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       SOIL SCREENING  SURVEY
                  AT
       FOUR MIDWESTERN SITES
              JUNE 1985
           GARY A. AMENDOLA

           PROJECT MANAGER
      MICHIGAN DIOXIN  STUDIES
U.S. ENVIRONMENTAL PROTECTION AGENCY
               REGION .V
  ENVIRONMENTAL SERVICES DIVISION
      EASTERN DISTRICT  OFFICE
            WESTLAKE, OHIO
            U.S. Environmental Protection Agency
            Region 5 Library (PL-12J)
            77 West Jackson Blvd., 12th Floor
            Chicago, IL 60604-3590

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                                ACKNOWLEDGMENTS


    A study of this magnitude and complexity could only be accomplished through
the combined efforts of many dedicated people  from  several  organizations.  The
study was designed by Region V of USEPA with input from the Michigan Department
of Public  Health  and  Michigan Department  of  Natural  Resources.   The  field
sampling was conducted by  Ecology and Environment, Inc.,  under  direction from
Daniel C. Watson,  USEPA.  The quality assurance project plan and quality control
report were principally  prepared by  Marcia A.  Kuehl, then  quality  assurance
officer, USEPA Region V,  Central Regional  Laboratory.   Samples were also coded,
tracked, and decoded by Marcia A. Kuehl.  Samples were homogenized and packaged
by the Illinois Institute  of Technology  Research Institute.  The extraction of
samples was conducted by Danny McDaniel and Dr. Aubry  DuPuy at USEPA's Toxicant
Analysis Center at Bay St.  Louis, Mississippi.  Samples were analyzed by Robert
Harless at  USEPA1s  Environmental  Systems  Monitoring  Laboratory at  Research
Triangle Park, North Carolina.   Vanessa Musgrave, USEPA Region V,  Public Affairs
Office, coordinated the  community relations activities for this  study and the
public Information document was prepared with assistance  from CHฃM Hill.  The
many thoughtful comments received from the public on the draft study plans, the
cooperation of the Dow Chemical Company,  and  the  support of the  USEPA Region V
Waste Management Division,  Region V Dioxin  Task  Force, USEPA Headquarters, and
the Centers for Disease Control,  are  also acknowledged.   The  data were reduced
by Donald  Schregardus, Brian  Buckham,  and Mark Conti, and this report typed by
Carol Kopcak of the USEPA Region V, Eastern District Office.
                                      NOTICE
     This  document  has  been  reviewed  in  accordance  with  U.S.  Environmental
 Protection  Agency  policy  and approved for publication.  Mention of trade  names
 or commercial  products does  not  constitute endorsement  or recommendation  for
 use.
                                        ii

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                                          TABLE  OF CONTENTS

                                                                                  Page

                   ACKNOWLEDGEMENTS  	     11


                   LIST OF TABLES	     1v


                   LIST OF FIGURES   	     1v


               I.   INTRODUCTION	      1


              II.   OBJECTIVES	      2


             III.   FINDINGS AND CONCLUSIONS  	      3


              IV.   STUDY SITES 	 *	      4


               V.   CONDUCT OF THE STUDY	      6

rj                  A.  Field Sampling and Field  Quality Assurance                   6
                   B.  Sample Homogenlzatlon                                        8
                   C.  Laboratory Analyses                                          8
                   D.  Quality Control  Summary                                      9


              VI.   DISCUSSION OF RESULTS	     10

                   A.  2378-TCDD                                                   10
                   B.  Other PCDDs and PCDFs                                       19
                   C.  Other Toxic Chemicals                                       20
                   D.  2378-TCDD in Municipal  Sewage Sludges                       21


             VII.   CONSIDERATION OF PUBLIC HEALTH RISKS  	     22


                   REFERENCES	     24


                   APPENDICES


                   EXHIBIT
                                                 ill

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Table 1
Table 2
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7


Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
LIST OF TABLES
2378-TCDD, Screening Survey at Four Midwestern Sites, . .
Summary of Results
2378-TCDD, Summary of Recent Environmental Measure- . . .
ments, Midland, Michigan Area
LIST OF FIGURES
Location Map - Study Sites . 	
Soil Screening Survey of Four Midwestern Sites
Soil Sampling Sites 	 	
Midland Area, Dow Chemical
2378-TCDD in Surface Soils 	
Four Midwestern Sites
2378-TCDD in Surface Soils 	
Dow Chemical - Midland Plant
2378-TCDD in Surface Soils 	
Perimeter, Dow Chemical - Midland Plant
2378-TCDD in Surface Soils 	
Location Map - City of Midland
2378-TCDD in Surface Soils 	
City of Midland
APPENDICES
Soil Screening Survey at Four Midwestern Sites;
Draft Study Plan, September 22, 1983.
In-Plant Soil Screening Survey,
Dow Chemical - Midland Plant; Draft Study Plan,
November 28, 1983.
Quality Control Summary
Study Results
Consideration of Public Health Risks
Page
11
23
5
7
12
13
15
16
17







                                        EXHIBIT

Exhibit 1     Dioxin and Other Toxic Pollutants;  Midland, Michigan;
              USEPA Region 5,  April  1985.
                                       iv

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                 SOIL SCREENING SURVEY AT FOUR MIDWESTERN SITES
I.  INTRODUCTION

    In response  to  concerns  about  possible  adverse  public  health  impacts
of 2,3,7,8-tetrachlorodibenzo-p-dioxin  (2378-TCDD)  and  other toxic  chemicals
in Midland,  Michigan,  the  U.S.  Environmental  Protection  Agency  (USEPA)  has
initiated a  series  of  multi-media  environmental  studies in  the Midland area.
The major purpose of these studies is to define current environmental  levels of
2378-TCDD and  other toxic  pollutants  such  that public  health  officials  can
make assessments regarding  the potential  public  health risks associated  with
exposures in the area.   Where appropriate, measures to manage or mitigate those
risks will  be  undertaken.   The studies  are  also  focused  on determining  the
source or sources  of these  pollutants  and providing additional  information and
data which will  be  useful to the  state of Michigan and the  USEPA  for environ-
mental permitting  for  the   Dow  Chemical  Company,  Midland,  Michigan  plant.

    Although planned and  initiated  prior to  completion  of USEPA's  national
Dioxin Strategy J./  and initiation of the corresponding National Dioxin Study, the
Region V dioxin studies that focus on Midland, Michigan, have been  incorporated
into the Dioxin  Strategy  and National  Dioxin  Study.   The Dioxin  Strategy  was
developed in response to growing  public concerns  about dioxin contamination in
the environment.   The  strategy provides  a framework  within which USEPA  will
study the nature of dioxin contamination in the United States and the associated
risks to people and the environment;  direct clean-up measures at dioxin contami-
nated sites  that threaten public  health;  and  conduct  research  directed toward
destroying and disposing of  dioxin contaminated wastes and soils,  and preventing
further contamination.

    This report presents the results of  a  soil  screening  study for  2378-TCDD
and other  toxic pollutants  and  associated  health  risk  statements   from  the
U.S. Department of  Health  and Human Services -  Centers for Disease Control (CDC)
and USEPA's Chlorinated Dioxins Work Group (CDWG).

    The other  studies  associated  with  this project include (1) assessment of
water quality  for  the  major public  water  supplies in  the area  and  selected
private potable water wells located  near  Dow  Chemical  brine mining operations;
(2) evaluation  of  Dow Chemical's brine  operations;  (3)  evaluation  of ground
water quality  near  active and closed hazardous waste landfills;  (4)  monitoring
of river  sediments,  bottom   feeding  fish  and  game  fish  from the Tittabawassee
River; (5) process  wastewater,  wastewater effluent, and  ground  water sampling
at Dow  Chemical;  and  (6)   air  emission  sampling  at Dow  Chemical's  hazardous
waste incinerator and limited ambient  air monitoring around the Dow plant.  In
addition, a final report will be issued for the USEPA/MDNR fish bioaccumulation
and Dow Chemical wastewater  characterization study for which preliminary results
were reported in 1983.

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     Planning for these studies  began  in the  spring  of 1983  in  response to a
 March 31,  1983,  request by the state of  Michigan  and  in  continuation of USEPA's
 regulatory activities in  the  area.   The objectives  and scope of the studies
 were developed by Region  V of USEPA  with considerable input from several  state
 agencies.   The general study  plans  were set  out for public comment in August
 1983.  Based upon the many  thoughtful comments  received,  the study plans were
 modified where appropriate.  Field work was  initiated  in  the fall  of 1983 and
 was completed in late 1984.  The results and major conclusions from this  study
 were reported at a public meeting held  in Midland, Michigan, on April 2,  1985.
 The public information document prepared  for that meeting  is presented  as an
 exhibit with this report.

     As presented below, this soil study had more than  one objective  and included
 analyses of many  environmental  contaminants.  The  real  limitations  of  time,
 money, and available  qualified analysts,  particularly for dioxins  at  trace
 levels, precluded analyses of all  of the samples  collected as part  of the  study
 design. Notwithstanding, the results  are of  sufficient  quality and quantity to
 address the most significant issues  posed by  the  study objectives.


II.  OBJECTIVES

     The principal  objective  of  this screening study was  to determine whether
 current ambient  levels of  2378-TCDD in surface  soils  might pose  unacceptable
 health risks to  Midland residents  such that more  detailed  environmental studies
 and remedial  cleanup actions would be warranted.  The study  was also conducted
 to determine the likely source or sources of ambient levels of dioxin in Midland;
 whether levels of 2378-TCDD found in Midland are  comparable  to levels found in
 other industrial  areas with combustion sources and process operations different
 than those at Dow Chemical; and whether levels  found in Midland are  significantly
 different  than background  levels  that  may  be  found  in  the  environment.   A
 limited number of  soil  samples were  also analyzed  for other polychlorinated
 dioxins (PCDDs),  polychlorinated furans (PCDFs),  and other  toxic   chemicals to
 determine  if  ambient  levels  of those pollutants might be  of concern  from a
 public health standpoint.   A complementary surface  soil  sampling program was
 also conducted inside the Dow Chemical - Midland  Plant.

     This study was the first large scale soil  sampling program conducted by EPA
 with stated analytical and  quality  assurance  objectives of  producing verified
 data for 2378-TCDD, other  PCDDs and PCDFs  in the low parts  per trillion  (ppt)
 range.

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III.  FINDINGS AND CONCLUSIONS

      A.   Current concentrations  of  2378-TCDD  in city  of Midland surface  soils
  beyond the perimeter of  the Dow Chemical - Midland  Plant range from 0.003  to
  0.27 ppb, and average well  less than 0.10 ppb.  These levels and corresponding
  levels of other PCDDs, PCDFs,  and other toxic chemicals found in city of Midland
  surface soils beyond the perimeter of  the  Dow Chemical  - Midland Plant do not
  pose an unacceptable public health risk.  The available data represent current
  soil levels and the CDC  can make no comment about  past environmental levels and
  potential risks that may have existed in the past.

      USEPA and the Centers  for Disease  Control  have advised the public to heed
  the Michigan Department  of Public  Health's  warning against consumption of fish
  taken from the Tittabawassee River  to avoid injestion of 2378-TCDD.

      B.   While below  a  level of concern from a public  health  standpoint, the
  levels of 2378-TCDD  in   Midland  surface soils  are  significantly  higher than
  trace levels  of 2378-TCDD   (<0.005 ppb)  found  in  a   few of  the samples  taken
  from other Industrial locations, and in  natural areas where 2378-TCDD was not
  detected.

      C.   The data obtained from this  study  do not suggest widespread environmental
  contamination by 2378-TCDD,  and  other PCDDs  and  PCDFs  at  significant levels
  with respect to public health or adverse  environmental Impacts.

      D.   Air emissions from  Dow Chemical's hazardous waste Incinerator  and  other
  less significant sources,  possibly Including  windblown dusts  from the  plant
  site, are the sources of dioxin  contamination  in Midland.

      E.   Current air  emissions of  2378-TCDD from  Dow Chemical  (<0.5  gm/yr  as
  reported by Dow Chemical),  cannot account for the mass of 2378-TCDD in Midland
  surface soils estimated  to  be  about  500  gm.   Past  incineration  operations
  and process emissions from  Dow  Chemical  are  the likely  sources of the dioxin
  not accounted for by current emissions.

      F.   Relatively  high   levels  of 2378-TCDD  were found  at  certain  locations
  Inside  and near  the perimeter of  the Dow Chemical plant.  While most surface soil
  samples from Inside the  plant contained  less  than  0.5 ppb of 2378-TCDD,  three
  samples contained concentrations ranging  from  3.5 to  36  ppb.  One sample on the
  perimeter of the plant had  a concentration  of about  2 ppb.  Action  to minimize
  or eliminate worker  and  public  exposure to  dioxin  from  these  sites  has been
  completed or is  underway.

      G.   The  quality of  data obtained for this study  demonstrate that USEPA has
  the capability to conduct dioxin Investigations for  soils at the low parts per
  trillion range.

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IV.  STUDY SITES

     Figure 1 is a map of the six states  in  USEPA Region V  showing  the locations
 of the study sites.

     Site 1 - Midland, Michigan

     The city of  Midland has a  population  of about  35,000 people.  The major
 industries are the Midland Plant of the Michigan Division of Dow Chemical Company
 and the Dow-Corning Silicone Products Plant.  The Dow Chemical -  Midland Plant
 falls within Tiers  1,  2, 3,  4, and  6  of  the  USEPA Dioxin  Strategy  in that
 2,4,5-trichlorophenol  (2,4,5-TCP)  was produced (Tier  1);  2,4,5-TCP was used  to
 make pesticide products (Tier 2);  and 2,4,5-TCP and derivatives were formulated
 into pesticidal products (Tier  3).   The  plant is  a combustion  source (Tier 4),
 and Dow Chemical  operates processes  for other organic chemicals  or pesticides
 that possibly could result in dioxin  formation (Tier  6).

     Site 2 - Henry.  Illinois

     The principal industry located near Henry, Illinois,  is a polyvinyl chloride
 manufacturing plant operated by the B. F. Goodrich Chemical  Company.  The plant
 has numerous process vents and  some combustion sources.  This  facility is not a
 Tier 1 or Tier 2  site  as defined by  USEPA's  Dioxin Strategy.   Henry, Illinois,
 has a population of about 2700  people.

     Site 3 - Middletown, Ohio

     The city of Middletown is located in southwestern Ohio and has a population
 of about  35,000  people.   The  principal   industries are  the  ARMCO,   Inc.   -
 Middletown Works; Sorg  Paper Company; and  Crystal  Tissue Company.  The ARMCO,
 Inc. - Middletown Works is a fully  integrated steel plant  including cokemaking,
 sintering, ironmaking,  steelmaking, continuous casting, hot forming, and steel
 finishing operations.  The plant has  numerous combustion  sources.  Sorg Paper
 manufacturers fine papers from purchased pulp, recycled paper, and  paper wastes.
 Crystal Tissue manufactures  fine tissue and  wrapping papers from  virgin pulp.
 There are no Tier 1 or Tier 2  facilities as  defined  by USEPA's Dioxin Strategy
 in the Middletown, Ohio area.

     Site 4 - Natural Areas in Minnesota

     Site 4 is  comprised of  the following  four areas managed by  the Minnesota
 Department of  Natural   Resources   as scientific  and  natural  areas   (SNAs):

         Kettle River Scientific and Natural  Area
         Pembina Trail Scientific and Natural  Area
         Itasca Wilderness
         Bluestem Prairie Scientific and  Natural Area

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    Scientific and Natural  Areas  are established by  the state to protect  and
perpetuate natural features that possess exceptional  scientific or educational
value.  The Kettle River  SNA Is a 760  acre  tract typical  of the woodlands  of
eastern Minnesota.  Pemblna Trail  1s one of  the  largest  remaining tracts  (1660
acres) of native prairie 1n Minnesota.  Itasca Wilderness Is a  2000  acre  tract
of pine-dominated forest that has never been logged.  Bluestem Prairie Is a 1500
acre prairie 1n northwest Minnesota.  There are no nearby pollution or  combustion
sources at these sites.  These areas are considered Tier 7  sites or  background
sites for USEPA's Dloxln Strategy.


V.  CONDUCT OF THE STUDY

    A.  Field Sampling and Field Quality Assurance

    Samples were collected  In the city  of  Midland,  Michigan,  during  the period
October 10-20, 1983; at the  Dow Chemical -  Midland Plant on December 1, 1983;  In
the city  of Mlddletown, Ohio,  on November  8-9, 1983;  at  Henry,  Illinois  on
September 18-19,  1984;  and at the four natural  areas  In Minnesota on October 6-7,
1983, and on November 16, 1983.

    Samples were collected  and  handled  according to  the protocols outlined  1n
the draft soil sampling plan dated September 22, 1983 (Appendix A).  The sampling
plan at the Dow  Chemical  - Midland Plant  called for both  random and targeted
sampling at a limited  number  of  sites  (Appendix B).   Targeted  sampling  was
focused at the hazardous waste  Incinerator and  previously  operated  trlchloro-
phenol production facilities (Figure 2).   All  samples analyzed from the  plant
were composite surface soil  samples obtained from grids set out at each sampling
site.  Both composite  and grab samples taken from  around the perimeter of the  Dow
plant were analyzed.   Soil  sampling  Inside the Dow plant was limited In  scope
due to laboratory resource constraints.  At the time, Dow Chemical was conducting
an Independent study  of 2378-TCDD  that Included  extensive  sampling  of surface
soils.  The data from  this  study and Dow Chemical data have been used by  USEPA
to assess conditions at the plant.

    Sampling  In  the city of Midland  was   focused on  the perimeter  of the  Dow
Chemical - Midland Plant and 1n public use and residential  areas throughout the
city (Figure  2).  The  residential  sampling  program  Included  both   open yard
composite samples and  composite samples taken at downspouts or roof drlpllnes.
The downspout  and  drlpllne  samples were  obtained to determine whether  atmos-
pheric emissions  of 2378-TCDD from the Dow  Chemical  - Midland Plant were  the
likely source of dloxln contamination In Midland.   The study design  called  for
collection and analyses  of residential  downspout samples obtained at radii  of
1 foot and  3  feet from the  downspouts.  A limited number  of core samples  (to
3 feet)  were  collected  from public  use  and  residential  areas for analyses.
However, due  to  laboratory resource  constraints,  the outer  ring  (3  feet)
downspout samples and  the  core samples could not  be analyzed.  These samples
have been archived for possible future analyses.

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                                                                                       B-4
                                                                  Consumers
                                                                  Power Company
                                                                  Lagoons
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UPW4
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TO-4


E-1
•
E-2


Per-4
DOW
CHEM
COMP
iH|
Per- 10^

•
P-11
                     Approx. Scale
         FIGURE 2

   (A-F)  Residential Sample
(Per.TO)  Perimeter & Trackout
         Sample
  (1-15)  Inplant Sample
     (P)  Public Access Sample
  (UPW)  Upwind Sample


     O  Sample Obtained.
         Not Analyzed
                                                                                                            P-6,

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    Samples from Henry, Illinois and Middletown, Ohio were also collected  from
the perimeter of  the industrial  facilities,  from public  use  areas, and  from
residential areas (see Figures 1 and 2, Appendix D).  Samples  from  the  natural
areas in Minnesota  were taken  in open  areas  away  from  access roads.  Also,
sewage sludge  samples from  the  Midland  and  Middletown  municipal   wastewater
treatment facilities were collected.

    Documentation of the sampling activity at each sampling site includes unique
sample identification  numbers;  site maps  showing the  locations  of  pertinent
landmarks and the sampling grids; photographs;  and a  site  report describing the
types of  samples  obtained,  site history where  available,  and any  noteworthy
characteristics.  Separate, disposable, precleaned sampling equipment was  used
for each sampling site to avoid cross-contamination of samples. To  the  maximum
extent practicable,  nonsoil   material   (twigs,  stones,  debris)  was  removed
from each  sample  in  the  field  prior to  blending  in  the laboratory.  Field
quality assurance included duplicate field  samples, analysis  of  blank field
samples, and analyses of  solvents used to clean field  equipment.   All  samples
were maintained under  strict custody  from  collection through compositing  and
analysis.  Significant problems  that  could  impact the  analysis of  samples did
not develop during  collection of  field  samples.  Some of the uncoated steel
cans used as sample containers developed minor  rusting of the interiors from the
time of sample collection to  sample homogenization.  This  occurrence was judged
to have  no impact  on the  results.   The  use  of  coated  steel  containers  or
containers made from other  suitable materials is recommended for future studies.

    B.  Sample Homogenization

    Prior to analysis, each sample was homogenized at the  Illinois  Institute of
Technology Research Institute according to the protocols set out in  the quality
assurance project plan for this study.  2J  In short, precleaned steel balls  were
introduced into the  steel  cans that  were used  as  sample  containers.  The  cans
were then  tumbled  until  replicate analyses for  certain  metals indicated the
samples were  thoroughly  blended.  A turntable device was used to  prepare ten
aliquots for  analyses.   The   moisture  content  of each  sample was  determined
after sample homogenization.  3/  To avoid the  high cost of commercial  blending
and to  produce  field samples of reasonable consistency,  the use of disposable
sieves in the field followed  by mixing of samples in the laboratory is suggested
for future studies.

    C.  Laboratory Analyses

    The field samples were coded by  USEPA Region V's quality assurance  officer
for this project and shipped  to the analytical  laboratories in discrete batches.
The analytical  laboratories  included USEPA's  Toxicant  Analysis Center  located
at Bay  St. Louis,  Mississippi,  and  USEPA's  Environmental Monitoring  Systems
Laboratory located at Research Triangle Park, North Carolina.  The  samples  were
extracted  and prepared for analysis at  the Toxicant Analysis Center and analyzed
by HRGC-HRMS  at the Environmental Monitoring  Systems Laboratory.   The  extrac-
                                       8

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tion, cleanup, and analyses were performed according to the analytical  protocols
set out in the quality assurance project plan.  2/  USEPA provided split samples
to Dow Chemical for this study.

    All of the laboratory analyses  were conducted on a  blind  basis.   That  is,
the analytical laboratories did  not know the  identification  or source  of  any
field samples.  Each discrete  batch  of samples included a control  sample with
known 2378-TCDD concentration,  a  clean soil  with no  detectable  2378-TCDD,  and
a number  of  field  samples.   Upon completion  of the  analyses,  USEPA and  Dow
Chemical analytical results for the coded samples were compared.


    D.  Quality Control  Summary

    Overall,  the quality of the data is exceptional  considering the ultratrace
analytical objectives for this  study.   The detailed quality control  report  for
this study is presented in Appendix  C.  Specific USEPA data  quality indicators
including precision, accuracy,  completeness,  and comparability  are  summarized
below:

    1.  Precision

        Field sampling precision  for  2378-TCDD  was less  than 50 ppt.   USEPA
    laboratory precision for 2378-TCDD  was generally within 3 ppt.  Sample homo-
    genization procedure precision expressed as  mean  coefficient of  variation
    (CV) was  14%.  The QA objectives for precision were <30%  RPD or ฑ detection
    limit (1-5 ppt).  USEPA results  were reasonably close to  these  goals con-
    sidering  the ultratrace  levels  and  lack  of  homogeneity  in many  samples.

    2.  Accuracy

        2378-TCDD  accuracy  expressed   as   the  95%  confidence  interval   for
    surrogate recovery was 52-116%.   The goal  was 70-130%.   The actual matrices
    encountered during the  analyses  rendered  this  an  optimistic  goal.  OCDD
    accuracy  expressed as the  95% confidence  interval  for surrogate recovery
    was 56-96%.  The goal again was  70-130%.   The unexpected  high  native OCDD
    levels in several samples complicated the surrogate recovery.

    3.  Completeness

        The goal  was 95%; USEPA valid data for 2378-TCDD in field samples totaled
    99%.  A total  of ten 2378-TCDD sample results did not meet the QA objective
    of 50-115% surrogate recovery.   Seven  of  these  were the  control  soil  and
    three were field samples.  Two of the field  samples were sewage sludges.   The
    control soil  and sewage sludges  are not  typical  of soils  encountered in  the
    study areas.   The completeness  overall  is sufficient  for a study  of this
    scope.

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     4.  USEPA/Dow Comparability

         Mean between-lab 2378-TCDD comparability CV was 105%.   The  QA objective
     was less than 50%.  The  large number of  results  at or near the detection
     limit and  the  positive  40%  bias  for Dow  Chemical versus  USEPA  results
     combined to Increase the variation expected  at the start of the study.   The
     positive bias in Dow Chemical's results  is attributed to sample handling in
     the laboratory.   Because of differences in  the  subsampling procedures  used
     by USEPA and Dow Chemical,  it is likely  that Dow Chemical  analyzed a higher
     proportion of fine  particles  than did USEPA  (see  Appendix C).  Mean  OCDD
     variation between labs was 38%  CV compared  to the  goal of less  than  100%.

     In  summary,  the  data  produced  are  well-defined,  comparable,   and  of
 acceptable quality for a pioneer  PCDD/PCDF study at ultratrace levels.


VI.  DISCUSSION OF RESULTS

     A.  2378-TCDD

     Appendix D  contains the 2378-TCDD  data  obtained  as part  of  this  study.
 Table 1 of  the appendix presents surface soil  concentrations of  2378-TCDD at
 15 locations inside  the Dow Chemical  - Midland  Plant. Table 2  presents the
 balance of the data obtained In and near Midland, Michigan.  Tables 3,  4,  and 5
 present data for the comparison sites of Henry,  Illinois; Middletown, Ohio; and
 the Minnesota natural areas, respectively.

