United States
               Environmental
               Protection Agency
                  Solid Waste and
                  Emergency Response
                  (5305W)
EPA530-F-99-040
   August 1999
  www.epa.gov
r/EPA
Environmental
Fact  Sheet
               EPA  PROPOSES LISTING CERTAIN
               WASTES FROM THE PRODUCTION OF
               CHLORINATED  ALIPHATICS
Background

Chlorinated aliphatic hydrocarbon chemicals
(CAHCs) entered into commerce in the US
in the early 1920s, and as of 1994,
approximately 32 billion pounds of CAHCs
were manufactured by 26 chemical plants
(facilities) in the United States.

CAHCs are a group of organic chemicals —
most of which are colorless liquids at room
temperature - primarily used as intermediate
feedstocks for the production of polyvinyl
chloride (PVC) plastics; CAHCs are also used
directly in liquid form as various types of
solvents, as intermediates for the production of
other types of chemicals, and in assorted other
commercial use categories.

In 1989, the Environmental Defense Fund
(EDF) sued the Environmental Protection
Agency (EPA), which resulted in a consent
decree setting out deadlines for promulgating
certain RCRA rules and for completing certain
studies and reports. Part of this consent
                      decree obliges EPA to propose a hazardous
                      waste listing determination for wastewaters
                      and wastewater treatment sludges generated
                      from the production of specified chlorinated
                      aliphatic chemicals.  With this notice, EPA is
                      proposing listing determinations for these
                      wastes in accordance with the consent decree.

                      Action

                      The Agency identified four waste groupings
                      for wastewater treatment sludges and one
                      category of wastewater generated by the
                      chlorinated aliphatics industry. These waste
                      groupings were based primarily upon the
                      particular production processes that generate
                      these wastes, and the type of chlorinated
                      aliphatic product being produced .  These
                      waste groups include sludges generated from
                      the treatment of wastewaters from the
                      production of:

                      •  ethylene dichloride and/or vinyl chloride
                        monomer (EDC/VCM);

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•  vinyl chloride monomer using mercuric
   chloride catalyst in an acetylene-based
   process (VCM-A);

•  methyl chloride; and

•  allyl chloride.

The wastewater grouping includes all
chlorinated aliphatics wastewaters except
wastewater from VCM production using an
acetylene-based process.

The scope of the notice does not include any
other process residuals generated by the
chlorinated aliphatics industry.  In particular,
EPA is not re-evaluating previously  listing
determinations concerning wastes generated by
chlorinated aliphatics production processes.

In today's notice, EPA is proposing to add
three wastes generated by the chlorinated
aliphatics industry to the list of hazardous
wastes in 40 CFR 261.32. Below are the
wastestreams EPA  is proposing to list as
hazardous with their corresponding  proposed
EPA Hazardous Waste Numbers:

•  K173 Wastewaters from the production of
   chlorinated aliphatic hydrocarbons,  except
   for wastewaters generated from  the
   production of vinyl chloride monomer
   using mercuric  chloride catalyst  in an
   acetylene-based process. This listing
   includes wastewaters from the production
   of chlorinated aliphatic hydrocarbons that
   have carbon chain lengths ranging from
   one to, and including five, with varying
   amounts and positions of chlorine
   substitution.

•   K174  Wastewater treatment sludges
    from the production of ethylene dichloride
    or vinyl chloride monomer (EDC/VCM).
•   K175  Wastewater treatment sludges
    from the production of vinyl chloride
    monomer using mercuric chloride catalyst
    in an acetylene-based process.

EPA is proposing to list these wastes because
these residuals meet the criteria for listing a
waste as hazardous. EPA assessed and
considered these criteria for all six
wastestreams through the use of risk
assessments and risk modeling, as well as a
consideration of other pertinent factors.  This
proposed listing determination follows the
elements of the  Agency's listing decision
policy that was  presented in the proposed
listing for wastes generated by the dye and
pigment industries (59 FR 66073, December
22, 1994).  This policy uses a "weight-of-
evidence" approach in which calculated risk
information is a key factor  considered in
making a listing determination.

The EPA also is proposing an alternative
approach to listing two of the wastes from
chlorinated aliphatics processes as hazardous,
rather than  proposing to list these wastes in
accordance with the Agency's traditional
listing approach. The Agency is proposing a
conditional-listing approach for one waste, and
as one of two options for a second waste,
because the Agency has evaluated the ways in
which the waste is likely to be managed and
has determined  that certain waste management
activities would present significant risks but
that others would be protective of human
health and the environment. Under this
approach, EPA  is proposing to list particular
wastes as hazardous only if the wastes are
managed in a way other than the manner in
which the Agency has determined is protective
of human health and the environment. In
implementing a conditional-listing approach,
the Agency is proposing that wastes that fall
outside the  scope of the listing description

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(e.g., are destined for the appropriate type of
disposal) are non-hazardous when generated.
EPA is also proposing technical requirements
for tanks managing certain chlorinated
aliphatic wastewaters, to minimize air releases
of dioxin from these wastewaters. Today's
action also proposes not to list as hazardous
the following three wastes:

    process wastewaters from the production
    of vinyl chloride monomer using mercuric
    chloride catalyst in an acetylene-based
    process,

•   wastewater treatment sludges from the
    production of methyl chloride, and

    wastewater treatment sludges from the
    production of allyl chloride
For More Information

The Federal Register Notice and this fact sheet
are available in electronic format on the
 Internet. The notice is available at
. This fact sheet and
other documents related to this proposed rule
 are available at .
For additional information, or to order paper
copies of any documents, call the RCRA
Hotline. Callers within the Washington D.C.
Metropolitan area must dial 703-412-9810,
or TDD 703-412-3323 (hearing impaired).
Long distance callers may call 1-800-424-9346
or TDD 1-800-553-7672. The RCRA Hotline
operates weekdays, 9:00 a.m. to 6:00 p.m.
Write the RCRA Information Center (5305W)
USEPA, 401 M Street, SW, Washington, DC
20460.  E-mail the RCRA Information Center
at .

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