs.   HCFC-22,  HCFC-123, HCFC-141b, HCFC-142b may be used in
future  foam blowing processes.    It should be noted that the new
Clean Air Act bans the use of HCFCs in non-insulating foams in
three years.  There is no information indicating that HFCs will
be used in foam  blowing.
3.6.1  RIGID PUR FOAMS

       Rigid PUR foams are produced by four different processes:
in the form of laminated boardstock; as bunstock; by pour-in-
place/ injection; or by spray technology.  There are an estimated

                                49

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85 facilities  operated by  55  firms that are major producers  of
rigid polyurethane  foam.   Average CFC throughputs were  2500
kg/site-day  for CFC-li-based  processes and 170 kg/site-day for
CFC-12-based processes based  on  1985 data.

       The number of  exposed  workers for rigid foams  is estimated
to range  from  two to  ten workers per site with the  lower estimate
for sprayed  foam and  the higher  estimate for boardstock,
bunstock, or slabstock plants.   The total number of workers
exposed is estimated  to be 170 - 850.

       Worker  activities in the  various foam manufacturing
processes include:  formulation of polyol and polyisocyanate
solutions, sampling,  monitoring  foam machines and foam  lines, and
cutting and  stacking  foam.  The  presence of isocyanates in the
work area, some of  which have OSHA Permissible Exposure Limits
(PELs) less  than 1  ppm, may be a factor that minimizes  exposure
to CFCs and  their substitutes.   Workers may perform these
activities for up to  8 hours  per day for up to 250  days per  year.
No personal  protective equipment is known to be routinely used  to
limit inhalation exposure  to  CFCs during foam manufacture.

       There were 103 personal inhalation measurements  for the
manufacture  of rigid  foam  using  CFC-11 with a geometric mean of
18.3 ppm.  These monitoring data are presented in Table 3-7,
along with monitoring data for flexible foam.  It is  not known
whether these  data  are representative of all foam blowing
operations and, in  particular, operations that may  use  HCFCs.
However,  considering  the existing CFC data, mid-range exposures
to HCFCs  can be expected to be less than 20 ppm during  rigid foam
manufacturing, provided that  engineering controls and operating
practices similar to  those used  in existing CFC operations are
used to limit  exposure.  Outerbound exposures to HCFCs  are
expected  to  be less than 500  ppm.

       Limited short-term  exposure data for rigid and flexible
foam production were  found and are displayed in Table 3-8.
Because none of these data exceeded the maximum 8-hour
measurements noted  in Table 3-7, it was assumed that  they were
not representative  of worst-case, short-term exposures.  EPA
investigations into occupational exposures to other chlorinated
volatile  compounds  during  use in metal and electronics  cleaning
and dry cleaning operations indicate that 15-minute exposures can
be up to  an  order of  magnitude greater than 8-hour  data. Based
on the 8-hour  data  and the results of the chlorinated volatile
investigations outerbound,  short-term occupational  exposures are
estimated to be about 5000 ppm for rigid foam.  There is a high
degree of uncertainty in this estimate because of the significant
differences  in activities  that may lead to peak exposures.


                                        Material belongs to:
                                        Office of To:-:-ic  .?:*v/vre-, Library  -•
                                50      U.S. !>-• •'••"••:•••  ' '•'•'• •-•••.•..:.K'n Agency
                                        401 Ms:-.01 .vV./ir, •:•'•"•
                                        Washivi'-;•!-, O.O. .XMOO
                                        (202)382-3944

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          TABLE 3-7  PERSONAL INHALATION MONITORING DATA
                   (8 HOUR TWA)  FOR FOAM BLOWING
Process
Rigid
Rigid
Flex.
Foam
Foam
Foam
CFC
CFC-11
CFC-12
CFC-11
No. of
Sites
16
1
3
No. of
Samples
103
1
46
Range
ppm
0.2 - 540
0.
0.05 - 55.
Geo. Mean
ppm
18.3
07
2 1.4
Data
Sources
NIOSH
OSHA
Industry
NIOSH
NIOSH
OSHA
     TABLE 3-8  15-MINUTE PERSONAL INHALATION MONITORING DATA
                         FOR FOAM BLOWING

                     No.  ofNo.  ofRangeGeo. MeanData
 Process      CFC     Sites   Samples     ppm       ppm     Sources
Rigid Foam
Rigid Foam
Flex. Foam
CFC-11
CFC-12
CFC-11
2
1
1
5
1
5
11.0 - 310.0
44.0
0.07 - 0.12
44 . 0 NIOSH
OSHA
NIOSH
0.09 NIOSH
OSHA
3.6.2  FLEXIBLE PUR FOAMS

       Flexible PUR foams are produced by two main processes in
the form of molded foam articles or slabstock.  There are an
estimated 105 facilities producing flexible polyurethane
slabstock and 39 facilities operated by 28 firms producing
flexible polyurethane molded foam.  In 1985, an average facility
using CFC-11 in flexible slabstock production had a CFC
throughput of 435 kg/site/day.  An average facility using CFC-11
in flexible molded foam production had a throughput of 325
kg/site-day in 1985.

       It is expected that many producers of flexible foams will
not convert their processes to HCFC blowing agents because of
their high cost and the availability of cheaper alternatives.
The number of sites using HCFCs as blowing agents for flexible

                                51

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 foams are expected to be much less than the number of sites
 currently using CFCs.

       The number of exposed workers for flexible foams is
 estimated to range from two to ten workers per site.  The lower
 estimate corresponds to sprayed-foam plants while the higher
 estimate is associated with boardstock, bunstock, or slabstock
 plants.  The total number of workers exposed is estimated at 288
 - 1440.