     The data are summarized by study site in  Table 1.  All data from outside the
 Dow Chemical -  Midland Plant  are  displayed  in  Figure 3.   These  data  clearly
 indicate that  surface  soil  concentrations  of 2378-TCDD found in  Midland are
 significantly higher than In the  Midland upwind  samples and in samples from any
 of the comparison  sites.   2378-TCDD  was  detected in  all  but one  sample  from
 Midland (see Appendix D, Table  2; Sample D-l-L was obtained  from the Dow Corning
 plant at a  site  that appeared  to have  been recently  disturbed).   No 2378-TCDD
 was detected in  the  Minnesota  natural  areas  where EPA's  analytical detection
 levels were in the range of 0.001 to 0.003 ppb.   For Henry,  Illinois, 2378-TCDD
 was detected in  only one  sample at  0.002  ppb;  and  for the   Middletown,  Ohio
 area, 2378-TCDD was detected in a few samples,  with the highest  value reported
 at 0.005 ppb.  The duplicate upwind  samples for Middletown  contained 2378-TCDD
 at 0.003 and 0.004 ppb.

     Targeted sampling inside the Dow Chemical  plant  yielded  two  of the  three
 2378-TCDD surface soil  concentrations detected  above  1.0 ppb  (Figure  4).   One
 was found near the  hazardous waste  incinerator and  another  was  found  at the
 periphery of an  abandoned  trichlorophenol production  facility.  The third high
 concentration area was  found at  a randomly  selected  site  near railroad tracks
 located in  the  northeast  section  of  the  1500-acre  plant.   The  incinerator
 and trichlorophenol  sites  had  concentrations  in the range of  3  to 5 ppb  2378-
                                        10

-------
                                         TABLE 1

                                        2378-TCDD
                        Screening Survey at Four Midwestern Sites
                                    Summary of Results
A.  Midland, Michigan Area

      Upwind Sites
        Open Areas
        Downspouts
      Dow Chemical Midland Plant
      Dow Plant Perimeter
      City of Midland
        Public Use and Residential  Areas
        Residential Open Areas
        Residential Downspouts

B.  Henry, Illinois Area

      Upwind Sites
      Perimeter Sites
      Residential Areas

C.  Middletown, Ohio Area

      Upwind Samples
      Perimeter Sites
      Public Use and Residential Areas

D.  Minnesota Natural Areas
Number of
Sampl es
3
2
15
8
33
12
12
2
4
7
2
6
14
Range
(all data in
ND
0.006-0.009
0.01-36.0
0.01-2.03
0.003-0.27
0.009-0.076
0.013-0.27
ND
ND
ND-0.002
0.003-0.004
ND-0.004
ND-0.005
Arithmetic
Mean
parts per bill
0.0075
3.09
0.34
0.06
0.027
0.092

-------
                     Figure 3
              2378-TCDD in Surface Soils
                Four Midwestern Sites
    2.5
    2.0
Q
O
O

 I   1.0
CO
CM
    0.5
       N
                    Geometric Mean
                    Arithmetic Mean
                  //
                 <—t-
                  &
           #/'
               /
            CDC LEVEL OF CONCERN
            FOR RESIDENTIAL SOILS

-------
                                   Figure 4
                          2378-TCDD in Surface Soils
                         Dow Chemical-Midland Plant
1  2
   1
   0L
                                       2378-TCDD (ppb) in
                                       SURFACE SOILS
                       1.0 3.0
                                              L
     3.5        4.0

Concentration (Parts Per Billion)
                                                      4.5 35.5
36.0

-------
TCDD, while the random  site had  a  concentration of 36 ppb.  All other  samples
had less  than  0.5  ppb  2378-TCDD.1   These  results  are  consistent  with  the
results of more  comprehensive independent sampling  conducted by Dow Chemical
that confirmed a few areas with relatively high concentrations above 1 ppb near
chlorinated phenols  production  areas  and  widespread  site  contamination  by
2378-TCDD in the range of a few parts per trillion up to 1.0 ppb. 4/

    One value above  1.0 ppb  (2.03  ppb) was found  on  the  east perimeter of the
Dow plant  adjacent to the  Union  Carbide Corporation  -  Linde Division  plant
(Figure 5).  Supplemental  sampling  by Dow Chemical  indicates only a  limited
area of high concentration. 5/  As a result of discussion with USEPA  Region V,
Dow Chemical has enclosed a Targe  area around  the  site  with fencing to  prevent
inadvertent public access.

    As shown in Figure 6, the  residential  and  public  use  area  samples with the
highest concentrations of  2378-TCDD were  found to the north-northeast  of the
Dow plant.  That area is downwind of generally prevailing winds with respect to
the plant.   2378-TCDD data from public  use  and  residential  open areas  with
winds generally prevailing from  the Dow plant  (downwind, 0-90ฐ) were compared
with all  other Midland  open   area data  (90-360ฐ).   This  comparison   shows  a
statistically significant  difference  at  the  80*  confidence level  (t-test),
indicating higher deposition in the downwind area.   The  data for all residantial
sites in Midland  show that downspout and roof  dripline  samples had an  average
concentration higher  than  the  average  concentration for  samples obtained from
open yards by  a  factor  of about 3.4.  The distribution  of  these data are such
that there  is  a  statistically  significant  difference  in   the  open area  and
downspout data at the 95% confidence level (t-test).  These data are consistent
with the hypothesis that air  emissions from Dow Chemical  are the likely source
of dioxin found in Midland outside the plant perimeter.

    Estimates were  made of  upper  bound  (99th  percentile)  concentrations  of
2378-TCDD that might be  expected  in Midland outside the Dow Chemical plant.  The
distribution of 2378-TCDD  in  Midland soils is  displayed in  Figure  7.  The data
appear to  be distributed in  a log-normal fashion,  as  are  data for  Dow plant
     ilJSEPA, the  state  of  Michigan,  and  Dow  Chemical  have  entered  into  a
consent order  pursuant  to  Section  106  of the  Comprehensive  Environmental
Response, Compensation,  and  Liability  Act  (Superfund)  which  requires  Dow
Chemical to cover two  of the three  high  concentration areas with asphalt.  The
purposes of  the covering  are  to prevent  worker exposure  to high  levels  of
2378-TCDD and to prevent possible migration  of  2378-TCDD  off-site by windblown
dusts.  The third area of  high concentration (near the hazardous waste inciner-
ator) is not generally accessible and will be considered as part of a long-term
remedial investigation of  the Dow plant  which  will  likely include supplemental
soil sampling in and around the perimeter of the plant and ground water quality
evaluations.
                                       14

-------
                            Figure 5
                     2378-TCDD in Surface Soils
                Perimeter-Dow Chemical-Midland Plant
I  3
I  2
                              2378-TCDD (ppb) in
                              SURFACE SOILS
                        f
                   0.5  1.
                    Concvntr
                                1.5
                         ition (Parts Per Billion)
2.0

-------
Figure 6
2378-TCDD
SURFACE SOIL CONCENTRATIONS
MIDLAND. Ml
                              2378 • TCDD
                           (PARTS PER BILLION)
                           1+

                           0.5-1.0

                           0.1 - 0.5

                           0.05 • 0.10

                           0.001 - 0.05

                           OPEN AREA SAMPLE

                           DOWNSPOUT SAMPLE
                                                                      25.0 	
                                                                      36.0)
DOW
CORNING
                                            DOW
                                            CHEMICAL
                                            COMPANY
                                                      CONSUMERS POWER CO.
                                                      COOLING PONDS

-------
o
w
0

1
   9

   8
(0

I  6
(0
co  5
4

3

2

1

0
                         Figure 7
                   2378-tCDD in Surface Soils
                       :ity of Midland
                      2378-TCDD (ppb) in
                      SURFACE SOILS
            .05     .10     .15      .20

                   Concentration (Parts Per Billion)
                                         .25

-------
perimeter (Figure 5).   Although  the  quantity  of data  is  not  sufficient  to
statistically determine  the  distribution   of   these  data  (Chi-square  test),
log-normal  statistics  were  used  to  estimate  99th  percentile   surface  soil
concentrations that may  be expected in  public use and  residential  areas,  at
residential  downspouts, and near  the perimeter of the Midland plant.  The  use
of lo^-normal statistics provides higher estimates of expected 99th  percentile
concentrations than would normal  statistics.  Accordingly,  99% of the open area
surface soil concentrations of 2378-TCDD in Midland away from Dow  Chemical plant
perimeter are expected to be less than 0.21 ppb; 99% of the residential downspout
area surface soil concentrations are expected to be less  than 0.43 ppb; and 99%
of the surface soil  concentrations  encountered near the  perimeter of the plant
are expected  to  be less than 3  ppb.   Based upon  these  values  and  the  public
health reviews of  the data  (Appendix  E),  further efforts to more  completely
characterize 2378-TCDD surface  soil concentrations in the city   of  Midland do
not appear  warranted.   The  probability  of  finding  significant  levels  of
2378-TCDD (e.g.,   greather  than  1  ppW  away  from the  perimeter of  the  Dow
Chemical  plant appear to  be quite  low.  Supplemental sampling near the perimeter
of the Dow Chemical Midland Plant to detect additional  areas that may have high
concentrations will be considered as part of the  remedial  investigation  of the
facility.

    The Dow  Chemical  hazardous  waste  incinerator  is  reported to be  the most
significant current source of 2378-TCDD air emissions from the Midland plant. 4/
Estimated current  annual  emissions  based  upon  emission  sampling  programs
conducted by  Dow Chemical  are about 0.33 gram. 4/  Estimated annual emissions
from several  other documented sources  (Midland plant powerhouse;  564,  1009 and
1058 Building burners; 2,4-D  chlorinolysis  vent; 2,4-D  process  scrubber vent;
and dichlorophenol process scrubber vent)  total  less  than 0.02  gram. ฃ/  Dow
Chemical  has  also "fingerprinted"  the dioxin found in Midland soils with various
in-plant sources through  isomer-specific analyses  of  tetrachlorodioxin Isomers
(TCDDs).  The conclusion made by the company from this work is that TCDDs found
in Midland  area  soils are similar, though  not  identical,  to TCDDs  found in
incinerator ash and incinerator stack particulates. 4/

    The computed geometric mean concentration  of 2378-TCDD from Midland public
use and residential  areas  is 0.03 ppb (Table  1).   Thirty-seven  percent of the
27.9 square  mile  surface  area  of the  city  of  Midland is  estimated  to be
impervious  (e.g.,  paved  areas, building  roofs). 6.7/   Assuming the  depth of
dioxin contamination is about six  inches (see sample D-2-6,  Table  2, Appendix D),
and there is  no dioxin on  impervious surfaces, the mass of 2378-TCDD in Midland
away from the perimeter  of the Dow  Chemical  plant is  estimated at about 500 gm
(1.10 Ibs).   From these  data,  it  is  obvious that  estimated  current  annual
emissions from Dow Chemical  cannot acccount  for  the  mass of dioxin  found in
Midland soils.  Accordingly, past emissions  from Dow Chemical waste incineration
operations  and  other  processes   must  account  for the  vast  majority  of the
2378-TCDD currently  found  in Midland  soils.   Based upon personal observation,
it appears  possible  that windblown  dusts from  contaminated surface soils  in the
plant may have also  contributed to  contamination outside the plant.
                                       18

-------
    Dow Chemical began  Incinerating  chemical  process wastes  at Midland during
the 1930s.  4/  Incineration  operations were  upgraded  from  time  to  time  in
response to changing production at the plant and more restrictive air pollution
control regulations.   The  combustion  conditions  and   air  pollution  control
systems for  the hazardous waste I incinerator  were last  substantially upgraded
during the 1978 to  1981 period. 4/   With  changing production  operations at the
plant, changes  1n  incinerator  operations,  and without actual  emission data,  it
is not possible to  estimate  annual  emission rates before  the  1978-1981 period
with a high degree  of confidence   However, based upon  incinerator practice at
Dow Chemical, It is  likely that higher emissions occurred  prior to 1978.  Average
annual emissions  from  1930 to  1
account for the  current levels (
was computed assuming steady stat
in the environment  of  12 years.
                                 978  of  about  40 grams  would be  necessary  to
                                 f 2378-TCDD  in Midland  soils.   This  estimate
                                 B conditions and with a half-life for 2378-TCDD
                                 8/  A  wide range of estimated  average annual
emission rates could be  made.   TlRe magnitude of the emission  rate  estimate is
heavily Influenced by  estimates of the  mass of dioxin  in Midland  soils,  and
assumptions regarding the half-life  of 2378-TCDD  in  soils and other  factors.
Depending upon assumptions made, one  could  conclude that the  estimated current
mass of 2378-TCDD  in  Midland  soi
(longer half-life  and  correspon
estimated mass of 2378-TCDD is at
half-life and corresponding higher emission rates).
                                  s is in the upper  range  of historical  values
                                 ling  lower  emission  rates),  or  the  current
                                  the lower range of historical  values (shorter
    Given  the  order-of-magnitude  nature  of
historical data, it is not possible to estimate
                                                these  estimates  and  lack  of
                                              historical exposures of 2378-TCDD
                                 of  certainty.    Nonetheless,  these  estimates
                                 n  in  Midland from soils were  somewhat  higher
                                       Public exposure  to  dioxin from Midland
                                     future.  Atmospheric  emissions  from  Dow
                                 ignificantly  reduced,  and  the  current  soil
burden should continue to decrease  slowly over time.
to the  public  with  any  degree
suggest public exposures  to  diox
in the  past  than current  exposures
soils will likely  decrease  in  ;he
Chemical have  apparently  been  ;
                               lard
    B.  Other PCDDs and PCDFs

    Tables 7, 8, and 9 of Appendi
selected samples  from  the Midi
natural  areas,  respectively.
certain qualifications and limitations
other PCDDs  and PCDFs.   Samples
relatively low levels  (<0.5 ppb)
These data appear to  be  consistent
the Minnesota natural  areas (Tabl
in Middletown, Ohio  (Table 8).  Li
'ligh ppb levels of several PCDDs
nore extensive  data  developed bj
lost samples  obtained  from Midli
n'gher levels of PCDDs and PCDFs
the comparison  sites.   The  dist
sublic use area samples  is  generlally
  x D present data for other PCDDs and PCDFs for
     area;  Middletown,  Ohio;  and  the  Minnesota
Reference  is  made to  Appendix  C,  page  3,  for
         regarding  analyses  of soil  samples for
   obtained upwind  from Midland  (Table  7)  had
   of HyCDDs  and  OCDD and  no detectable  PCDFs.
     with  "natural  background" levels found  in
    9)  and  levels  found in most  samples obtained
  mited  data for the Dow Chemical  plant indicate
  and PCDFs.  These results are in the range  of
  '  Dow  Chemical  for  the  Midland plant.  4,9/
  nd  public use  areas contained  significantly
  than found  at the Midland upwind sites  and  at
   ibution   of PCDD homologues  in the Midland
       consistent  with that found  in  hazardous
                                       19

-------
waste and chemical  waste incinerator emission  samples. 9.10/   Relatively  low
levels of 2378-TCDD were found compared to relatively high levels of HyCDDs  and
OCDD.  These data  further  support the hypothesis that  air emissions  from  Dow
Chemical have been the primary source of dioxins found In Midland.

    The data for  the Middletown,  Ohio,  upwind samples  appear to  be  somewhat
anomalous (Table 8).   Samples  13377  and  13400 were  duplicate  field  samples
obtained at the same location.  The data for 2378-TCDD show excellent agreement
(0.003 ppb and 0.004  ppb).   However data  for  HgCDDs,  HyCDDs,  and OCDD do  not
agree.  Also, as discussed  below,  data for other toxic  organic pollutants  for
these samples are not in complete agreement.

    Bumb, et.al.. suggest that chlorinated dioxins are by-products of combustion
of most types  of organic material  and are widespread  in  the  environment,  ll/
Czuczwa, et.al., suggest the  most  significant  source of PCDDs and PCDFs to tFe
atmosphereTTsthe   combustion of  domestic and chemical  wastes that  contain
chlorinated compounds. 12/  USEPA has reported  findings  of 2378-TCDD and  other
TCDDs in  municipal   waste   combustor  emissions, and there  have been  several
studies completed in Europe with similar findings.  13,14/

    Data from this  study demonstrate the  highest levels  of 2378-TCDD and  other
PCDDs were found at and  near  the Dow  Chemical  - Midland Plant  where 2,4,5-tri-
chlorophenol and derivatives were manufactured  and where significant amounts of
chlorinated compounds and  other chemical  process wastes have  been  incinerated
over a  long period  of time.  Trace levels of 2378-TCDD and other  PCDDs found in
a few  of the samples obtained near other  industrial  sites  with processes  and
combustion operations different  than  those at  Dow  Chemical  may  be related to
fallout from combustion. The distribution  of  the data  at the  other industrial
sites do  not  suggest a dominant  local  source.   Four  natural  areas had no
detectable 2378-TCDD  and only trace  levels  of HyCDDs  and  OCDD.   These  low
levels  may also be  related  to  combustion.

    The results  of  this  study do not suggest widespread contamination by 2378-
TCDD, other  PCDDs  and PCDFs at  levels that may be  significant with respect to
public  health  or adverse environmental  impacts.   EPA's  National Dioxin  Study
should  provide sufficient data to  characterize  the extent  of 2378-TCDD contami-
nation  in  the  United States and more  information about dioxins  and combustion
(Tier 4).

     C.  Other Toxic Chemicals

     Selected soil samples from the Midland area; Dow Chemical;  Middletown, Ohio;
and the Minnesota  natural   areas were  subjected to  broad scan  organic chemical
analyses  for  acid  compounds,  base/neutral  compounds, and  pesticides,  including
PCBs at low ppm  and high  ppb detection levels.  These  data  are presented in
Appendix  D,  Tables  11,  12,  and  13.   The  results  are  somewhat unexpected in
 that relatively  few  compounds were  quantitatively  detected  in most samples,
particularly those  from  inside the Dow Chemical  plant.   The major distinguishing
                                        20

-------
feature of these  data  1s the hit
carbons (PAHs)  found  In  Middlet
Middle town Works steel  plant (Tab
by-product coke  plant  operated
for duplicate  field  samples  pbt
Middletown appear  somewhat diffe
relatively low In  concentration
had 13 PAHs detected In  the 1-2
six detected.  Not all  of the det

    Phthalate compounds  were  de
levels) in many samples at and si
Including some of those from Minne
potential low-level  widespread
environment or  potential  low-lev
addition to  the data  reported
organic compounds were  tentativel

    0.  2378-TCDD in Municipal Se
    USEPA did not achieve the qua
for 2378-TCDD analyses of the Mid
sewage sludge  samples.   The  com
(Appendix C, Appendix D,  Tables
reported 0.021 ppb (49% recovery)
(69% recovery).  Dow  Chemical d
data Indicate low-level  contamina
surface runoff entering the  sewe
these data about comparable  leve
municipalities.  Lamparski,  et.a
(0.002, 0.011,  0.016  ppb)  from
sewage sludge  sold  as a  fertili
TCDDs found In those samples is su
resulting from  the  chlorination
potable waters  and  wastes.  15/
plant include intermittent chTori
chlorination of  the  trickling  f
practices could  result  in chlor
reacting with the sludge which is
system.  Sufficient data  are  no
findings of 2378-TCDD in  municipa

The amount of 2378-TCDD in Midi an
of the  sludge  as a  soil  conditio
conditioner for  tree  plantings  b
used in the past by some Midland
to 2378-TCDD from sewage sludges
population in Midland.
ler  incidence of  polynuclear  aromatic hydro-
 wn  samples  taken  near  the  ARMCO,  Inc.  -
 e 12).   The  likely  source of the PAHs is the
 y  ARMCO,  Inc.   As  noted above,  the  data
 ined  from  the upwind  sampling   station  near
 ent.   Although  the  analytical   results  are
or both  samples, the duplicate  field sample
 Dm range,  while  the original  sample had only
cted compounds were the same in both samples.

ected  (below contract  laboratory  detection
 htly  above levels found in laboratory blanks,
 ota natural areas.  These  data indicate either
 istribution  of  phthalate compounds  in  the
 1  phthalate  contamination of   samples.   In
  Tables  11-14  for toxic pollutants,  other
 identified in certain samples (Tables 15-18).

 age Sludges
ity assurance objective for surrogate recovery
and, Michigan and Middletown, Ohio, municipal
lex  sample matrices  caused  poor  recoveries
  4).   For the Midland  sludge  sample, USEPA
and Dow Chemical reported 0.019 ppb 2378-TCDD
  not analyze  the  Middletown  sample.   These
ion of  the Midland sludge that may be due to
age system.   No statements  can be made from
s in  sewage sludge from Middletown  or other
    report  2378-TCDD  at  similar  low  levels
samples  of Milorganiteฎ,  a  dried municipal
er. 15/   The  source  of 2378-TCDD  and other
gestecTto be the condensation of chlorophenols
f  naturally occurring  phenolic  compounds in
Operations at  the Midland  sewage treatment
ation of final effluent filters  and occasional
Hers to  control   excess growth.  16/   These
lation products and  free available chlorine
Itimately processed in  a thermal wet oxidizing
  currently available   to  fully resolve  the
 sewage.

 surface soils cannot be accounted for by use
er.   The sludge is currently used as  a soil
  the  Midland parks  department and  had been
•esidents for similar purposes. 17/  Exposure
  not  likely to  be  significant for  the general
                                       21

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VII.  CONSIDERATION OF PUBLIC HEALTH RISKS

      All  of  the   data  from  this  study  and  supplemental  2378-TCDD  data  for
  Tlttabawassee River fish and 2378-TCDD  ambient  air data in and around  the  Dow
  Chemical  plant were forwarded for review to the U.  S.  Department  of Health  and
  Human Services,  Public Health Service,  Centers  for Disease Control  (CDC),  and
  USEPA's Chlorinated Dioxins Work Group  (CDWG).   Table 2 presents a  summary of
  the fish, ambient air, and soil  data provided to  CDC.  Appendix  E  (Attachment 1)
  presents the CDC  review of health  risks associated with exposure  to 2378-TCDD,
  other PCDDs  and  PCDFs  and  other  toxic  chemicals  found  in  Midland  soils,
  Tittabawassee River fish  and ambient  air.  The  CDWG applied its  recommended
  "2378-TCDD equivalents"  approach  to  public  use  area  soil  samples  with  the
  highest levels of PCDDs and PCDFs to determine if  those  samples would indicate
  potential public  health  risks  due to higher  chlorinated PCDDs and  PCDFs (see
  Appendix E,  Attachment  2).   The  major  conclusions   from  these  reviews  are
  presented below:

      1.  Current levels  of  2378-TCDD  in Midland  residential  soils,  including
          downspout areas, are well below one part  per billion and do not represent
          an unacceptable public  health risk.

      2.  Ambient air levels of 2378-TCDD, as characterized  by  limited available
          data, are  unlikely to  be  a  risk from   bioaccumulation  through  the
          respiratory route.

      3.  The warning on  consuming  fish  from  the Tittabawassee River  should be
          continued.

      4.  The levels in  soils of other PCDDs, PCDFs, and other chemicals all less
          toxic than 2378-TCDD, do  not  represent  an unacceptable  public  health
          risk.

      5.  The available data  represent  current  soil  levels and the CDC  can make
          no comment  about  past  environmental  levels  and  potential   risks that
          may have existed in the  past.

      Potential public health  risks  will  be reviewed  again  when  complete data
  from the multi-media investigations are available.
                                         22

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                                                         TABLE  2

                                                        2378-TCDD
                                       Summary  of Recent Environmental Measurements
                                                  Midland,  Michigan  Area
Number
of
Measurements Range
Ambient Air* (March 1983-February 1984)
Total - all measurements
Dow Plant
Dow Plant Fence Line
City of Midland
	 *Data provided by Dow Chemical Company 	

CO
Tittabawassee River Fish (August- September 1983)
Carp - whole fish composite (5 fish)
Carp - individual skinless fillets
Catfish - skinless fillet composite (5 fish)
Smallmouth Bass - skin-on fillet composite (5 fish)
Walleye - individual skin-on fillets
Surface Soils (October-December 1983)
Dow Plant
Dow Plant Perimeter
Public Use and Residential Areas
Residential Areas*
Residential Downspouts*

10
2
6
2




1
25
1
1
5

15
9
17
8
8

0.010-0.21
0.019-0.022
0.010-0.21
0.019-0.16




190
12-530
75
5.1
2.8-5.1

0.01-25.0
0.01- 2.03
0.003-0.17
0.009-0.076
0.013-0.27

pg/m3
pg/m3
pg/m3
pg/m3




ppt
ppt
ppt
ppt
ppt

ppb
ppb
ppb
ppb
ppb
Arithmetic
Mean

0.061
0.021
0.064
0.090





50


3.9

2.38
0.74
0.037
0.025
0.104
Arithmetic
Standard
Deviation

0.069

0.075






102


0.8

6.41
1.43
0.042
0.022
0.103
Geometric
Mean

0.036

0.038






28.6


3.8

0.24
0.17
0.026
0.020
0.062
*Data for four additional sites available 12/15/84.

