Categorization and Summary of Public Comments on the
Chemical Emergency Preparedness Program Interim Guidance
and Chemical Profiles
Prepared by
ICF Incorporated
1850 K Street, N.W.
Washington, D.C. 20006
For the
Economics and Technology Division
Office of Pesticides and Toxic Substances
U.S. Environmental Protection Agency
Washington, D.C. 20460
EPA Contract 68-02-3976 Task 32
and
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, D.C. 20460
EPA Contract 68-01-6872 Task 38
April 9, 1986
ICF INCORPORATED International Square
1850 K Street, Northwest, Washington, D. C. 20006
-------
Categorization and Summary of Public Comments on the
Chemical Emergency Preparedness Program Interim Guidance
and Chemical Profiles
Prepared by
ICF Incorporated
1850 K Street, N.W.
Washington, D.C. 20006
For the
Economics and Technology Division
Office of Pesticides and Toxic Substances
U.S. Environmental Protection Agency
Washington, D.C. 20460
EPA Contract 68-02-3976 Task 32
and
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, D.C. 20460
EPA Contract 68-01-6872 Task 38
April 9, 1986
-------
PREFACE
As requested, we have reviewed the comments received on the Chemical
Emergency Preparedness Program (CEPP) Interim Guidance, the list of acutely
toxic chemicals, the chemical profiles, and the criteria for inclusion on the
list. A total of 54 letters was reviewed.
Each letter was analyzed and distinct comments within the letter were
identified. Verification or validation of the comments has not been performed
during this phase of the review. While many of the comments may be valid,
some clearly are not. For example, one letter recommended adding to the list
chemicals already on the list.
Several conventions were established in defining comments for this
exercise. When a commenter suggested adding or deleting a group of chemicals
from the list for a specific reason (e.g., the chemicals did not meet EPA's
toxicity criteria), it was considered as one comment. • If a commenter
suggested adding or deleting a chemical for two distinct reasons, the letter
was divided into two comments. Comments on each specific chemical profile
were considered as a single comment, but each suggestion for a change in the
profile is noted as a subcomment in the comment summary. Several comments on
the profiles are grouped by profile section, with all suggestions on a
particular section considered as a single comment.
The comments have been classified into 12 categories which are described
in Exhibit 1. Four of the categories have also been divided into
subcategories. The first six categories include comments on the list of
chemicals, the criteria used for establishing the list, and the chemical
profiles. Two of the categories include comments on the site-specific
guidance provided in Chapter 3 and Appendix D of the CEPP document, and four
of the categories include comments on the general guidance. The number of
summary comments and the number of individual comments are shown in each
category in Exhibit 1.
A summary of the responses received for each category is presented in
Exhibit 2. The majority of the comments were concerned with the list of
chemicals, the criteria, and the chemical profiles, but there was also a
significant number of comments on the site-specific and general guidance.
Over half of the letters expressed support for the program. Exhibit 1 also
notes that 42 of the 54 letters were received on or before the closing date
for comments. Letters were received from federal (1), state (11), and local
(6) government agencies; trade associations (7); private corporations (27);
public interest groups (1); and unaffiliated individuals (1).
Exhibit 3 provides a summary of the comment log. For each comment
received, the EPA log number of the letter is noted as well as the comment
number assigned by ICF. The exhibit also provides the category of the
comment, the type of organization that sent the letter, an indication of
whether the letter was received on or before the closing date for comments,
and the name of the organization that sent the letter.
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-11-
Brief summaries of all comments are provided in Exhibit 4. The comments
are presented by category, and for each comment the number and distribution by
organization type that made the comment are noted. The comments are
summarized briefly, and the log and comment numbers are noted so that the full
comments can be easily located.
There were 358 individual comments, grouped under 146 summary comments
derived from the 12 categories of comments from the letters. While many of
the comments were unique and attributed to only one commenter, there were
several comments that were supported by many commenters. The most frequent of
all comments was that the guidance provided by the EPA interim document is
very helpful. A total of 23 letters expressed this comment, 7 from state and
5 from local agencies, one from a trade association, 9 from private
corporations, and one from a public interest group (Exhibit 4, Section X).
Support for the goals of the CEPP was also expressed in 6 letters (Exhibit 4,
Section X). The areas that received comments from several letters are briefly
highlighted in the following paragraphs.
There were many unique comments that recommended deleting or adding
specific chemicals based on toxicity data, physical/chemical properties or
other characteristics. Among the chemicals that were recommended for deletion
from several letters were nickel (5), cobalt (4), bacitracin (3), cyclopentane
(3), and hydrogen peroxide (3). Among the chemicals that were recommended for
addition from several letters were dioxin (2), tetrachloroethane (2), carbon
tetrachloride (2), and carbon monoxide (2) (Exhibit 4, Sections IIA and IIB).
A total of 48 various comments were made regarding the criteria, with 5
comments recommending that liquids and solids with low vapor pressures be
given lower priority and be removed from the list, 7 comments recommending
that the toxicity criteria be expanded, 5 comments that suggested that the
criteria are too conservative, and 4 comments that suggested that the
selection criteria should be the same as the criteria used to develop the
lists of chemicals-of-concern for the European Economic Community (EEC) and •
the World Bank (Exhibit 4, Sections IIIA and IIIB). Seven comments suggested
that the primary data source, the Registry of Toxic Effects of Chemical
Substances (RTECS) may be inaccurate (Exhibit 4, Section IV).
There were 11 chemical profiles that received specific comments concerning
the information provided in the profile: nickel, hydrogen peroxide, ethylene
oxide, chlorine, hydrogen sulfide, ammonia, sulfuric acid, sulfur dioxide,
sulfur trioxide, methyl trichlorosilane, dimethylchlorosilane, and
trimethylchlorosilane. There were 33 general comments made regarding the
profiles. Among the 32 comments that were placed in a miscellaneous category
concerned with the list, criteria, and profiles, two comments suggested that
the EPA list is too long and two comments suggested that the list of acutely
toxic chemicals be subjected to peer-review. It was also suggested that the
listing for metals indicate what form of the material is hazardous (4
comments) (Exhibit 4, Sections VA, VB, and VI).
Of the 12 comments concerning Chapter 3, Gathering and Analyzing Site-
Specific Information, of the guidance document, 3 comments suggested obtaining
information under OSHA's Hazard Communication Standard and other standards and
3 comments indicated that the guidance for site-specific planning is too
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-iii-
complex and technical for communities (Exhibit 4, Section VII). Twenty-one
comments were received concerning the Appendix D, Quantity Determination
Method of the guidance document. Nine comments suggested that the Quantity
Determination Method is too conservative, and 3 comments suggested that the
method is scientifically indefensible (Exhibit 4, Section VIII).
Four comments suggested that the CEPP be coordinated with the Federal
Emergency Management Agency (FEMA) (Exhibit 4, Section IX), 3 comments
suggested that the CEPP should address the prevention of accidental releases
(Exhibit 4, Section XI), and lastly, 6 comments indicated that local
communities do not have the resources to implement the CEPP (Exhibit 4
Section XII).
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LIST OF EXHIBITS
Exhibit
1. Categories of Comments Received and the Number of Comments
Tabulated on the Chemical Emergency Preparedness Program
(CEPP) Interim Guidance Document 1
2. Summary Tabulation of the Comments by Categories 2
3. Contents of Comment Log for the Chemical Emergency Preparedness
Program Interim Guidance 4
4. Summary of Comments by Category 11
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E*"'?1I .1-._?^TEGORIES OF COMMENTS RECEIVED AND THE NUMBER OF COMMENTS TABULATED
ON THE CHEMICAL EMERGENCY PREPAREDNESS PROGRAM tCEPP) INTERIM GUIDANCE DOCUMENT
Number of Number of
Categories Summary Comments Individual Comments
Comments on the List, the Criteria, and the Profiles
I. Suggested deletions from the list of acutely toxic chemicals 7 96
A. Deletions from Ijst based on toxicity data
B. Deletions from list based on physical/chemical or other criteria
II. Suggested additions to the list of acutely toxic chemicals 12 25
A. Additions to list of specific chemicals
B. Additions to list of categories of chemicals
III. Comments on criteria 23 UB
A. Physical/chemical properties
B. Other
IV. Comments on data sources t| 10
V. Comments on prof) les 33 j,5
A. Comments on specific profiles
B. General comments on profiles
VI. Miscellaneous comments on list, criteria, and profiles 26 32
Comments on Site-Specific Guidance
VII. Comments on Chapter 3, Gathering and Analyzing Site-Specific Information 8 12
VIM. Comments on Appendix D, Quantity Determination Method 8 21
Comments on Guidance
IX. Coordination g 1/4
X. Support for guidance 3 30
XI. Scope of guidance 12 19
XM. Resources for implementation 1 6
Total 1(«6 358
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2-
EXHIBIT 2. SUMMARY TABULATION OF THE COMMENTS BY CATEGORIES
Comment
Area
List,
Profi les.