       Worker activities in the various foam manufacturing
 processes are: formulation of polyol and polyisocyanate
 solutions, sampling, monitoring foam machines and foam lines, and
 cutting and stacking foam.  The presence of isocyanates in the
 work area, some of which have OSHA Permissible Exposure Limits
 (PELs) less than 1 ppm, may be a factor that minimizes exposure
 to CFCs and their substitutes.  Workers may perform these
 activities for up to 8 hours per day for up to 250 days per year.

       No personal protective equipment is known to be routinely
 used to limit inhalation exposure to CFCs during foam
 manufacture.

       There were 46 personal inhalation measurements for the
 manufacture of flexible foam using CFC-11, with a geometric mean
 of 1.4 ppm.  These data are presented in Table 3-7.  Considering
 the existing CFC data, mid-range exposures to HCFCs can be
 expected to be less than 5 ppm for flexible foam manufacture,
 provided that engineering controls and operating practices
 similar to those used in existing CFC operations are used to
 limit exposure.  Based on available data, outerbound exposures to
 HFCs and HCFCs are expected to be less than 55 ppm for flexible
 foam.  Outerbound short-term occupational exposures are estimated
 to be about and 550 ppm for flexible foam production.


 3.7  COMMERCIAL REFRIGERATION AND AIR CONDITIONING

       CFC-11, CFC-12, CFC-114, and CFC-115, as well as HCFC-22,
 are currently used as refrigerants in retail food storage, cold
 storage warehouses, chillers, industrial process refrigeration,
 as well as in other minor uses.  Chillers are defined, for the
purposes of this report, as the cooling systems used in
commercial air conditioning applications.  The four major
applications account for a vast majority of the total CFC
consumption for commercial refrigeration and air conditioning.
The substitutes that may be used in the future include HCFC-123,
HCFC-124, HFC-125, HFC-134a, and HFC-152a, as well as continued
use of HCFC-22.  Equipment for cold storage warehouses, chillers,
and industrial process refrigeration can be either inside or
outside of a building.  Retail food storage equipment is always
 inside.

                                52

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        The greatest potential for occupational exposures  to  CFCs
 or their substitutes when used as refrigerants occurs during
 servicing.  Currently,  prior to servicing,  a portion of a
 refrigeration system's  charge may be vented to the atmosphere  in
 an uncontrolled fashion resulting in exposure to workers.
 Recharging vented units may also lead to similar exposures.
 However,  there are several factors that will change current
 worker exposures patterns including:  the use of new equipment
 designs,  which are essential as the CFC substitutes are not  drop-
 in replacements; mandatory recycling under  the Clean Air  Act
 Amendments, and a prohibition on the venting of CFC substitutes,
 also under the Clean Air Act Amendments.
 3.7.1  RETAIL FOOD STORAGE

        Retail food storage refrigeration systems  are used to
 refrigerate food (e.g.,  frozen foods and dairy products) and
 beverages in display cases or cabinets.   These types of systems
 are  located in convenience stores,  small independent grocery
 stores,  and large supermarkets.   The average refrigerant charge
 is about 130 kilograms.   There are  approximately  305,000 retail
 food storage units currently operating.   Servicing  is estimated
 to occur once per year for each unit.

 3.7.2   COLD STORAGE WAREHOUSES (CSWs)

        Refrigeration systems are employed in CSWs to provide
 long-term storage during the distribution process of items such
 as meats,  produce,  dairy products,  and other perishable foods.
 CSW  refrigeration systems include both coolers and  freezers.  A
 typical  unit is charged  with 11,400 kg of refrigerant.  There are
 an estimated 18,900 CSWs currently  operating that use CFCs or
 HCFCs.   CSW units are reported to be serviced four  times per
 year.
3.7.3  CHILLERS

       A chiller is a critical part of air conditioning systems
used to cool large buildings, hospitals, and schools.  The
chiller system consists of a central refrigeration unit that
"chills" a secondary fluid (e.g., water or brine), which is
circulated through remote heat exchangers to cool air.  Typical
refrigerant charge quantities can vary from 65 to 1200 kilograms.
100,000 chillers are currently in operation.  Each system may
receive service once every four years.
                                53

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3.7.4  INDUSTRIAL PROCESS REFRIGERATION

       Industrial process refrigeration systems are used for a
wide variety of purposes ranging from storing volatile liquids to
maintaining ice rinks.  Process refrigeration may be used in
facilities such as refineries, chemical plants, dairy and meat
packing plants, and ice making plants.  The refrigerant may
provide cooling directly to the surface to be cooled or be used
to cool a secondary working fluid.  These systems may contain
refrigerant charges that range in size from one to several
thousand kilograms.  It is estimated that more than 1 million
industrial process refrigeration units may currently be in
service.  Servicing is estimated to occur two to three times per
year.
3.7.5  SERVICING

       Assuming one to two workers are exposed during each
servicing, each service takes an entire working day, and each
service employee works 250 days/year, the total number of workers
exposed per year for each application is estimated to be:

       retail food storage                       1220 -  2440
       cold storage warehouses                    300 -   600
       chillers                                   100 -   200
       industrial process refrigeration          8500 - 25000

       No personal protective equipment or engineering controls
are known to be routinely used to limit inhalation exposure to
CFCs during servicing of refrigeration units.