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                                    REFERENCES
 1.  Dioxin  Strategy,  Office  of  Water .Regulations and  Standards, Office of Solid
     waste and  Emergency Response, Dioxin Strategy Task Force, U.S. Environmental
     Protection Agency, Washington,  D.  C.,  October 20,  1983.
 2.   State of  Michigan   and   USEPA  Region V  Study of  Dioxins and Other Toxic
     Pollutants;   City of Midland,  Dow Chemical ,  and Michigan Rivers;  quality
     Assurance  Project  Plan,   USEPA   Region  71  Central  Regional  Laboratory,
     April  1,  1984.

 3.   Jones, D. R., Craig, J.,  Blending  and  Aliquoting  of  Soil  Samples,  IIT
     Research  Institute,  Chicago,  Illinois, December 19134.

 4.   Point Sources and Environmental Levels of 2378-TCDD (2,3,7,8-tetrachlorodi-
     benzp-p-dioxln)   on  the Midland   Plant Site of the Dow Chemical Company  and
     in the City of Midland, Michigan, Dow  Chemical  Company, Midland, Michigan,
     November 5,  1984.

 5.   Rio, J. M., Chairman Dioxin Initiatives Team, Michigan Division, Dow Chemical
     U.S.A., Midland,  Michigan to  (Gary  Amendola,   USEPA   Region V,  Eastern
     District Office,  Westlake, Ohio)  November 15, 1984, ALS, 3 pp.

 6.   Personal  communication from  James  Schrader, Planning  Department,  City of
     Midland,  May 1985.

 7.   Combined Sewer Overflow Analysis  Handbook for use in 201 Facility Planning;
     Volume 1  - Procedures and Example Analyses, E.  D.  Driscol  and Associates,
     Inc.,  EPA Contract No. 68-01-6148, prepared  for USEPA, Facility Requirements
     Division, Policy  Guidance Branch, February 1983.
 8.   Kimbrough,  R. D., Falk, H.,  Stehr,  P.,  Fries,  G., "Health Implications of
     2,3,7,8-Tetrachlorodibenzo  dioxin (TCDD) Contamination of Residential Soil,"
     Journal  of  Toxicology and Environmental  Health,  14:47-93,  1984.

 9.   Point Sources and Environmental  Levels of  2378-TCDD  (2,3,7,8-tetrachlorodi-
     TSenzo-p-dToxin)   on  the Midland  Plant Site  of  the Dow Chemical Company and
     in the city of Midland, Michigan (database),  Dow Chemical  company, Midland,
     Michigan, November 5, 1985.

10.   Review and  Development of   Chlorinated Dioxins  and Emissions Data  (draft),
     Radian Corporation,  Durham,  North  Carolina, EPA Contract No. 68-02-3513,
     March 1983.
                                        24

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                                    REFERENCES (continued)


11.  Burnt),  R.  R., Crunmet, W. B., Cutie,  S.  S.,  Gledhill,  J.  R.,  Hummel,  R.  H.,
     Kagel, R.  0., Lamparski, L. L.,  Luoma, E.  V., Miller, D. L., Nestrlck,  T.  J.,
     Schadoff,  L. A., Stehl,  R.  H., Woods, J.  S.,  "Trace Chemistries of F1re:
     A Source  of Chlorinated Dioxins,"  Science, 210:385-390,  1980.

12.  Czuczwa,  J. M., McVetty,  B.  D.,  Kites,  R. A.,  "Polychlorlnated  D1benzo-p-
     Dioxins and  Dibenzofurans  in  Sediments from Si ski wit Lake, Isle Royale,"
     Science,  210:568-569, 1984.

13.  "Interim  Evaluation  of Health Risks Associated  with Emissions of  Tetra-
     chloroinated Dioxins  from Municipal   Waste  Resource  Recovery  Facilities,"
     Office of the Deputy Administrator, USEPA, November 1981.

14.  "TCDD Emissions for Municipal  Waste  Combustors,"  Office  of  Solid Waste  and
     Emergency Response, USEPA (memorandum), December 16, 1983.

15.  Lamparski, L.  L. Nestrick, T. J., Stenger, V. A.,  "Presence of Chiorodibenzo
     Dioxins  in  a  Sealed  1933  Sample  of  Dried  Municipal  Sewage Sludge,
     Chemosphere, 13:361-365, 1984.

16.  Personal   communication  with Merlin  Lavkack,  City  of Midland,  Wastewater
     Treatment Plant, June 1985.

17.  Personal   communication with   George Young, City  of Midland,  Wastewater
     Treatment, June 1985.
                                        25

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                   APPENDIX A

Soil Screening Survey at Four Midwestern Sites;
      Draft Study Plan, September 22, 1983

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                                                                               Draft
                                                                            9/22/S3
                             SOIL SCREENING SURVEY
                                         AT
                             FOUR MIDWESTERN SITES
INTRODUCTION

Limited data published by Dow Chemical suggest that dioxins are present in soils in the
city of Midland in the parts per trillion range and somewhat  higher within the Dow
Chemical - Midland Plant boundaries. Dow Chemical has also reported limited data in the
same range for other cities.  There are currently not enough data available to adequately
assess whether the levels of dioxins reported by Dow Chemical represent typical levels in
Midland or whether higher levels that may be of concern from a  public health standpoint
may be  found at certain locations.   There are also not  sufficient  data  available to
determine whether  dioxin levels reported  by Dow Chemical  for  Midland  and other
locations are  representative of "background" levels that might  be found in almost any
location.  Finally, there are no substantial soil data available for Midland and other
locations for  several other  toxic pollutants that are emitted or  discharged from Dow
Chemical operations and other chemical and industrial operations.  The design of this
study is based upon the premise that the primary method by which surface soils become
contaminated is from deposition of air emissions from  point sources  of the pollutants.
While other methods of soil  contamination are possible (e.g., application of pesticides or
contaminated sewage sludges, land disposal of contaminated solid and liquid  wastes))  air
deposition is the most likely method of contamination of surface soils in the study areas.

This  study is planned  to address some of the above questions.  Although  the study is
principally ah environmental study, it  is being conducted  to provide sufficient data to
state and federal  health agencies such that they can determine whether there is a health
concern,  and  whether comprehensive  health-related  studies  or  remedial  action are
warranted.   For  each city, several samples will be taken in areas with the greatest
likelihood of showing contamination.  Thus, positive results should represent worst-case
conditions in each case and the need  for any  health-effects studies can be determined
accordingly.  The results from  this study will be  evaluated by EPA, the  Centers  for
Disease  Control,  and the  respective  state  agencies.   After the  results have been
evaluated, the results and  all  conclusions  regarding possible  health effects will be
presented to  federal, state,  and local elected officials prior to publication of any
information.

OBJECTIVES

The objectives of  this screening study are as follows:

 1.   To provide sufficient data such that state and federal health agencies can determine
     whether more comprehensive health-related environmental  soil studies  or  remedial
     clean-up actions are warranted.   Should more  detailed health-related studies be
     required, supplemental sampling,  analytical, and quality assurance protocols will be
     developed and  implemented. The results from this study should be compatible with
     those that may be obtained in future studies.

 2.   To determine the levels of PCDDs and PCDFs at the parts per trillion level and other
     toxic organic pollutants at the parts per billion level in soils from four midwestern
     sites with contrasting levels and  types of industrial development.  These data will

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                                        -2-


    indicate  whether levels  of  dioxins reported by Dow Chemical for several locations
    represent "background" conditions; and allow for comparison of levels of dioxins and
    several other toxic pollutants at different sites. Pollutants  to be studied in addition
    to PCDDs and PCDFs include PCBs, pesticides,  acid pollutants (principally chlori-
    nated  phenols), and  base/neutral  pollutants (principally  chlorinated benzenes and
    polynuclear aromatic hydrocarbons).  Data for these pollutants are necessary to assist
    in the interpretation of the data  for PCDDs and PCDFs and  to focus  ambient air
    sampling, point source emission sampling, and in-plant soil sampling at Dow Chemical
    which  will follow this study. Volatile pollutants are not being studied since they are
    not  likely  to  be found on soils  and  because their  physical/chemical properties
    generally  make  them  less persistent  in  the  environment  than  other  types of
    pollutants.

3.  To distinguish  any patterns in soil contamination that may  indicate whether and to
    what extent the Dow Chemical -  Midland Plant is a source of pollutant contamination
    in Midland, Michigan.

4.  The  analytical objectives. for the  compounds to be  studied including  limits of
    detection, levels of quantitation, precision, accuracy, completeness and comparability
    are  specified  in the analytical protocols  and quality assurance plan for this  study
    presented in Attachment A.

THE FOUR MIDWESTERN SITES

1.  Midland, Michigan

    The,-city-of Midland has  a population of about 35,000 people.  The major industries are
    the  Midland Plant of the Michigan Division of Dow Chemical Company and the Dow-
    Corning  Silicone Products  Plant.  The  Dow Chemical - Midland Plant  falls within
    Tiers 1,  2, 3, and  * of the  U.S. EPA  National  Dioxin  Strategy  in  that 2,*,5-
    trichlorophenol (2,4,5-TCP) was produced  (Tier 1); 2,4,5-TCP was used  to  make
    pesticide products (Tier 2);  2,4,5-TCP and derivatives were formulated into pesticidal
    products (Tier 3)j and, the plant is  also a  combustion  source (Tier 4).  Based  upon
     limited data published by  Dow  Chemical  and Dow Chemical's status  as a former
    producer and user of 2,^,5-TCP, dioxin contamination in the Midland area at some
    level is expected.  Based upon other production operations  at Dow  Chemical, other
    toxic pollutants are likely to be present as well. Sewage treatment plant sludge from
     the  Midland sewage works has reportedly been used as a soil conditioner in Midland.

2.   Site 2

     The second  midwestern  site  will  be  a  municipality with  significant  chemical
     production facilities and other combustion sources. The site will not be a Tier 1 or
     Tier 2 site as defined by EPA's draft  National Dioxin Strategy.

3.   Site 3

     Site 3 will be a municipality  with significant industrial production facilities largely
     unrelated  to  chemical  manufacturing.   These facilities are  likely to include an
     integrated steel plant. This site will also not be a Tier 1 or Tier 2 site.

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                                        -3-
*•  Siteป

    Site 4 will be a rural site that should be largely unaffected by any nearby industrial or
    municipal point sources or nearby major combustion sources.

SAMPLING DESIGN

For the  three  municipalities with significant industrial point sources, sampling will  be
conducted around the perimeters of the industrial plants as well as in public use areas such
as parks, playgrounds, and schoolyards.  The public use areas will be selected to show
possible  pollutant gradients with distance from  the  sources.   For the  rural site, soil
sampling  will be conducted in  open areas and at residences.  Background  samples well
away from each city will also be collected.  For Midland, Michigan, and Site 2, sampling
will also be attempted at private  homes located on concentric rings around the industrial
facilities. The results of the residential sampling will be used to determine if  there is a
pattern or trend of pollutant concentrations with distance from the industrial facilities.

1.  Sampling Sites

    a.   Midland, Michigan

         Air quality  modeling  conducted  by the  Michigan  Department  of Natural
         Resources,  Air Quality Division, suggests that  ground level concentrations  of
         contaminants released from  the Midland Plant will be highest near  the north
         fence line of the plant.  Thus, samples taken around the perimeter of the Dow
         plant  will be concentrated in that  area as opposed to equally  spaced samples
         arosnd the entire perimeter.  About 11 plant perimeter samples wUl be taken.
         The plant perimeter samples are likely to have the highest contaminant levels.

         Wind  patterns  at Midland indicate  that  winds  are from  the northwest  to the
         south-southwest about  55 percent of  the time, Figure 1. Thus, heavier deposition
         of pollutants emitted  by Dow Chemical operations may be expected in  an arc
         from the north-northeast to the southeast. Sample sites at public use areas and
         residences  will be concentrated  in this  arc  rather  than  randomly  spaced
         throughout the  city.

         To determine possible levels of exposure in  public use areas, about 11 samples
         from schoolyards, parks, and playgrounds will be obtained. Core samples  will  be
         obtained at selected locations for possible future analyses.

         Sampling at private  residences will be conducted for two purposes:   (1) to
         supplement the public use area sampling described above, and (2) to determine if
         there is a trend  or pattern of pollutant concentrations with distance from the
         Dow plant.   Airborne particles  tend to collect on exposed  surfaces such  as
         building roofs.  These particles then can  be washed from the roofs by subsequent
         rains,  caught  by  the  gutters,  and  deposited  in the  soils surrounding the
         downspouts.  Dioxins and related pollutants are known to adhere to soil and dust
         particles. Since  downspouts  are good concentrators of airborne dusts and soil,
         soil samples obtained  in the  vicinity of downspouts can serve as  indicators  of
         environmental  contamination.   Additional  soil  samples  from   yard  areas
         unaffected  by  roof drainage will  provide information  on ambient  levels  of

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   pollutants and will indicate  possible contamination  by routes other than air
   deposition,  such as direct application  of pesticides or contaminated sewage
   sludges. Efforts will be made to assure that the samples collected at the various
   sites are comparable.  Sampling conditions will be made as similar as possible for
   each sample type and location.

   The 20 residential sampling locations are arranged in four concentric rings at
   varying distances from the center of the  Dow Chemical - Midland Plant.  The
   residential samples taken from the first (innermost) and third concentric rings
   will be analyzed first.  The remaining residential samples will be collected, but
   analyses will be contingent upon findings from analyses of the first set. At each
   residence three  samples will be taken:  (1) a composite of  individual samples
   taken within  one foot of the downspout, (2) a composite of individual samples
   taken about three feet from the downspout, and (3) an open yard  composite
   sample taken away from the downspout.  If higher concentrations of pollutants
   are found at the outer (three foot) downspout ring than at the inner (one fool)
   ring, this may indicate that emission rates from potential point sources are lower
   now than in the past, or that pollutants are migrating away from the downspout.

   Figure 2 presents tiie approximate sample site locations for the plant perimeter,
   public use area, and residential sampling.  (Note that a few of the  residential
   sampling sites are located within the boundaries of the Dow Corning plant.  If
   possible, downspout sampling from buildings will be conducted. If not, open area
   samples will be obtained.) In addition, about 10 samples of  dust or soil will be
   collected from areas near the Dow Chemical plant gates likely to reflect track-
   out of pollutants by foot or vehicular traffic.  Four samples will  be collected
   along the railroad  tracks near the plant boundary. Local background composite
   soil samples  will be collected at four locations upwind of the  Dow plant site,
    about  10 miles  south  and west  of  the facility.  At two  of  the background
    locations, downspout samples will be obtained; and, at  the other two locations,
   public use  areas will be sampled.  Core samples will be  obtained at selected
    locations for possible future analysis.  The results from these samples would be
    used to determine whether higher concentrations of pollutants are found below
    the surface of  the ground.   The field sampling team will also be. instructed  to
    obtain a limited number of  samples from  home roof gutters and  other areas
    where airborne contaminants may collect.  Finally, a sewage sludge sample will
    be  obtained from  the Midland STP to indicate the  possible impact of sludge
    application  on  soil  contaminant  levels.   Sample types  and  numbers  are
    summarized in Table 1.

b.  Site 2

    About ten composite soil samples will be obtained at Site 2.  These samples will
    be from the perimeter of the industrial complex and public use areas that may  be
    impacted by air emissions from local industries.

c.  Site 3

    Sampling at Site 3 will be similar to that for Midland, Michigan. Approximately
    20 to 30 samples will be obtained. These will include perimeter samples around
    the industrial facilities, public use area samples, and residential samples.

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                                       -5-
    d.  Siteป

        About four open area samples and  one residential sample will be obtained at
        Site 4.

SAMPLING METHODS

1.  Residential Samples

    Two samples will be collected adjacent to each residential downspout. These samples
    will be composites  of  several  small cores or plugs arranged  in  two concentric
    semicircles extending out about one foot  and three feet from the bottom of the
    downspout.   Drip lines may be sampled in a composite  fashion at homes without
    gutters as an alternative if a sufficient number  of homes with gutters cannot be
    found.  At sites where splash pads  are used to  divert  rainwater  away  from the
    foundation of the building, a similar procedure will be used.  The composite samples
    will be taken at one foot and three foot rings away  from the end of the splash pad.. A
    third composite sample, comprising a similar number of cores selected from a grid
    will be collected from an area at a distance from  each downspout and isolated from
    the effects of its discharge.  The size of the grid  will be dependent upon the size of
    the yard.   However, grid sizes  between 3 meters by 3 meters and  10 meters by
    10  meters will be sought. The composite sample from the open yard will be collected
    first, followed by the three foot and one foot ring composite samples adjacent to the
    downspout.  Photographs will be taken of each sampling location. Information about
    each sampling site will be obtained from the home owner.

    Areas with bare soil will be sampled preferentially to grassed areas.  Before sampling,
    any grass will be trimmed to just above the. soil surface  at the points to  be cored.
    Next,  the cores, about two  inches  in  diameter  and several inches  deep, will be
    extracted. The top one-inch layer of each core will be shaved off and retained as the
    sample.   The remaining soil  will be  returned to the core holes, and repairs to the
    lawns will be made by refilling the holes with topsoil and plugging with purchased sod.

    As each soil grab sample is taken, the sample will  be placed on a cleaned, disposable
    aluminum pan and  miscellaneous  debris  (e.g., twigs, roots, wood chips,  stones,
    pebbles, and other nonsoil material that can be distinguished) will be removed with
    cleaned tweezers. Since the objective is to determine the concentration of pollutants
    in  soils which can be transferred to  humans through ingestion, inhalation or dermal
    contact, the miscellaneous debris must be removed to prevent biasing the analytical
    results in either  direction.  A new aluminum pan and new tweezers  will be used for
    each composite sample.  The sampling team will  also use new  disposable gloves at
    each composite sample site.  The grab sample will then be deposited in a new, cleaned
    gallon paint can.  This can will become the sample repository for  each composite
    sample.  Each composite sample will be thoroughly blended in  the laboratory to make
    the composite sample as homogenous  as possible.  Aliquots of  the composite samples
    will be shipped blind to the analytical laboratories for  analyses.   Portions of the
    composite sample will be retained for possible future analyses.

2.  Public Use Area Samples

    Composite  soil samples will  be  collected  from a 10 meter  by 10 meter grid, at
    appropriate intervals.  Collection methods will be similar to  those described above.
    Areas with bare soil will be sampled preferentially  to grassed areas.

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                                       -6-


3.  Dow Plant Perimeter Samples

    Plant perimeter samples also will be collected as composites from a grid.  However,
    grid size and shape  may vary depending upon the particular  characteristics of the
    sample location.  The surface soil layer will be sampled at each site.

*•  Track-out Samples

    Eleven track-out samples will be collected from the perimeter  gate areas of the plant
    with the greatest vehicular and pedestrian traffic.   Emphasis will be placed on the
    northwest corner of the plant, where production of pesticides and other  chemicals
    with the potential for dioxin contamination is believed to  have occurred.  These soil
    or sediment samples will be collected from road gutters of low areas likely to receive
    runoff that may have  been contaminated with pollutants carried out of the plant.
    Five of the 11  samples will be analyzed first, with analyses of the remaining  six
    samples contingent upon results from the first five.  Four  samples along the main
    railroad lines  entering and leaving the plant  will be collected and held for possible
    future analyses.

5.  Core Samples

    Core samples  will be collected at selected locations for possible future analyses. The
    core sample will be made up of three separate grab samples,  the first beginning at the
    ground surface to 6  inches in depth, the second beginning at 6 inches to 12 inches, the
    third beginning at 12 inches to 18 inches.

SAMPLE-HANDLING AND  EQUIPMENT

The soil sampling equipment will be a coring device such as a metal tulip bulb planter.  A
new,  cleaned  coring device will be used for each composite sample.  A new, cleaned
disposable  aluminum pan will be used as a receptacle to remove miscellaneous debris from
each set of individual grab samples used to form a composite sample.

1.  Details  on specific sampling  locations with rationale for  the selection of each
    sampling point will  be carefully documented prior to the  time of sample collection.
    The documentation of each sampling location will be maintained in the team leader's
    site log along with information about the site obtained from the home owner.

2.  Log book entries, sample tags, and field record sheets  with identification of sampling
    locations will be completed for each sample and will include date, time, and name or
    initial of the team leader.

3.  Each  sample  container will be identified by  a sample identification tag and  unique
    sample number.

*.  The top one inch of the grab samples for each sampling site will be shaved off with a
    cleaned, disposable  knife.  This sample will be used to form  the composite sample.
     The samples will be kept cool during shipment and when held in  the laboratory prior
    to analyses.   The  sample will  be thoroughly blended in  the laboratory prior  to
     analyses.

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                                      -7-
5.  All of the disposable sampling equipment (coring devices, gloves, knives, aluminum
    pans, and tweezers) will be collected and disposed of under RCRA.

CLEANING OF SAMPLING EQUIPMENT

Each piece of new, disposable sampling equipment will be cleaned in the laboratory prior
to use in the field.   Cleaning will consist of a  soap and water wash, a water rinse, an
alcohol rinse, and a trichloroethylene (TCE) rinse.

Equipment cleaning in the field will not be required. However, the field team will have on
hand appropriate solvents to clean equipment in the field should the need arise.

FIELD QUALITY ASSURANCE

The field quality assurance plan will consist of the following:

1.  In order to verify  that cleaning of new, disposable equipment and sample containers
    has been effective, a second TCE rinse for each type of equipment will be submitted
    in a standard sample container for analysis (the knives and tweezers will be cleaned
    together).

2.  One sample container blank will be carried into the field each day and handled in the
    same fashion as the other sample containers.  Upon reaching the laboratory, a  soil
    sample without 2,3,7,8-TCDD (analytical result N.D. at 1 ppt)  will be placed in the
    sample container blank.  This sample will then be process and  analyzed with actual
    samples.

3.  A duplicate field sample will be obtained at a rate  of one duplicate sample per ten
    samples.  The duplicate sample will consist of a second composite sample container
    filled with one-half of each grab sample obtained from the aluminum pan after debris
    has been removed.

LABORATORY QUALITY ASSURANCE

A comprehensive laboratory quality assurance plan and analytical protocols are presented
in Attachment A.

CHAIN OF CUSTODY

Standard EPA chain of custody procedures will be followed throughout the survey.

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                              TABLE I
                         SAMPLE SUMMARY
     Type
Residential

Public Use Area

Plant Perimeter
Track-out
Municipal Sewage Sludge  1
Background
             TOTAL
Number
of
Locations
20
5
11
5
11
15
Ige 1
_J_
72
Samples
per
Location
3 Composite
3 Cores
1 Composite
2 Cores
1 Composite
1 Composite
1 Composite
1 to 3 Composites

Total
Samples
Collected
60
15
11
10
11
15
1
8
131
Samples for
Immediate
Analysis
30
—
11
~
11
5
1
8
66
The above sample summary does not include field and  laboratory quality
assurance samples. In addition, the field sampling team will be instructed to
collect samples from a limited number of catchment areas (e.g., low spots in
roof gutters, catch basins, etc.).
Note:   A sample summary for Sites 2, 3, -and 4> will be included in the.final
        study plan.
                                 -8-

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                   NNW
NE
          N
   WNW>
                ENE
   WSW
          sw
          SE
                  SSW
                            FIGURE I

Surface Wind Rose at the Midland' Nuclear Plant  (adjacent to Dow
Chemical)*   On.-site data at 10 meters aboveground, March 1, 1975,
through February 28, 1977,  Bars show the direction from which
the wind blows.  Calms are hourly average windspeeds less than
0.3.m/s.

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                                                                  FIGURE  2
                                                      PROPOSED SOIL SAMPLING LOCATIONS
                                                              MIDLAND, MICHIGAN
    DOW CHEMICAL COMPANY
                                     DOW CORNING
          SAMPLE TYPES
     Residential
  A Public Use Area
i  II Plant Perimeter

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                          APPENDIX B

In-Pi ant Soil  Screening Survey, Dow Chemical  - Midland Plant;
             Draft Study Plan, November 28,  1983

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                                                                          Draft
                                                                          11/28/S3
                        IN-PLANT SOIL SCREENING SURVEY
                        DOW CHEMICAL - MIDLAND PLANT
INTRODUCTION
This study is planned in conjunction with the city of Midland soil screening survey being
performed at locations outside  the  Dow Chemical - Midland  Plant.   The data to be
gathered in  this study will supplement data reported by Dow Chemical that indicate the
presence of  dioxins in soils within the Midland Plant. These data will indicate whether
contaminated soils and dusts within the plant may be a source  of contamination outside
the plant from transport  by  winds or trackout, or by transfer through the wastewater
treatment facilities.

OBJECTIVES

The objectives of this study are as follows:

1.   To determine concentrations of PCDDs, PCDFs, and other toxic pollutants in surface
     soils across the Dow Chemical - Midand Plant and specifically in the areas of former
     trichlorophenol production and the waste incinerators.

2.   To compare soil concentrations of PCDDs and PCDFs within the Midland Plant with
     concentrations outside the plant.

SAMPLING  DESIGN

The sampling program will be conducted in two phases.  Phase 1 includes limited surface
soil sampling at selected locations as outlined in this plan. Phase 2, to be conducted at a
later time,  may include  additional  surface soil sampling and core  sampling at certain
locations. The Phase 2 sampling will be  conducted after the results  of Phase 1 sampling
and additional data from Dow Chemical are available.