Criteria
Site-
Spec i f i c
Guidance
Guidance
Category
IA
IB
1 IA
1 IB
1 1 IA
1 1 IB
IV
VA
VB
VI
VII
VII 1
IX
X
XI
XII
Number or
Letters
With
Description Comments
Deletions from list based on
toxic ity data
Deletions from list based on
physica l/chemlca 1 or other
criteria
Additions to list or specific
chemica Is
Additions to list or cate-
gories of chemicals
Comments on criteria:
physica 1 /chemica 1 properties
Comments on criteria: other
Comments on data sources
Comments on specific profiles
General comments on profiles
Miscellaneous comments on
list, criteria, and profiles
Comments on Chapter 3, Gathering
and Analyzing Site-Specific
Information
Comments on Appendix D, Quantity
Determination Method
Coordination
Support for guidance
Scope of guidance
Resources for implementation
21
11
6
2
8
11
9
6
11
16
10
12
9
29
11
6
Timel iness
T i me 1 y
19
9
6
2
7
12
7
1
11
13
9
9
6
20
8
3
Untimely Fed
5
2
1
2
2
2
3 1
3
1
3
3
9
3 1
3
Number of Letters with Comments
by Organization Type
State Local
1
1
1 1
1
1
3 1
1
1 1
1
1 1
3
5 2
7 5
5 2
1
Trade
1
2
1
2
3
3
1
3
1
1
2
Private Publ ic
19
8
2 1
1
5
6 1
5
5
6 1
7 1
2 1
8
2
11 1
2 1
1 1
Ind
1
1
1
Total number of letters a/
12
11
27
a/ Because some letters contain comments in several categories, the total number of letters in all categories is greater than
the number of letters received.
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-3-
EXHIBIT 2. _ SUMMARY TABULATION OF COMMENTS BY CATEGORIES
(Continued)
Term Used In Heading Meaning
n-i Comments received on or before March 17, 1986
Untimely Comments received after March 17, 1986
£et> Federal Government
State State Government
Local Local Government
Trade Trade Association
Private Private Industry
Publ«c Public Interest Group
lnd Unaffi Mated Individual
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EXHIBIT 3.
CHEMICAL EMERGENCY PREPAREDNESS PROGRAM INTERIM filimANrr
Log
Number
7 a/
9
10
11
12
13
15
16
17
18A
18B
18C
180
18E
18F
18G
18H
19
Comment
Number a/
1
1
See 18E
1
See 18H
1
1
See 18G
1
1
2
3
1
2
1
2
3
1
2
3
t|
5
6
7
8
9
1
1
1
2
3
U
1
2
3
M
1
2
3
1
2
Category
IA
IA
IA
IA
IA
X
VI
VB
VI 1
IX
XI
X
VI
II IB
VI 1
VI 1
VB
VB
VB
VB
VB
VB
VB
X
IX
X
X
IX
1 1 IB
1 IA
X
IX
IX
VB
VI 1
XI
VB
XI
VI 1
Type of
Organization
Trade
Private
Private
Private
Private
Loca 1
Individual
State
State
State
State
Loca 1
Loca 1
Loca 1
State
Loca 1
Timel iness
Status
Timely
T i me 1 y
Timely
Timely
Timely
Timely
Timely
T i me 1 y
T i me 1 y
Timely
Timely
T i me 1 y
Timely
Timely
Timely
Timely
Organization
American Wood Preservers Institute
Buckman Laboratories
International Minerals & Chemical Corporation
A.L. Laboratories, Inc.
ARCO Chemical Company
Office of Emergency Management, San Antonio,
Texas
Howard B. Brown, P.E.
Texas Department of Public Safety
Texas Air Control Board
Texas Department of Health
State Department of Highways and Public
Transportation (Texas)
Guadalupe County Emergency Management
(Texas)
City of Midland, Texas
Pampa Fire Department (Texas)
Texas Parks ft Wildlife Department
City of Lauderdale Lakes Fire Department
(Florida)
fi/ comments^contafried"?!! the^ocke number 8 are not included in this report because they are not written
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-5-
EXHIBIT 3. CONTENTS OF COMMENT LOG (Continued)
Log
Number
20
21
22
23
24
25
26
27
Comment
Number
1
3
4
5
6
7
8
9
10
11
12
13
14
15
1
2
3
4
1
1
2
3
4
5
6
7
8
9
10
11
12
13
1
2
3
4
5
6
7
8
9
1
1
1
2
3
4
5
Type of
Category Organization
X Pub 1 i c
XI
1 1 IB
XI
VB
XI
XI 1
1 1 IB
VI
MB
1 IA
MB
VI
VI 1
VB
X State
XI
XI 1
VI II
1 A P r i va te
X Private
VI 1
IV
II IB
IA
IA
VI 1 1
VI 1 1
VI II
1 1 IA
VB
VA
VB
IV Private
IA
IA
IA
IA
IB
IA
1 1 IA
IB
XI Federal
VB
IA Private
XI State
XI
IX
XI
VI 1
Timel iness
Status Organization
Timely Natural Resources Defense Council
Timely Natural Resources and Environmental
Protection Cabinet (Kentucky)
Timely Merck ft Co., Inc.
Timely Inco Limited
Timely Eastman Kodak Company
Timely EPA (Region 7)
Timely Sumitomo Chemical America Inc.
Timely State of Colorado
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-6-
EXHIBIT 3. CONTENTS OF COMMENT LOG (Continued)
Log
Number
27
(cont'd)
29
30
31
32
33
Comment
Number
6
7
8
9
10
11
12
13
m
15
16
17
18
19
20
21
22
23
2U
1
2
3
(|
5
6
7
1
1
2
3
I*
5
6
7
8
1
2
1
2
3
l»
5
6
7
8
Type of Time I iness
Category Organization Status Organization
VI
1 1 IB
VII 1
X
1 1 IA
VI
1 IB
1 IA
1 IB
IB
IB
IA
1 IB
IA
IB
1 IB
VB
VB
VI
X Private Timely FMC Corporation
VI
IB
VI
VB
IA
VA
IB Private Timely Lithium Corporation of America (subsidiary
of FMC Corporation)
X Private Timely The Hall Chemical Co.
1 IA
1 MB
VI
IA
IA
VI
VI
IA Private Timely Biosystems Incorporated
VI
X Private Timely Shell Oil Company
1 1 IB
VB
IV
VA
VA
VA
VB
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-7-
EXHIBIT 3. CONTENTS OF COMMENT LOG (Continued)
Log
Number
33
(cont'd)
31
35
36
37
38
39
10
11
Comment
Number
9
10
1
2
1
1
3
1
5
6
7
8
9
10
1
2
3
1
1
2
3
1
1
2
3
1
1
2
3
U
5
6
1
2
3
1
5
6
7
8
9
10
11
12
13
11
Type of
Category Organization
VI 1 1
VIII
X Private
VI 1 1
IA Private
X Private
1 IB
VI
1 1 IB
VI
1 1 IB
1 IA
IB
1 IB
VI 1 1
IV Trade
VI
IB
IB
IV Trade
IA
IA
IA
VA Trade
VA
VA
VA
VI Private
IB
1 MA
VI 1 1
VII
X
X Trade
1 IB
IA
IA
IA
IA
MB
1 IA
IA
VI
IA
VI
VI
VI
Timel iness
Status
Timely
Timely
T I me 1 y
Timely
Timely
Timely
Timely
Timely
Organization
Union Carbide Corporation
Johnson Mat they Inc.