         Only six 8-hour personal exposure measurements were
found for workers to CFCs during refrigeration servicing.  These
data are presented in Table 3-9.  This data set is not extensive
enough to draw conclusions regarding 8-hour exposures.  In
addition, no short-term CFC substitute exposure data were found
for workers servicing commercial refrigeration and air
conditioning equipment.  Therefore, modeling estimates of
exposures were made using HCFC-22 as a representative compound
for retail food storage, cold storage warehouses and industrial
refrigeration.  HCFC-123 was used as a representative compound to
estimate occupational exposures related to servicing of chillers.

       The ranges of values of exposure scenario-specific model
inputs used to estimate exposures during commercial refrigeration
and air conditioning servicing were:
                                54

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                            Room Volume   Emission    Duration of
                               fro )       Mass  (kg)   Release(min)

 Retail Food Storage         500-10,000    0.91-3.65       5-30
 Cold Storage Warehouses     250-1,000     0.23-0.68       5-30
 Chillers                    250-1,000     1.25-5.0        5-30
 Industrial Process Refrig.  250-1.000     0.45-0.90       5-30

        The room volume range chosen for retail food was intended
 to encompass the sizes of typical retail food stores.   The room
 volume ranges for the other applications were intended to
 encompass the sizes of small compressor rooms.  The ranges of
 emission masses used in the modeling were based on assuming that
 a portion (generally less than 5% for the above scenarios)  of a
 cooling system's refrigerant charge is vented during servicing.
 These estimates of emission mass assume some portion of the
 refrigerant charge is recycled.   Emissions into the workplace
 were assumed to last from 5 to 30 minutes.

        Mid-range and outerbound exposures  were modeled to be:

                             8-hour TWA  8-hour TWA   15-minute
                             Mid-range   Outerbound   Outerbound
                                ppm         ppm          ppm
 Retail Food Storage             20         71            497
 Cold Storage Warehouses         20         48            325
 Chillers                        66        171           1179
 Industrial Process Refrig.       21         71            476


 TABLE 3-9   PERSONAL INHALATION MONITORING  DATA (8  HOUR TWA)
               FOR SERVICING OF REFRIGERATION UNITS*
CFC
CFC-12
CFC-115
HCFC-22
No. of
Samples 	
2
2
2
Range
ppm
0.7
1.6 - 2.2
0.8 - 1.4
Data
Source
OSHA
NIOSH
NIOSH
  Each line of data represents measurements at a single site.

A recent Finish  (Antti, 1990) paper included data on short-term
HCFC-22 exposures experienced during refrigerator repair work.
The exposures presented ranged from 1300 to 10,000 ppm.  The
duration of the exposures were cited to be 70 to 150 minutes.
                                55

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3.8  MOBILE AIR-CONDITIONING

       Currently, CFC-12 is the only CFC used in mobile air-
conditioning.  HCFC-22, HCFC-124, HCFC-142b, HFC-134a, and HFC-
152a may be used in the future.


3.8.1  MANUFACTURING

       Mobile air conditioners (MACs) are refrigeration systems
that are installed in motor vehicles to provide cooling in the
passenger area.  MACs are installed in automobiles, light-duty
trucks, heavy-duty trucks, and buses during vehicle manufacture
as original equipment.

       There are 64 vehicle manufacturing sites in the U.S. where
MACs are installed in vehicles.  In 1985, U.S. production of
motor vehicles was approximately 11.7 million vehicles.  A
typical charge of CFC-12 in MACs is approximately 1 kilogram.

       It is estimated that up to 20 workers per manufacturing
site will be involved in this activity.  The total number of
workers potentially exposed to CFC substitutes during MAC
manufacture is estimated to be 1280.

       The process for charging MACs with HFCs/HCFCs during
vehicle manufacture is expected to be similar to existing
operations.  Although HFCs and HCFCs are comparable with the
current MAC systems, some necessary modifications prevent them
from being drop-in substitutes.  MAC compressors will have to be
redesigned to compensate for efficiency losses resulting from the
inherent chemical properties of the HFCs and HCFCs.  Use of
substitutes may also require the development of alternate
compressor oils and hose material.  Increased costs of
refrigerants may result in greater emphasis on recovery and
recycle systems prior to servicing or disposal of motor vehicles.

       No 8-hour TWA monitoring data were found for charging MAC
units at auto manufacturing sites.  However, monitoring data were
found for the charging of refrigerants to household refrigerators
at assembly plants, which is a similar operation.  Personal
inhalation exposures of CFC-12 in this study ranged from 0.7 to
4.9 ppm.  The same model used to estimate exposures in
refrigeration servicing was used to predict 8-hour mid-range and
outerbound exposures of 53 and 105 ppm respectively.  HFC-134a
was the modelled substitute.

       For modeling purposes, MAC manfacturing room volumes were
assumed to be 5,000 to 20,000 m3.   The emission mass range was
based on an analogy to measured releases during manufacturing of
household refrigerators.  Emissions to the workplace were assumed
to last from 5 to 30 minutes.

                                56

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        No short-term exposure data was found for auto
 manufacturing sites.  The model that was used to predict
 exposures in refrigeration servicing predicted 15-minute
 exposures of 158 ppm.


 3.8.2  SERVICING

        MAC system repairs are performed in factory-authorized
 shops,  independent repair shops,  and by the vehicle  owner.  The
 number  of service sites in the U.S.  was estimated in 1986 to be
 329,000.   The number of NACs serviced per site per year may range
 from 11 for a fleet maintenance shop to 170 for a new car/truck
 dealer.

        The number of workers servicing MA.Cs is estimated to be
 from 1  to 5 per site.   The total  number of workers potentially
 exposed to HFCs/HCFCs during MAC  servicing is estimated to range
 from 329,000 to 1,654,000.