Sampling will be concentrated in the vicinity  of  former  production facilities involving
2,4,5-trichlorophenol and existing facilities  in which phenoxy chemicals and agricultural
chemicals  are  manufactured, and  the  waste incinerators  and  wastewater  treatment
facilities.  Other samples will be gathered from points  approximately on the centers of
grid squares measuring approximately 3/8 mile  on a side.  The selection of actual sample
sites will be determined on the sampling date by EPA, thus  Dow  Chemical will not have
prior notification of the specific sampling locations.

The attached map shows  the approximate locations of the Phase 1 sampling points.  Four
samples  are to be taken in and near the  703 and 830 Building incinerators, and four
samples  in  the phenoxy (agricultural chemical) area.   Seven additional samples will be
obtained from the grid, as shown. Phase 2 sampling sites will be selected at a later time.

SAMPLING METHODS

Composite  soil samples will be collected at each sampling site from a 10 meter by 10
meter grid, at appropriate intervals.  Areas with bare soil will be sampled preferentially
to grassed  areas.  Areas that  have recently  been disturbed will be avoided.   Before

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          any grass will be trimmed to just above the soil surface at the points to be
cored.  Next, the cores, about two inches in diameter and several inches deep, will be
extracted. The top one-inch layer of each core will be shaved off and retained as the
sample. The remaining soil will be returned to the core holes. The sample site locations
will be staked or otherwise permanently marked at the time of sampling to allow for
positive identification and resampling, as necessary.

As each soil grab sample is taken, the sample will be placed on a cleaned, disposable
aluminum pan and miscellaneous debris (e.g., twigs, roots, wood chips, stones, pebbles, and
other nonsoil material that can be distinguished) will be removed with cleaned tweezers.
Since one of the objectives is to determine the concentration of pollutants in surface soils
which can be transferred to humans through ingestion, inhalation or dermal contact, or
transferred outside the plant by winds  or through the wastewater treatment facility, the
miscellaneous debris must be removed to prevent biasing the analytical results in either
direction. A new aluminum pan and new tweezers will be used for each composite sample.
The sampling team will also use new disposable gloves at each composite sample site.  The
grab sample will then be deposited in a new, cleaned one-gallon paint can.  This can will
become the sample repository for each composite sample.  Each composite sample will be
thoroughly blended in  the laboratory  to make  the composite sample as homogenous as
possible.  Aliquots of the  composite samples  will be shipped blind to the analytical
laboratories for analyses. Portions of the composite sample will be retained for possible
future analyses.

SAMPLE HANDLING AND EQUIPMENT

The soil sampling equipment will be a coring device such as a metal tulip bulb planter.  A
new,  cleaned  coring device will be used for each composite sample.  A  new, cleaned
disposable aluminum pan will be used as a receptacle to remove miscellaneous debris from
each set of individual grab samples used to form a composite sample.

1.  Details on specific sampling locations with rationale  for  the selection of  each
    sampling  point will be carefully documented at the time of sample collection.   The
    documentation of each sampling location will be maintained in the team leader's site
    log along with historical information about the site obtained from  Dow Chemical.
    Photographs will be taken of each sampling site.

2ป  Log book entries, sample tags, and field record sheets with identification of sampling
    locations will be completed for each sample and will include date, time, and name or
    initials of the team leader.

3.  Each sample container will be identified by a sample identification tag and unique
    sample number.

*.  The top one inch of  the grab samples for each sampling site will be shaved off with a
    cleaned, disposable knife.  This sample will be used to form the composite sample.
    The samples will be kept cool during shipment and when held in the laboratory prior
    to analyses. The sample will be thoroughly blended in the laboratory prior to analysis.

5.  AH of the disposable sampling equipment (coring  devices, gloves, knives, aluminum
    pans, and tweezers) will be collected and disposed of under RCRA.
                                        -2-

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CLEANING OF SAMPLING EQUIPMENT

Each piece of new, disposable sampling equipment will be cleaned in the laboratory prior
to use in the field.   Cleaning will consist of a soap and  water wash, a water  rinse, an
alcohol rinse, and a trichloroethylene (TCE) rinse.

Equipment cleaning in the field will not be required. However, the field team will have on
hand appropriate solvents to clean equipment in the field should the need arise.

FIELD QUALITY ASSURANCE

The field quality assurance plan will consist of the following:

1.  In order to verify that cleaning of new, disposable equipment and sample containers
    has been effective, a second TCE rinse for each type  of equipment will be submitted
    in a standard sample container for analysis (the knives and tweezers will be cleaned
    together).

2.  One sample container blank will be carried into the field each day and handled in the
    same fashion as  the  other sample containers.  Upon  reaching the  laboratory, a soil
    sample without 2,3,7,8-TCDD (analytical result N.D. at 1 ppt) will be placed in the
    sample container blank.  This sample  will then be processed and analyzed with actual
    samples.

3.  A duplicate field sample will be obtained at a rate of one duplicate sample per ten
    samples.  The duplicate sample will consist of a second composite sample container
    filled with one-half of each grab sample obtained from the aluminum pan after debris
    has been removed.

LABORATORY QUALITY ASSURANCE

A comprehensive laboratory quality assurance plan and analytical  protocols are presented
in Attachment A.

CHAIN OF CUSTODY

Standard EPA chain-of-custody procedures will be followed throughout the survey.
                                       -3-

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       APPENDIX C





Quality Control Summary

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          SOIL SCREENING SURVEY
                    AT
          FOUR MIDWESTERN SITES
         QUALITY CONTROL SUMMARY
USEPA REGION V CENTRAL REGIONAL LABORATORY
  PARTICIPATING ANALYTICAL LABORATORIES
   U.S. Environmental Protection Agency
         Toxicant Analysis Center
        Bay St. Louis, Mississippi
Environmental Monitoring System Laboratory
  Research Triangle Park, North Carolina
           Dow Chemical Company
          Analytical Laboratory
            Midland, Michigan
                 May 1985

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INTRODUCTION

The quality of the polychlorfnated  dlbenzodloxln (PCDD) and polychlorlnated
dlbenzofuran (PCDF) data generated for the EPA Region V Midland Michigan
Soil Survey was determined based on Internal  and external  audits.   Each
sample batch sent to the participating labs Included a blind blank soil
and control soil.  In addition, batches contained blind field duplicates,
and homogenlzatlon check samples.  All samples were coded and not  traceable
to the sample location.  Labs did not communicate while the analyses were
being conducted.  Data were submitted to Harda A. Kuehl, CRL QC Coordinator
for QC assessment and sample decoding.  Ms. Kuehl was the sole possessor
of the sample codes which were kept under custody along with the data.

This summary presents the results of Internal  lab prepared QC audits and
Internal blind QC audits.  In addition, the comparabllHty between lab
results 1s presented.  Assessment of the data was done 1n accordance with
the "State of Michigan and U.S. EPA Region V Dloxlns and Other Toxic
Pollutants, City of Midland, Dow Chemical, Michigan Rivers, Quality
Assurance Project Plan for Laboratory Analysis 4/1/84".

I.  Methodology

Before any study samples were analyzed, EPA and Dow conducted a method
comparability study.  The extraction method decided upon was Soxhlet
extraction as outlined In Analyt1cal_Chem1stry, Vol. 52, No. 13, pp. 2045-
2053, November, 1980.  Analytical standards for 2,3,7,8-TCDD and other
PCDD/PCDFs were exchanged and found to vary less than 20% between  labs.
The clean up methodology used by Dow consisted of HPLC/RPHPLC, as
described In Analytical Chemistry, Vol. 52, No. 8, pp. 1239-1245,  July,
1980 with an additional carbon column reverse eluted with toluene  as
described by D.C. Stalling ASTM STP 686, pp.  302-323, 1979.

Quantltatlon and calculation procedures for each lab have been described
by the labs and are set out below.  Percent solids determinations  were
done by the Illinois Institute of Technology Research Institute with a
precision of < 5% as determined by In-lab duplicates.

A.  EPA - Research Triangle Park, NC.

"The HRGC-HRMS method of analysis Is briefly described.  60mm SP-2340
fused silica capillary columns were used for analysis of TCDD and  TCDFs.
Retention times of 2378-TCDD were 30 to 35 minutes and 2378-TCDF were 36
and 41 minutes respectively.  Retention times did change after a number
of highly contaminated samples were analyzed, but this did not cause any
problems.  20m SP-2330 fused silica and 15m SE-54 UCOT glass capillary
columns were used In the analysis for penta through octa CDDs and  CDFs.
The HRGC-HRMS multiple Ion selection (MIS) analysis was performed  using
an Integration rate of 30 milliseconds per mass and a jump time of 12
milliseconds.  This speed Is sufficient to produce responses slmlllar to
those of an EC or FID detector for components elutlng from a capillary
column.  The Individual HRGC-HRMS-MIS analysis sequence and exact  masses
of reference and CDD and CDF compounds are described:

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                                    2.
0  PFK, 318.9793; JCDDs, 319.8965./321.8936;  13C12-TCDD,  333.9338.

0  PFK, 292.9825; TCDFs, 303.9016/305.8987; TCDDs,  319.8965/321.8936;
   13C12-TCDD, 333.9338.

0  PKF, 330.9793; 13C12-TCDD,  333.9338;  PCDDs;  355.8546/357.8517; HxCDDs,
   389.8156/391.8127.

0  PKF, 330.9793; 13C12-TCDD,  33.9338; PCDFs, 339.8597/341.8567; HxCDFs,
   373.8207/375.8178.

0  PFK, 418.9729; Hepta CDDs,  423.776/425.7737; OCDD,  457.7377/459.7348;
   13C12-OCDD, 471.7750.

0  PFK, 404.9761; Hepta CDFs,  407.7817/409.7788; OCDF, 441.7428/443.7398;
   13C12-OCDD, 471.7750.

Analytical  standards that were used In analysis for the Identification and
quantification of tetra through octa CDDs and CDFs  are listed:

   13C12-2378-TCDD
   2378-TCDD
   1368/1379-TCDD
   2:2 type TCDDs
   3:1 type TCDDs and 1234-TCDD
   other pairs of TCDD Isomers
   2378-TCDF
   12378-penta-CDD
   13478-penta-CDF
   124679-hexa-CDF
   123478-hexa-CDD
   1234689-hepta-CDF
   1234678-hepta-CDD
   OCDD
   OCDF
   13C12-OCDD
   Extracts of municipal Incinerator fly ash  that contained all  tetra
through octa CDDs and CDFs were analyzed previously on slmlllar capillary
columns.

This limited supply of CDD and CDF reference  standards was sufficient to:
determine method efficiency for tetra through octa CDDs and CDFs;
Identification of 2378-TCDD and the other 21  TCDD Isomers; Identification
of hepta CDDs and CDFs, OCDD and OCDF.   Conclusive Identification  of
TCDFs, penta and hexa CDDs and CDFs can  not be made with this limited
supply of reference Isomers.  However,  retention time windows were
determined relative to the Internal standard  and recent literature.
Labeled and native CDD and CDF Isomers  were colnjected prior to and during
the analysis of test samples to provide the data and labeled/native ratio
response required to determine method efficiency, concentrations of
respective compounds and the minimum limit of detection for each sample.
Typical amounts of analytical  standards Injected for these purposes were:

-------
                                    3.
   250pg 13C12-TCDD,  lOpg 2378-TCDD.
   250pg 13C12-TCDD,  lOpg 2378-TCDD,  16pg  2378-TCDF.
   250pg 13C12-TCDD,  50pg each of penta  and hexa CDF.
   250pg 13C12-TCDD,  50pg of hexa CDD.
   lOOOpg 13C12-OCDD, lOOpg each of hepta  CDD  and  OCDD.
   lOOOpg 13C12-OCDD, lOOpg each of hepta  CDF  and  OCDF.
   NOTE:  nanogram amounts used for determination  of  high  concentrations.

Specific qualifications and limitations  should accompany the  results:

0  Quantification of  TCDD Isomers Is based on  concentration of  2378-TCDD
   analytical  standard.

0  Quantification of  penta through octa  CDDs and CDFs  1s based  on  specific
   standards previously mentioned.

0  The analysis reported for 2378-TCDF 1s  for  a very  narrow time window.
   One or more of these TCDF Isomers In  test samples  has exact  retention
   time of the 2378-TCDF analytical  standard.   NOTE:   However,  conclusive
   assignment of 2378-TCDF can not be made because sufficient reference
   standards are not  available.

0  Several TCDF Isomers are present In much higher concentration
   that reported for  2378-TCDF.  However,  these Isomers could not  be
   quantified because they elute 1n the  early  time frame of TCDD Isomers
   and the Instrumentation has certain limitations.  These analyses for
   the other TCDF Isomers can be performed on  the  remainder of  each
   extract If necessary.

0  Conclusive Isomer  assignments for penta and hexa CDDs and  CDFs  can  not
   be made because sufficient reference  standards  are not  available.

0  HRGC-HRMS peak matching analysis In real time were performed on a
   number on Ions to  determine and confirm exact masses that  correspond
   to PCDDs and PCDFs.  COCL loss analysis Indicative of TCDDs  and
   analyses to determine the absence of  hexa,  hepta,  and octa chlorinated
   dlphenylethers were performed on 13412.  The distribution  of CDD and
   CDF Isomers In this sample Is slmlHar  to those detected 1n  most of
   the other samples  In this study.

The analytical results Indicate:

0  Method efficiency  of tetra through octa CDDs and CDFs was  adequate  for
   almost all  samples.

0  Certain samples caused peak broadening  and  loss In MS sensitivity due to
   enormous contamination present.

0  Results generated  for "blind" QA samples were acceptable 1n  most cases.
   However, large differences are noted  In some.   For example,  13399 and
   13412 were derived form one actual test sample  but the  concentrations
   detected are quite different.  ECL Indicates the original  sample
   consists of about  25% small pebbles.  This  may  explain  the difference
   In results reported for the two samples.

0  10% to 30% of each extract 1s stored  for reference 1n case there are
   any questions and  additional analyses need  to be performed.

-------
                                    4.

B.  Dow Chemical Company

"The reporting format Is: a(b), where a Is the determined concentration,
and (b) Is the limit of detection (LOO).  The LOO Is defined as 2.5X peak
to valley noise In an adjacent region of the HRGC-LRMS (mass resolution
1000, El Mode) mass chromatogram.  Whenever the determined concentration
of a given analyte exceeds 10X LOO (analyte signal  Is > 25X noise)  we do
not report the LOO.  Species not detected are listed as "nd" along  with a
specific LOD.

Regarding TCDD Isomers, the data presented are Isomer-specific and  have
been corrected for the observed recovery of 3.0 ng of [13CJ-2378-TCDD
Internal standard mechanically administered onto each sample prior  to
extraction.  All TCDD Isomers are determined via HRGC-LRMS at m/z 320 and
322, and quantftatlons are based upon a primary reference standard  of
native 2378-TCDD.  Regarding 2378-TCDF, the data presented are believed
to be Isomer specific, but until additional TCDF Isomers become available
we cannot prove Isomer specificity.  These results have been corrected
for the observed recovery of 200 pg of [13C3-2378-TCDF Internal standard
added to each sample prior to extraction, and are determined via HRGC-
LRMS at m/z 304 and 306 (also monitor M+ for a C16-d1phenyl ether)  using
a primary reference standard of native 2378-TCDF.  Regarding HCDDs, the
data are Isomer specific with regard-to the groupings presented 1n  the
tables and have been corrected for the observed recovery of 1.0 ng  [13C]-
123478-HCDD Internal standard added to each sample prior to extraction.
All HCDD Isomers are determined via HRGC-LRMS at m/z 388 and 390 using a
primary reference standard of a mixture of two native HCDD Isomers  prepared
at Dow.  Whenever native CDDs concentrations are sufficiently high  so as
to preclude monitoring of the Internal standard, we report our findings
as absolute, which means that the values are those observed and are not
corrected for the Internal standard recovery.  Regarding H7CDDs, the data
are Isomer specific and have been corrected for recovery as Indicated on
the tables.  The H7CDD Isomers are determined via HRGC-LRMS at m/z  424
and 426 using a primary reference standard of native 1234678-H7CDD.
Regarding OCDD, the data have been corrected for the observed recovery of
5.0 ng of [13C1-OCDD added to each sample prior to extraction.  OCDD Is
determined via HRGC-LRMS at m/z 458 and 460 using a primary reference
standard of native OCDD.

The analytical procedure employed for these samples Is summarized as
follows:  Each soil sample was subjected to exhaustive benzene Soxhlet
extraction for a period of  20 hours.  The crude extracts were concentrated
to  20 mL volume via atmospheric pressure distillation and subsequently
diluted with  80 mL of hexane.  This solution was passed through a  multi-
layered chromatographlc column containing silica, sulfurlc acid on  silica,
and aqueous sodium hydroxide on silica.  The total  column effluent  was
concentrated to dryness and redlssolved in  5 mL of hexane.  This solution
was passed through a 10% AgN03 on silica column and a high-aspect ratio
flash chromatography column containing basic alumina.  The resulting
crude CDDs/CDFs fraction was concentrated to dryness and subsequently
quantitatively Injected Into a semi-preparative reverse phase HPLC  system
for component fractlonatlon.  The RP-HPLC fractions containing HCDDs,
H7CDDs, and OCDD were examined directly by HRGC-LRMS on a Kratos MS-80
operating at a mass resolution of  1000 In the El Mode employing single
Ion monitoring conditions as previously described.  The RP-HPLC TCDD
fractions and 2378-TCDF fraction were subjected quantitatively to further
normal phase adsorption (silica)-HPLC fractionation and the resulting
residues subjected to HRGC-LRMS examination as described above.

-------
                                  5.


BLANK RESULTS

For each batch of samples, both labs  prepared an Internal method  blank.
This blank consisted of the glassware reagents and clean  up columns
used for the samples.  An empty soxhlet thimble was extracted and the
extract carried through the rest of the procedure.  Neither lab detected
any 2,3,7,8-TCDD In any of the blanks (Table 1).  However traces  of
hepta CDD (H7CDD) and OCDD were found.  This may be due to  the ubiquitous
nature of these pollutants as evidenced by the field blank  results.

Field blanks were collected for every sampling location.  These blanks
consisted of a sample paint can container, strawberry huller, tulip
bulb planter, spoon, and knife used In the collection of  real samples.
These Items were rinsed with trlchloroethylene and placed Into the can.
The EPA lab rinsed the can and contents with the extracting solvent  and
analyzed the extract.  The results (Table 2) Indicate the presence of
400-900 plcograms of OCDD.  Based on  a typical can filled with 500
grams of real sample, this translates to approximately 1-2 ppt.

In each batch, a blind soil blank was Included.  This sample originated
from nursery top soil.Three positives were found (Table 3).  Two positive:
(2ppt, 0.1 ppt) were near the laboratory detection limit.   One positive
of 7ppt did not Invalidate the entire batch of results as between lab
comparability was reasonable.  Two Independent contract laboratories
analyzed this sample (n-20).  After a review of the data  3  points were
discarded due to lab Induced contamination, (Table 4).

Althrough the low detection limits requested of the contractors (l-5ppt)
were not reached, no Indication of 2378-TCDD was found.  All results In
Tables 3 & 4 are on different allquots of the blended blank sample.
These allquots were contained In separate jars with unique  untraceable
codes.  Details of the preparation of this sample are available on videotape
and will be described In the final report from the Illinois Institute of
Technology Research Institute.

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NOTE:
                                    6.
There was a change 1n the labeling system for the last three batches.
They are prefixed with 2476, then numbered sequentially starting  again
with one.
Table 1.  Lab Method Blank Results
BATCH
1
2
3
4
5
6
7


8
9
10
11
12
-1
-2
-3
2,3,7,
EPA
nd (10)
nd (10)
nd (10)
nd (20)
nd (10)
nd (10)
nd (10)


nd (10)
nd (50)
nd (30)
nd (10)
nd (60)
nd (2)
nd (1)
nd (3)
8-TCDD (pg)
DOW
nd (22)
nd(22), nd(31), nd(45)
nd (10)
nd(20), nd(22)
nd(15), nd(15)
nd(9), nd(8), nd(6), nd(13), nd(8)
nd(2), nd(4)


nd (10)

nd (10)
nd ( 6)
nd ( 6)
nd ( 6)
PCDD/PCDF (pg)






170 pg OCDD (EPA)
46 pg H7CDD (DOW)
90 pg OCDD (DOW)






nd ( 6) (Batch 2 & 3 run together)


Table 2.  Field Blank Results - EPA
Field Blank
A
B
C
D
2378-TCDD (pg)
nd (27)
nd (24)
nd (25)
nd (30)
OCDD (pg)
632 (216)
735 (191)
890 (225)
437 (244)

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                                    7.
Table 3.  Blind Soil Blank Results
BATCH #
1
2
3
4
5
6
7
8
9
10
11
12
1
2
3
2378 TCDD (ppt)
DOW
7 (1)
nd (2.5)
nd (0.6)
nd (0.8)
nd (0.6)

0.1 (0.1)





nd (0.3)
320
0.3 (0.2)
EPA
nd (1)
2 (1)
nd (2)
nd (2)
nd (1)
nd (2)
nd (1)
nd (1)
nd (1)
nd (3)
nd (2)
nd (3)
nd (1)
nd (1)
nd (2)
OTHER PCDD/PCDF (ppt)*






H6CDD:3.7/nd(15); H7CDD:14.9/31; OCDD;504/271

%




*61ven as Dow/EPA values


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                                    8.
LAB
CODE
2,3,7,8-TCDD
(ppt)
Referee
  A
 34*
 11*
 <4
 <6
 <5
 <6
 <6
 <3
 <18*
 <4
Referee
  B
 <8
 <7
 <3
                        <9
                        <7
                        <5
                        <9
    < - Not detected at matrix dependent level cited
*data point Invalid due to Internal lab contamination

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                                    9.
III.  DUPLICATES
In batches designated by Region V, the EPA lab chose a sample at random
and analyzed two allquots.  Dow selected batches at random to perform In
1ab_dupl1cates on.  These samples consist of 2 separate 10-20 gram allquots
taken out of the same sample jar.  EPA analyzed the duplicates In the
same analytical run whereas Dow analyzed the allquots 1n two separate
analytical runs.  Results (Table 5) Indicate that the QA Plan objective
of RPD < 30% or + detection limit for TCDD and TCDF were not met.  The
precision of OCDD was not within the objective of 60% RPD or + detection
limit, either.  However, the data are valid for purposes of project
objectives considering the relatively low levels encountered.

In order to determine the Inherent Imprecision In the sample preparation
and splitting process, horoogenlzatlon checks were Inserted Into sample
batches.  These were coded as a regular sample and were analyzed blind.
Two separate subsample jars of the sample were analyzed In the same analytical
run and 1n different analytical runs.  Results (Table 6) Indicate a
coefficient of variation of between 10-27%.

F1eld_dupl1cates consisted of two separate 500 gram samples allquoted out
of the soil composite contents 1n the field and placed In separate
sample cans.  Results (Table 7) Indicate rather wide and Inconsistent
variation In field sampling.  The RPD ranges for Dow analyses were 8-23%
and EPA analyses 0-110% RPD.

In summary, the greatest variation occured In field duplicates which Is
due to field subsampllng error plus sample homogenlzatlon and analytical
error.  The smallest degree of variation Is associated with the
homogenlzatlon/spllttlng procedure.  The analytical precision Is better
within an analytical run than between analytical runs.

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                                   10.
Table 5.  In - Lab Duplicate Precision
LAB
EPA
DOW
SAMPLE
13319
13343
13366
13412*
14176
DE013004
13304
13317*
13341
13315
13331
DE013103
2378 TC
sample
28
6
nd(2)
271
74
nd(l)
33
160
220
52
67
32
;DD (p
dup.
29
5
nd(l)
103
72
nd(l)
28
82
240
23
24
34
)t)
RPD.
4
18
36
31
16
64
9
77
94
2
2378 TC
sample
27

;DF i
dup
34

PPt)
RPD
23

OCDD
sample
375000

(ppt)
dup
120000

RPD
103

Note:  Only batch 8 has other PCDD/PCDF data due to request for full  scan analysis
      *sample Inhomogenelty noted by lab personnel.
Table 6.  Homogenlzatlon Check Precision
                  2378 TCDD (ppt)
Type
between run
between run
within run
EPA
12,17
169,213
DOW
25,23
220,240,250,
220,210
CV
27%
5%
10%
Table 7.  Field Duplicate Precision
BATCHES
1.2
2,3
3,3
6,7
7,9
11,12
1,1
2378
San
DOW
51
82
23
2.6
TC
iple
EPA
57
26
17
3
3
34
nd(l)
:DD i
Dup'
DOW
47
96
29
ppt)
1cate
EPA
26
67
21
3
4
20
nd(l)
RF
DOW
8
16
23
'D
EPA
74
110
21
0
28
52

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                                   11.
IV.  SPIKE RESULTS

Each sample was spiked with a surrogate for 2378-TCDD.  Other PCDDs and
PCDFs were also added If a full scan analysis was requested.  Table 8
summarizes the TCDD surrogate recovery.  Actual recoveries for each sample
are found in Table 12.  Overall batches, EPA mean recovery was 83.9%,
Sd=16.1%, m ป 135.  Ten EPA recoveries did not meet the QA objective of
50-115%.  Two if these samples were mlnicipal sewage sludges and seven
were control samples not typical of soils found at the study sites
(See Section V).  Dow mean recovery was 72.9%, Sd=9.21, m=88.  A Dow
recovery (116%) did not meet the QA objective.  A test for significant
difference between the two lab means was significant at p=0.05.  Both
labs added 13C12-OCDD to samples requiring full scan analysis.  Actual
OCDD recoveries for each sample are found In Table 13.  Overall EPA mean
recovery was 75.9%, Sd=9.63%, n = 22.  Overall Dow mean recovery was
87.1%, Sd=5.19, n = 11.  A test for significant differences between the
two labs means was significant at p=0.05.  No recoveries were outside the
QA objective of 40-110%.