Monsanto Company
National Agricultural Chemicals Association
Chemical Manufacturers Association
The Fertilizer Institute
AMAX Exploration and Technical Services
Nickel Producers Environmental Research
Association (NiPERA)
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-8-
EXHIBIT 3. CONTENTS OF COMMENT LOG (Continued)
Log
Number
42
43
44
45
46
47
Comment
Number
1
2
3
See 39
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
1
2
3
4
5
1
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Type or Timel iness
Category Organization Status Organization
VIII Private Timely Amoco Corporation
XI
IA
X Trade Timely Chemical Manufacturers Association
VI
IV
IA
IB
V
IA
IB
IB
VI 1 1
IB
VI 1
VI 1
VI 1
VI
VI 1
X State Timely Department of Natural Resources (Missouri)
XI 1
IX
IX
X
IA Trade Timely Ecological and Toxicologica 1 Association of
I'lB the Dyestuffs Manufacturing Industry
X Private Timely Union Pacific Railroad Company
1 1 IB
1 MA
VI
VI
1 1 IB
1 MB
1 MB
1 1 IB
VI
1 1 IA
1 1 IB
IB
VB
VB
1 1 IB
VI
IV
1 IA
IA
1 1 B
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-9-
EXHIBIT 3. CONTENTS OF COMMENT LOG (Continued)
Log
Number
U7
(cont'd)
U8
i»9
50
51
52
53
5U
55
56
57
Comment
Number
22
23
21
1
2
3
it
5
6
7
8
9
10
1
2
3
1
2
3
<4
5
6
7
See 35
1
1
2
3
1
2
3
1
5
1
2
3
it
5
6
7
See i«8
1
2
3
it
Category
VI
I MA
VI
IX
XI
IX
XII
IX
VI I 1
VI
XI
XI
VB
VB
VB
XI 1
IB
IA
IB
X
VI 1 1
VII 1
VIM
IV
IA
X
IB
IA
X
IX
VI
VI 1 1
VA
X
IX
IX
XI
XI
VB
XI
X
1 1 IB
1 MA
IA
Type of Timel iness
Organization Status Organization
*
State Not Timely Department for Environmental Protection
( Kentucky)
Private Not Timely Axcess Corporation
Private Not Timely Hoffman-LaRoche Inc.
Private Not Timely International Flavors and Fragrances
Private Not Timely The Shepherd Chemical Company
Private Not Timely General Electric
Private Not Timely Texaco
Private Not Timely Mobay Chemfca 1 Corporation
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-10-
EXHIBIT 3. CONTENTS OF COMMENT LOG (Continued)
Log
Number
58
58A
59
60
Comment
Number Category
1 X
3
it
5
6
7
8
9
10
11
12
'
IB
IB
IB
IB
IB
IB
IB
IB
f
IB
IB
1 X
2 VI 1
3 VI
U XI 1
1 X
2 XI
1 X
2 IA
3 VA
Type or Timel iness
Organization Status
State Not Timely Department or
Eng i nee ring
State Not Timely Department or
Engineering
Local Not Timely Department or
(City or New
Private Not Timely DuPont
Organization
Environmental Qua!
(Massachusetts)
Environmental Qua!
(Massachusetts)
ity
ity
Environmental Protection
York)
Term Used In Exhibit
Timely
Not Timely
Federal
State
Loca I
Trade
Private
Pub Iic
IndividuaI
Meaning
Comments received on or berore March 17, 1986
Comments received arter March 17, 1986
Federal Government
State Government
Local Government
Trade Association
Private Industry
Public Interest Group
Unaffi Mated Individual
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-1I-
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY
IA. Suggested Deletions from list based on toxicity data.
Number
Comment Comment
1. The following chemicals should be deleted
because their toxicity is too low to meet
EPA's criteria:
b/ Pentachloropheno 1
b/ Thiocyanic acid, (2-benzothiazolyl thio)
methyl
a±b/ Bacitracin
b/ Cyclopentane
a.b/ Indomethacin
a.b/ Nickel
a.b/ Coba 1 t
b/ Dimethyl phthalate
)/ Di butyl phthalate
)/ Butadiene
a.b/ Hydroquinone
b/ Fen it roth ion
b/ Ammonium chloroplat inate
b/ Platinous chloride
b/ Platinum tetrachloride
b/ 1 ridium tetrachloride
b/ Rhodium trichloride
b/ Di-n-octyl phthalate
b/ Pseudocumene
b/ C. 1 . Basic Green
b/ Phyl loquinone
b/ Butyl isovalerate
b/ Carvone
a/ Ergoca Iciferol
1
1
3
3
1
5
t|
2
2
1
1
1
1
1
1
1
1
1
1
2
2
1
1
1
of Log Number-
s Comment Number Fed
7-1
9-1
11-1,13-1,27-17
H4-1.U2-3, 147-20
22-1
23-U, 214-5, 31-8, U1-11,
53-3
23-6,2«4-5,31-5,53-3
214-2,38-2
2«4-3, 38-14
214-14
2U-7
26-1
35-1
35-1
*f S •
35-1
•J J \
35-1
& J 1
35-1
w J 1
38-3
<42-3
«46-1,57-«4
50-2,27-26
52-2
52-2
27-26
Number of Comments by Organization Tvoe
State Local Trade Private Public Ind
i
i
1 2
3
1
1 <4
14
1 1
1 1
1
1
1
1
1
1
1
1
1
1 1
1 1
1
1
2. Hydrogen peroxide should be deleted
or concentration should be specified
because only concentrated solutions
meet EPA's criteria.b/
29-6,32-1,60-2
3. 38 chemicals (see Attachment A) should be
deleted because no data are presented to
show whether they are air toxics.
27-19
Total Number of Comments for Category IA
-' o^vapor SrlSsSK'JStSSofy'lB?!' ChemicalS that Should be deleted because they are solid and have no appreciable volatility
b/ Data to justify statement are presented by some commenters.
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-iz-
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
IB. Suggested Deletions from list based on physical/chemicaI or other criteria
Comment
Number of
Comments
Log Number-
Comment Number
Number of Comments bv Organization Type
Fed StateLocalTradePrivatePublic Ind
1.
The following chemicals should be deleted
because they are solid and have no
appreciable volatility or vapor pressure:
Nickel
Coba It
Hydroquinone
Precious metal salts
Lithium hydride
Vanadium oxide
Bacitracin
Oigoxin
Amphetamine
Warfarin
Indomethacin
Ergocalei ferol
FluorouraciI
a.b/
a/
S/
a/
H 2i4-6,27-20,i4i4-11,53-2
14 2ii-6,27-20,i4i4-11,53-2
24-9
27-29
30-1
140-2
147-13
l»7-13
147-13
147-13
50-1
50-3
2. The following chemicals should be deleted
because they are solid, haye no appre-
ciable volatility or vapor pressure, and
are low volume chemicals:
Cantharidin
Ouaba in
Muse i mo 1
Picrotoxin
Lithium hydride
Aluminum phosphide
Aminopterin
Antimycln-A
Antu
Arsenic compounds
Chlorophacinone
Coumatetra lyl
C r i m i d i ne
Diphacinone
Bromadiolone
Fluoroacetamide
Fluoroacetlc acid
Sodium f luoroacetate
Methiocarb
Norbormide
Phosacetim
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
27-16
27-16
27-16
27-16
30-1
37-<4
37-4
37-H
37-<4
37-U
37-14
37-14
37-14
37-li
37-14
37-li
J I *t
37-i»
37-14
37-U
37-ii
*f t T
37-14
1
1
1
1
1
1
?XtegoryaiA°.aPPearS °" "8t °f chemicals that shou|d ">e deleted because their toxicity is too low to meet EPA's criteria
b/ Data to justify statement are presented by some commenters.
