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F' JAN 12 1993 BOOK 88 ?,rF506 -1 I --am writing to.expresss:my deep concern regarding the imminent move of Macho Produotsp,-Ino,,, from Brevard county to Indian River county. I first became aware of this move when I read the Press -Journal ar- ticle of 7-26-1992 (Ref. 1). This article stated, among other things, that toxic air pollution in Indian River county in 1990 (the last year for which data was available) was a minuscule 1510 pounds (dropp- ing to.zero when Hercules, Inc. ceased production 7-1-192). That same year, Macho Inc., Brevard's worst polluter by far, released an almost unbelievable 156 TONS, 312,.346 pounds of toxic pollutants,(Ref. 1). Ref. 1 also quoted Macho president Dudley Gordon as _saying the comp- any had out its toxic releasee 40%, but that increased production had made the reduction "a wash" --basically stating that total pollution had not decreased at all. An information sstiaet recent -.y distributed by Macho (Ref. 2) states: "--Macho expecte to be• able to reduce daily fugitive solvent evaporation to about 50 gallons." (Underlining is mine) Assuming the toxic pollution -to about equally divided be- tween the two pollutants released (Toluene and Methyl Ethyl Ketone, known as MEK), this amounts to about 126,500 pounds yearly, which Is over 63 tons; Since pollution control is expensive, it is obviously advantageous to the polluter to do as little pollution control as they can. My experience with Phoenix industry was that cleanup pro- jections were rarely,_if ever, met. It was always a case of "We will try to do better next year", or "Reducing pollutants will be too expensive. We would just have to cease production, with atten- dant lose of jobs and tax revenues. You don't want that, do you.?", etc. EPA threats and industry promises just seem to go on forever. To put the toxicity of these solvents in perspective: the toxicity rating of MEK is 3 (Moderately toxic), and the toxicity rating for Toluene is 4 (Very toxic). If ingested, the probable lethal dose for a 150# person is "Between one ounce and one pint" Por a rating of 3 (MEK), and "Between one teaspoon and one ounce" for a rating of 4 (Toluene). These toxicity data per Ref. 3. The Ref. 4 Fact Sheet tells us the following about MEK: "The chemical should be handled as a teratogen --with extreme caution." (A teratogen is a substance that causes birth defects by damaging the fetus). "Repeated exposures, along with other solvents, can damage the nervous system." "The liquid can severely burn the eyes and may irritate the skin." And a few items from Ref. 5 Fact Sheet on Toluene: "Cancer Hazard: Toluene may cause -mutations (genetic changes) in liv= Ing cells. Whether or not it poses a cancer hazard needs further study." "It may damage -the developing fetus." "Toluenecan_ ffect_,you when breathed in and by passing through the skin." "Repeated exposures can damage bone marrow causing low blood cell count. It can also -damage the liver and kidneys." %th•---solvents are- limited by --OSHA, =The_ legal _airborne. exposure limit -.(PEL) is_ 20QrPm:1dFx'ts parsllan) avaged-aver-an--S-houry�workshif t (Toluene) and over a:0 :hour_-workahift for K- Ref, 4 note that the evaporation quantity ofttheme solventslMaehot toiexpeats"nteresti,1g63o tons yearly,- would pollute 315,000 tone of air yearly to OSHA's 200 ppm limit; 32