The EPA lab prepared in-lab spikes of a real soil  samples in batches
designated by Region T.Results (Table 9) met the QA objectives except for
the 145% recovery.  OCDD outliers were due to contribution from the native
example.  The QA objective for OCDD was 70-130%.  Hexa CDF recovery (0%)
was also outside the QA objective of 40-160%.  Associated sample batch
data were not rejected.

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                                   12.
V.  CONTROL SAMPLE RESULTS
In each batch, a blind control  son  was Included.   This  sample originated
from an Industrial site near a city  of Chicago Incinerator.   Initial
results of this sample prior to homogenlzatlon Indicated 9-25 ppt 2,3,7,8-
TCDD and a host of other PCDD/PCDFs.  After homogenlzatlon 1t appeared
that <5 ppt was present.  Results (Table 10) Indicate that the nature  of
the sample which was found to contain high ppb levels of PAH's, methyl
naphthalenes and benzene with long hydrocarbon chains prevented the EPA
from consistently analyzing 1t with  acceptable TCDD recoveries.  Two
Independent contract laboratories analyzed this sample (Table 11). After
a review of the data by Jay Smith, CDC Statistician, It  was  decided that
analysis of this sample was not a valid means of accepting or rejecting
associated sample batches since the  extrapolation of this diffident
sample matrix behavior to the study  samples was not technically correct.
All results in Tables 10 & 11 are for different allquots of  the blind
control sample.  These allquots were contained 1n separate jars with
unique untraceable codes.  Details of the preparation of this sample are
available on videotape and will be described In the final report from
Illinois Instituted of Technology Research Institute.

-------
                                   13.
table 8.  TCDD Surrogate Recovery Results
BATCH *
1
2
3
4
5
6
7
8
9
10
11
12
-1
-2
-3


DOW
X
73.1
76.3
74.3
71.9
74.3
70.4
78.8
67.2

85
65
63
67.5
72.8
73.9


Sd
6.09
19.9
8.46
7.14
10.1
3.93
7.57
6.12


4.00

6.36
1.71
5.44


n
11
10
10
11
10
5
10
6

1
2
1
2
4
9


EF
Y
74.0
87.0
87.3
87.8
79.1
74.2
88.4
90.8
79.6
91.4
74.6
78.1
90.8
82.8
88.8


>A
Sd
14.3
15.6
10.1
9.45
15.3
12.4
18.9
9.21
14.6
13.8
20.8
18.7
18.1
15.5
16.3


n
10
10
9
9
9
9
10
9
9
9
9
8
10
8
8


SURROGATE CONCENTRATION INFORMATION
Dow - Batches 1-12, Episode 2476, Batch 1
5.0 ng 13C 2378 TCDD added

Dow Batch 7
1.5 ng 13C 2378-TCDD added

Dow Episode 2476, Batch 1-2
3.0 ng 13C 2378 TCDD added

EPA Batches 1-3
5.0 ng Cl 37 2378-TCDD added

EPA Batches 4-8, Episode 2476, Batch 1-3
5.0 ng 13C 2378-TCDD added

EPA Batches 9-12
10.0 ng 13C 2378-TCDD added

-------
                                   14.
Table 9.  EPA In-lab Matrix Spike Results
EPA
BATCH #
1
3
5
7
10
11
12
12
-1
2378 TCDD
ppt added
10
8
9
10
10
8
11
20
12
ppt recovered
13
7
9
11
11
7
16
18
16
%
Recovery
130
87
100
91
110
87
145
90
133
EPA
BATCH
7
12
2378 TCDF
added
16
32
ppt
recovered
16
29
%
recovery
100
91
OCE
added
100
100
)D ppt
recovered
244*
391**
%
Recovery
•ป•ป•
 *  native cone  290 ppt
**  native cone  271 ppt

EPA OTHER PCDD/PCDF RECOVERY
 1,2,4,7,8 P5CDF
 1,2,4,6,7,8 H6CDF
 1,2,4,7,8   H6CDD
(25 ppt):   48%
(50 ppt):    0%
(50 ppt):   64%

-------
                                   15.
Table 10.  BLIND CONTROL SAMPLE
BATCH
1
2
3
4

5
6
7

8
9
10
11
12
DOW
4 (1)
3.7 (3.6)
3.4
4.7 (0.8)

3.4 (0.7)
4.3 (0.6)
3.4






2378
EPA
32
12
nd
nd

nd
6
5

nd
nd
nd
13
nd
TCDD
(3)
(3)
(10)
(7)/15 (5)

(11)
(2)
(3)

(19)/nd (7)
(54)
(42)
(4)
(6)
Units
COMMENTS

EPA 50% Recovery
EPA 40% Recovery
= ppt



EPA 34%, 22% Recovery; 2 injections
of same extract
EPA 23% Recovery




2378 TCDF: H6CDD: H7CDD: OCDD
37/17 477/640 1680/NA
EPA 10%, 19% Recovery
EPA 22% Recovery
EPA 13% Recovery

EPA 46% Recovery
6300/NA





   Recovery refers to 13C 2378-TCDD recovery.
   Dow/EPA.

   NA = Not Analyzed
Other isomer values given as
For the last three batches, Episode 2476-Batch 1,2 & 3,  a previously analyzed
positive sample was used for the blind control.  Since no true values exist,
the previously reported values are used for comparison.

                     2,3,7,8 - TCDD
Batch
2476-1
-2*
-3
Dow
250
88
60
EPA
95
not reported
40
RPD
90%
40%
Previous Value
169 (EPA)
220 (DOW)
240 (DOW
250 (EPA)
290 (DOW)
49 (EPA)
90 (DOW)
* The QC for Batch 2476-2 is not usable.  EPA did not submit a result for the
control.  Wide deviations between the three sequential  samples listed below
indicate a possible sample mix-up.

-------
                                   16.
Sample
                          ID
                             DOW
EPA
DE013008
DE013009
DE013010
Field Sample
Blind Control
Blind Blank
0.2 (0.2)
88
320
90
not reported
ND
Table 11.  Control Sample Referee Lab Results
LAB
CODE
2,3,7,8-TCDD
  (ppt)
Referee
    A
                <30
                < 7
< 3
< 3
< 7
< 3
                <30
Referee
    B
< 3
< 9
<30
                <20
                <37
                <24

-------
                                   17.
VI.  COMPARABILITY

In Tables 12 & 13, the comparfslon between EPA and Dow data Is made by a
RPD calculation.  The QA objective for TCDD precision was < 50% RPD.  It
appears that 32% of the data did not meet this goal.
X TCDD concentration
(ppt)
< detection limit
1 - 10
11 - 20
21 - 35
36 - 60
61 - 80
81 - 100
101 - 500
501 +
_% RPD
X
0
46
63
41
53
46
36
55
76
sd
0
38
47
36
31
14
17
43
-
n
16
12
8
12
7
3
4
11
1
Tests for significance (p =0.05) between the concentration levels Indicate
that the generally smaller RPD's observed at TCDD levels >61  ppt are not
statistically different from those seen at lower levels.

Other PCDD/PCDF comparability In Table 13 Indicates discrepancies In
H7CDD concentrations between labs.  The QA objectives for these
homologues was < 50% RPD for 2378-TCDF and < 100% RPD for all  others.
10% of the data points fell outside these goals.  No significant
correlation (p =0.05) between concentration level and RPD was found.

In September, partial comparability data were sent to Jay Smith of Center
for Disease Control for statistical verification of a suspected bias.
CDC concluded that Dow consistently had results that are aproxlmately 40%
higher than EPA.  This bias Is statistically significant.  Possible
sources of this bias were discussed.

Dow described their subsampling procedure.  They stored samples 1n the
freezer.  An Ice collar near the cap formed during storage.  The samples
were brought to room temperature, and shook to Incorporate the condensed
water.  Rocks, roots found In the samples were excluded by Dow when a
subsample was taken.  The material was broken up with a spatula to attempt
to get finer particles.  A 20 gram aliquot was then taken.

-------
                                      18.
EPA broke up large balls of soil, but Included roots,  and rocks 1n their
subsample.  It appears that Dow analyzed more of the finer particle size
material In each sample.  It has been shown that dloxln 1s preferentially
bound to smaller particle sizes.  This could explain the consistent high
bias 1n Dow results.  Subsequent batches (6,8,10,11,12) analyzed after this
discovery Indicated a less consistent bias when Dow subsampled like EPA.

Both EPA and Dow chemists recommend a consistent field procedure to define
the original soil sample as everything that will pass through a 1mm (18
mesh) polypropylene sieve.  These sieves could then be disposed of to
avoid cross contamination.  It was decided not to do any further
Investigation of analysis of split samples, since given the differing
homogeneity of this study's samples even after blending, and extended
holding times differences between labs, data comparability would probably
not get any better than 40%.  Nonetheless, caparablllty of the data 1s
adequate to satisfy project objectives.

-------
TABLE 12.  BETWEEN LAB COMPARABILITY




scc#
13300
13301
13302
13303
13304
13305
13306
13307
13308
13309
13312
13313
13314
13315
13315
13317
13318
13319
13320
13321
13324
13325
13326
13327
13328
13329
13330
13331
13332
13333
13336
13337
13338
B
A
T
C
H
1









2








3









4

2378 TCDD (ppt)



DOW
51
28
23
93
33 [28]D
200
30
370
4 (1)
7 (1)
47
17 (2)
25 (2.7)
52 [23]R
33
160 [82]R
ND (2.4)
45
3.7 (3.6)
ND (2.5)
96
415
29
0.96 (0.7)
92
38
90
67 [24]R
ND (0.6)
3.4
5.3 (0.6)
ND 0.8)
ND (0.9)

EPA
57 (5)
9 (1)
13(1)
54 (3)
20 (1)
157 (6)
22 (1)
235 (15)
32 (3)
NO (1)
26 (3)
13(1)
12 (1)
17 2)
18 (1)
26 (1)
ND 1)
28 (1)
12 (3)
2 (1)
67 (1)
273 (13)
21 (1)
4 (1)
76 (7)
31 (4)
49 (1)
24 (1)
ND (2)
ND (10)
4 (1)
ND (1)
ND (1)

RPD
11
103
56
53
49/33
24
31
45
156
—
57
27
70
101/30
59
144/104
0
47
106
—
35
41
32
122
19
20
59
94/0
0

28
0
0
% Recovery Surrogate TCDD



DOW
72%
79%
67%
67%
65% [71%]D
71%
70%
86%
78%
78%
71%
68%
61%
63%
66%
65%
53%
98%
116%
102%
75%
72%
75%
69%
71%
64%
76%
79%
66%
96%
66%
78%
61%

EPA
112%
75%
73%
64%
70%
63%
71%
71%
58%
83%
96%
92%
108%
72%
100%
86%
94%
92%
50%
80%
97%
74%
94%
82%
100%
86%
80%
100%
73%
40%
92%
88%
96%

-------
TABLE 12.  BETWEEN LAB COMPARABILITY

Mil

scc#
13339
13340
13341
13342
13343
13344
13345
13348
13349
13350
13351
13352
13353
13354
13355
13356
13357
13360
13361
13362
13363
13364
13355
13366
13367
13368
13369
B
A
T
*
*
H
4






5









6








2378 TCDD (ppt)


DOW
ND (0.7)
220 [240]D
210
9.2
5.4 (0.9)
4.7 (0.8)
ND (0.8)
6.7
ND (0.6)
0.8 (0.6)
ND (0.8)
1.4
11
1.8 (0.6)
ND (0.7)
ND (0.6)
3.4 (0.7)
290

22

38

ND (0.7)
4.3 (0.6)


EPA
ND (1)
169 (6)
213 (6)
9 (1)
6 (2)
ND (7) [15(5)]R
ND (2)
5 (2)
ND (1)
ND (2)
ND (3)
ND (2)
11 (3)
ND (2)
ND (2)
ND (1)
ND (11)
250
ND (2)
19 (2)
ND (2)
28 (2)
3(2)
ND (2)
14 (2)
6 (2)
ND (2)

RPD
0
26
1
2
11
-/104
0
29
0
-
0
-
0
-
0
0
~
15

15

30

0
33

% Recovery Surrogate TCDD


DOW
65%
65% [67%]D
78%
72%
82%
75%
82%
73%
75%
82%
65%
68%
62%
68%
93%
67%
90%
76%

69%

64%

71%
72%


EPA
96%
94%
68%
84%
76%
34% [22%]R
96%
94%
94%
86%
54%
82%
52%
82%
78%
100%
23%
21%
86%
64%
76%
64%
104%
70%
68%
66%
70%

-------
TABLE 12.  BETWEEN LAB COMPARABILITY




see*
13372
13373
13374
13375
13376
13377
13378
13379
13380
13381
13387
13388
13390
13391
13392
13393
13394
13395
13396
13397
13386
13400
13401
13403
13404
13405
13406
13407
13408
13409
13402
13412
13413

13414
13415
13416
13417
13384
13385
13389
B
A
T
C
H
7









B









9









10









2378 TCDD (ppt)



DOW
0.3 (0.2)
NO (0.1)
2.4
99
0.7 (0.2)
2.6
ND (0.2)
ND (0.1)
3.4
0.1 (0.1)
ND (0.5;
ND (0.6)

4.4 (0.5)
8.4
33
55






















910

EPA





ND (2)
ND (3)
3 (1)
76 (
ND I
3)
2)
3 (1)
ND (1)
ND (2)
5
ND
4
3)
1)
ii
ND (2)
ND (2)
12 (3)
15 I
78 <
[3)
[3)
108 (2)
ND (4)
ND(19),ND(7)
ND
ND
4
1
*)
(2)
ND (4)
ND
18
2)
3)
45 (5)
3500 (39)
223
ND
ND
10
(7)
:D
54)
t>)
271 (7)
36000 (290)
25000 (500)
ND (27)
ND (24)
ND (25)
ND (30)
ND
ND
(3)
(42)
2030 (42)

RPD
—
0
22
26
-
14
0
0
38
ป
-
0

93
56
81
65






















76
% Recovery Sur



DOW
70%
76%
64%
91%
82%
77%
85%
84%
84%
75%
60%
62%

66%
73%
74%
56%






















85%

EPA
106%
64%
104%
58%
76%
106%
98%
106%
60%
100%
94%
80%
106%
92%
86%
88%
81%
84%
101,19%
106%
72%
98%
90%
70%
71%
80%
100%
51%
84%
22%
104%
100%
66%

102%
100%
96%
80%
103%
13%
72%

-------
            TABLE 12.  BETWEEN LAB COMPARABILITY




scc#
14175
14176
14177
14179
14180
14181
1418Z
14183
14184
14187
14188
14189
14190
14191
14192
14193
14194
14195
1419€
B
A
T
C
H
11







12







2378 TCDO (ppt)



DOW
W (3)
90






470








EPA
21 (8)
74 (5)
69 (3)
4600 (83)
130 (13)
40 (2)
463 (12)
NO (2)
13 (4)
440 (16)
314 (14)
ND (31),NO(24)
420 (13)
212 (8)
20 (3)
146 (10)
10 (3)
ND (3)
ND (6)

RPD
10
26






40







% Recovery Surrogate TCDO



DOW
69%
61%






63%








EPA
49%
52%
55%
101%
103%
73%
94%
97%
59%
119%
84%
6%, 6%
90%
62%
63%
65%
61%
81%
46%
2378 TCDD (ppt)




scc#

DE012901
-02
-03
-04
-05
-06
-07
-08
-09
-10
B
A
T
C
H
2476
-1












DOW








250
ND (0.3)

EPA

ND (1)
ND 3)
2 (1)
ND (1)
ND (1)
MD (2)
NO (1)
ND (1
95 (3)
ND (1)

RPD








99%


% Recovery Surrogate TCDD


DOW








63%
72%

EPA

100%
58
112
100
104
62
98
94
80
100

-------
2378 TCDD (ppt)
scc#
OE013001
-02
-03
-04
-05
-07
-08
-09
-10
DE013101
-02
-03
-04
-05
-06
-07
-08

B
A
T
C
H

-2
















-3
















DOW





150
0.2 (0.2)
88
320
50
350
32,34
34
35
183
60
0.3 (.2)

EPA
ND (1)
ND (1)
ND (2)
ND (1)
ND (1)
75
90
-
ND (1)
9 (2)
112 (8)
19 (2)
28 (4)
24 (2)
32 5)
40 (4)
ND (2)

RPD





67%
199%
_
-
139%
103%
51,57%
19%
37%
140%
40%
-

% Re<
DOM





75%
73%
71%
72%
80%
63
71,73
81
73
78
74
72

:overy Surrogate TCDD
EPA
92%
90
70
88
80
102
52
ซ.
88
102%
92
88
54
86
88
110
90


-------
                                           BETWEEN LAB COMPARABILITY PCOD/PCDF
Table 13.
SCCI
1 4479
1 4 Jit
1 4471
1 JJ/'i
13375
1447C
1 4477
1 JJff
1447ft.

1 44DA
1 JJnU
1 4401
1 JJnl
1 4407
1 JOfW
13391
13392
13393
13394
B
A
T
C
H

7

7

7




8
8
8
8
1368
Dow



260



""*"

2JC
.0
14
24
54
220
TCDD
EPA



135





n/4
30
30
100
120

RPD



63






73
22
60
59
1379
Dow



84





] c
5.7
10
22
80
TCDD
EPA



65





fuf
10
10
50
56

RPD



25






55
0
78
35
1378 1
Dow



27





itrff 5
1.9
3.2
7.6
26
rCDD
EPA



19






nd
nd
17
23

RPD



35






0
0
76
12
2378 T(
Dow
1 2
0.2
1 6
31
3 2
1 6
nd (3)
nd 121
47
nd (?\
roi \c.)
4 5
3.7
3.8
7.8
NR
:DF
EPA
nd (1)
nd (2)
nrf f2l
13
nd (5)
2
nd (2)
nd H)
17
nd M)
IIU \ 1 /
ฃ
nd (5)
nd (5)
13
15

RPD

o
o
82**
n
99
o

47

90
0
0
50
HTcno
Dow
15
2.9
56. 1
583
31.8
8.8
nd (11
1.9
477
3 7

46.2
75.8
190
169

EPA
nd
nd I
67
243
nd |
nd {
nd {
nd (
640
nd 1
mi 1
nrf
86
63
335
413


19)
5

39)
10)
12)
11)

!15)
20)
cu/

RPD


18
82
o
o
o
o

o

59
18
55
84
HiCDD
Dow

14.7
310
3900
147
42
8.7
6.2
1680
U.o
30
175
330
930
570

EPA
73
47
350
417
23
91
25

31
145
346
376
2280
2350

RPD
1
104**
12
161**
18
58
164**
122**

69
131**
66
13
84
122**
OCDD
Dow
350
200
2200
18000
670
340
260
170
6300
540
1 jo
960
1900
5700
3800

EPA
172
130
3100
12000
840
195
196
92
MA
271
277
680
860
7000
7000

RPD


34
40
22

28


66
72
34
75
20
59
13 c-ocn
Recovery
Dow

97

absolute
on
89
91

absolute
79
84
87
82
absolute
D
EPA
ฃ7


78
7C

M'


M.
O7
78
76
75
95
** Outside QA Plan goal of SOX RPD TCDF, 100X RPD others

             * All below Detection
NR           ซ Not Recovered
Absolute     ซ Not determined due to native concentration
NA           • Not analyzed for

-------
                                   25.
VII.  SUMMARY_OF_EPA_DATA_QUALITY

      A.  Precision

          1.   Field precision as measured by absolute  difference  (Ri)
          between aTl  field duplicates was:

                "R"ป = 15 ppt
                Sd = 15 ppt
                 n = 6

          The 95% confidence limit for the precision of each  field
          duplicate Is calculated as 2.46 R*:

          TCCD
          Results (ppt)       Ri (ppt)
          57,26  ~              11
          26,67                 41
          17,21                  4
          3,3                    0
          3,4                    1
          34,20                 14

          2.   Lab precision as measured by absolute difference (Ri)
          between all  lab duplicates was:

              "R~t   = 1 ppt
                Sd = 1 ppt
                 n = 3

          TCDD
          Resul ts__( ppt)       RMppt)

          28,29                  1
          6,5                    1
          nd  (l),nd (2)          0
          74, 72                 2
          nd  (1), nd (1)         0
          271,103              168*
          * Analyst noted extreme Inhomogenelty.

          3.   Sample_homogen1zat1on_prec1s1on  as measured  by the coefficient
          of variation between TCDD measurements of different allquots  of
          three samples was:

              x CV = 14%
                 n = 12

-------
                                   26.
B.  Accuracy

    1.  TCDD

    2,3,7,8-TCDD accuracy expressed as the percent recovery for the mean
    surrogate (13C or C137) recovery was:

       x = 83.9%
      Sd = 16.1%
       n = 135
    95% CI = (52-116%)

    2.  OCDD

    OGDD accuracy expressed as the percent recovery for the mean 13C-OCDD
    surrogate recovery was:

         x" = 75.9%
        Sd = 9.63%
         n = 22
    95% CI = (56-96%)

    C.  Completeness

    A total of 10 EPA sample TCDD surrogate recoveries were judged as
    outliers.  Two of these samples were municipal sewage sludges and
    seven were control samples not typical of soils found at the study
    sites (See Section V).  Completeness as expressed by the percent of
    valid TCDD data obtained for the study was:

        (124  x 100) = 99%
        (125

    D.  Comparability

    Comparability, expressed as mean RPD between EPA and Dow results was
    as follows:

    2,3,7,8-TCDD                             OCDD

       x = 41%            CV = 105%          7 = 48%     CV = 38%
      Sd = 43%                              Sd = 18%
       n = 73                                n = 14

-------
  APPENDIX D





Study Results

-------
Figures
   1
   2
                        APPENDIX D
                      Study Results

Sample Site Location Map, Henry, Illinois.
Sample Site Location Map, Mlddletown, Ohio
Tables
   1       2378-TCDD, Dow Chemical - Midland Plant
           In-Pi ant Surface Soil Samples
   2       2378-TCDD, Site #1 - Midland, Michigan Area
           Surface Soil Samples
   3       2378-TCDD, Site #2 - Henry, Illinois Area
           Surface Soil Samples
   4       2378-TCDD, Site #3 - Mlddletown, Ohio Area
           Surface Soil Samples
   5       2378-TCDD, Site #4 - Minnesota Natural Areas
           Surface Soil Samples
   6       2378-TCDD, Control and Blank Samples
   7       PCDDs and PCDFs, Site #1 - Midland, Michigan Area
           Surface Soil Samples
   8       PCDDs and PCDFs, Site #3 - Mlddletown, Ohio Area
           Surface Soil Samples
   9       PCDDs and PCDFs, Site #4 - Minnesota Natural Areas
           Surface Soil Samples
  10       PCDDs and PCDFs, Control and Blank Samples
  11       Toxic Organic Pollutants, Site #1 - Midland, Michigan Area
           Surface Soil Samples
  12       Toxic Organic Pollutants, Site #3 - Mlddletown, Ohio Area
           Surface Soil Samples
  13       Toxic Organic Pollutants, Site #4 - Minnesota Natural Areas
           Surface Soil Samples
  14       Toxic Organic Pollutants, Blank and Control Samples

-------
                                   APPENDIX D
                                   (continued)

                                 Study Results

Tables

  15       Tentatively Identified Compounds, Site #1 - Midland, Michigan Area
           Surface Soil Samples

  16       Tentatively Identified Compounds, Site #3 - Mlddletown, Ohio Area
           Surface Soil Samples

  17       Tentatively Identified Compounds, Site 14 - Minnesota Natural Areas
           Surface Soil Samples

  18       Tentatively Identified Compounds - Blanks and Control Samples
           Surface Soil Samples

-------
                   LEGEND
            Q_ perimeter Sample (PER)
              - Residential Area Sample
                 (M, N, & P)
            Q. Upwind Sample (UPW)
OPER-18
       PPENDIX   D
       FIGURE  1
 SAMPLE   SITE   LOCATION
 MAP} HENRY, ILLINOIS

-------
        ARMCO
             STEEL
                  CORP
           LEGEND
    Q- perimeter Sample (PER)
      - Residential Sample (G, H, & K)
    Q. public Use Area Sample (P)
SAMPLE  SITE  LOCATION
MAPjMIDCXJELTOWN, OHIO

-------
                                                          APPENDIX D

                                                            Table 1

                                                           2378-TCDD
                                                 Dow Chemical  - Midland Plant
                                                 In-Plant Surface Soil  Samples
Sampl e
Number
13404
14176
14190
14192
13406
14180
14178
14193
14194
13405
14187
14182
13407
13412
13413
Field
Identification
Station 1
Station 2
Station 3
Station 4
Station 5
Station 6
Station 7
Station 8
Station 9
Station 10
Station 11
Station 12
Station 13
Station 14
Station 15
                                   Location

                           South of 492 Building
                           South of 1005 Building;  Southwest of 703 Building
                           South of 703 Building
                           West of 703 Building
                           Southwest of 956 Building;  East of 703 Building
                           Northwest of 1159 Building; North of Shot Pond
                           llth and J Streets - Northwest Corner
                           8th and G Streets - Northwest Corner at Steam Pipeline
                           Northwest of 1050 Building  at F Street
                           South of 543 Building;  West of 14th Street
                           16th and G Streets - Southwest Corner
                           16th and G Streets - Northwest Corner
                           17th and G Streets - Northwest Corner
                           West of 934 Building
                           South and East of 874 Building North of RR Tracks
2378-TCDD (DL)
    (ppb)
0.018
0.074
0.42
0.020
3.50
0.13
4.60
0.15
0.010
0.045
0.44
0.46
0.22
0.27
25.0
[36.0]R
(0.003)
(0.005)
(0.013)
(0.003)
(0.039)
(0.013)
(0.083)
(0.010)
(0.003)
(0.005)
(0.016)
(0.012)
(0.007)
(0.007)
(0.50)
(0.28)
% Recovery   % Solids
                      71
                      52
                      90
                      63
                     100
                     103
                     101
                      65
                      61
                      80
                     119
                      94
                      51
                     100
                      66
               92.
               96.
               96.
               95.
               96.
               98.
               96.
               99.
               90,
               99.
               99.
               96.
               99.
              100.
               85.5
Notes:  (1) 2378-TCDD concentrations and detection levels (DL)  reported In parts per
            billion (ppb).
        (2) % Recovery - Recovery of Internal  standard (Cl37 2378-TCDO or 13c 2378-TCDD)
            expressed as percent.
        (3) % Solids - Solids content of sample determined after sample homogenlzatlon,
            expressed as percent.  Analytical  results not adjusted for moisture content.
        (4) [ ]R = Repeat analysis of same sample.