-------
-U-
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
IB. Deletions from list based on physicsl/chemicaI or other criteria (continued)
Comment
Number or
Comments
Log Number-
Comment Number
Number of Comments by Organization Type
Fed State Local Trade Private Public Ind
(continued)
Py r i m i n i 1
Strychnine
Strychnine sulfate
Warfarin
Warfarin sodium
Zinc phosphide
Coumafuryl 1
Pyridine, U-amino 1
Tha 1 lous sul rate
37-U
37-H
37-«t
37-«4
37-«t
37-H
37-l|
37-
-------
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
IA. Additions to list of specific chemicals
Comment
1. The following chemicals should be
included on the acutely toxic list
rather than the list of other chemicals:
Hydrogen sulfide
Phosgene
Number of
Comments
1
1
Log Number-
Comment Number
18F-U
«»7-20
Number of Comments by Organization Tvoe
Fed State Local Trade Private Public Ind
1
1
2. Aldicarb oxime should be added to the 1 20-11
list because it is known to cause health
problems as a result of accidents.
3. Methylene chloride should be added 1 20-11
because it is a probable carcinogen.
U. i|i| chemicals (see Attachment C) should 1 27-13
be added to the list because they can
be air toxics.
5. The following chemicals should be added
to the list because they have known
chronic and possibly toxic effects:
Dioxin ;
Tetrachloroethane ;
Carbon tetrachloride ;
Carbon monoxide ;
Chlorine dioxide
Arsenic
Cadmium
Lead
Mercury
' 31~2'l1""3 1 1
> 31-2!«»1-6 1 1
J 31-2,l|1-6 1 1
'. 31-2.U1-U 1 1
H1-9 1
1*1-9 i
U1-9 1
Total Number of Comments for Category IIA 18
-------
15-
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
I IB. Additions to list of categories of chemicals
Number of Log Number- Number of Comments by Organization Type
Comment Comments Comment Number Fed State Local Trade Private Public Ind
1. Neurptoxic chemicals, teratogens, 1 20-10 1
carcinogens, and mutagens should be
included on the list.
2. Chemicals used solely as drugs and 1 20-12 1
cosmetics and radioactive chemicals
should not be excluded from the list.
3. 38 functional groups (see Attachment D) 1 27-12 1
should be included on the list; any
chemical whose name includes one of
these groups would be identified as an
a i r tox i c.
U. A more comprehensive listing of pesti- 1 27-14 1
cides, such as that found in the Farm
Chemicals Handbook, should be included.
5. 23 chemicals or chemical groups (see 1 27-18 1
Attachment E) should be added to the
list because they are flammable and
of particular interest to fire
officials.
6. There should be a listing for cadmium 1 27-21 1
compounds, N.O.S., and similar listings
for mercury and arsenic compounds.
7. The names of metallic compounds should be 1 27-21 1
rewritten as shown in Attachment F.
Total Number of Comments for Category MB 7
-------
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
IA. Comments on criteria: physical/chemicaI properties
Number of
Comment Comments
Log Number-
Comment Number
Number of Comments by Oraanization Tvoe
Fed State Local Trade Private Public Ind
Physical/chemicaI properties should be 1 2U-8
considered more important than produc-
tion capacity for identifying risk from
"other chemicals."
Criteria should address chemicals that 2 27-10 iiU-
cause a disruption of normal activities.
These criteria should include, for example
an overpowering odor, a choking sensation,
burning of the eyes, and nauseation.
3. Low vapor pressure liquids and solids 5 35-7 UO-3 U7-3 U7-11
should be given lower priority or 57-3
removed from the list.
Chemical substances should be evaluated 1 i|1-8
based on their chemical properties,
concentrations, exposure times, and
other factors encountered in accidental
releases.
5. Criteria should include vapor density, i ii«»-7
molecular weight, specific heat ratios,
and the potential for dermal absorption.
Numerous solids are included that in i U7-23
practical terms have no significant
potential for harm if released into
the air (e.g., calcium arsenate, cobalt,
and nickel).
Total Number of Comments for Category 11IA 11
-------
-17-
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
11 IB. Comments on criteria: other
Comment
1. The criteria should be expanded.
Number or Log Number- Number of Comments by Organization Tvoe
Comments Comment Number Fed State Local
7 20-3,«4l-7,«t'»-9,U7-2 3
58-2,58-11,58-11
Trade Private Public Ind
2 1 1
2. The criteria for inhalation should be
expressed in ppm rather than mg/L, and
atmospheric conditions should be
specified.
18F-3
3.
4.
5.
6.
7.
8.
9.
10.
11.
The criteria should include health effects 2
surrogates other than LD50s.
The DOT criteria should be used as the 2
basic criteria unless the literature
suggests acute toxic ity.
The criteria should be the same for toxic 2
chemicals and "other chemicals."
The criteria should be the same as those 1
used by the EEC and World Bank.
The criteria should generate a list of 2
chemicals that is manageable.
The criteria are too conservative. 5
Exposure potential should be considered, 1
as well as acute lethality.
The route of exposure should be considered. 3
Duration of exposure should be considered 2
20-8,58-8 1 1
23-1,17-21 2
27-7,17-7 1 1
31-3,33-2,36-6,11-2 1 3
18B-3, 36-2 1
36-9,11-8,16-2, 1 2 2
17-16,58-3
47-6 1
17-8,57-2,58-9 1 2
17-9,58-6 1 1
in evaluating inhalation data.
-------
-18-
EXHIBIT *»• SUMMARY OF COMMENTS BY CATEGORY 'Continued)
I IB. Comments on criteria: other (continued)
12. The listings based on LDLO should be
reevaluated.
Hi. The criteria are not universally
applicable.
17. Criteria for high hazard materials
should include gases, high acute
toxicity, and serious fire or explosion
hazard.
Total Number of Comments for Category 1MB 37
13. Extrapolation of toxicologica I data from 1 53-7
animal species to humans should be con-
sidered when calculating LD50.
15. The criteria used to generate the 1 1*7-12
list should exclude commonly used drugs
16. LC50 and dermal LD50 data should have i u«i-5
priority over oral LD50.
"as
-------
-19-
EXHIBIT It. SUMMARY OF COMMENTS BY CATEGORY (Continued)
IV. Comments on data sources
1. RTECS may be inaccurate; original
should be used for
Total Number of Comments for Category IV 10
2. RTECS does not include data that indi- i 37-1
cate possible risk to the public of
exposure to a chemical.
3. Updated versions of references should be 1 33-11
used consistently in preparing profiles.
l|. LC50 data from old studies can understate 1 tiU-6
the toxicity of a chemical.
-------
-2u-
EXHIBIT It. SUMMARY OF COMMENTS BY CATEGORY (Continued)
VA. Comments on specific profiles
c Number of Log Number- Number of Comments by Organization Type
Comment Comments Comment Number Fid state Local Trade Private—Public Ind
1. The following comments were made about
the nickel profile:
o The synonym list should be revised 1 23-12 i
because it includes names of
materials that are only partly nickel
and obsolete names;
o The ACGIH TLV is 1 mg Ni/m3; the oral
LDLO given is in error;b/
o The "Fire and Explosion Hazard Data"
and "Reactivity Data" sections are
misleading because they include
hazards of nickel alloys and
catalysts;b/
o The "Health Hazard Data" section
should be modified and the statement
about the carcinogenic)ty of nickel
should be weakened;b/
o The "Signs and Symptoms of Exposure"
appear to be more applicable to
nickel carbonyl than to nickel;
o The "Medical Conditions Generally
Aggravated by Exposure" should
include a warning for people with
allergic skin problems;
o The "Emergency and First Aid Procte-
dures" section exaggerates possible
health hazards;
o The "Precautions for Safe Handling
and Use" section should not mention
liquids containing nickel..."
2. The following comments were made about
the hydrogen peroxide profile:
o The IDLH level given is questionable; 1 29-10 1
b/ Data to Justify statement are presented by commenter.