        Prior to servicing,  MAC units are frequently  vented to the
 atmosphere in an uncontrolled manner.   Recharging, after
 servicing,  is performed manually.  The recharging is usually
 accomplished by connecting a pressurized container of refrigerant
 to the  MAC.   Recharging can also  be  performed using  prepackaged
 aerosol cans of refrigerant.

        Servicing and recharging practices are expected to be
 modified  for the HFCs  and HCFCs.   It is anticipated  that recovery
 units will  be put into service to recover the used refrigerant
 that had  been vented prior to servicing,  thereby limiting
 environmental releases and worker exposure.   Some states are
 enacting  recycling legislation, and  the anticipated  Clean Air Act
 amendments  would require mandatory recycling of MAC  refrigerants.
 These systems would have to purify recovered refrigerant before
 it could  be returned to MAC systems  for reuse.

        No personal  protective equipment are  known to be routinely
 used to limit inhalation to CFCs  during the  MAC recharging or
 servicing.   Some service sites may have ventilation  systems to
 dilute  potential  exposures  when service is performed in service
 bays with closed doors.

        No data  on 8-hour or short  term occupational  exposures to
 CFCs or their substitutes were found for MAC service sites.
 Estimates of  occupational exposures during MAC  recharging and
 servicing (venting  and  recharging) were developed using the same
model used  in refrigeration servicing.   HCFC-l34a was the
 compound used in  the modeling.  An outerbound modeling  estimate
 of 8-hour exposure with  recycling  is 21  ppm.  An  outerbound
estimate of 15-minute exposures with recycling  is 26 ppm.


                                57

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        For modeling purposes, MAC servicing room volumes were
 assumed to range  from 250 to 10,000 m3.  This range was intended
 to encompass  service facilities that have one to several service
 bays.   The emission mass range was based on information on
 average release quantities during servicing.  These estimates of
 emission mass assume some portion of the refrigerant charge is
 recycled.  Emissions to the workplace were assumed to last 5 to
 20 minutes.
3.9  STERILANT CARRIER

       Currently, CFC-12 is the only CFC used as a sterilant
carrier.  In this application, CFC-12 is used as a flame
suppressant carrier for ethylene oxide, which is used to destroy
bacteria, viruses, and fungi present on contaminated hospital
equipment.  CFC-12's function is to serve as an inert diluent to
reduce the flammability concerns associated with handling pure
ethylene oxide.  The ethylene oxide/CFC-12 mixture makes contact
with the contaminated hospital equipment in sealed vessels.
HCFC-123, HCFC-124, and HCFC-141b are potential substitutes for
CFC-12 due to similar physical properties.

       A 1977 source estimates that there are about 6,000
hospitals in the U.S. that have sterilizers.  Host hospitals
operate more than one sterilizer.  NIOSH National Occupational
Hazard Survey (NOHS) data indicate that approximately 30,000
workers in the health care field are potentially exposed to CFC-
12 in sterilant use.  Based on the above data, there would be an
average of 5 workers per site.

       Worker activities for sterilization operation include
loading, operating, and unloading sterilizers; transferring
sterilized articles to aerators; unloading aerators; and putting
the articles into a sterilized storage area.  There are also
workers involved in washing instruments and carts, folding
linens, and wrapping and packaging items for sterilization.

       Typically, engineering controls are used to limit exposure
to ethylene oxide.  These include a dedicated local exhaust
ventilation that directs air away from areas in which workers
function.  The only personal protective equipment expected to be
used is gloves, which are used when removing sterilized articles.

       No exposure data were found for CFC substitutes.  A
limited amount of personal monitoring data for CFC-12 used as a
sterilant was found.  Table 3-10 presents a summary of these
data.  These data are probably not relevant to this assessment
because the OSHA PEL for ethylene oxide has recently been reduced
to 1 ppm.  Using the new OSHA PEL coupled with adjustments for
differences in vapor pressures and solution concentrations,
exposures to CFC substitutes are estimated to be about 3 ppm.

                                58

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        Short term (15 minute)  HFC/HCFC exposures  are  estimated to
 be less than 15 ppm.   This estimate was developed by  considering
 the recently modified NIOSH Recommended Exposure  Limit (REL),
 which is a 10 minute  ceiling,  for ethylene oxide  and  adjusting
 this value for differences between CFC-12  and ethylene oxide
 vapor pressures.


    TABLE 3-10 PERSONAL INHALATION MONITORING DATA (8  HOUR TWA)
               FOR CFC-12  USE AS A 8TERILANT CARRIER*
NO. Of
samples
3
1
4
1
Range
ppm
1.3 - 27.9
0.5
0.9 - 32.0
1482.7
Data
Source
NIOSH
NIOSH
OSHA
OSHAb
b
Each line of data represents measurements at a single site.
This measurement was taken at a facility which has been out of
business since  1981.
3.10  ELECTRONICS AND METAL CLEANING

       CFC-113 is used in the electronics industry to clean
printed circuit  (PC) boards and other equipment.  It also has
applications in  a variety of other manufacturing and service
industries to degrease and clean metal parts.  Although CFC-113
is the only existing CFC which is currently used extensively in
these applications, methyl chloroform as well as several other
chlorinated solvents are also used.  CFC-113 usage has been
greatest in areas requiring "precision" cleaning.  HCFC-123 and
HCFC-141b may be used in the electronics and metal cleaning
applications in  the future.  An azeotrope of these two HCFCs and
methanol is particularly promising for PC board cleaning.