-------
                             APPENDIX D

                              Table 2

                             2378-TCDD
                  SITE #1 - Midland, Michigan Area
                        Surface Soil Samples


Sample      Field          2378-TCDD (DL)
Number  Identification         (ppb)          % Recovery   % Solids

Upwind Areas

13354      UPW-l-L             ND (0.002)        82%        94.9%
13343      UPW-1-1          0.006 (0.002)        76%        98.6%
13401      UPW-2-L             ND (0.004)        90%        94.0%
13395      UPW-4-L             ND (0.004)        84%        98.1%
13342      UPW-4-D          0.009 (0.001)        84%        84.2%
Track Out and Perimeter Samples - Dow Chemical-Midiand Plant

13353      TO-4-G           0.011 (0.003)        52%        99.3%
13360      TO-6-G           0.25  (0.018)*       21%        99.0%

13367      TO-9-6           0.014 (0.002)        68%        99.0%

14188      PER-2-L          0.31  (0.014)        84%        82,8%
14177      PER-2-1          0.069 (0.003)        55%        99.0%
14191      PER-5-L          0.21  (0.008)        62%        99.2%
13402      PER-8-L          0.010 (0.005)       104%        99.0%

13389      PER-9-G          2.03  (0.042)        72%        95.6%
14181      PER-10-L         0.040 (0.002)        73%        97.1%
Public Use Areas

13362      P-l-L            0.019 (0.002)        64%        99.5%
13364      P-2-L            0.028 (0.002)        64%        89.7%
13374      P-5-L            0.003 (0.001)       104%        99.7%
13392      P-6-L            0.015 (0.003)        86%        80.2%
13393      P-7-L            0.078 (0.003)        88%        98.8%
13340      P-8-L            0.17  (0.006)        94%        96.5%
13375      P-9-L            0.076 (0.003)        58%        89.2%
13391      P-10-L           0.012 (0.003)        92%        96.6%

13394      P-ll-L           0.108 (0.002)        81%       100.0%

-------
                             APPENDIX D

                               Table  2  (continued)

                             2378-TCDD
                  SITE #1 - Midland, Michigan  Area
                         Surface  Soil Samples
Sample      Field          2378-TCDD  (DL)
Number  Identification          (ppb)          % Recovery   % Solids

Residential Areas

13007      A-l-L            0.075  (0.006)          102%        83.0%
13008      A-l-1            0.090  (0.008)           52%        89.7%
13101      A-3-L            0.009  (0.002)          102%        88.5%
13102      A-3-1            0.112  (0.008)           92%        76.5%

13328      B-l-L            0.076  (0.007)          100%        93.2%
13305      B-l-1            0.16   (0.006)           63%        97.0%
13306      B-3-L            0.020  (0.001)           71%        97.8%
13325      B-3-1            0.27   (0.013)           74%        87.1%
13103      B-4-L            0.019  (0.002)           88%        84.7%
13104      B-4-1            0.028  (0.004)           54%        88.1%

13317      C-l-L            0.026  (0.001)           86%        78.7%
13303      C-l-1            0.054  (0.003)           64%        84.4%
13314      C-3-L            0.012  (0.001)          100%        98.6%
13307      C-3-1            0.24   (0.015)           71%        98.1%
13105      C-4-L            0.024  (0.002)           86%        91.0%
13106      C-4-1            0.032  (0.005)           88%        88.9%

13318      D-l-L                ND  (0.001)           94%        84.0%
13331      D-l-D            0.024  (0.001)          100%        99.5%
13319      D-2-6            0.028  (0.001)           92%        94.9%
13316      D-3-L            0.018  (0.001)          100%        90.9%
13329      D-3-1            0.031  (0.004)           86%        99.8%

13312      E-l-L            0.026  (0.003)           96%        97.5%
13330      E-l-1            0.049  (0.001)           80%        97.0%
13301      E-3-L            0.009  (0.001)           75%        97.6%
13304      E-3-1            0.020  (0.001)           70%        99.1%

13302      F-l-L            0.013  (0.001)           73%        99.0%
13313      F-l-1            0.013  (0.001)           92%        96.8%
Miscellaneous

14175      Sludge           0.021 (0.008)*         49%        88.7%

-------
                                        APPENDIX D

                                         Table 2  (continued)

                                        2378-TCDD
                              SITE #1 - Midland, Michigan Area
                                   Surface Soil Samples


Notes:  (1)  2378-TCDD  concentrations  and detection  levels (DL)  reported  1n parts  per
            billion (ppb).
        (2)  %  Recovery - Recovery of Internal  standard (Cl37 2378-TCDD  or "C 2378-TCDD)
            expressed as  percent.
        (3)  %  Solids -  Solids content of  sample determined after  sample homogenlzatlon,
            expressed as  percent.   Analytical results  not adjusted for  moisture  content.
        (4)  Field Identification of samples:

                     Location                               Type

                   UPW -  Upwind          L      - Yard, lawn, or open area composite
                   TO  -  Track Out        1 or D - Downspout or drlpllne composite
                   PER -  Perimeter        G      - Open area grab sample
                   P   -  Public Use
                   A-K -  Residential

         * Data not valid.   Quality assurance objective not achieved.

-------


SITE
Sample Field
Number Identification
APPENDIX D
Table 3
2378-TCDD
n - Henry, Illinois
Surface Soil Samples
2378-TCDD (DL)
(ppb)


Area
% Recovery



% Solids
Upwind Area - Henry, Illinois
12901 UPW-7-L
12902 UPW-7-1
Perimeter Samples
13002 PER-16
13003 PER-17
13004 PER-18
13012 PER-18CD]
Residential Areas
12903 M-l-DL
12904 M-l-L
12905 N-l-L
12907 N-l-LCD]
12906 N-l-1
13001 P-l-L
12908 P-l-l
NO (0.001)
NO (0.003)
NO (0.001)
NO (0.002)
ND (0.001)
NO (0.001)
0.002 (0.001)
ND (0.001)
ND (0.001)
NO (0.001)
NO (0.002)
ND (0.001)
ND (0.001)
100%
58%
90%
70%
88%
80%
112%
100%
104%
98%
62%
92%
94%
89.5%
88.1%
88.0%
98.7%
90.8%
90.8%
90.6%
92.7%
87.5%
87.3%
83.5%
90.1%
88.6%

-------
                             APPENDIX D

                              Table 4

                             2378-TCDD
                  SITE #3 - Middle town, Ohio Area
                        Surface Soil  Samples
Sample Field
Number Identification
Upwind Area - Hamilton,
13400 UPW-5-L
13377 UPW-5-L
Perimeter - ARMCO, Inc.
13366 PER-12-L
13337 PER-12-1
13387 PER-13-L
13363 PER-13-D
13372 PER-14-L
13376 PER-15-L
Public Use Areas
13349 G-l-L
13386 P-ll-L
13327 P-12-L
13338 P-13-L
13339 P-14-L
13390 P-15-L
13352 P-15-1
Residential Areas
13336 G-2-L
13348 G-2-1
13355 H-l-L
13403 H-l-1
13361 K-l-L
13351 K-l-1
13350 K-2-L
Miscellaneous
2378-TCDD (DL)
(ppb)
Ohio
0.004 (0.002)
0.003 (0.001)
, Mlddletown Plant
ND (0.002)
ND (0.001)
0.004 (0.003)
ND (0.002)
ND (0.002)
ND (0.002)
ND (0.001)
ND (0.002)
0.004 (0.001)
ND (0.001)
ND (0.001)
ND (0.002)
ND (0.002)
0.004 (0.001)
0.005 (0.002)
ND (0.002)
ND (0.002)
ND (0.002)
ND (0.003)
ND (0.002)

                                              % Recovery  %  Solids
                                                 98%        79.3%
                                                106%        79.9%
                                                 70%        87.4%
                                                 88%        88.4%
                                                 94%        86.4%
                                                 76%        87.4%
                                                106%        84.9%
                                                 76%        88.4%
                                                 94%        77.5%
                                                 72%        87.5%
                                                 82%        87.5%
                                                 96%        83.2%
                                                 96%        82.0%
                                                106%        78.8%
                                                 82%        67.3%
                                                 92%        87.7%
                                                 84%        86.7%
                                                 78%        95.9%
                                                 70%        94.7%
                                                 86%        81.3%
                                                 54%        88.3%
                                                 86%        86.4%
14189      Sludge              ND (0.031)*        6%        92.3%

-------
                                        APPENDIX D

                                         Table 4 (continued)

                                        2378-TCDD
                              SITE  #3  - Middletown, Ohio Area
                                    Surface  Soil Samples
Notes:  (1)   2378-TCDD  concentrations  and  detection  levels  (DL)  reported  in  parts  per
            billion (ppb).
        (2)  % Recovery - Recovery  of internal  standard (Cl37 2378-TCDD  or 13c 2378-TCDD)
            expressed as  percent.
        (3)  % Solids -  Solids content of sample determined  after  sample homogenization,
            expressed as  percent.   Analytical  results  not adjusted  for  moisture content.
        (4)  Field identification of samples:

                     Location                               Type

                   UPW  -  Upwind            L       - Yard, lawn, or open area composite
                   TO  -  Track Out         1  or  D  - Downspout or dripline composite
                   PER  -  Perimeter         6       - Open area grab sample
                   P   -  Public Use
                   A-K  -  Residential

         * Data  not valid.   Quality assurance objective not achieved.

-------
                                        APPENDIX D

                                         Table 5

                                        2378-TCDD
                             SITE 14  - Minnesota Natural Areas
                                   Surface Soil Samples
Sample      Field
Number  Identification
13373
13378
13379
13388
IWD-l-L
BSP-4-L
KR-l-L
PT-l-L
    location

Itasca Wilderness

Bluestem Prairie

Kettle River

Pemblna Trail  Preserve
2378-TCDD (DL)
    (ppb)

  ND (0.003)

  ND (0.001)

  ND (0.002)

  ND (0.002)
% Recovery   % Sol Ids

    64%       94.7%

    98%       98.0%

   106%       79.5%

    80%       53.5%
Notes:  (1)  2378-TCDD  concentrations and  detection  levels  (DL)  reported  1n  parts per
            billion (ppb).
        (2)  %  Recovery - Recovery of Internal standard (Cl37 2378-TCDD or 13C 2378-TCDD)
            expressed as percent.
        (3)  %  Sol Ids -  Solids content of  sample determined after sample homogenlzatlon,
            expressed as percent.   Analytical  results not adjusted for moisture content.
        (4)  Field Identification of samples:
                     Location
                   UPW - Upwind
                   TO  - Track Out
                   PER - Perimeter
                   P   - Pu&Hc Use
                   A-K - Residential
                                    Type
                 L      - Yard,  lawn,  or open  area  composite
                 1 or D - Downspout or dripllne composite
                 G      - Open area grab sample

-------
                                   APPENDIX D

                                    Table 6

                                   2378-TCDD
                           Control  and Blank Samples
Sample
Number
14196
14184
13368
13308
13320
13333
13344
13344
13357
13380
13396
13396
13409
13385
14183
14195
13309
13321
13332
13345
13356
13369
13381
13397
13408
13414
13415
13416

13417
13384
Field
Identification
Control Soil
Control Soil
Control Soil
Control Soil
Control Soil
Control Soil
Control Soil
Control Soil
Control Soil
Control Soil
Control Soil
Control Soil
Control Soil
Control Soil
Blank Soil
Blank Soil
Blank Soil
Blank Soil
Blank Soil
Blank Soil
Blank Soil
Blank Soil
Blank Soil
Blank Soil
Blank Soil
Can Blank (PER-5)
Can Blank (In-Plant)
Can Blank
(Middle town)
Can Blank #6
Blank Soil

2378-TCDD (DL)
ND (0.006)*
0.013 (0.004)
0.006 (0.002)
0.032 (0.003)
0.012 (0.003)
ND (0.010)*
ND (0.007)*
0.015 (0.005)*
ND (0.001)*
0.005 (0.003)
ND (0.019)*
ND (0.007)*
ND (0.054)*
ND (0.042)*
ND (0.002)
ND (0.003)
ND (0.001)
0.002 (0.001)
ND (0.002)
ND (0.002)
ND (0.001)
ND (0.002)
ND (0.001)
ND (0.001)
ND (0.001)
ND (0.027)
ND (0.024)
ND (0.025)

ND (0.030)
ND (0.003)
                                                   %  Recovery

                                                       46%
                                                       59%
                                                       66%
                                                       58%
                                                       50%
                                                       40%
                                                       34%
                                                       22%
                                                       23%
                                                       66%
                                                       10%
                                                       19%
                                                       22%
                                                       13%

                                                       97%
                                                       81%
                                                       83%
                                                       80%
                                                       73%
                                                       96%
                                                      100%
                                                       70%
                                                      100%
                                                      106%
                                                       84%
                                                      102%
                                                      100%
                                                       96%

                                                       80%
                                                      103%
% Solids

 98.4%
 98.4%
 98.4%
 98.4%
 98.4%
 98.4%
 98.4%
 98.4%
 98.4%
 98.4%
 98.4%
 98.4%
 98.4%
 98.4%

 53.7%
 53.7%
 53.7%
 53.7%
 53.7%
 53.7%
 53.7%
 53.7%
   NR
 53.7%
 53.7%
 53.7%
Notes:  (1) 2378-TCDD concentrations and detection levels (DL) reported  In
            parts per billion (ppb).
        (2) % Recovery - Recovery  of Internal  standard (Cl37 2378-TCDD  or
            13c 2378-TCDD)  expressed  as percent.
        (3) %  Solids  -  Solids  content of sample  determined after  sample
            homogenlzatlon, expressed as percent.   Analytical  results not
            adjusted for moisture content.
        (4) NR - Not reported.
         *  Data  not valid.   Quality  assurance  objective  not achieved.
            See Quality  Assurance Summary,  Appendix  C.

-------
        Sample No.:
         Field ID.:
          Location:

PCDDs (PL)

2378-TCDD
Total Iso TCDDs
Total penta CDDs
Total hexa CDDs
Total hepta CDDs
OCDD

PCDFs (DL)
2378-TCDF
Total TCDFs
Total
Total
      penta CDFs
      hexa CDFs
Total hepta CDFs
XDF


SITE

13401
UPW-2-L
PI easant
View School
ND (0.004)
ND (0.004)
ND (0.024)
ND (0.024)
0.15 (0.024)
0.34 (0.026)
ND (0.004)
ND (0.008)
ND (0.022)
ND (0.031)
ND (0.051)
APPENDIX D
Table 7
PCDDs and PCDFs
#1 - Midland, Michigan
Surface Soil Samples
Upwind
13395
UPW-4-L
4853 W. Kent
ND (0.004)
ND (0.023)
ND (0.023)
0.17 (0.034)
0.33 (0.034)
ND (0.004)
ND (0.008)
ND (0.023)
ND (0.028)
ND (0.045)


Area
Dow Chemical
In-Plant
13406 13412
Station 5 Station 14
Incinerator West of 934 Building
3.5 (0.039) 0.27 (0.007)
0.32
0.24 (0.067)
4.0 (0.067)
75.0 (0.9)
375.0 (1.3)
0.45 (0.06) 0.027 (0.007)
0.90 (0.14)
3.1 (0.13)
15.4 (0.38)
8.6 (0.48)
Notes:  (1)
             Concentrations of PCDDs,  PCDFs,  and detection
             levels (DL) reported in parts  per  billion  (ppb).

-------
APPENDIX D
Table 7
PCDDs and PCDFs
SITE #1 - Midland, Michigan Area
Surface Soil Samples
Public Use Areas
Sample No.:
Field ID.:
Location:
PCDDs (DL)
2378-TCDD
Total 1so TCDDs
Total penta CDDs
Total hexa CDDs
Total hepta CDDs
OCDD
PCDFs (DL)
2378-TCDF
Total TCDFs
Total penta CDFs
Total hexa CDFs
Total hepta CDFs
OCDF
13374
P-5-L
County Line Rd.
0.003 (0.001)
ND (0.001)
ND (0.014)
0.067 (0.007)
0.35 (0.013)
3.1 (0.096)
ND (0.002)
ND (0.002)
ND (0.01)
ND (0.01)
0.065 (0.02)
0.044 (0.023)
13392
P-6-L
Mapleton School
0.015 (0.003)
0.040
ND (0.035)
0.063 (0.035)
0.38 (0.028)
0.86 (0.027)
ND (0.005)
ND (0.008)
ND (0.024)
0.14 (0.043)
0.10 (0.071)
13393
P-7-L
Longvlew School
0.078 (0.003)
0.17
Interference
0.34 (0.02)
2.3 (0.055)
7.0 (0.068)
0.013 (0.007)
ND (0.025)
0.26 (0.036)
0.72 (0.021)
0.64 (0.037)
13375
P-9-L
Virginia Park
0.076 (0.003)
0.29
0.10 (0.018)
0.24 (0.018)
0.41 (0.093)
12.0 (1.5)
0.013 (0.002)
0.040 (0.01)
0.064 (0.01)
0.50 (0.034)
0.37 (0.049)
13391
P-10-L
Central School
(ball diamond)
0.012 (0.003)
0.040
ND (0.034)
0.086 (0.034)
0.35 (0.031)
0.68 (0.031)
ND (0.005)
ND (0.007)
ND (0.029)
0.16 (0.062)
0.11 (0.070)
13394
P-ll-L
Bullock School
0.11 (0.002)
0.22
0.12 (0.022)
0.41 (0.022)
2.4 (0.042)
7.0 (0.052)
0.015 (0.003)
0.11 (0.017)
0.17 (0.037)
0.82 (0.045)
0.66 (0.045)
Notes:  (1)  Concentrations of  PCDDs, PCDFs, and detection
             levels (DL)  reported  In parts per billion (ppb).

-------
     Sample No.:
      Field ID.:

       Location:

PCDDs (PL)

2378-TCDD
Total Iso TCDDs
Total penta CDDs
Total hexa CDDs
Total hepta CDDs
OCDD


APPENDIX D
Table 8




PCDDs and PCDFs
SITE #3 - Middle town, Ohio Area
Surface Soil Samples
Upwind
13377
UPW-5-L
5130 Princeton
0.003 (0.001)
ND (0.001)
ND (0.010)
ND (0.010)
0.023 (0.007)
0.20 (0.009)

13400 13387
UPW-5-L PER-13-L
5130 Princeton 2820 Packaging
0.004 (0.002) 0.004 (0.003)
ND (0.002) ND (0.003)
ND (0.044) ND (0.020)
0.072 (0.044) ND (0.020)
0.20 (0.17) 0.15 (0.014)
10.6 (0.23) 0.28 (0.014)
Perimeter
13372
PER-14-L
Perimeter 14 - West
ND (0.002)
ND (0.002)
ND (0.014)
ND (0.009)
0.073 (0.018)
0.17 (0.026)

13376
PER-15-L
Oxford Road
ND (0.002)
ND (0.002)
ND (0.039)
ND (0.039)
0.12 (0.009)
0.84 (0.071)
PCDFs (PL)

2378-TCDF
Total TCDFs
Total penta CDFs
Total hexa CDFs
Total hepta CPFs
OCOF
        0.002 (0.001)
NP (0.004)
0.006 (0.004)
ND (0.001)
ND (0.008)
ND (0.008)
NP (0.018)
NP (0.026)
ND (0.016)
ND (0.036)
ND (0.023)
ND (0.056)
ND (0.010)
ND (0.028)
NP (0.026)
ND (0.046)
ND (0.012)
ND (0.012)
ND (0.017)
ND (0.024)
   ND (0.005)

   ND (0.015)
   ND (0.015)
0.043 (0.023)
0.050 (0.026)
Notes:  (1)
Concentrations of PCDDs, PCDFs, and detection
levels (DL) reported In parts per billion (ppb).

-------
                                      APPENDIX D

                                       Table 9

                                   PCDDs and PCDFs
                          SITE #4 - Minnesota Natural  Areas
                                 Surface Soil Samples
     Sample No.:
      Field ID.:

       Location:

PCDDs (PL)

2378-TCDD
Total Iso TCDDs
Total penta CDDs
Total hexa CDDs
Total hepta CDDs
OCDD
                 13373
                IUD-1-L

           Itasca Wilderness
   ND
   ND
   ND
   ND
0.047
0.13
                   (0.003)
                   (0.003)
                   (0.010)
                   (0.005)
                   (0.009)
                   (0.019)
                           13378
                          BSP-4-L

                      Bluestem Prairie
   ND (0.001)
   ND (0.001)
   ND (0.012)
   ND (0.012)
0.091 (0.010)
0.20  (0.012)
                           13379
                          KR-l-L

                       Kettle River
   ND
   ND
   ND
   ND
(0.002)
(0.002)
(0.004)
(0.011)
0.025 (0.009)
0.092 (0.011)
PCDFs (PL)

2378-TCDF
Total TCDFs
Total penta CDFs
Total hexa CPFs
Total hepta CPFs
OCPF
   NP
   ND
   ND
   NP
   ND
   ND
                   (0.002)
                   (0.002)
                   (0.010)
                   (0.010)
                   (0.017)
                   (0.024)
   NO (0.002)

   NP (0.009)
   NP (0.009)
   NP (0.009)
   NP (0.010)
   NP (0.001)
   NP
   NP
(0.013)
(0.013)
   NP (0.009)
   NP (0.014)
Notes:  (1)
Concentrations of PCDPs, PCPFs, and detection
levels (PL)  reported 1n parts per billion (ppb).

-------
                                                        APPENDIX D

                                                         Table 10

                                                      PCDDs and PCDFs
                                                 Control  and Blank Samples
                                                           Blank and Control  Samples
     Sample No.:
      Field ID.:

       Location:

PCDDs (PL)

2378-TCDD
Total Iso TCDDs
Total penta CDDs
Total hexa CDDs
Total hepta CDDs
OCDD
13380
Control Soil

13381
Blank Soil

13414
Can Blank
PER-5
13415
Can Blank
In-Plant Blank
13416
Can Blank
Blank Middle town
13417
Can Blank
Blank #6
0.005 (0.003)
   ND (0.003)
0.081 (0.033)
0.64  (0.033)
   NA
   NA
ND (0.001)
ND (0.001)
ND (0.015)
ND (0.015)
0.031 (0.005)
0.27 (0.007)
ND (0.027)
ND (0.027)
ND (0.097)
ND (0.097)
ND (0.17)
0.63 (0.22)
ND (0.024)
ND (0.024)
ND (0.10)
ND (0.10)
ND (0.15)
0.74 (0.19)
ND (0.025)
ND (0.025)
ND (0.098)
ND (0.098)
ND (0.17)
0.89 (0.23)
                                                                        ND
                                                                        ND
                                                                        ND
                                                                        ND
                                                                        ND
                                                         (0.03)
                                                         (0.03)
                                                         (0.11)
                                                         (0.11)
                                                         (0.19)
                                                                      0.44 (0.24)
PCDFs (PL)

2378-TCDF
Total TCDFs
Total penta CDFs
Total hexa CDFs
Total hepta CDFs
OCDF
0.017 (0.005)

   NA
   NA
   NA
   NA
ND (0.001)

ND (0.011)
ND (0.011)
ND (0.012)
ND (0.013)
ND (0.039)
ND (0.039)
ND (0.021)
ND (0.35)
NA
NA
ND (0.022)
ND (0.022)
ND (0.032)
ND (0.14)
ND (0.15)
ND (0.15)
ND (0.023)
ND (0.023)
ND
ND
ND
ND
(0.14)
(0.13)
(0.19)
(0.19)
ND (0.027)
ND (0.027)
ND (0.074)
ND (0.12)
ND (0.16)
ND (0.16)
Notes:  (1)  Concentrations of PCDDs, PCDFs, and detection
             levels (DL) reported in parts per billion (ppb)
        (2)  NA - Not analyzed.  Peak broadening in GC/MS
             system prevented quantitation.