-------
-21-
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
VA. Comments on specific profiles (continued)
r«mm«»» Number of Log Number- Number of Comments by Organization Type
Comment Comments Comment Number Fed State Local Trade Private Pub I!c Ind
o The statement that inhalation of 7 ppm
hydrogen peroxide causes lung Irrita-
tion is questionable;!)/
o OSHA PEL and ACGIH TLV are for 90% 1 29-7 i
hydrogen peroxide and do not apply
to lower concentrations; ACGIH STEL
has been deleted from the 1985-86
TLVs;b/
o OSHA PEL and ACGIH TLV should be 1.U 1 60-3 1
mg/m3, not 1.5 mg/m3;
o The synonym list should include either
all or none of the trade names;
o Boiling point, specific gravity,
vapor pressure, melting point,
vapor density, and evaporation rate
are provided;!)/
o Odor should be described as slightly
pungent, irritating;b/
o Hydrogen peroxide will not burn;b/
o Commercially available hydrogen
peroxide is not explosive;
o A catalyst is required for decompo-
sition of hydrogen peroxide;
o The statement that hydrogen peroxide
decomposes in water is incorrect;
o Solutions less than 27.5% can cause
eye injury.
3. The following comments were made about
the Ethylene oxide profile:
o OSHA PEL should be 1 ppm; 1 33-5 1
o The NIOSH recommendations listed are
out of date.
b/ Data to justify statement are presented by commenter.
-------
EXHIBIT *»• SUMMARY OF COMMENTS BY CATEGORY (Continued)
VA. Comments on specific profiles (continued)
Number of
Comment Comments
Log Number-
Comment Number
Number of Comments by Organization TVDB
tea state Local Trade Private Public Ind
U. The following comment was made about the
Chlorine prof!le:
o OSHA PEL should be 1 ppm ceiling; 0.5 1 33-6
ppm/15 minutes is a NIOSH recommda-
tion and should be under "Other Limits
Recommended."
5. The following comments were made about
the hydrogen sulfide profile:
o The entry for OSHA Peak should note 1 33-7
that the value given is for one
exposure per day;
o The entry for "Other Limits" should
note that the value given is a NIOSH
recommendation for a 10-minute sample
time.
6. The following comments were made about
the Ammonia profile:
o The "Conditions to Avoid" entry is 1 39-1
too broad and should be rewritten;
o Copper and copper alloys should be
included under "Incompatibility"^/
o Acid vapors are included under
"Incompatibility," but the incom-
patibility results from the
neutralization of ammonia vapor to
form salts;
o The "Emergency and First Aid Procedures"
section should specify flushing with
water first because exposure to liquid
ammonia cou|d result in the victim's
clothing being frozen to the skin.b/
b/ Data to justify statement are presented by commenter.
-------
EXHIBIT It. SUMMARY OF COMMENTS BY CATEGORY (Continued)
VA. Comments on specific profiles (continued)
Number of Log Number- Number of Comments by Organization Type
Comment Comments Comment Number Fed State Local Trade Private Public Ind
7. The following comments were made about the
suIfuric acid profile:
o The "Conditions to Avoid" entry is too 1 39-2 1
vague;
o The "incompatibility" entry is too
brief; cautions about not adding water
to acid should be included.
8. The following comment was made about the
sulfur dioxide profile:
o Ammonia should not be listed under l 39-3 1
"Incompatibility"; ammonia is used
for the neutralization of sulfur
oxides.
9. The following comment was made about
the sulfur trioxide profile:
o Water should not be listed under 1 39-<« 1
"IncompatibiIity."
10. The following comment was made about
the methyltrichlorosilane, dimethyl-
dfchlorosilane, and trimethy I-
chlorosilane profiles:
o It is unlikely that phosgene is 1 54-5 1
formed In the burning of methy I-
chlorosllanes, as stated in the
profiles.b/
Total Number of Comments for Category VA 12
b/ Data to justify statement are presented by commenter.
-------
-2U-
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
VB. General comments on profiles
1.
2.
3.
"'
5.
6.
7.
Comment
MSOSs should be used to provide infor-
mation on the listed chemicals.
The profiles should contain information
about acute toxicity to fish and wi Id-
1 ife.
Chronic health hazards are not addressed
in the profiles, and medical infor-
mation is very brief.
The profile title should be changed,
e.g., to "EPA Chemical Profile for
Emergency Response Personnel."
An emergency phone number should be
1 isted.
The DOT commodity code number should be
listed.
The following comments apply to Section 1
of the profiles, "Hazardous Ingredients/
Identity Information":
o The heading is misleading;
o There should be a subheading for
Number of Log Number- Number of Comments by Organization Tvoe
Comments Comment Number Fed State Local Trade Private Public Ind
3 17-2,33-3,55-6 2 1
1 18H-3 1
1 18C-3 1
1 18C-U i
1 18C-5 1
1 18C-5 1
1 18C-6 1
1 18C-6 1
occupational exposure limits for
contaminants in air;
Occupational exposure limits may not 2 18C-6,<«7-1U 1 1
be helpful;
Acute lethality data should be 2 18C-6,47-15 1 1
included;
Section I should be revised and placed 1 18C-6 1
at the end of the profile.
-------
-25-
EXHIBIT b. SUMMARY OF COMMENTS BY CATEGORY (Continued)
VB. General comments on profiles (continued)
Comment
Number of
Comments
Log Number-
Comment Number
Number of Comments by Organization Type
Fed State Local Trade Private Public Ind
8. Section III, "Fire and Explosion Hazard
Data," should not contain nonspecific
information.
18C-7
9. The following comments apply to
Section V. "Health Hazard Data":
o This section should be near the start
of the profile;
o Delayed or chronic effects of
chemicals should be noted;
o Data on warning properties should be
included.
18C-8
10. The following comments apply to
Section VIII, "Precautions for Safe
Hand I ing and Use":
o The title should be changed to show
that the section deals with spill
cleanup precautions;
o More evacuation information should
be IncIuded.
18C-8
18C-9
11. The commenter learned of the availabil-
ity of the profiles from the Interim
Guidance document and is ordering them.
18G-U
12. Emergency medical advice often merely
suggests moving victims to fresh air and
staying upwind.
20-5
13. Evidence of carcfnogenesis and muta-
genesis should be noted in the profiles.
20-15,19-1
14. The profiles should be carefully
rev i ewed.
23-11
-------
-2o-
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
VB. General comments on proMles (continued)
Comment r!!!I!mfLcr nL°9 NumSer: Number or Comments bv Organization Type
loniment Comments Comment Number FedState LocTiTrade Private—Public Ind
15. The health hazards and signs and symptoms 1 23-13 i
should be directly linked to the routes
of entry.
16. An alphabetical index should be included 1 25-2 1
with the profiles.
17. The names of 23 chemicals (see Attachment 1 27-22 1
G) are not included in the alphabetical
11st ing.
18. CrotonaIdehyde and thallous sulfate are 1 27-23 1
listed with two CAS numbers.
19. Health hazard data were not scientifically 1 29-5 ,
documented. '
20. The term "TWA" is used inconsistently; 1 33-3 1
the word "air" is unnecessary. '
21. The sources of recommendations for "Other 1 33-8 1
Limits Recommended" should be clearly noted.
22. The chemical profiles should be made 1
-------
-27-
EXHIBIT tt. SUMMARY OF COMMENTS BY CATEGORY (Continued)
VI. Miscellaneous comments on list, criteria, and profiles
Comment
1. Plant hazard communication programs under
OSHA would include a listing or all
chemicals of concern to EPA.
2. The EPA list is too long.
The criteria do not take into account
the fact that accidental releases of
chemicals can result in subacute and
chronic health effects and, because of
persistence or bioaccumulation, may
cause chronic exposures.
Number of
Comments
Log Number-
Comment Number
t|. EPA should make available information on
sources of chemicals and history of
environmental releases; EPA should collect
such data if necessary.
