EPA FACT SHEET REGARDING  THE INCIDENT IN BHOPAL

                            DEC.  1O,  1984
     I want to thank everyone who  cooperated  so'full  in helping us
to pull this backgrounder together  on  short notice.   We hope it is
helpful in achieving Jack McGraw's  goal  of having  the Agency respond
with "one voice" on inquiries about  the  Indian  situation.

     This Q&A mill undoubtedly  have  to updated  regularly over the
coming weeks as new questions are  asked.  We  will  be  sending out
such updates on an as-needed basis.

     Again,  only answer those questions  in your area  of expertise/
and don't hesitate to refer any  inquiries to  the press office,  where
n/e can find the appropriate person  to  handle  given questions.

     Thank you once more for your  responsiveness.


                                          Dave  Cohen
                                          Acting Director
                                          Press Services Division

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   FACT SHEET ON METHYL ISOCYANATE, EPA  AND  THE  SITUATION IN .INDIA


[Note to EPA employees: If you receive any press calls  on this issue,
 please refer them to  the EPA Press Office,  Dave Cohen  (382-558?)
 Dave Ryan(382-29Sl),   Robin Woods(382-4377)  or the  general  number
 382-4355.  Any calls  the Press Office can't  handle  itself will be
 referred to the proper people in  the programs.   If you are asked  to
 talk to a reporter/  don't hesitate to make  it clear  that you will
 only talk on your areas of expertise/ and on nothing  else.   If
 reporters try to steer you into areas you can't or don't want to
 talk about/  just refer them back  to  the  Press Office  or the proper
 number to reach the  press coordinator.    We  will notify any program
 contacts before referring a call.  If a  Task Force Team is set up to
 coordinate information/ Dave Ryan will  represent the  press office.]

 Q.  Is anybody coordinating the Federal  Government's  response to this
 i ssue?

 A.  Jack McGraw,  Deputy Assistant  Administrator  for Emergency
 Response has been designated by Al Aim/  EPA's Deputy  Administrator/
 to head a special task force for  coordination of EPA's activity in
 this matter.  He has  designated Jim Makris as his Project Leader.  The
 Task Force can be reached on 475-8600.   The  overall Federral
 coordination will be  achieved through the National Response Team/
 which is chaired by  EPA and includes representation  from 12 Federal
 Agencies.  Press calls should not  be  referred to the  Task Force or
 Jim Makris unless they have first been  handled  by  the  Press Office.
 It is important to note that the  Task Force is  being  set up merely
 to handle the abundance of calls/ not as an emergency  response
 measure.


 Q.  What is methyl isocyanate (MIC) and  how  is it used?

 A.  MIC is a chemical  used mainly  as  an  "intermediate"  in the process
 of manufacturing certain pesticides  such as Temik/  Carbaryl and
 Sevin.  It does not appear in the  finished product/  so  it is not a
 pesticide problem.

 Q.  What are the health effects of MIC?

 A.  The human health  effects data  which EPA  has  available indicate
 that MIC causes an acid burn in the  lungs.  MIC  attacks ang part of
 the body which is particularly moist/ such  as the  eyes/  lungs/
 mucous membranes.   The short-term effect  is eye irriatation and
 difficulty breathing.  Eventually/ the symptoms  are similar to those
 of pneumonia.  The long-term effect is possible  permanent lung and
 eye damage with extensive scar tissue formation.  Isocyanates cause
 pulmonary sensitization and mau trigger  asthmatic  epispdes.