-------
                                                  APPENDIX D

                                                   Table 11

                                           Toxic Organic Pollutants
                                       SITE II - Midland, Michigan Area
                                             Surface Soil Samples

                                     (Results In parts per million (ppm))
                                                Upwind
                                                      In-Plant
  CAS
 Number

Acid Compounds
Sample Number:
    Field ID.:
 13401
UPW-2-L
106-44-5    4-methylphenol
122-83-2    2,4-d1chlorophenol
876-36-5    pentachlorophenol
108-95-2    phenol
 65-85-0    benzole acid

Base/Neutral Compounds

206-44-0    f1uoranthene
 91-20-3    naphthalene
117-81-7    b1s(2-ethylhexyl) phthalate
 84-74-2    d1-n-buty1 phtifelate
117-84-0    dl-n-octyl phthalate
 84-66-2    dlethyl phthalate
 56-55-3    benzo (a) anthracene
 50-32-8    benzo (a) pyrene
205-99-2    benzo (b) fluoranthene
207-08-9    benzo (k) fluoranthene
218-01-9    chrysene
208-96-8    acenaphthylene
120-12-7    anthracene
191-24-2    benzo (ghi) anthracene
                  13. OT
                   1.3TC
                   1.3TC

                   1.3T
 13395
UPW-4-L
13404
#1
13406
#5
13405
#10
13407
#13
13412
#14
13413
#15
           12.3T
                                             0.01T
                                            0.01T
            1.2TC
            1.8C

            1.2T
                         0.01T
                   5.0
11.0
 8.1

 0.01T
                                                                            1.2
                                                                            0.02T
0.01T
4.4

-------
                                                  APPENDIX D

                                                   Table 11 (continued)


                                                  Upwind                          In-Plant
    CAS                     Sample Number:
   Number                       Field ID.:
13401
UPW-2-L
13395
UPW-4-L
13404
#1
13406
#5
13405
#10
13407
#13
13412
#14
13413
#15
  Base/Neutral Compounds (continued)

   86-73-7    fluorene
   85-01-8    phenanthrene                     —       —     —      —   0.01
   53-70-3    dlbenzo (a,h) anthracene         —       —     —      —    —      —    —     —
  193-39-5    Indeno (1,2,3-cd) pyrene
  129-00-0    pyrene                           —       —     —     0.01
  132-64-9    dlbenzofuran
   91-57-6    2-methyl naphthalene
  118-74-1    hexachlorobenzene                —       —     —     —     0.01    —     —     —
  131-11-3    dimethyl  phthalate               —       —     —     0.5
  100-51-6    benzyl alcohol                   —       	
   87-86-5    pentachlorophenol                —       —     —     —     —     —     —
   83-32-9    acenaphthene

  Pesticides/PCBs

  309-00-2    aldrin                           —       	     	
   57-74-9    chlorodane
   50-29-3    4,4J-DDT                         —       	
   72-55-9    4,41-DDE                         —      0.01     	
12672-29-6    PCB-1248                         —       	     1.3
11097-69-1    PCB-1254                         —       	
11096-82-5    PCB-1260                         —       	


Notes and Symbols:

    (1)  { } - Coeluted Isomers, Indistinguishable concentration.
    (2)   C  - Value corrected for blank  concentration.
    (3)   T  - Trace, less than detection limit.
    (4)  	 Not detected.

-------
                                                       APPENDIX D

                                                        Table 11

                                                 Toxic  Organic Pollutants
                                             SITE #1  -  Midland, Michigan Area
                                                   Surface Soil Samples

                                           (Results in  parts per million (ppm))
                                                  Perimeter
                                           Public Use
  CAS
 Number

Acid Compounds
106-44-5    4-methylphenol
122-83-2    2,4-dlchlorophenol
876-36-5    pentachlorophenol
108-95-2    phenol
 65-85-0    benzole acid

Base/Neutral Compounds

206-44-0    f1uoranthene
 91-20-3    naphthalene
117-81-7    b1s(2-ethylhexyl) phthalate
 84-74-2    di-n-butyl phthalate
117-84-0    d1-n-octyl phthalate
 84-66-2    diethyl phthalate
 56-55-3    benzo (a) anthracene
 50-32-8    benzo (a) pyrene
205-99-2    benzo (b) fluoranthene
207-08-9    benzo (k) fl uoranthene
218-01-9    chrysene
208-96-8    acenaphthylene
120-12-7    anthracene
191-24-2    benzo (ghl) anthracene
 86-73-7    f1uorene
 85-01-8    phenanthrene
Sample Number:
Field ID.:
13367
PER-9-6
13402
PER-8-L
13392
P-6-L
13393
P-7-L
13375
P-9-L
13391
P-10-L
13394
P-ll-L
13374
P-5-[Re]
3.3
0.2T
                     0.04T
                     0.04T
13.2T
          1.3TC
          1.3TC

          1.3T
 0.3T



 O.IT

 0.2T

 0.04T

 0.04T

,0.08T*,
I     *i
 0.08T


 0.04T

 0.08T
                    1.1TC
                    1.1TC

                    1.1T
                                                           0.04T


                                                           0.04T
                                                           0.04T
                                                           0.04T
                                                           0.04T
                                      0.04T
0.2T

0.2T

-------
                                                        APPENDIX D

                                                         Table 11 (continued)
  CAS
 Number
               Sample Number:
                   Field ID.:
    Perimeter

 13367      13402
PER-9-G    PER-8-L
                                                                                           Public Use
13392
P-6-L
Base/Neutral Compounds (continued)

   53-70-3    dibenzo (a,h) anthracene
  193-39-5    indeno (1,2,3-cd) pyrene
  129-00-0    pyrene
  132-64-9    dibenzofuran
   91-57-6    2-methyl naphthalene
  118-74-1    hexachlorobenzene
  131-11-3    dimethyl  phthalate
  100-51-6    benzyl alcohol
   87-86-5    pentachlorophenol
   83-32-9    accenaphthene
                                  3.5
                      0.08T
                      0.04T
13393    13375     13391
P-7-L    P-9-L    P-10-L
                                                                         0.04T
                                                                 1.3T    0.08T
                   0.08T
13394
P-ll-L
 13374
P-5-[Re]
                             0.3T
Pesticides/PCBs
  309-00-2
   57-74-9
   50-29-3
   72-55-9
12672-29-6
11097-69-1
11096-82-5
aldrin
chlorodan
4,41-DDT
4,4l-DDE
PCB-1248
PCB-1254
PCB-1260
            0.01
                             0.02
                             0.03
                                                                                                          0.05
Notes and Symbols:

    (1)  { } - Coeluted isomers, indistinguishable concentration.
    (2)   C  - Value corrected for blank concentration.
    (3)   T  - Trace, less than detection limit.
    (4)  	 Not detected.

-------
            APPENDIX D

             Table 12

      Toxic  Organic Pollutants
     SITE  #3 - Middletown,  Ohio
        Surface Soil Samples

(Results in  parts per million  (ppm))
 Upwind
Perimeter
Public Use
Residential
CAS
Number
Sample Number:
Field ID.:
13400
UPW-5
13377
UPW-5 [D]
13387
PER-13-L
13372
PER-14-L
13376
PER-15-L
Acid Compounds
106-44-5
122-83-2
876-36-5
108-95-2
65-85-0
4-methyl phenol
2,4-dichlorophenol
pentachloro phenol
phenol
benzoic acid
• ••
—
—
___
—
___
_..
...
...
11. 6T
._•
...
...
...
—
0.04T
---
---
—
— — —
___
...
...
---
0.08T
Base/Neutral Compounds
206-44-0
91-20-3
117-81-7
84-74-2
117-84-0
84-66-2
56-55-3
50-32-8
205-99-2
207-08-9
218-01-9
208-96-8
120-12-7
191-24-2
86-73-7
f 1 uoranthene
naphthalene
b1 s{ 2-ethyl hexyl ) phthal ate
di-n-butyl phthal ate
di-n-octyl phthal ate
di ethyl phthal ate
benzo (a) anthracene
benzo (a) pyrene
benzo (b) fl uoranthene
benzo (k) fl uoranthene
chrysene
acenaphthylene
anthracene
benzo (ghi) anthracene
f 1 uorene
1.4T
LOT
LOT
—
0.6T
___
0.6T
___
— _
___
1.2T
___
___
— _
...
1.4
...
1.2TC
2.3C
...
1.2T
1.2T
2.3T
2.3T
2.3T
2.3T
1.2T
1.2T
2.3T
1.2T
1.5T
—
1.5TC
1.5TC
—
1.5T
1.5T
2.9T
2.9T
2.9T
2.9T
_ซ_
1.5T
2.9T
—
0.2T
—
0.04T
-—
...
-—
0.08T
0.4
0.6*
i */
0.2T
0.04T
___
0.2T

2.3
...
0.4T
...
...
...
1.0
1.4
2.0*
i *•>
1.2
0.3T
0.2T
0.8T
O.IT
                                                    LIT
                                                    LIT
                                                    1.1TC
                                                    LIT
                                                    2.2T
                                                    2.2T

                                                    2.2T
                                   1.4T

                                   2.3T
                                   1.4T
                                   1.4T
                   1.2T

                   1.2T


                   L2T

-------
                                                         APPENDIX D

                                                          Table 12 (continued)
                                              Upwind
                                                          Perimeter
  CAS
 Number
          Sample Number:
              Field ID.:
Base/Neutral Compounds (continued)

 85-01-8   phenanthrene
 53-70-3   dibenzo (a,h) anthracene
193-39-5   Indeno (1,2,3-cd) pyrene
129-00-0   pyrene
132-64-9   dibenzofuran
 91-57-6   2-methyl naphtha!ene
118-74-1   hexachlorobenzene
131-11-3   dimethyl  phthalate
100-51-6   benzyl alcohol
 87-86-5   pentachlorophenol
 83-32-9   acenaphthene
Pestlcldes/PCBs
  309-00-2
   57-74-9
   50-29-3
   72-55-9
12672-29-6
11097-69-1
11096-82-5
aldrln
chlorodane
4,4'-DDT
4,4'-DDE
PCB-1248
PCB-1254
PCB-1260
13400 13377
UPW-5 UPW-5 [D]
2.2
1.4T
0.4T
2.0
™— ซ•
M*ปW
1.2T
2.3T
1.2T
—
WMM
13387
PER-13-L
1.5T
2.9T
1.5T
—
••ป•
13372
PER-14-L
O.IT
0.04T
0.3T
0.2T
0.04T
• ซ•••
13376
PER-15-L
1.0
0.7
1.2
0.04T
0.04T
0.04T
0.08T
0.05
0.03
0.06
                                                        Public Use

                                                      13386     13390
                                                      P-ll-L    P-15-L
                                                                                   1.1T
                                                                                   1.1T
                                                                 1.4T
                                        Residential

                                           13403
                                           H-l-1
                                                                           1.2T
                                            1.2T
                                                                           0.2
Notes and Symbols:

    (1)  { } - Coeluted Isomers, indistinguishable concentration.
    (2)   C  - Value corrected for blank concentration.
    (3)   T  - Trace, less than detection limit.
    (4)  	 Not detected.

-------
                                         APPENDIX D

                                          Table 13

                                  Toxic Organic Pollutants
                              SITE #4 - Minnesota Natural Areas
                                    Surface Soil Samples

                            (Results In parts per million (ppm))
                                                          Minnesota Natural Areas
  CAS
 Number

Add Compounds
Sample Number:
    Field ID.:
13388
PT-l-L
106-44-5    4-methylphenol
122-83-2    2,4-dlchlorophenol
876-36-5    pentachlorophenol
108-95-2    phenol
 65-85-0    benzole acid

Base/Neutral Compounds

206-44-0    f1uoranthene
 91-20-3    naphthalene
117-81-7    b1s(2-ethylhexyl) phthalate
 84-74-2    di-n-butyl phthalate
117-84-0    dl-n-octyl phthalate
 84-66-2    diethyl phthalate
 56-55-3    benzo (a) anthracene
 50-32-8    benzo (a) pyrene
205-99-2    benzo (b) fluoranthene
207-08-9    benzo (k) fluoranthene
218-01-9    chrysene
208-96-8    acenaphthylene
120-12-7    anthracene
191-24-2    benzo (ghi) anthracene
 86-73-7    f1uorene
                   24.5T
                    2.5TC
                    2.9C

                    2.5T
13379
KR-l-L
 13378
BSP-4-L
                                           0.04T
             6.6



             0.08T

             0.04T
             O.IT
             0.04T

             0.04T
 13373
IWD-l-L
               O.IT
               0.2T
               0.08T
               0.2T

-------
APPENDIX D
 Table 13 (continued)
                     Minnesota Natural Areas
CAS Sample Number:
Number Field ID.:
Base/Neutral Compounds (continued)
85-01-8 phenanthrene
53-70-3 dlbenzo (a,h) anthracene
193-39-5 Indeno (1,2,3-cd) pyrene
129-00-0 pyrene
132-64-9 dlbenzofuran
91 -57-6 2 -methyl naphthal ene
118-74-1 hexachlorobenzene
131-11-3 dimethyl phthalate
100-51-6 benzyl alcohol
87-86-5 pentachlorophenol
83-32-9 acenaphthene
Pest1c1des/PCBs
309-00-2 aldrin
57-74-9 chlorodane
50-29-3 4,4' -DDT
72-55-9 4, 4 '-DDE
12672-29-6 PCB-1248
11097-69-1 PCB-1254
11096-82-5 PCB-1260
Notes and Symbols:
13388
PT-l-L

2.5T

—
2.5T
...
...
...
...
...
...
...

...
...
...

...
...
...

13379 13378
KR-l-L BSP-4-L

0.04T
... ...
... ...
0.04T
... ...
0.04T
... ...
... ...
0.04T 0.08T
... ...
...

... ...
...
... ...
... ...
0.04
0.03
... ...

13373
IWD-l-L

...
...
...
...
...
0.04T
•ป*ปM
ซปปป
...
...
...

...
...
...
...
• ซ••
...
...

(1) { } - Coeluted Isomers, Indistinguishable concentration.
(2) C - Value corrected for blank concentration.
(3) T - Trace, less than detection 1
(4) 	 Not detected.
Imlt.






-------
                                                         APPENDIX D

                                                          Table 14

                                                  Toxic Organic Pollutants
                                                    Surface Soil Samples

                                             (Results 1n parts per million (ppm))
                                                                           Blanks and Controls
  CAS
 Number

Acid Compounds
Sample Number:

    Field ID.:
E9199    E9200
Blank   Control
 Soil    Soil
106-44-5    4-methylphenol
122-83-2    2,4-d1chlorophenol
876-36-5    pentachlorophenol
108-95-2    phenol
 65-85-0    benzole add

Base/Neutral Compounds

206-44-0    f1uoranthene
 91-20-3    naphthalene
117-81-7    bis(2-ethylhexyl) phthalate
 84-74-2    dl-n-butyl phthalate
117-84-0    d1-n-octyl phthalate
 84-66-2    dlethyl phthalate
 56-55-3    benzo (a) anthracene
 50-32-8    benzo (a) pyrene
205-99-2    benzo (b) fluoranthene
207-08-9    benzo (k) fluoranthene
218-01-9    chrysene
208-96-8    acenaphthylene
120-12-7    anthracene
191-24-2    benzo (ghi) anthracene
 86-73-7    f1uorene
 85-01-8    phenanthrene
                  0.01T
                           1.1
                           0.7
                           0.4
                           0.02T
                           1.0

                           0.6

                           0.01T


                           2.0
E8064
Blank
 Soil
                    3.4TC

                    3.4TC
 E8065    E8076
Control    Can      Lab
 Soil     Blank    Blank
           1.1

           0.9TC
                              1.0
                              1.8T
                              2.1

                              1.8T

                              0.9T
                              1.8T

                              3.3
E8061     E8063     E8051
Blank    Control     Can
 Soil     Soil      Blank
                     2.8
                     0.3T
                    O.IT
                    O.IT

                    O.IT
                                                                           O.IT
                                                                           0.06T
                                                                                      3.4
           2.4
           1.8T
           1.4T

           1.2T

           LOT

           2.2

           1.8T
           0.2T
           0.8T
           0.6T

           4.0T

-------
                                                          APPENDIX D

                                                           TABLE  14 (continued)
                                                                           Blanks and Controls
  CAS
 Number
            Sample Number:

                Field ID.:
E9199
Blank
Soil
E9200
Control
Soil
E8064
Blank
Soil
E8065
Control
Soil
E8076
Can
Blank

Lab
Blank
E8061
Blank
Soil
E8063
Control
Soil
E8051
Can
Blank
Base/Neutral Compounds (continued)

   53-70-3    dibenzo (a,h) anthracene
  193-39-5    Indeno (1,2,3-cd) pyrene
  129-00-0    pyrene
  132-64-9    dlbenzofuran
   91-57-6    2-methylnaphthaiene
  118-74-1    hexachlorobenzene
  131-11-3    dimethyl phthalate
  100-51-6    benzyl alcohol
   87-86-5    pentachlorophenol
   83-32-9    acenaphthene
                                        0.7
                                        0.4
                                        1.3
Pestlcldes/PCBs
  309-00-2
   57-74-9
   50-29-3
   72-55-9
12672-29-6
11097-69-1
11096-82-5
aldrln
chlorodane
4,4'-DDT
4,4l-DDE
PCB-1248
PCB-1260
PCB-1260

* 0.087 ppb
1.8T
1.8T
2.0
0.9
1.9
0.2T
0.6T
2.4
LOT
4.0
Notes and Symbols:

    (1)  { } - Coeluted Isomers, Indistinguishable concentration.
    (2)   C  - Value corrected for blank concentration.
    (3)   T  - Trace, less than detection limit.
    (4)  	 Not detected.

-------
                       APPENDIX D

                         Table IS

             Tentatively  Identified Compounds
            SITE  fl  -  Midland, Michigan Areas
                  Surface Soil Samples

           (results  in parts per Billion  (ppm))
Upwind
Inplant
Perimeter
Public Use
CAS
Number
17301-30-3
54410-98-9
127-18-4
79-34-5
33374-28-6
62016-37-9
630-07-9
638-66-4
74685-33-7
17301-27-8
52783-43-4
629-96-9
69576-82-5
29053-04-1
79-00-5
55499-02-0
103-23-1
Sample Number:
Field Identification:
Compound list
Undecane, 3,8-dimethyl
1-nonene, 4,6,8-trlmethyl
ethene, tetrachloro
ethane, 1,1, 2,2- tetrachloro
1,2-benzene dlcarbozylic acid
2, butoxyethyl butyl ester
octane, 2,4.6-trimetnyl
pentatriacontane
octadecanal
3-elcosene, (E)-
undecane. 2,10-dimethyl
nona decanal
1-elcosanol
l,lt-bicyclo[2.2.2]ocune
(alpha-methylpropyl )-
ethane. 1.1,2-trichloro-
hexanedloicalid, b1s(2-
ethylhexyl) ester
13401 13395 13404 13406 13405 13407 13412 13413 13367 13402 13374
UPV- UPU- PER- PER-
2-L 4-L fl 15 110 113 114 115 8-t 9-G P-5



39 tt fi ..........
6 1ft ...........


HfiltA ..........
12.8
1.99 	 0.66
1.99
2.99

*


13392 13393 13375
P-6-L P-7-l P-9-L
1 AQ


27
I W
1.6






13391
P-
10-BD
2.7
23.8
1.33
1.55
1.14
13394
P-
11-L

-------
Upwind
             APPENDIX D
        Table IS  (continued)

(results In parts per million (ppn)}
               Inplant
Perimeter
Public Use
CAS
Number
5675-51-4
74685-29-3
630-06-8
21048-65-9
44635-30-6
57-88-5
1002-84-2
57-10-3

111-04-9
4CCt.C1.Jt
tt.47.fi
471-68-1
1058-61-3
123-08-0
4429-77-0
18835-33-1
37571-80-5
559-74-0
Sample Number:
Field Identification:
Compound List
I.l2-dodecand1o1
9-elcosene, (E)-
hexatrlacontane
1-decanol, 2-ethyl-
S-e1cosene, (E)-
cholest-S-en-3-ol, (3-.beta.)-
pentadecanolc acid
hexadecanolc acid
7.hปxitarซn.l .nl 3 7 11 1C.
tetramethyl-[R-[R*. R*-(ฃ)]J

•rnnrt. >.-•ซ. l.nl 11. hซta 1.
ct1i*mact.th**fh_l.n1 11. h*ta '
olean-12-ene
st1gmast-4-en-3-one
benzal dehyde-4-hydroxy
cjrcloheptadecanol
1-hexacosene
stl9Basta-5>22-d1en-3r
ol, (3-.beta. 22E)-
0:A-Fr1edooleanan-3-one
unknown aliphatic acid
13401 13395 13404 13406 13405
ura- UPW-
2-L 4-L 11 15 110^
3.29
39.5
11.5
5.84
4.94
5.49
I 0.66 - -




•
13407 13412 13413 13367 13402 13374 13392
PER- PER-
113 114 115 8-L 9-6 P-5 P-6-L
0.49 2.8
0.64UK 0.68UK 4.8 4.6
20
So

- - - _ . .. 10
043
	 1.05
	 1.06
1.10
2.1
5.7
0.87
0.85
0.76
13393 13375 13391
P-
P-7-L P-9-l 10-80
1.9
2.3
2 5

1 i
3 4
1.9
0.47
13394
P-
_U-L
1.1
2.8
4 2

066

1.4
4.2

-------
Upwind
             APPENDIX D
        Table IS (Continued)

(results In parts per Million  (ppซ0)
                Inplant
Perimeter
                                                                                 Public Use



CAS
Number
134-96-3

9AQA.AA.A
tH3W"^O"*
6624-79-9
143-07-7
481-17-4


57-11-4
15968-05-5
77-90-7

54932-67-1
6330-09-2

31504-88-8

605-45-8

3790-71-4

288-13-1
60-12-8
Sample Number: 13401 13395 13404 13406 13405 13407
UPU- UPW-
Fleld Identification: 2-L 4-L fl IS 110 ซ13

Compound list


3,5-dlMethoxy


1-dotrfacontano) -
dodecanolc acid .....
st
-------
Upwind
            APPENDIX 0

        Table  15  (continued)


(results In parts per Million  (ppm))

               Inplant



CAS
Nimber
103-82-2
104-54-1
501-52-0
544-63-8
5009-33-6
1454-85-9
490-99-3

106-02-5
593-45-3
629-99-2
112-95-8
630-01-3
661-19-8
100-41-4
108-94-1
92-69-3
6738-04-1
3933-94-6
2432-11-3
141-04-8
6093-03-4
Sample dumber: 13401 13395 13404
UPU- UPH-
Fleld Identification: 2-1 4-1 11

Compound List
benzeneacetlc acid
2-propen-l-ol, 3-phenyl-
benzene propanolc acid
tetradecanolc acid - -
ll-dodecen-2-one
1-heptadecanol
cyclohexanol, S-nethyl-2-(l-
•ethylethyl)-, (1-. alpha., 2)
oxacyclohexadecan-2-one
octadecane
pentacosane
elcosane
hexacosane
l-doco$anol
benzene, ethyl -
cyclohexanone
l.l'-btphenyl-4-ol
l.l'-biphenyl, 2-phenoxy-
l.l'-blpbenyl, 4-phenoxy-
l.r:3M"-terpheny1-2'-ol
hexanedlolc acid. b1s(2-ซ*thyl-
propyl) ester
l.r:3' ,r-terpbenyl-4'-ol
\ 13406 13405 13407 13412 1341.

15 110 113 114 115


• * • <• •
....
....
....
....
-
....

.....
.....
.....
.....
.....
.....
0.7 4.7
0.84
3.7
1.2
1.7
3.2
1.1UK
9.4
Perimeter
Public Use
                                                     PER-
                                                     8-L
                                                 PER-
                                                 9-6
                                         P-
             P-5   P-6-L  P-7-l   P-9-L   10-BD
                      P-
                     U-L
                                                            2.4
                                                            3.0
                                                            1.5
                                                            0.5
                                                            0.51UK
                                                            1.2
                                                            0.65UK

                                                            1.2UK
                                                            0.51
                                                            1.1
                                                            1.5
                                                           13.0
                                                            4.7

-------
Upwind
             APPENDIX 0

        Table 15 (continued)


(results in parts per million (ppm))

                Inplant


CAS
Number
131-18-0

17851-53-5
28080-85-5
52161-54-3

29812-79-1
922-28-1
6570-92-9
55334-42-4
84-61-7

108-10-1
629-20-9
98-82-8
33021-02-2

105-05-5
98-86-2
768-49-0
21898-96-4

Sample Number: 13401 13395 13404
UPU- UPW-
Field Identification: 2-L 4-L 11
Compound List
1,2-benzenedicarboxylic acid.
dipentyl ester
1.2-benzenedicarboxylic acid,
butyl 2-methylpropylester
10-undecenoic acid, octyester
benzene, l,lMl.4-dimethyl-l-
butene-l,4-diyl) bis-
hydroxylMine, o-decyl-
heptane. 3,4-diwethyl
pentane, l-brซmo-3.4-dlMethy1-
dodecane, 1,2-dibromo-
l,2-benzenedicarboxyl1c acid.
dlcyclohexylester
2-pentanone, 4-methyl- ...
1,3,5,7-cyclo octatetraene
benzene. (1-methyl ethyl )-
propane, l-(l.l-dlmethylethoxy)-
2 -methyl -
benzene, l,4-diethy1-
ethanone, 1-pnenyl-
benzene (2-methyl-l-propenyl)-
tricyclo 4.3.1.13,8 undecane,
1-brono-
13406 13405

15 110

1.9UX

6.1UK
3.1UK
1.3UK

1S.OUK
2.2UK
0.84UK
7.8UK
4.0UK

m
m








13407 13412 1341.