17-1
18B-2.36-3
20-9
20-13
Number of Comments by Organization Type
Fed StateLocalTradePrivatePublic Ind
5. More emphasis should be given to the
profiles in Chapter 6 of the Interim
Guidance document.
27-6
6. There are inconsistencies between the
alphabetical listing of chemicals and
the listing by CAS number.
27-11
7. Identification of acutely toxic chemicals 1
should be a group effort including chemists
from the public and private sectors.
27-2U
8. Including hydrogen peroxide on the list
would impose unnecessary regulatory costs
on producers, users, and communities.
29-2
9. 90% hydrogen peroxide is no longer pro-
duced in the U.S.b/
29-U
b/ Data to justify statement are presented by commentsr.
-------
-2o-
EXHIBIT I*. SUMMARY OF COMMENTS BY CATEGORY (Continued)
VI. Miscellaneous comments on list, criteria, and profiles (continued)
Comment rJZ!;!oL0r oL°9 Num5er: _ Number of Comments bv Organization Type
uomment Comments Comment Number Fid state Local Trade Privae —
state Local Trade Private — Public ind
10. There should be clarification of the U 23-10 31-U UO-1 U1-10
listings for metals to show what form of '
the material is hazardous.
11. The list is misleading because of the 1 31-7
different hazard levels of the chemicals
on the Iist.
12. Acute toxicity data for a number of nickel 2 31-8 41-13
and cobalt compounds are presented by the
commenter.
13. The Department of Transportation does not 1 32-2
require the labeling of hydrogen peroxide
of concentration less than 52%.
1U. A safety program covering all the chem- 1 36-5
icals on the EPA list would be extremely
difficult and costly to implement.
15. 150 agricultural chemicals are on the 1 37-2
EPA list; 72 are produced in the U.S.
or imported.
16. The inclusion of nickel carbonyl on the 1 U1-12
Iist is appropriate.
17. The acutely toxic chemicals list should be 2 U1-1U UU-2
subjected to independent peer review. '
18. Exposure circumstances and different risks 1 U7-U
to different populations should be con-
sidered.
-------
-29-
EXHIBIT *»• SUMMARY OF COMMENTS BY CATEGORY (Continued)
VI. Miscellaneous comments on list, criteria, and profiles (continued)
Comment
Number of
Comments
Log Number-
Comment Number
19. Chemicals on the list should be ranked
by degree of risk or a measure or
relative risk should be included.
«l7-5
20. If chemicals on the list react with air
or water to form other materials, the
lethality of the reaction products should
be considered.
«47-10
21. Consistency of EPA's criteria with the
European Economic Community/World Bank
criteria should be documented.
i»7-17
The listing of acutely toxic chemicals
should include the name of the chemical,
concentration, volume, and physical state
that are of public concern.
i»a-7
Number of Comments by Organization Type
State Local Trade Private Pub Iic Ind
22.
23.
The list should be substantially revised. 1 (17-22
Hydrogen chloride gas (not on the list) 1 i47-2«i
is a greater hazard than hydrochloric
acid.
1
1
25. The list of chemicals should not be so
large as to be unmanageable, but
chemicals that could cause an emergency
should not be missed.
5U-3
26. The list overemphasizes acutely toxic
chemicals and catastrophic incidents
and does not consider chronic effects.
58A-3
Total Number of Comments for Category VI
32
-------
-30-
EXHIBIT t>. SUMMARY OF COMMENTS BY CATEGORY (Continued)
VII. Comments on Chapter 3, Gathering and Analyzing Site-Specific Information
Comment
Number of
Comments
Log Number-
Comment Number
Number of Comments by Organization Type
Fed State Local Trade Private Public Ind
1. Chapter 3 should discuss the possibility
of obtaining information under OSHA's
Hazard Communication Standard and other
federal regulations.
17-3.18C-2.27-5
2. Guidance for site-specific planning is
too complex and technical for communi-
ties.
18C-1.23-2,i»0-5
Add "environmentally sensitive" to the
list of factors considered when evalu-
ating the potential risk and corres-
ponding need for a contingency plan for
a particular site.
18H-1
<4. Develop an instant retrieval method to
obtarn critical data on chemicals for
on-site emergency response.
19-2
Guidance should be given to help citizens
and local officials obtain information
on the location of sources of hazards
and the history of environmental releases.
20-11
6. Guidance should discuss the details of
state programs.
27-5
7. Guidance should not suggest a uniform
method for hazard identification and
response plans.
UU-15
8. Guidance should emphasize the responsi-
bilities of companies that use. process
or store hazardous substances.
58A-2
Total Number of Comments for Category VI
12
-------
-3
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
VIM. Comments on Appendix 0, Quantity Determination Method
Number or Log Number- Number of Comments by Organization Type
Comment Comments Comment Number FedStateLocalTrade PrivatePublic Ind
1. The Dispersion Model is not useful and 2 21-4,33-10 1 1
is inaccurate.
2. The Quantity Determination Method sped- 2 23-7,44-12 1 i
fies an incorrect factor of 213 for
converting LD50 to inhalation dose.
3. The quantity Determination Method is too 9 23-8,36-11,40-4 42-1 1 2 6
conservative. 44-10,44-14,48-6,50-5
54-4
4. The dispersion model should take into 1 23-9 i
account source elevation.
5. Appendix D is too technical and complex. 1 27-8 1
6. The Quantity Determination Method is 3 33-19,34-2,44-13 1 2
scientifically indefensible.
7. A more detailed hazard evaluation should 2 44-16,50-6 1 1
be performed, taking into account
important factors governing releases
(for example, volatility, physical state).
8. For liquids an evaporative spill model 1 50-7 1
("Evaporation and Dispersion of
Hazardous Materials" prepared by
Charles Springer for the U.S. Department
of Air Force Office of Scientific
Research) should be used to estimate the
downwind level of concern. A puff type
model should be used to evaluate the
level of concern for solids.
Total Number of Comments for Category VIII 21
-------
-32-
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
IX. Coordination
Number of Log Number- Number of Comments bv Organization Type
Comments Comment Number Fed State Local—Trade Private Public Ind.
1. Coordinate with the Federal Emergency 14 18A-1.18G-3 27-3 U8-1 3 1
Management Agency (FEMA) so that efforts
are not duplicated.
2. Coordinate with private industry so that 2 54-2 55-3 y
industrial experts can inform communities
on emergency preparedness and prevention.
3. Specifically define state, local, 2 48-5 55-2 1 i
and federal roles in the guidance.
i*. Interstate coordination is necessary 1 U8-3 1
for the development of emergency
plans.
5. The final document should not only 1 <45-(| 1
be djstributed to the mayor and
presiding commissioner, but to many
local officials.
6.
7.
CEPP and other EPA programs regarding 1 U5-3
hazardous substance safety should be
comb i ned .
Coordinate with cities so that efforts 1 18G-3
are not dupl icated.
1
1
Emphasis should be placed on the use 1 18F-2
of the 1984 Emergency Response
Guidebook and UN ID number as the
guide for the first action by
responders.
9. CEPP adequately addresses coordination 1 18D-2
between state and local agencies that
a re i nvoIved i n deveI op i ng I oca I
contingency plans.
Total Number of Comments for Category IX 14
-------
-33-
EXHIBIT <4. SUMMARY OF COMMENTS BV CATEGORY (Continued)
X. Support for Guidance
Comment
1. Guidance provided by the EPA interim
document is very helpful.
2. CEPP goals, which are in line with
Community Awareness Emergency Response
(CAER) program, are supported.
3. The voluntary nature of the program
Is supported by local officials and
industry representatives.
Total Number of Comments for Category X
Number of
Comments
Log Number-
Comment Number
23
30
Number of Comments by Organization Type
Fed StateLocalTradePrivatePublic Ind.
16-1,188-1,180-1,
20-1,21-1,23-1,27-9,
29-1, 31-1, 36-1, «40-6,
11-1, 15-1, H7-1.50-U,
51-1, 55-1, 58-1.58A-1,
59-1
33-1,3H-1.UU-1,53-1
57-1,60-1
15-5
-------
-34-
EXHIBIT 4. SUMMARY OF COMMENTS BY CATEGORY (Continued)
XI. Scope of Guidance
Number of Log Number- Number of Comments by Organization Type
Comment Comments Comment Number FedStateLocalTrade PrivatePublic Ind.