       There are two major types of cleaning processes in which
CFC-113 is used: vapor degreasing and cold cleaning.  Vapor
degreasers are used primarily in electronics industry
applications.  There are an estimated 6000 vapor degreasers
operated by the  electronics industry.  An additional 700 units
are used to clean other kinds of electronic cleaning operations.
Annual CFC-113 consumption in electronics applications is
estimated to be  26 million kilograms per year.

                                59

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        There are an estimated  12,200 vapor degreasers and cold
 cleaning units  operated  to  clean metal parts.  This cleaning may
 be necessary for subsequent assembly, painting, welding,
 electroplating,  and further inspection.  Approximately 43 million
 kilograms of CFC-113 are consumed per year for these uses.

         An estimated 3 workers per cleaning unit are potentially
 exposed to CFC-113  during electronics and metal cleaning
 operations.   Worker activities that may contribute to exposure
 include transfer of CFC  solvent to cleaning equipment, handling
 of cleaned articles during  their removal from the cleaners, and
 disposal of dirty solvent.

        No information was found on personal protective equipment
 used in solvent cleaning operations.  Ventilation is used
 frequently to limit worker  exposure.  Engineering controls and
 operating practices that limit CFC loss, such as keeping
 equipment sealed, positioning  work to minimize drag out, and
 directing solvent sprays below vapor levels, will also reduce
 occupational exposures.

        Table 3-11 displays  pertinent occupational exposure data
 for CFC-113-based electronics  and metal cleaning operations.  The
 geometric means  of  the data indicate that mid-range or expected
 likely  exposures for PC  Board  Cleaning can be expected to be less
 than 20 ppm and  less than 10 ppm for metal cleaning.  Given the
 range of the CFC-113 data,  workers attending similar HCFC-based
 operations in the future can be expected to have outerbound 8-
 hour exposures of less than 1000 ppm.


   TABLE 3-11  PERSONAL INHALATION MONITORING DATA (8  HOUR TWA)
           FOR CFC-113 IN ELECTRONICS AND METAL CLEANING

              No. ofNo.  ofRangeGeo. MeanData
 Process      sites   samples      ppm       ppm        Source


 PC  Boards        16       62   0,04 - 890.0    19.3        NIOSH
                                                           OSHA
                                                         Industry

Other Elect.     48       144   0.001 - 970.0    8.1       NIOSH
  Cleaning                                               OSHA

Metal            29       55    0.04 - 730.0    8.3       NIOSH
  Cleaning                                               OSHA
                                60

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       Table 3-12 displays short-term data for CFC-113.  Short-
term exposures to CFC substitutes are hard to gauge with this
limited amount: of data.  EPA has gathered data on worker
exposures to methylene chloride during electronics cleaning and
trichloroethylene during vapor degreasing.  These data indicate
that outerbound short-term HFC/HCFC exposures during electronics
and metal cleaning should be less than an order of magnitude
greater than the 8-hour data or 10,000 ppm.


    TABLE 3-12  15 MINUTE PERSONAL INHALATION MONITORING DATA
          FOR CFC-113 IN ELECTRONICS AND METAL CLEANING

               No. of.    No. of     Range      Geo. Mean    Data
Process        sites    samples      ppm          ppm      Source


Other Elect.     4        10     3.1 -  330      73.7       NIOSH
  Cleaning                                                   OSHA
                               61

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                      4.  CONSUMER EXPOSURE

       This section presents a summary of EPA's assessment of the
potential exposures to consumers which could occur from the use
of the HFCs and HCFCs.  Since no exposure data for these
chemicals existed, the exposure assessment was based on analogies
to present CFC use exposure.

       This assessment estimates amounts of individual exposure
and the populations exposed for representative scenarios.
Because of EPA's mission to safeguard human health, these
exposures have been estimated conservatively; that is, the
assumptions selected in the estimation process have in some cases
tended to drive estimates of exposure to the high end of the
range.  These exposure and population values are believed to be
possible based on the information presently available.  In these
estimates, it has been assumed that the HFCs and HCFCs will
completely replace present CFCs in both the type and extent of
use described.  The maximum exposures reported are not likely to
apply to the entire exposed population.

       The consumer product use scenarios discussed in this
report are a few of the applications that may cause exposures to
CFC substitutes.  They were selected because they satisfied at
least one of the following conditions: large percentages of CFCs
are used in the application; the application was believed to have
a greater potential for either short-term high exposures or long-
term lower level exposures when compared to other applications;
and information useful to the assessment was readily available
for the application.  Consumer exposure to CFCs, and by analogy
HFCs and HCFCs, is estimated for the following scenarios:
refrigerated home appliances, motor vehicle air conditioning, and
video tape head cleaners.  Table 4-1 presents the estimated
exposures and the exposed populations.

       Two other uses which meet the preceding conditions are
rigid closed cell foam insulation and rigid polystyrene foam used
in food packaging.  Consumer exposures to emissions from foam
insulation are not estimated here because an industry-sponsored
foam insulation testing program is currently underway which is
intended to provide more complete blowing agent emission rate
data than that currently available.  Consumer exposure is also
not estimated here for food packaging, which is subject to Food
and Drug Administration regulations.