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Q. Does EPA regulate  methyl  isocyanate?
A. Yes. under both  the  Resource Conservation and Recovery Act(RCRA)
and Superfund. Under  RCRA,  MIC is listed as a hazardous waste
whenever it's discarded,  and  therefore is subject to the various
requirements  under  that law (For example,  one requirement is that  it
must be managed  in  RCRA-permitted storage,  treatment and disposal
facilities).  Under  the Superfund program.  MIC released into the
environment from an  accident  or a waste site must be controlled.
neutralized,  or  cleaned up  to  the extent necessary to protect health
or the environment.   MIC entered the market place 15 years ago,
before EPA was formed and  before TSCA was passed.  MIC is subject,
however,  to reporting under Section 8(e) of TSCA.  8(e) requires  the
manufacturer,  processor,  or distributor of a chemical to immediatley
notify EPA  if he obtains information which reasonably supports  the
conclusion that  the  chemical  presents a substantial risk of injury
to health or  the environment.  EPA did receive on 8(e> notificiation
on MIC from UNion Carbide.  That notification provided data from  an
inhalation study on  rats showing that MIC was highly, acutely toxic.
MIC is also subject  to  recordkeeping under Section 8(c) of TSCA.
Under 8(c>,  manufacturers,  processors or distributors must maintain
records of significant  adverse reactions to health or the
environment.  Health  records must be maintained for 30 years and  can
be filed by employees or plant neighbors.  EPA may inspect such
records upon  request.

Q.  What is Union Carbide's position on MIC?

A.  We cannot speak  for the company.   Their information number  is
(2O3) 794-69B6 in Danbury,  Connecticut.   Any questions on what  is
happening in  India  should  be referred to Union Carbide unless such
questions deal with  any personnel EPA may dispatch to that country.

Q.  Is MIC made  in  the  U.S.?

A.  Union Carbide has a plant  in Institute.  West Virginia(near
Charleston) which manufactures MIC and ships it to other
manufacturers who use it as a  chemical intermediate in the
production of pesticides. Union Carbide has shut down the MIC part
of the W.  Va.  plant  until a safety investigation is completed on the
India situation.

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Q.  Does EPA  know  where  MIC  is shipped to from the West Virginia
plant?

A.  Union Carbide  does  have  this information but thus far refuses  to
officially divulge it  from their Danbury,  Connecticut headquarters
(Although there  are  recent indications that Union Carbide may change
its mind.  Callers should  be encouraged to check customer lists with
Union Carobide)  It is  not  a  part of EPA's record keeping.   Such
information is not normally  required under TSCA.  and even if it were
required, this type  of  information is often claimed as confidential
by the submitting  company.  Confidential business information cannot
be released by EPA to  the  public without criminal penalties.  Under
Section 7 of  FIFRA,  registrants of pesticides are required to
register their facilities/  and annually must provide information to
EPA on the types and amounts of pesticides produced.   Based on our
knowledge of  pesticides  which  use MIC as a chemical intermediate(  we
might be able to deduce  locations and volumes.   However/  that
information would  also  be  protected as confidential business
information under  the  pesticide statutes and it would not be
released to the  general  public.  OPTS does have access to proprietary
data collected by  one  of  its contractors.  That data is more up to
date than the TSCA inventory on production volume and also contains
customer information.  We  are  checking now to determine if we can
release this  set of  propietary data.
    On Dec.  11 George Hanks,  the Federal Environmental Affairs
Director of Union  Carbide  in Washington,  D. C.  "unofficially"
confirmed at  least part  of a customer list for the Institute plant:
FMC Corp.  plant  in Middleport.  N. Y. ;  the Dupont plant in La Porte,
Texas;  the Morton-Thioko1  plant in Weeks Island,  Louisiana;  the
NOR-AM plant  in Muskegon,  Michigan;  the Union Carbide plant in
Woodbine, Georgia;   the Velsicol plant in Pasadena,  Texas;  Shell
Chemical, Institute, West  Virginia.  (Note to EPA employees:  This
list is given you  for your information.   Most of it has already
appeared in the Wall Street  Journal.   Callers should confirm these
sites with Union Carbide).

Q.  What other Federal agencies have responsibilities for safety
regarding MIC?

A.  The Occupational Safety  and Health Administration (OSHA) has a
worker protection  standard (.02 parts per million).   The Dept.  of
Transportation (DOT) classifies MIC as a flammable liquid in the
"hazardous" class,  which means that certain protective shipping
requirements must  be met.  OSHA contact:  Susan Fleming(523-8151);
DOT contact:  Lee MetcaIf(426-2075)

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Q. What about protecting  the tanks MIC is stored in?