1. The CEPP should address the preven- 3 20-2,21-2 59-2 11 i
tion of accidental releases.
2. The gujdance should include trans- 2 42-2,48-8 1 1
portation and/or storage of hazardous
chemicals.
3. The guidance does not accurately 2 20-4,27-4 1 i
portray the magnitude of the acci-
dental release problem.
4. The guidance should be presented in 2 18A-2.27-2 2
a manner that will incorporate hazard
planning into existing multi-emergency
contingency plans.
5. Any contractual agreements placed in 1 55-4 1
the contingency plan should be
subjected to appropriate legal review.
6. Post-accident investigations should be 1 55-7 i
performed by someone with legal
authority and not be a voluntary
process.
7. There should be more guidance for state 1 48-2 1
and local governments to identify
communities that should prepare chemical
emergency preparedness plans. Users,
transporters, and storage facilities
of the listed chemicals should also be
identified.
8. The guidance should consider the 1 18H-2 1
environmental effects of chemical
releases on fish and wildlife.
-------
-35-
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
XI. Scope of Guidance (continued)
Number of Log Number- Number or Comments by Organization Type
Comment Comments Comment Number FedStateLocalTrade PrivatePublic Ind.
9. The guidance on restoration of an area, 1 55-5 1
which may be a long-term project,
is not directly related to responding
to the emergency and therefore
should not be included in CEPP.
10. CEPP cannot be accomplished as a 1 20-9 i
voluntary program.
11. This emergency service management 1 19-1 1
report is not needed and will not be
hejpful. A report providing appro-
priate actions to perform for an
emergency situation is necessary.
12. Address for the Region VII contact 1 25-1 1
should be corrected.
13. EPA should concentrate on developing 1 i»8-9 1
training programs for first response
personnel and should provide these
programs within local communities.
1U. It is inappropriate to expect local 1 27-1 1
communities to develop a separate
emergency response plan for acutely
toxic chemicals.
Total Number of Comments for Category XI 19
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-36-
EXHIBIT U. SUMMARY OF COMMENTS BY CATEGORY (Continued)
XII. Resources for Implementation
Comment
Number or
Comments
Log Number-
Comment Number
Number of Comments by Organization Type
Fed State Local Trade Private Public Ind.
1. Local communities do not have the
resources to implement chemical
emergency programs.
20-7,21-3, l»5-2,l»8-«»
19-3.58A-I4
Total Number or Comments for Category XI
Term Used In Heading
Fed
State
Loca I
Trade
Private
Pub Iic
Ind
Meaning
Federal Government
State Government
Local Government
Trade Association
Private Industry
Public Interest Group
Unaffiliated Individual
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ATTACHMENT A
The State of Colorado (log number 27, comment 19) suggests that the
following 38 chemicals should be deleted from the list because no data are
presented to show whether they are air toxics.
Orotic add
Oxetane, 3,3-Bisfchloromethyl)-
Benzen? 1-Chiorothy1)-4-N1tro-
Butyl Isovalerate
Sod1urn anthraqulnone-1-sulfonate
Methanesulfonyl fl uorlde
Thlourea, (2-MethylphenyD-
Chloroethyl chloroformate
Cyanurlc fluoride
Methacryllc anhydride
Acrylyl chloride
Trlmethylolpropane phosphite
Methacryloyl chloride
Trlethoxysllane
Trimethyl tin chloride
Nltrocyclohexane
Pyrldlne, 4-Nitro. 1-Oxide
Propylene glycol, allyl ether
Trlchloro (chloromethyl)s1lane
Ethanesulfonyl chloride, 2-Chloro
Acetone Th1osem1carb1z1de
Phenylsllatrane
Phosphonothlolc acid, methyl-
0-(4-N1trophenyl) 0-Phenyl ester
Phosphonothlolc add, methyl-, 0-ethyl
0-(4[Methylth1o]Phenyl) ester
Silane, (4-Am1nobutyl)01ethoxymethyl-
Vlnylnorbomene
Sulfoxide, 3-Chloropropyl Octyl
Bltoscanate
Phosacetlm
Phenol, 2,2'-Th1ob1s (4-Chloro-6-Methyl)-
Hexamethylenedlcamlne, N, N'-D1butyl-
Methacroleln D1acetate
Salconrfne
Formparanate
Xylylene D1 chloride
Hethacryloyloxyethyl Isocyanate
Z1nc, D1chloro (4,4-D1methyl-5((((Methylam1no)
Carbonyl)Oxy)Im1no)Pentanen1tr1le)-, (T-4)-
Cobalt, (2,2'-(l,2-Ethaned1ylb1s
(N1trl1omethyl1dyne)B1s(6-F1uorophenolato))
(2-)-N,N'J0,0')-SP-4-2)
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ATTACHMENT Bl
The State of Colorado (log number 27, comment 13) suggests that the
following 42 pesticide chemicals be deleted from the list because they are not
registered for use nor manufactured in the United States.
•"rfnopterln
Physost1gm1ne
rtiysost1gm1ne, sallcylate (1:1)
Thlosenricarbazlde
Propargyl bromide
TEPP
Dime fox
Isopropylmethyl pyrazolyl dimethylcarbamate
D1phosphoramlde, octamethyl-
Isobenzan
Thionazln
Mexacarbate
Trlchloronate
Ethyl ene fluorohydrln
Isodrln
Dlthlazanlne Iodide
Cr1m1d1ne
letraethyltln
Tr1phenylt1n chloride -
Dlmetllan
Demeton-s-methyl
Mephosfolan
Trlamlphos
Metocarb
Vallnomycln
Dimethyl phosphorochlorldothloate
Promecarb
Cyanophos
Endothlon
Methyl phenkapton
Fuberldazole
Fluentetn
Piprotal
Thlourea. (2-Chlorophenyl)-
B1cyc1o[2.2.l3Heptane-2-Carbon1tr11e,
5-Chloro-6-((((Methyl amino)Carbony1)Oxy-Im1no)-,
(1S-(1 Alpha. 2 Beta. 4 Alpha, 5 Alpha. 6E)).
Fosthletan
Leptophos
Chlorthlophos
Trlazofos
Chlormephos
Carbamlc Acid, Methyl-. 0-(((2.4-D1methyl-1,
3-D1th1olan-2-yl)Methy!ene)Amino)-
Pyrlmlnll
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ATTACHMENT B2
The National Agricultural Chemicals Association (log number 37, comment 3)
suggests that the following 43 pesticides should be deleted from the list
because they are not produced nor used in the U.S. and are not registered for
use as pesticides.
Q?f™c°2?cOL PRODUCTS "HOSE PRODUCTION IN THE UNITED
STATES HAS BEEN TERMINATED AND EPA HBCISTRASoS
DEMETON: "Systox" CAS. 8065-48-3
«™srffius3«^^
Contact: Ciba-Geigy Corp., Agr! Div
. DIPHOSPHORAMIDE, OCTAMETHYLr "OMP^ (Sol. canceled 1976,
ENDOTHION: *CAS. 2778-04-3
Contact: American Cyanamid
ENDRIN: Registration canceled 8/14/84. CAS. 72-20-8
Contact: Velsicol Chemical Corporation
POSTHIETAN: "Nem-a-tak" CAS . 21548-32-3
Contact: American Cyanamid
PHENOI,2,2'-THIOBIS(4-CHLORO-6-MErHn.): canceled 11/30/70
Contact: American Cyanamid
PYRIMINIL: "Vacor" (Cancelled 10/26/79) CAS. 53538-25-1
Contact: Rohm & Haas Company
THIONAZIN: "Zinophos" CAS. 297-97-2
Tt,«m«« Contact: American Cyanamid.
LEPTOPHOS: "Phosvel" CAS. 21609-90-5
Never registered for use in U.S. no longer produced
for export. Contact: Velsicol Chemical Corp?