                                62

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 TABLE 4-1  POTENTIAL CONSUMER INHALATION EXPOSURES  TO HFCs/HCFCs
 Scenarios
Exposures

 (mg/yr)
                                                       Exposure
                                                   population
     sizes
 Household Appliances  (Normal leakage)
   Refrigerator1*
        10th percentile house0
        Mean housed

   Freezer6
        10th percentile house
        Mean house

   Dehumidifier
        10th percentile house
        Mean house

 (Service emission*)
        10th percentile
        Mean
5.1 or 15.3
2.1 or 6.5
10.2 or 20.4
4.3 or 8.6
   14.7
    6.2
   1529
    647
12.5 x 106  each
87.5 x 106  each
5.5 x 10a each
38.5 x 106  each
  2.4 x 103
  1.7 x 10*
       NA
       NA
Mobile Air  Conditioners   (System leakage*)
Subcompact
Compact
Midsize
Large
(Recharging)
Video Taue Head Cleaners

0.76 or 167
1.09 or 218
1.37 or 240
1.61 or 259
865
21
7.2 X 10°
8.4 X 106
16.8 X 106
13.5 X 106
2.1 X 106
55 X 106
levels of exposure estimated for each scenario is not known.
Maximum exposures are not likely to apply to the entire exposed
population.  Populations estimated for the 10th percentile volume
house are one-tenth of the total estimated exposed population.
Those estimated for the mean volume house are 70 percent of the
total estimated exposed population.
6 Refrigerators and freezers may have either reciprocating or
rotary compressors.  The former require less charge and are
estimated to have proportionately lower emissions, and the lower
estimated exposures shown here.
c The 10th percentile house volume equalled 174 m .
d The mean house volume equalled 411 m .
" Service emissions are estimated to occur once every 13 years.
f System leakage may be in engine compartment or in evaporator
case.  The latter causes the higher exposures to vehicle
passengers shown here.
                                63

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       The range in appliance exposure estimates are due to
different house volumes and charge sizes.  Differences in motor
vehicle air conditioning exposure estimates are from different
leak locations and passenger compartment volumes.

       Sources of uncertainty for each scenario are as follows:

o      In the home appliance scenario, limited information was
       available for differences in the size and frequency of
       service releases.  Refrigerant reclamation and recycling
       during servicing would be expected to lower or eliminate
       the service releases.

o      In the automobile air conditioning refrigerant leakage
       scenario, the chief uncertainties are: the fraction of
       refrigerant leakages that occur inside the evaporator case
       versus those outside the case, the actual fraction of the
       leakage outside the evaporator case that enters the
       passenger compartment, and data on automobile air exchange
       rates.

o      In the scenario for use of video tape head cleaners, a
       critical uncertainty is the amount of replacement of the
       CFC cleaners by new chemicals versus other presently
       available substitutes, i.e., alcohol.

       Data on actual HFC/HCFC exposures to consumers would
greatly improve this assessment.  Additional information could be
gathered as a precursor to field measurements, emissions
(chamber) testing, and model development.  As an example,
representatives of the foam insulation industry are presently
pursuing limited emissions testing of their products to assist in
data development needs.  These steps are discussed further in the
consumer exposure support document.
                                64

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                 5.  GENERAL POPULATION EXPOSURE


       This section estimates the potential exposures to the
general population from the manufacture and commercial use of the
HFCs and HCFCs.


5.1  ENVIRONMENTAL FATE

       Because the HFCs/HCFCs are very volatile, they are
expected to migrate to the atmosphere as gases.  These chemicals
pose some ozone depletion and global warming concerns.  An
extensive discussion of ozone depletion and global warming can be
found in Scientific Assessment of Stratospheric Ozone: 1989, Vol
I and II, published by the World Meteorological Organization as
the Global Ozone Research and Monitoring Project - Report # 20.


5.2  ENVIRONMENTAL RELEASE AND EXPOSURE

       The release data information available to EPA at the time
of this report was "generic", that is, representative of the
HFC/HCFC amounts which may be released for the given activity.
These release data are summarized in Table 5-1.  Since there is
no current data on HFCs and HCFCs, the release estimates are
based on current average CFC releases.  Actual HFC/HCFC releases
may be lower than current CFC releases both in total and per
site.  This is because new Clean Air Act emission regulations and
potentially higher costs of the HFCs and HCFCs are expected to
cause more conservative use, more reclamation and recycling, or
use of other substitutes.  Lack of data makes it impossible to
determine what actual reductions in releases may be.

       The Toxic Release Inventory was used to estimate releases
from manufacturing and electronics and metal-cleaning by type,
i.e., stack or fugitive,  other stack/fugitive release estimates
were based on a number of other sources and professional
judgment.
                                65

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          TABLE 5-1  HFCs/HCFCs AMBIENT RELEASE ESTIMATES
Activitv
Manufacture
Foam Blowing
- Rigid
- Flexible
Mobile Air Conditioning
- Manufacture
- Servicing
*
sites
11
85
144
(MAC)
64
329,000
Release
days/year
350
250
250
250
11 to 170
Release
(kg/site-day)
Stack Fuaitive1
93 34
195 20
390 45
56
0.3 to 4.3
Sterilization
                        6,000
Electronics and Metal Cleaning
        - PC Board Cleaning  705
        - Other Electronics   82
        - Metal Cleaning   1,435

Refrigeration
        - Retail Food Storage
          Manuf/Install.   33,200
          Servicing       304,520
        - Cold Storage Warehouses
          Manuf/Install.     1600
          Servicing        18,900
        - Chillers
          Manuf/Install.    4,260
          Servicing        25,000

Industrial Process Refrigeration
        - Ice Machines
          Manufacture
              Medium
              Large
              X-large
          Servicing
              Medium
              Large
              X-large
        - Chemical Processing
          Manuf/Install
          Servicing
        - Refineries
          Manufacture
          Servicing
        - Ice Skating Rinks
          Manufacture
          Servicing
365
                                     250
                                     250
                                     250
                                       1
                                       1

