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DS1
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UNFTED
STATES
ENV~
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ONAGENCY
WASH~
NGTON,
D.
C.
20460
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PRO~

SEP
26
2001
OFFICE
OF
PREVENTION,
PESTICIDES
AND
Dr.
Peter
Voytek
TOXIC
SUBSTANCES
HAP
Task
Force,
Manager
Regulatory
Sciences
International
P.
O.
Box
331
Miliwood,
VA
22646
RE:
EDC
Enforceable
Consent
Agreement
(
OPPTS
42197
B)

Dear
Dr.
Voytek:

I
am
writing
to
acknowledge
the
receipt
of
your
letter
ofJune
25,
2001.
In
this
letter
you
indicate
that
your
response
to
my
letter
of
February
13,
2001
has
been
delayed
by
the
need
to
coordinate
with
the
Vinyl
Chloride
Health
Committee
(
VCHC)
ofthe
American
Chemistry
Council,
which
is
representing
the
ethylene
dichloride
(
EDC)
producers
in
developing
their
response
to
the
Voluntary
Children's
Chemical
Evaluation
Program
(
VCCEP).
EPA
is
also
in
receipt
ofa
letter
(
June
25,
2001)
from
the
VCHC
committing
to
the
VCCEP
Tier
I
pilot.
The
VCHC
letter
indicates
that
EDC
producers
intend
to
fulfill
a
component
of
the
VCCEP
commitment
by
executing
and
implementing
(
through
the
HAP
Task
Force)
the
Enforceable
Consent
Agreement
(
ECA)
for
EDC.

Pursuant
to
the
above
mentioned
correspondence,
EPA
has
drafted
language
to
document
these
agreements
into
the
draft
EDC
ECA
which
was
included
as
an
attachment
to
my
letter
of
February
13,
2001.
I
propose
that
we
insert
the
following
text
at
the
end
ofPart
I
(
Introduction)
in
the
draft
EDC
ECA
document.

In
the
December
26,
2000
Federal
Register,
EPA
announced
the
Voluntary
Children's
Chemical
Evaluation
Program
(
VCCEP)
which
is
intended
to
provide
data
to
enable
the
public
to
understand
the
potential
health
risks
to
children
associated
with
certain
exposures
to
commercial
chemicals.
EDC
and
some
22
other
chemicals
have
been
selected
for
inclusion
in
a
pilot
of
VCCEP.
Under
the
VCCEP,
EPA
asks
that
companies
which
manufacture
and/
or
import
chemicals
selected
for
this
pilot
of
VCCEP
volunteer
to
sponsor
Tier
1
of
the
program.
The
VCCEP
pilot
consists
ofthree
tiers,
which
a
sponsor
may
commit
to
separately.
EDC
producers
(
sponsors),
as
represented
by
the
American
Chemistry
Council
Vinyl
Chloride
Health
Committee
(
Health
Committee),
intend
to
voluntarily
sponsor
EDC
in
Tier
1
of
the
VCCEP
pilot.
Part
of
this
commitment
is
being
executed
and
implemented
via
this
ECA
through
the
HAP
TASK
Force.
The
relationship
between
the
Health
Committee
and
the
HAP
Task
Force
is
described
Recyc~
eci
T
RecycIabIe
Prined
with
Vegetable
Oil
Based
Inks
on
100%
Recycled
Paper
(
40%
Postconsurner)
RECEIVED
OPPT
NCIC
2003
MAR11
5:
03PM
OPPT­
2003­
0010­
0041
in
the
June
25,
2001
letter
ofcommitment
to
the
VCCEP
Tier
1
from
Courtney
Price
to
the
Honorable
Christine
T.
Whitman.
The
above
mentioned
correspondence
is
available
in
the
EPA
OPPTS
Docket
No.
42197
B
(
see
Part
XVI
of
this
ECA).

In
the
commitment
letter
EDC
producers
proposed
to
complete
the
ECA
testing
program
before
submitting
risk
and
exposure
assessments
under
the
VCCEP.
In
this
way,
results
from
this
HAPs
ECA
testing
program
would
feed
back
in
consideration
ofdata
needs
for
the
VCCEP
and,
where
possible,
could
avert
some
or
all
of
the
overlap
testing
requirements
between
the
two
initiatives.
A
concern
expressed
by
the
EDC
producers
was
whether
scheduled
deliverables
for
the
VCCEP
will
be
considered
timely
if,
due
to
the
time
needed
for
completing
the
ECA
testing,
the
VCCEP
deliverables
extended
beyond
the
expected
VCCEP
timelines.
EPA
has
accepted
that
the
VCCEP
Tier
1
deliverables
could
be
submitted
within
six
months
following
the
completion
ofall
testing
to
be
conducted
under
this
ECA.
EPA
understands
that
the
test
schedule
set
forth
in
this
ECA
includes
some
higher
tier
VCCEP
toxicity
studies
and
may
also
depend
in
part
on
EPA
performing
certain
actions
in
a
timely
manner
during
the
course
of
the
testing.
Additionally,
events
could
occur
that
would
cause
the
ECA
test
schedule
to
be
extended
beyond
what
is
contemplated
inthe
ECA.
If
the
schedule
for
ECA
testing
is
extended,
the
schedule
for
VCCEP
commitments
would
be
likewise
extended.

In
addition,
as
there
is
an
apparent
discrepancy
between
the
membership
ofthe
HAP
Task
Force
and
the
VCHC,
I
propose
that
a
footnote
be
added
to
each
sponsor
signature
page
indicating
whether
or
not
the
Company
is
a
member
ofthe
VCHC.

I
look
forward
to
the
receipt
of
your
response
to
my
letter
of
February
13,
2001
and
I
remain
optimistic
that
we
will
conclude
this
ECA
agreement
within
your
proposed
time
frame
(
December,
2001).
If
you
have
questions
please
contact
John
Schaeffer
at
(
202)
260­
1266
or
Richard
Leukroth
at
(
202)
260­
0321.

Sincerely,

cc:
Ward
Penberthy
Richard
W.
Leukroth,
Jr.
John
Schaeffer
W.
Caffey
Norman,
III
Docket
OPPTS
42197B
Docket
OPPTS
00274D
Chemical
Control
Division