A. When RCRA was reauthorized by the President early last November,
a major new section  of  the  law was enacted to ensure the safety of
underground storage  tanks.  The new regulations(the deadline for
development is 33 months  from signing for new tanks and 45 months
for existing tanks)  would  call for the assured integrity of the
entire underground tank  structure/  including such considerations as
valves and pressurization.  so as to prevent  releases to ground and
surface water and to soil.  EPA requires a response to above-ground
chemical releases into  the  atmosphere under  Superfund.  Above-ground
tanks with hazardous wastes are regulated under  RCRA.

Q.  What would happen  if  there were a leak?

A.  Three federal agencies  would have emergency  response
responsibilities, depending on the circumstances.   Superfund
legislation requires that release of any hazardous substances into
the environment must be reported to the Coast Guard National
Response Center  in Washington D. C.   MIC i~sFfifteUas a hazardous
substance under Superfund and a hazardous waste  under RCRA and the
agency would respond to any emergency involving  MIC.  The Federal
Emergency Management Administration(FEMA) and DOT also have
emergency response capabilities.

Q.  Are there other  mechanisms for assuring  safety?

A.  There are standards set up by the American Society for Testing
Materials,  an industry  testing association.   Their number is (2O2)
737-6815.   Their standards  are designed to prevent chemical leaks
from equipment and pipes. The standards are  not  mandatory,  although
companies have generally  accepted them.   There are also national and
local firecodes which could come into play in preventing a situation
posed by a chemical  accident.


Q.  Will people from EPA  go to India?

A.  EPA has received  a request from several  West Virginia
politicians to send  a team  to India.  If the  State Department
approves/  EPA will do so.   We have done this in  the past with other
overseas disasters,   such  as the dioxin problem in Seveso/  Italy in
1976.

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Q.  Could this happen  here?

A.  First off, no  one  knows yet exactly what happened in India.  As
of Dec. 10,  Union  Carbide  believed that there wasn't even an.
equipment failure. Even  if it  was an equipment failure,  it is
extremely unlikely that  a  disaster on the scale of Dhopal could
occur  in the U.S.  Ue have  tighter regulatory controls that reduce
the likelihood of  an accident  happening and better and more
effective emergency response plans and capabilities.  Bill
Ruckelshaus recently said  that the India situation underscores the
need for environmental protection and agencies like EPA doing their
job effectively.    However,  no  set of laws or regulations,  no matter
how well designed  or enforced,  will ever be a fool-proof system.  We
must make sure that we take those actions which seem prudent and
reasonable to prevent  such an  occurrence and that we be prepared to
respond quickly  and effectively should there be such an unlikely
event.

Q. What about Sen. Byrd's  proposal?  What is EPA's response?

A.   Ser..  Byrd of  West Virginia has made two requests of EPA.  One i =.
to send a investigative  team to India.  We will go to India if the
State  Dept.  requests us  to.   He also requested EPA send a team to
the Institute, West Va.  Union  Carbide plant for a special safety
investigation, which EPA did Dec.  6.


Q. Have any Congressional  hearings been called on this issue?

A. We  understand  that Congressman Gaydos of Pennsylvania has called
a hearing on Capitol Hill  for  Dec.  12,  and that Cong.  Waxman of
California has called a  hearing in Institute,  W.  Va.  on Dec.  14.  So
far EPA has been  invited to testify only at the Waxman hearing.