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ATTACHMENT B2 (Continued)
PEST CONTROL PRODUCTS REMOVED FROM MARKETING IN THE
UNITED STATES THRU EPA REGISTRATION CANCELLATION
CARBOPHENOTHION: "Trithion" CAS. 786-19-6
Contact: Stauffer Chemical Company.
PHOSPHAMIDON: "Dimecron" CAS. 13171-21-6
Contact: Chevron Chem. Co., Ortho Agr. Chem Div
ACRYLONITRILE: "Acritet" CAS. 107-13-1
Contact: Stauffer Chemical Company.
TEPP: "Vapotone" CAS. 107-49-3
Contact: Chevron Chem. Co., Ortho Agr. Chem Div
ETHYL MECURIC PHOSPHATE: CAS. 2235-25-8
Contact: E.I. DuPont, Agricultural Chem. Div
METHYLMERCURIC DICYANAMIDE: CAS. 502-39-6'
Contact: Nor-Am Chemical Company
RESEARCH CHEMICALS THAT WERE NEVER COMMERCIALIZED.
AMINOPTERIN: CAS. 54-62-6
Contact: Union Carbide Agricultural Products
METHYL PHENKAPTON: CAS. 3735-23-7 Products
Contact: Ciba-Geigy Chem. Corp..
PHOSPHONOTHIOIC ACID MEr!?L-,0- (*-»I&
-,- -,-**nm. ESTER
t-ft.5. 2665-30-7: Contact: Monsanto Aar Prod Co
SSf" SSC
Contact: Monsanto Agr. Products Co.
CONTACT: 3M Company
PHENOL,3-(1-METHYLETHYL)-,METHYLCARBAMATE. CAS. 64-00-6
CONTACT: Union Carbide Agricultural Products Co.
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ATTACHMENT B2 (Continued)
PEST CONTROL PRODUCTS THAT ARE PRODUCED OVERSEAS, BUT
NOT REGISTERED FOR MARKETING IN THE UNITED STATES.
CHLORMEPHOS: "Dotan" CAS. 24934-91-6
Contact: Rhone-Poulenc, Inc.,Agrochemical Div.
COUMATETRALYL: "Racumin" CAS. 5836-29-3
Contact: Mobay Chen. Corp., Agr. Chem. Div.
CRIMIDINE: "Castrix" CAS. 535-89-7
Contact: Mobay Chem. Corp., Agr. Chem. Div.
DINOTERB: CAS. 1420-07-1
Contact: Rhone-Poulenc Inc., Agrochemical Div.
FORMOTHION: CAS. 2540-82-1
Contact: Sandoz Ltd.,Agro Division
FUBERIDAZOLE: "Neo-Voronit" CAS. 3878-19-1
Contact: Mobay Chem. Corp., Agr. Chem. Div.
ISOBENZAN: "Telodrin" CAS. 297-78-9
Contact: Shell Chemical Company.
MEPHOSFOLAN: "Cytrolane" CAS. 950-10-7
Contact: American Cyanamid Company
THIOFANOX: "Dacamox" " CAS. 39196-18-4
Reg. application dormant: recently sold to
Rhone-Poulenc. Contact: SDS Biotech Corp.
THIOMETON: CAS. 640-15-3
Contact: Sandoz Ltd., Agro Div.
TRIAZOPHOS: "Hostathion" CAS. 24017-47-8
Contact: Hoechst-Roussel Agri-Vet Company
TRICHLORONATE: "Agritox" CAS. 327-98-0 (now discontinue*)
Contact: Mobay Chem. Corp., Agr. Chem. Div.
TRIPHENYLTIN CHLORIDE: "Phenostat-C" CAS. 639-58-7
Contact: Nitto Kasie Co., Japan
ISOPROPYLMETHYLPYRAZOLYL DIMETHYLCARBAMATE: "Isolan"
c^;ae^9"r?K°V ?Prod,uction overseas discontinued)
Contact: Ciba-Gexgy Corp., Agr. Div.
CHLOROACETIC ACID: "Monoxone (Na)" CAS. 79-11-8
Contact: ICI Americas Inc.
DIBUTYL PHTHALATE: - CAS. 84-74-2
Contact: Rhone-Poulenc Inc.,Agrochemical Div.
MERCURIC OXIDE: CAS. 21908-53-2
Contact: Sandoz Ltd., Agro Div.
METHOXYETHYLMERCURIC ACETATE: CAS. 151-38-2
Contact: Kengard Vt Ab (Sweden)
-------
ATTACHMENT C
The State of Colorado (log number 27, comment 15) suggests that the
following UL chemicals should be added to the list because they can be air
toxics.
Acetic add (greater than 10£)
Acrylon1tr1le
Aluminum chloride
Ammonia
Ammonium sulflde
Aniline
Antimony pentachlorlde
3oron trichloride
Bromine
Bromoform
Calcium carbide
Carbon d1sulflde
Carbon tetrachlorfde
Cellosolves™
C re sol
Cyanogen chloride
Cyclohexylamlne
Dlchlorobenzene
Olchloroethylene
Dimethyl suflde
Ethylene oxide
Formaldehyde
Formic add
Hydrobromlc add
Hydrochloric acid
Hydrogen peroxide (greater than IDS)
Hydrogen sulflde
Methylene chloride
Morphllne
Nitrobenzene
Perchloroethylene
Phosgene
Propylene oxide
Sodium fluoroacetate
Sodium hydroxide
Styrene
Sulfur dioxide
Tetrahydrofuran
Tetrame thy Head
THchloroe thanes
Trlchloroethylene
Valeric acid
Vinyl acetate monomer
Vinyl chloride
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ATTACHMENT D
The State of Colorado (log number 27, comment 12) suggests that the
following 38 functional groups should be included on the list. Any chemical
having one of these functional groups in its name would be identified as an
air toxic.
acetyl- fluoro-
acryl- -Isocyanate
-acrylate- -1socyanlde
-acrylic -Isocyano-
-aldehyde -1sothlocyanate
ally!- roercaptan
-anrine mercapto-
-benzoly- -nltrlle
benzyl - peroxy-
borane -phenone
bromo- -pyrldlne
-butyl- -sllane
butyr- sulflde
chloro- -sulfonyl-
-chloroformate -th1enyl
croton- -thlocyanate
cyanide -thlol
cyano- -thlonyl
-cyanohydrln
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ATTACHMENT E
The State of Colorado (log number 27, comment 18) suggests that the
following substances should be added to the list because they are flammable
and of particular interest to fire officials.
Gasoline
Kerosene
Aviation fuels
Diesel fuels
Mineral spirits
Naphtha
Solvent naphtha
V M 4 P naphtha
Stoddard solvent
Benzene
Toluene
Petroleum distillates
Xylene
Butanes
Pentanes
Hexanes
Heptanes
Octanes
Butadiene
D1 ethyl ether
Ethylene
Dioxane
Metal hydrides
-------
ATTACHMENT F
The State of Colorado (log number 27, comment 21) suggests that names of
metallic compounds on the list should be rewritten as shown below.
Arsenic Potassium Metal
-arsenltes
-arsenates Selenium
-selenlte
Cadmium -selenate
Calcium metal Sodium metal
Chromium Thallium
-chromate -thai1ous
-chromic -thai He
-dlchromate
Tin
Lead -stannous
Lithium metal Vanadium
-vanadyl
Mercury
-mercurous
nnercurlc
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ATTACHMENT G
The State of Colorado (log number 27, comment 22) says that the following
chemicals are not in the alphabetical listing.
Acryl amide
Acrylonltrlle
Ad1pon1tr1le
Ammonia
Aniline
Bromine
Carbon dlsulflde
Chi orof onn
Cyclohexamlne
D1g1toxin
Eplchlornydrln
Formaldehyde
Hydrochloric add
Hydrogen peroxide
Hydrogen sulflde
Hydroqulnone
Methyl bromide
Nitrobenzene
Phosgene
Propylene oxide
Sulfur dioxide
Tetramethyllead
Vinyl acetate monomer
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