 ~
~
r
~,
c)

BY
HAND
Mr.
Charles
M.
Auer
Director,
Chemical
Control
Division
(
TS­
778)
Office
of
Pollution
Prevention,
Pesticides
and
Toxic
Substances
Environmental
Protection
Agency
Waterside
Mall,
East
Tower
(
Room
403)
401
M
Street,
S.
W.
Washington,
D.
C.
20460
Re:
Ethylene
Dichioride
ECA
(
OPPTS
 
42197C)

Dear
Mr.
Auer:

Thank
you
for
your
letter
ofFebruary
13,
2001
confirming
points
of
agreement
on
the
testing
program
for
ethylene
dichioride
(
EDC)
outlined
in
a
submission
by
the
HAP
Task
Force
dated
March
19,
1999.
Enclosed
are
the
draft
Enforceable
Consent
Agreement
(
ECA)
you
provided,
red­
lined
to
show
suggested
changes,
and
all
the
appendices
except
the
published
studies.

We
have
expanded
and
clarified
the
discussion
of
the
pharmacokinetics
proposal
in
the
draft
ECA
to
take
into
account
the
concerns
expressed
in
your
letter.
You
will
note
in
Table
I
that
we
have
inserted
final
deadlines
for
various
test
reports
where
question
marks
were
shown
in
the
draft
you
provided.
Some
of
these
deadlines
are
earlier
and
some
than
those
you
had
provided.

4~
O2~
UOOU~
9
A~

Task
Force
P.
O.
Box
331,
Millwood,
VA
22646
(
540)
837­
1602
~
2/?
7C
~
7~
7/
2
October
30,
2001
N)

N)
cc,

­
:
~
:`~`~)
­~
1
Ni
Ni
RECEIVED
OPPT
NCIC
2003
MAR11
5:
03PM
OPPT­
2003­
0010­
0042
Mr.
Charles
Auer
October
30.
2001
Page
2
Your
letter
also
pointed
out
that
EDC
was
one
of
the
chemicals
identified
for
sponsorship
under
the
Voluntary
Children's
Chemical
Evaluation
Program
(
VCCEP)
pilot.
As
you
know,
a
separate
organization
representing
the
EDC
producers,
the
American
Chemistry
Council
Vinyl
Chloride
Health
Committee,
has
committed
to
sponsor
EDC
under
the
Tier
I
VCCEP
pilot.
We
have
revised
the
ECA
to
include
the
language
provided
in
your
letter
ofSeptember
26,
2001
concerning
the
relationship
between
the
ECA
testing
and
the
completion
of
Peer
Consultation
documents
under
the
YCCEP
Tier
I
commitment.
We
have
incorporated
your
language
verbatim
with
one
change:
We
made
the
delivery
date
for
the
Peer
Consultation
documents
twelve
months
following
completion
of
all
testing
under
the
ECA
instead
of
six
months
in
order
to
provide
the
time
that
we
think
will
be
needed
to
complete
the
hazard,
exposure,
risk,
and
data
needs
assessments.
We
have
also
included
appropriate
language
on
the
signature
page
of
each
HAP
Task
Force
participant
which
is
also
a
sponsor
of
EDC
under
the
VCCEP.

The
only
other
substantive
revision
to
the
draft
ECA
you
provided
is
at
the
end
of
Section
IV,
where
the
draft
ECA
stated
that
"
it
is
intended
that
the
data
generated
under
this
ECA
will
satisfy
toxicological
data
needs
for
[
various
endpoints]
as
identified
in
the
amended
proposed
HAPs
rulemaking."
We
have
expanded
this
language
to
make
clear
that
EPA
and
the
Task
Force
also
intend
that
the
data
to
be
generated
under
the
ECA
and
related
VCCEP
activities
will
satisfy
all
relevant
priority
data
needs
forEDC
identified
by
the
Agency
for
Toxic
Substances
and
Disease
Regist~
in
a
recent
notice
that
appears
at
66
Fed.
Reg.
42659
(
Aug.
14,
2001).
The
Task
Force
wishes
to
be
assured
that
it
will
not
be
asked
by
EPA
to
duplicate
the
testing
and
assessments
it
will
be
agreeing
to
conduct
in
the
ECA..

The
purity
of
the
test
material
has
been
left
in
brackets.
We
are
in
the
process
of
reviewing
analyses
of
various
company's
products.

As
previously
noted,
the
Task
Force's
willingness
to
pursue
an
ECA
for
EDC
is
without
prejudice
to
our
position
as
to
the
need
for
the
proposed
testing
or
EPA's
statutory
authority
to
require
it,
more
fully
addressed
in
our
comments
on
the
proposed
test
rule.

We
look
fonvard
to
execution
of
the
ECA
by
November
25,
2001.
Please
let
me
know
if
there
are
any
issues
we
need
to
discuss.

Sincerely,

I
~
I
I
~
~­
L
~
h
Peter
E.
Vovtek,
Ph.
D.
Manager
Mr.
Charles
Auer
October
30,
2001
Page
3
Enclosures
cc:
Ward
G.
Penberthv
Richard
W.
Leukroth,
Jr.,
Ph.
D.
John
Schaeffer
\
X~.
Caffev
Norman,
Esq.
Docket
42197C
Docket
00274D
I),,
c
(,(,`
23(,