Q.  Are any air  emission rules appliable to the Indian situation?

A.  MIC is not regulated as a  hazardous air pollutant.   The Clean
Air Act is normally concerned  about stack emissions,  and a faulty
tank would not necessarily fall within the body of existing
regulations.   Also, at present,  there volatile organic compounds are
also within EPA  requirements at the plant.
                                 (End)

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   THE NEW XOreK T-VuES, SA'S'JL'LMY. DLCF.MUER 8, 1984
U.S. System  Is  in  Place
      For Curbing  Disasters
                      By PHILIP SHABECOFF
                           l to Tb« NV» York TlflMi
   WASHINGTON. Dec. 7 — A highly
 organized  Federal  emergency   re-
 sponse network now In place across the
 country could contain, but not entirely
 prevent, disasters of the kind caused by
 the leak of lethal gas in India, Govern-
 ment officials said today.
   "Any time you deal with chemicals
 there Is a risk, but the chance of Jt hap-
 pening  here is  much  less  than in
 India," said John J. Stanton, director
 of the Environmental Prelection Agen-
 cy's emergency response division. "We
 are  better able to respond quickly, to
 evacuate  people  and come  In  with
 cleanup operatit/ns."
   Under a \natlonal jcontlngencv  plan
 prepared with the authority of the Fed"-
 eral  toxic waste cleanup  law,  the
 E.P.A.  and the United  States Coast
 Guard  operate  a \natlonal  response
 tcam^set up to deal with  chemical
 "splTrrtnd other environmental emer-
  §encles. The Coast Guard is responsi-
  le  for emergencies in  coastal areas
 and the E.P.A. for those in inland
 areas.
      Offices Ready to'Respond
   Each of the 10 regional offices of the
 E.P.A.  has 6 to  12 people who  are
 trained to respond to such emergencies
 as spills of poisonous chemicals and
 who are equipped with gear for protec-
 tion, testing and containing the hazard.
 The response teams can call-in experts
 from other agencies, like the Centers
 for Disease Control, the Defense De-
 partment-and the Federal Emergency
 Management Authority.
   Private  operators have  been  re-
 tained across the country who are re-
 quired by contract to be able to reach
 the scene of any accident In their re-
 gion withla one to tvrj hours through
 the use of subcontractors able to  deal
 with chemical emergencies.
   The E.P.A. has also eel up anjl
 ronmeotal response center" in
i"envi- phone
Edison.,  The
 NJ., starred oy scientists and engi-
 neers who have the training to provide
 information on  chemicals  and the
 means to deal with such emergencies
 In any pan of the country.
  Nationally, the Federal emergency
system has dealt with about 500 chemi-
cal emergencies in the last throe years,
some of them potentially serious, ac-
cording to  E.P.A. officials.
  When a cloud of the pesticide mala-
thlon  escaped from  an American
Cyanamid  plant in  New Jersey  and
drifted over  Staten Island  several
weeks ago. "we responded very quick-
ly," said Mr. Stanton of the E.P.A.
  He said the Coast Guard "was out al-
most immediately, putting up a water
curtain" to act as a barrier against the
noxious cloud. The New  Jersey state
response team, which Mr. Stanton said
was ooe  of the best, also moved In.
  Although more than  ISO people ex-
posed to the cloud had to be treated, the
consequences could have been worse if
not for the rapid response, be said.
      How It Would Respond.
  Asked to describe what action would
be taken If a leak similar to the one in
India occurred at the  Union Carbide
plant in  Institute. W. Va., Thomas I.
Massey, chief of emergency response
for E.P.A.  In the region, said be could
give only  a "generic" answer.  The
West Virginia plant makes methyl iso-
cyanate. the same chemical that has
killed  more than 2,000 people In India
after It leaked from a  Union Carbide
plant.
  Mr.  Massey said that under  the
emergency plan, after the accident hafl
been noticed — by the company, the
local Fire Department or "some  Boy
Scouts on a hike" — authorities would
call the National Emergency Response
Center operated by the  Coast Guard in
Washington. The center takes all such
colls on chemical emergencies, wher-
ever they might occur in the United
States. The emerggacxjenter's tele-
phone number ls((800) 424-8801!) The
      Is  staffed 24
  The center would immediately notify
the state Governor and the state's own
ejne£g£Q££rgfponse team. After that,
the E.P.A^s  regional  emergency re-
sponse team would De~noUfled and be-
gin an assessment.  '.'  '

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