                                       1
                                       4

                                       1
                                       1
127,112
8
1
1,060,000
150
20
C* 1 Y^ff
sing
182
4,000
2
26
Ve
JCS
10
200
1
1
1
3
3
3
1
1
1
1
1
1
          42
          36
          36
98
86
86
                    20
                     8

                   273
                    76

                    28
                   118
                                                        0.15
                                                        2.1
                                                        32

                                                        0.1
                                                        0.6
                                                        8.5

                                                       1,436
                                                       2,240

                                                       1,436
                                                       2,270

                                                        202
                                                        320
1
  These estimates assume unregulated venting and will be  lower
for HCFC/HFCs based on controls mandated by the Clean Air Act.
                                66

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        Because most of the site locations corresponding to the
 release data are unknown, the usual exposure estimation technique
 of utilizing site-specific meteorological and population
 information to estimate concentrations and the populations
 exposed at those concentrations was not utilized.  Instead, a
 generic site was selected for its meteorological information
 only.   The ramifications of this selection are discussed in
 Section 5-2.

        Concentration and exposure estimates based on the release
 estimates are presented in Table 5-2.  The concentrations
 presented were estimated using the EPA Industrial Source Complex
 Long Term  (ISCLT) Dispersion Model.  Exposures were calculated
 from these concentrations using the equation:

                            E = (C x I)/BW

 where E is the exposure in mg/kg-day, C is the annual average
 concentration in mg/m3,  I is the inhalation rate in m3/day  (20
 m ) ,  and BW is the average body weight in kilograms (70 kg).
 Each exposed individual is assumed to live and work in the same
 ambient zone of concentration 24 hours a day year-round through a
 70 year lifetime.  Since this zone could be located near several
 release sources, the exposed individual's overall exposure could
 be the  sum of multiple exposures, although not necessarily at the
 maximum concentrations presented here.  The probability of
 multiple exposures is expected to be small.


 5.2  UNCERTAINTIES IN RELEASE, CONCENTRATION, AND EXPOSURE
 ESTIMATES

        To make use of these estimates, it is important to
 understand the uncertainties associated with them.  Considerable
 uncertainty is associated with the release estimates because much
 of the  data were based on analogy to existing CFCs, which will
 have differences in physical and chemical properties, material
 quantities, equipment design, and emission controls compared to
 the HFCs/HCFCs.  Since it was not possible to factor in all of
 the variables, these results may be higher than actual releases.

        Since the concentration and exposure estimates were
 derived from the estimated releases, it follows that there are
 uncertainties associated with these values as well.  There were
 additional uncertainties associated with the estimation of the
 concentrations to which people may be exposed.  A major source of
 uncertainty was the need to use a generic site location to
 evaluate aerial releases because insufficient information was
 available to select specific release sites.  This generic site
 was selected from an analysis of maximum exposed individual (MEI)
 concentrations calculated for an identical release from each of
 392 sites across the U. S.  These MEIs were calculated from ISCLT
model runs of statistical wind summaries available for the 392
 sites.
                                67

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TABLE 5-2  POTENTIAL AMBIENT INHALATION EXPOSURES TO HFCS/HCFCS
Highest life-
Maximum exposure time exposure**
Activity concentration (ug/m ) (mg/kg-d)
Manufacture
- Stack Release
- Nonstack Release
Foam Blowing, Rigid
- Stack Release
- Nonstack Release*
Foam Blowing, Flexible
- Stack Release
- Nonstack Release*
Mobile Air Conditioning (MAC)
- Manufacture*
- Servicing* 5.
Sterilization
- Stack Release
- Nonstack Release
Electronics and Metal Cleaning
- PC Board Cleaning
- Stack Release
- Nonstack Release*
- Other Electronics
- Stack Release
- Nonstack Release*
- Metal Cleaning
- Stack Release
- Nonstack Release*
Refrigeration
- Retail Food Storage
- Manuf /Install .*
- Servicing*
- Cold Storage Warehouses
- Manuf /Install .*
- Servicing*
- Chillers
- Manuf/Install.*
- Servicing

9.2
22.8

9.6
9.9

19.2
22.3

26.4
3 to 22.9

0.043
0.98


3.2
128

2.7
319

2.7
115


0.15
0.22

0.88
0.96

0.17
0.17

2.6 X 10"3
6.5 X 10*3
9
2.7 X 10"3
2.8 X 10"3
9
5.5 X 10"3
6.4 X 10"3
T
7.6 X 10 3
1.5 (to 6.5) X 10"3

1.2 X 10"5
2.8 X 10"4

/
9.1 X 10 4
3.7 X 10"2

7.7 X 10"4
9.1 X 10"2
.£
7.7 X 10 4
3.3 X 10*2

c
4.4 X 10"5
6.3 X 10"5
.L
2.5 X 10 4
2.8 X 10'4

4.8 X 10"5
4.8 X 10"5
- Industrial Process Refrigeration
- Ice Machines
- Manufacture*
- Medium
- Large
- X-large
- Servicing*
- Medium
- Large
- X-large


0.001
0.014
0.21

0.005
0.03
0.42


3.0 X 10"7
4.0 X 10"6
6.1 X 10"5
•A
1.4 X 10 6
8.6 X 10*6
1.2 X 10"4
                               68

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                         TABLE 5-2 (cont)
                                                   Highest life-
                               Maximum exposure    time exposure6
Activity                    concentration8 (ug/m3)      (mg/kg-d)

   - Chemical Processing
       - Manufacture                2.8             8.0 x 10~4
       - Servicing                  39.9            1.1 x 10~2
   - Refineries
       - Manufacture                2.8             8.0 x 10~4
       - Servicing                  39.9            1.1 x 10"2
   - Ice Skating Rinks
       - Manufacture                1.6             4.6 x 10"4
       - Servicing                  7.7             2.2 x 10~3


a The concentrations presented were estimated using the EPA
Industrial Source Complex Long Term (ISCLT) Dispersion
Model.These concentrations are the maximum possible at or beyond
site fencelines.  Because of data limitations, concentrations for
activities marked with an asterisk  (*) could not be estimated at
the fenceline, but only at some point beyond the fenceline.
Because of this, those activities may have larger concentrations
between the fenceline and the point estimated than presented
here.

b The Highest Lifetime Exposure (E)  = (C x I)/BW,  where:

       C = maximum annual average concentration (mg/m3)
       I = inhalation rate (20 m /day)
       BW = average body weight  (70 kg)

  Example calculation:

       (22.4 ug/m3 x 1 mg/1000 ug x 20 m3/d)/70 kg =

       6.4 x 10'3 ma/ka-d

  Exposures are conservatively assumed to be 24 hours a day,
year-round, for a 70 year lifetime.
       The effects of this type of use of a generic release site
were twofold.  First, the meteorological conditions (prevailing
winds, etc.) at the site selected were known to cause
conservative (i.e., high) maximum concentrations resulting in
upper-bound exposure estimates.  It is important to note,
however, that the maximum concentration for this site in the
sensitivity analysis was only about twice the lowest maximum
concentration calculated.  Second, using a generic release site
does not permit an estimate of how many people, if any, are
exposed at the estimated air concentrations of the HFCs and
HCFCs.

                                69

-------
        The estimates of model parameters for stack and fugitive
 releases are obvious sources of uncertainty because they are
 based on professional judgment assumptions about  the facilities
 at the release point.

        Model parameters such as the type of release,  release
 height, and size of release facility are key determinants of
 downwind ambient air concentrations.   For example,  a volume
 fugitive release,  which is typically a release  from building
 ventilators, will cause higher ambient air concentrations than an
 area release of the same size.   Also,  a stack release at a 30
 meter height will have its maximum concentration  further from the
 source than the same release from a 5-meter stack.

        The facility fenceline distance estimates  were also
 assumed.   These distances are not used in the ISCLT model itself,
 but are compared to the distances the model predicts that release
 concentrations will be from the release source.   Only those
 concentrations beyond the assumed fenceline distance are
 considered available for general population exposure.  An
 additional uncertainty regarding fenceline estimates is that
 although the exposures presented here were calculated from the
 maximum concentrations predicted by the ISCLT aerial release
 model,  there were insufficient data available to  estimate
 concentrations within certain distances of assumed  building
 source releases.   This means that releases from buildings with
 fencelines within these distances of  unknown concentrations may
 or  may not have larger concentrations  than the model  could
 predict.   The activities where  this occurred are  marked in Table
 5-2;  the  concentration values used in  these instances  are the
 maximum the model  could predict.

        It is important to understand that these maximum
 concentrations are defined by a particular direction  as well.
 For example,  the  area of maximum concentration for  a  release
 might be  said to be 200 meters  from a  source on a westerly
 heading.   In other directions and further away from the source of
 release,  the concentrations will  decrease.


 5.3.  OTHER AMBIENT RELEASES

        Direct releases to environmental media other than air are
 only  estimated for HFC/HCFC manufacture,  assuming 11  sites and
 350 days  release per year.   The receiving media and release
 amount, in  kg/site-day,  are:

       water:   0.1
        landfill:   0.07
        incineration:   21
       underground  injection:   8.5

       Because  of the high vapor pressures of the HFCs and HCFCs,
any disposal method that  is  exposed to air is expected to result
in volatilization of the  substitutes.  HFC/HCFC release after

                                70

-------
incineration is expected to be <0.1 kg/site-day, assuming a 99.9
percent destruction.  Because many of the HFCs/HCFCs are somewhat
soluble in water, their underground injection disposal in aqueous
materials could lower their volatilization.  The possibility of
migration of the injected material into groundwater used for
drinking water depends on regulation of the injection site.  For
example, hazardous waste injection sites are segregated from
potable groundwater supplies.  Present CFCs are federally
regulated as hazardous wastes for certain solvent uses or if
contaminated with hazardous materials.  There may also be
additional state regulations.  Regulation of HFC/HCFC materials
used as CFC substitutes is expected to be similar.

       Although HFC/HCFC releases to water, landfill, and
incineration may eventually volatilize to air, these release
amounts cannot be summed with the air releases previously
presented because their release sites may be spatially distant
from the manufacturing sites.  Because of these uncertainties,
and the small sizes of these releases compared to the direct air
releases, exposures were not calculated for these releases, or
the injection release.
                                71

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                      EPA SUPPORT DOCUMENTS

PEI Associates, inc. 1990.  Occupational Exposure and Environmental
Release Data for Chlorofluorocarbons (CFCs) and their Substitutes.
Prepared  under  Contract  No.   68-D8-0112  for  Office  of  Toxic
Substances, U.S. EPA.

Versar, Inc. 1990. Consumer Exposure to Chlorinated Fluorocarbons
(CFCs) and CFC Substitutes.  Prepared under  Contract No. 68-D9-0166
for Office of Toxic Substances, U.S. EPA.

U.S.  EPA,  Office  of  Toxic  Substances.  1990.  Interim  Hazard
Assessment of HFCs/HCFCs.

U.S.  EPA, Office  of Toxic  Substances.  1990. Potential  Ambient
Inhalation Exposures for Chlorofluorocarbon Substitutes.
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