113 114 115












1.1
8.4 0.4!
4.5
1.5

6.3
2.3
1.4
1.6

                                                      Perimeter
              Public Use
                                                     PER-
                                                     8-L
                                                 PER-
                                                 9-G
                             P-
P-5   P-6-L  P-7-l  P-9-l  10-BD
 P-
U-l

-------
                                                                      APPENDIX 0

                                                                 Table IS (continued)
                                               Upxlnd
(results In parts per million (ppro))

                Inplant
Perimeter
Public Use
             Sample Number:


             Field Identification:
    CAS
  Number     Compound List

 2049-95-8   benzene (1,1-dimothyl  propyl)-
  101-84-8   benzene, l.l'-oxybis-
  100-42-5   benzene, ethenyl-
17104-67-5   2-naphthonitrlle, 5,6,7,8-
               tetrahydro
  780-25-6   benzene methanamine,
               n-(pheny1methylene)-
56728-02-0   benzene l,r-2-methy1-2-
               (phenylthio) cyclopropyliden
35825-28-6   stannane, cyclopropyltriethyl
 1120-21-4   undecane
33046-84-3   2-pentenal, S-phenyl-
  108-88-3   benzene, methyl
 5131-66-8   2-propanol, 1-butoxy-
 2091-29-4   9-hexadecenoic acid
13401 13395 13404 13406 13405
UPU- UPU-
2-L 4-L 11 15 110
	
	
	
.
13407 13412
*13 114
0.62
1.2UK
0.79
1.3UK
5.7UK
0.69UK
26.0
0.5RS
0.57UK
0.31
13413 13367 13402 13374 13392 13393 13375 13391
PER- PER- P-
115 8-L 9-6 P-5 P-6-L P-7-L P-9-L 10-BD
0.49

0.47UK
0.37
0.74UK
1339'
P-
11-1




             Notes:

               UK * Unknown, not in NBS library.
               RS * Reasonable identification;
                    retention time compatibility.

-------
                                                        APPENDIX D

                                                         Table 16

                                             Tentatively Identified Compounds
                                                SITE #3 - Mlddletown, Ohio
                                                   Surface Soil Samples
                                           (results in parts per million (ppm))
                                                  Upwind
                                                                Perimeter
                                                                                Public Use
    CAS
  Number
 4537-
 4536-
 2719-
 2719-
54986-
 4534-
 4534-
 4534-
10544-
•15-9
•86-1
•62-2
•64-4
•44-6
•49-0
•50-3
•54-7
•50-0
33374-28-6


  103-23-1

  630-06-8
              Sample Number:
              Field Identification:
Compound List

benzene (1-butylheptyl)
benzene(1-propyloctyl)-
benzene!1-pentylheptyl)-
benzenet1-propylnonyl)-
benzene(l,33-trimethylnonyl)
benzened-pentyloctyl )-
benzene(l-butylnonyl)-
benzened-hexyloctyl )-
sulfur, Mol(58)
phenanthrene-methyl isomer
aliphatic hydrocarbon
polyunsaturate
1,2-benzenedicarboxylic
  acid, 2-butoxyethyl
    butyl ester
hexanedioicalid, bis(2-
  ethylhexyl)ester
hexatriacontane
                                        13400    13377    13387   13372    13376

                                                 UPW-5
                                        UPW-5
 6.0
 2.7
10.0
 3.1
 2.3
 4.4
 2.0
 4,3
 3.1
 2.0
 5.5
 3.30
                                          [D]    PER-13  PER-14   PER-15
                                                 47.6


                                                  2.78

                                                 13.9
                                                                             13386
                                              P-ll
                                                        13390
P-15-L
         Residential

            13403
H-l-1
                                                                    24.9

-------
                                                        APPENDIX D

                                                   Table 16 (continued)

                                           (results in parts per million (ppm))
                                                  Upwind
                        Perimeter
   Public Use
              Sample Number:
              Field Identification:

    CAS
  Number      Compound List

  117-82-8    1,2-benzenedicarboxil1c
                acid, b1s(2-methoxyethyl)
  124-25-4    tetradecanal
  506-52-5    1-hexacosanol
17301-30-3    undecane, 3,8-dimethy1-
  127-18-4    ethene, tetrachloro
   79-34-5    ethane, 1,1,2,2-tetrachloro-
  638-66-4    octadecanal
74685-33-9    3-elcosene, (E)-
 5675-57-4    1,12-dodecandlol
 1002-84-2    pentadecanoic acid
  100-83-4    benzaldehyde, 3-hydroxy
  148-53-8    benzaldehyde, 2-hydroxy-
                3-methoxy
   57-10-3    hexadeconoic acid
  150-86-7    2-hexadecen-l-ol, 3,7,11,15-
                tetramethyl-[R-CR*,R*-(E)]]
  111-03-5    9-octadecenoic acid
                (Z)-2,3-dihydroxypropylester
25154-56-7    nonacosanol
 4651-51-8    ergost-5-En-3-ol, (3-.beta.)-
   83-47-6    stigmast-5-en-3-ol,
                (3-.beta. 24S)
13400    13377    13387   13372    13376

         UPW-5
UPW-5     [D]  , PER-13  PER-14   PER-15
 1.86

12.4
27.8

 1.47

 3.09
5.05
1.55
1.83
10.3
21.8
2.02










-
-
_
_

1.3
0.51
0.83
3.6
0.83
1.101
2.6
0.64
1.3
                                    0.79
13386
 P-ll
                                               1.73
                                               1.44
                                              11.8
                                              19.4
                                               13390
                                              P-15-L
Residential

   13403
   H-l-1
            15.2
                        1.42'
                        1.57
                                    0.930

-------
                                                        APPENDIX D

                                                   Table 16  (continued)

                                           (results In  parts per million  (ppm))
                                                  Upwind
Perimeter
              Sample Number:
              Field Identification:

    CAS
  Number      Compound List

  471-68-1    olean-12-ene
 1058-61-3    stigmast-4-en-3-one
 2091-29-4    9-hexadecenolc acid
  630-07-9    pentatrlacontane
62108-21-8    decane, 6-ethyl-2-methyl-
74685-29-3    9-e1cosene(E)-
10486-19-8    trldecanal
  630-06-8    hexatrlacontane
74645-98-0    dodecane, 2,7,10-trlmethyl-
50871-03-9    1-decene, 3,4-dimethyl
62016-37-9    octane, 2,4,6-tr1methyl
13400
UPU-5
;
13377
UPU-5
[D]
:
13387 13372
PER-13 PER-14
0.72
0.91
13376
PER-15
0.62
            0.95
            0.89
Public
13386
P-ll
16.2
3.93
Use
13390
P-15-L
23.3
-23.0
2.62
13.1
Residential
13403
H-l-1

                                             4.76
                                             1.14
                                             1.78

-------
                                                              APPENDIX D

                                                               Table 17

                                                   Tentatively Identified Compounds
                                                  SITE #4 - Minnesota Natural Areas
                                                         Surface Soil Samples

                                                 (results In parts per million (ppm))
                                            Minnesota   Natural   Areas
              Sample Number:

              Field Identification:
    CAS
  Number      Compound List

74645-98-0    dodecane, 2,7,10-trlmethyl-
33374-28-6    1,2-benzenedicarboxyllc acid
                2-butoxyethyl butylester
50871-03-9    1-decane, 3,4-dlmethyl-
62016-37-9    octane, 2,4,6-trlmethyl-
13828-37-0    cyclohexanemethanol
                4-(l-methylethyl)-c1s
  148-53-8    benzaldehyde, 2-hydroxy-3-
                methoxy
   57-10-3    hexadecanolc acid
  123-08-0    benzaldehyde, 4-hydroxy
  143-07-7    dodecanolc acid
 2004-39-9    1-heptacosanol
  150-86-7    2-hexadecen-l-ol, 3,7,11,15-
                tetramethyl-[R-[R*. R*-
   83-47-6    stigmast-5-en-3-o1,
                (3-.beta., 24S)-
 1058-61-3    st1gmast-4-en-3-one-
   83-48-7    st1gmasta-5,22-d1en-3-ol,
                (3-.beta., 22E)-
13388

PT-l-L
  3.92
 35.2

  2.45
  3.92
  5.23
13379

KR-l-L
             0.59

             1.1
             0.44
             0.48
             0.43
 13378

BSP-4-L
                        1.2

                        2.2

                        2.0
                        1.4
 13373

IWD-l-L

-------
    CAS
  Number

13151-81-0

 2490-48-4
14021-23-9

20475-86-9
Sample Number:

Field Identification:

Compound List

undecane, 6-cyclohexyl-,
  6-cyclohexyl
1-hexadecanol, 2-methyl
D-Friedoolean-14-ene,
  3-methoxy-(3-.beta.)-
urs-12-en-24-o1c acid,
  3-oxo-, methyl ester,  {+)•
                                                              APPENDIX D

                                                         Table 17 (continued)

                                                 (results in parts per million (ppm))


                                            Minnesota   Natural   Areas
13388
PT-l-L


13379 13378
KR-l-L BSP-4-L
0.78
4.4
3.3
13373
IWD-l-L


0.9

-------
                                                        APPENDIX  D

                                                         Table  18

                                             Tentatively Identified Compounds
                                                   Surface  Soil Samples

                                           (results 1n  parts  per  million  (ppm))
              Sample Number:

              Field Identification:

    CAS
  Number      Compound List

  123-08-0    benzaldehyde, 4-hydroxy
  621-59-0    benzaldehyde, hydroxy,
                methoxy Isomer
55638-41-0    5-octen-2-one-6-methyl-8-
                (2,6,6-trlmethyl-l-
                  cyclohexen-1-yl)-
 2091-29-4    9-hexadecenolc acid
62016-37-9    octane, 2,4,6-trlmethyl-
   96-48-0    2(3H)-furanone, dlhydro
 3648-21-3    l,2-benzened1carboxy11c acid
                dlheptylester
  629-99-2    pentacosane                *
   57-10-3    hexadecanolc acid
 4536-86-1    benzene(1-propyloctyl)-
18435-22-6    tetradecane, 3-methyl-
 2719-62-2    benzened-pentylheptyl )-
 2719-64-4    benzene(1-propylnonyl)-
 2400-00-2    benzene!1-ethyldecyl)-
 4534-49-0    benzeneU-pentyloctyl)-
 4534-50-3    benzene(1-butylnonyl)-
 4534-54-7    benzene(l-hexyloctyl)-
 4534-52-5    benzene(1-ethylundecyl)-

E8061
Blank
Soil
2.0
1.3
1.8
B 1 a
E8051 E8064
Can Blank
Blank Soil

13.5
n k s
E8076
Can
Blank


and
E9199
Blank
Soil
.0.6
4.0
Control s
E8063 E8065
Control Control
Soil Soil



E9200
Control
Soil


0.26
                 0.573
                 0.57
                 3.13
                          0.59 UK
 4.0

16.0
 4.9
 3.2
 6.7
 3.2
 5.2
 2.0
                                                3.11
                                                2.61
                                               10.2
                                                4.34
                                                3.6
5
2
                                                  09
                                                  97
                                                2.75
                                                           2.4  UK
          11.0
           3.6
           2.6

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                                                        APPENDIX D

                                                         Table 18 (continued)

                                           (results In parts per million (ppm))
    CAS
  Number

 4534-51-4
 2719-61-1

10544-50-0
 1002-17-1
17301-30-3
54004-41-0
25368-56-3
211662-16-8
62108-21-8
54410-98-9
74645-98-0
25368-56-3
  100-83-4
21964-48-7
 2719-63-3
 2400-03-5
 4534-54-7
 2400-04-6
  613-12-7
  593-45-3
55162-61-3
Sample Number:

Field Identification:


Compound List

benzene(1-propyldecyl )-
benzened-methyl undecyl )-
aliphatic hydrocarbon
sulfur, Mo1(58)
methyl phenanthrene
dimethyl naphthalene Isomer
decane, 2,7-dlmethyl-
undecane, 3,8-dlmethyl-
l-pentanolt 4-methyl-2-propyl-
2-nonanone, 9-hydroxy-
2,4-dodecandlenal, (E,E)-
decane, 3-ethy1-2-methyl-
1-nonene, 4,6,8-trfmethyl-
dodecane, 2,7,10-trlmethyl-
2-nonanone, 7-hydroxy-
benzaldehyde, 3-hydroxy-
1,12-trldecadlene
benzenetbutyl octyl)-
benzene(1-propylheptadecyl)-
tetradecane, 7-phenyl-
benzene(1-butylhexadecyl)-
anthracene, 2-methyl
octadecane
tetracontane, 3,5,24-trlmethyl-

E8061
Blank
Soil

E8051
Can
Blank
B 1 a
E8064
Blank
Soil
n k s
E8076
Can
Blank
and C
E9199
Blank
Soil
o n t r o
E8063
Control
Soil
1 s
E8065
Control
Soil

E9200
Control
Soil
 7.59
11.4
18.0
 8.06
 9.17
 3.97
15.3
13.8
10.7
                 1.3
                 0.73 UK
                            2.4
                            3.4
                            8.4
                            5.6
                            3.3
                            2.3
                                       2.95
                                                  1.9 UK
                                                  2.1 UK
                                                  3.2 UK
                                                  1.4 UK
                 0.45
                 1.0 UK

-------
                                                        APPENDIX D

                                                        Table  18  (continued)

                                           (results  in  parts  per million  (ppm))
              Sample Number:

              Field Identification:

    CAS
  Number      Compound List
  630-06-8    hexatriacontane
 2922-51-2    2-heptadecanone
17302-27-1    nonane, 2,5-dimethyl
  294-62-2    cyclododecane
  131-18-0    1,2-benzenedicarboxylic acid,
                dipentylester phthalate
56554-96-2    2-octadecanal
 1921-70-6    pentadecane, 2,6,10,14-tetramethyl
  629-59-4    tetradecane
  544-76-3    hexadecane
  569-41-5    naphthalene, 1,8-dimethyl-
18335-17-6    benzened-propylpentyl )-
 4170-84-7    benzene(l,l-diethylpropyl)-
17376-04-4    benzene(2-iodoethyl)-

E8061
Blank
Soil

E8051
Can
Blank
B 1 a
E8064
Blank
Soil
n k s
E8076
Can
Blank
and C
E9199
Blank
Soil
o n t r o
E8063
Control
Soil
1 s
E8065
Control
Soil

E9200
Control
Soil
 1.5 UK
 0.5 UK
 0.92 UK
 1.3 UK
 0.74 UK

1.0 UK
                                  4.4
                                  1.3
                                  1.4
                                  2.1
                                  2.8 UK
                                  0.64 UK
                                  1.3 UK
              Notes:

                UK =  Unknown, not in NBS library.
                RS =  Reasonable identification;
                     retention time compatibility.

-------
                               APPENDIX E

                  Consideration of Public Health Risks

Attachment 1      Centers for Disease Control  (January 22,  1985)
Attachment 2      USEPA, Chlorinated Dloxlns Work Group (April  4,  1985)

-------
        DEPARTMENT OF HEALTH & HUMAN SERVICES
          Public Haalth Sซrvicซ
          Centers for Disซau Control
o,te   January 22, 1985
From  Chief, Superfund Implementation Group
          Memorandum

       Attachment 1

Centers for  Disease Control
    (January 22, 1985)
Subject Review: Preliminary Dioxin Study
      Midland, Michigan

To    Louise A. Vabinski
      Public Health Advisor
      6TA lesion V
      The material you submitted on the subject site has been reviewed by staff of
      both the Hational Institute for Occupational Safety and Health, and the
      Center for Environmental Health, Centers for Disease Control.  I hope  that
      you find their comments useful.

      COMMOTS

      The reviewers found that the precision, accuracy, and quality  control  ware
      acceptable.  They were aware that all field samples had not been analyzed.
      They believe that the study represents a state-of-the-art attempt  to measure
      the polychloroinated dibenzo dioxlns (PCDD's) and furans (PCDF's)  in soil.

      The surface soil 2,3,7,8-TCDD content is well below the 1 ppb  level at which
      some action to limit human exposure to residential soils needs to  be
      considered (Kimbrough, H.D., Falk, H. Stehr, P. and Tries, G., "Health
      Implications of 2,3,7,8-Tetrachlorodibencodioxin (TCDO) Contamination  of
      Residential Soil." 3. Toxicol. Environ. Health 14:47-93, 1984.)  Thus, we
      agree that levels found in residential soils, including downspout  areas  do
      not represent a significant health risk to either the persons  living there
      or the public at large.

      the results from public use areas are also well below the 1 ppb  level  and
      represent an acceptable risk as defined in Kimbrough et. al.,  1984.

      The soil data in the chemical plant site are consistent with data  from
      similar chemical production facilities.  Without seeing the actual work
      site, it is difficult to assess the degree of potential worker exposures
      from this soil contamination.  However, based on experience at similar
      facilities, it is doubtful whether any significant dioxin exposure would
      occur unless the soil was disturbed due to construction or similar
      activities.  An asphalt or other cover material would be a prudent approach
      to minimize this hazard.

      The ambient air levels presented in Exhibit 5 at the maximum of  0.21 pg/m3
      are unlikely to be a risk for bioaccumulation through the respiratory route.

-------
Pag* 2 - Louis* A. Pabinski

tto f**l that th* warning on sating flab from th* Tittabawaaa** tlv*r ahould
b* continued b*caua* of th* likelihood that fiซh. particularly bottom
f**d*rs. will eontinu* to bioaccumlat* th* anall awnmta pr*a*nt in
detritus and ป*diJMmt.

Th* i*vปle of othซr chemicals, all less hazardous than 2,3.7,8-TCDD. ar*
fairly low and ar* within th* rang* of lev*la found g*n*rally in th*
enviroRMnt and do not r*pr***nt an unaec*ptabl* rl*k.

Th* l*velg ef oth*r dioxine (PCDD's) and furan* (PCDP'ป> that w*r* found in
varioua ar*aa Clxhiblt 7) ar* also I*M than 1 ppb.  Th* ralatlv* proportion
of PGDD** and PCDP'a in th* various aamplaa appaar aittllar although th* high
proportion of "BD'v" m*k*a thia difficult to *•••ป•.  Th*a* eh*mlcalป ar*
Ittas toxie than th* 2r3,7,8-TCOD,  Son* in-plant SMasur*in*nta ar* hlgh*r
(incinarator, w*8t.of building 934>, but ar* unllk*ly to pos* • hasard,
sine* dir*et contact of th* g*n*ral public and of work*ra would b* at a
niniatn.

W* auซt atat* that th*ป* data r*pr*a*nt current l*v*la and w* can nak* no
cotcnant about past *nvironiD*ntal l*v*la, and pot*nti*l rlika that nay hav*
*xiat*d in th* paat.                              /
                                      Gซorgi

-------
                                                   Attachment 2

..                                     USEPA, Chlorinated Dioxins Work Group
                                                  (April 4>  1985)
     |     UNITED STATES ENVIRONMENTAL PR
     '                  WASHINGTON, D.C. 20460

                              April  4,  1985
                                                         OFFICE OF
                                                  PESTICIDES AND TOXIC SUBSTANCES
MEMORANDUM
SUBJECT:  Assessment  of  CDD/CDF  Levels  Found in
          Midland, Michigan
FROM:     Donald G. Barnes     ,jn 
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                              -2-


     Further, CDC has indicated that in many exposure situations
other than residential soils, lซvels higher than 1  ppb could be
tolerated.  An exception discussed by CDC is contaminated soil
in pastureland.  Such cases would require closer analysis;
however, the CDC understands that none of the Region V samples
came from areas in which livestock graze.

     For areas within the perimeter of the Dow plant, some of
the soil samples did contain residues levels above 1 ppb.  It
is the understanding of the CDWG that Dow and Region V have
taken action at these locations to reduce the levels and/or the
associated exposure.

Fish

     The data supplied by Region V indicate that some of the
specimens of certain species of fish taken from the Tittawabassee
River exceed the 25 and 50 ppt "levels" of concern of 2,3,7,8-
TCDD identified by the Food and Drug Administration (FDA).
The data from this set of samples appears to be consistent
with data from earlier studies on fish taken from the same river.

     It is our understanding that other CDDs/CDFs were not
found in these samples; therefore, the 2,3,7,8-TCDD equivalents
approach was not used in this case.

     Further, it is our understanding that on the basis of the
earlier studies, governmental authorities in Michigan have
issued a recommendation against consumption of fish from the
Tittawabassee River.  Based upon the similarity between the
earlier and the recent data, the CDWG sees no reason to relax
whatever restrictions have been deemed appropriate to address
health concerns associated with consumption of fish from this
river.

Attachments

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                                                           TABLE 6

                                                        PCDDs and PCDFs
                                               SITE II - MIDLAND, MICHIGAN AREA
                                                    SURFACE SOIL SAMPLES
                                                             Public Use Areas
Sample No.: 13374 13392 13393 13375 13391 13394
Field ID.: P-5-L P-6-L P-7-L P-9-L P-10-L P-ll-L
Central School
,<, Location: County Line Rd. Mapleton School. Longvlew School Virginia Park (ball diamond) Bullock School
•\\A. 	 "• 	 —
^ PCDDs -tDL)
l 2378-TCDD 0.003 0.001'
.01 Total Iso TCDDs ND 0.001
.xTotal penta CDDs ND 0.014
.evTotal hexa CDDs 0.067 (0.007
oOTotal hepta CDDs 0.35 (0.013
'oOCDD 3.1 0.096
PCDFs (DLJ,
> .<ปป 0.015 (0.003)
I - 0.040
ND (0.035
,"" 0.063 i 0.035
- 0.38 (0.028
_^ 0.86 (0.027;
00 t
,12378-TCDF NO 0.002)- ND (0.005)
ooiTotal TCDFs ND 0.002) -
.'Total penta CDFs ND 0.01) - ND (0.008
,ปiTotal hexa CDFs ND 0.01) - ND 0.024
<06iTotal hepta CDFs 0.065 0.02) " 0.14 0.043
oOCDF 0.044 0.023Jb_ 0.10 0.071
.ซซ• 0.078 (0.003) .air 0.076 (0.003]
- 0.17 ../JL 0.29
- Interference • 0.10 (0.018
.*ป 0.34 (0.02) .ซ** 0.24 (0.018
- 2.3 (0.055) .ป•* 0.41 (0.093
^ 7.0 (0.068) ^ 12.0 (1.5)
1- 0.013 (0.007) .0-* 0.013 (0.002,
ND (0.025) ~ 0.040 (0.01)
0.26 (0.036). ."v 0.064 (0.01)
0.72 (0.021) .•ปซ' 0.50 (0.034
0.64 (0.037) - 0.37 (0.0491
I ,^ 0.012 (0.003)
• ••* 0.040
••ป ND (0.034
ป' 0.086 (0.034
- 0.35 (0.031
~1 0.68 (0.031!
I ,<>•< ND (0.005]
."ป ND (0.007
.••ป NO (0.029
)',-' 0.16 (0.062,
1 - 0.11 (0.070,
*tg ซi*
<**^^ sฃ
.oป 0.11 (0.002)."v
- 0.22 .'*
- 0.12 (0.022).<
."ซ> 0.41 0.022)/
- 2.4 0.042)/
- 7.0 0.052)-
,t>if .|!H
1- 0.015 (0.003K
> - 0.11 (0.017)-
i - 0.17 (0.037)/
- 0.82 (0.045).-'
- 0.66 (0.045)'
Notes:
(1)  Concentrations of >CU0s, PCDFs, andSfet^ctlon
     levels (DL) reported In parts  per  billion  (ppb),

-------
                                                                                                    Attachment 1
                                                            TABLE 6

                                                        PCDDs and PCDFs
                                               SITE fl - MIDLAND, MICHIGAN AREA
                                                     SURFACE SOIL SAMPLES
Upwind
                                                                            Dow Chemical
                                                                              In-Pi ant
13401 13395
UPU-2-L UPH-4-L
Pleasant
View School 4853 U. Kent
ND
ND
ND
ND
0.15
0.34
0.004
0.004
0.024
0.024
0.024
0.026
ND {
ND
ND
0.17
0.33
[0.004)
0.023)
0.023
0.034
0.034
ND (0.004) - ND (0.004)
ND
ND
ND
ND
0.008]
0.022
0.031
0.051,
ND <
ND
ND
^_ ND
0.008
0.023
0.028
0.045
    PCDDS (DL)
 1   2378-TCDD
 tH Total  Iso TCDDs
 .a Total  penta CDDs
 !oV Total  hexa CDDs
 00i Total  hepta.CDDs
' cOCDD
    PCDFs (DL)

 .'  2378-TCDF
.001 Total TCDFs
  .1 Total penta CDFs
 .iiTotal hexa CDFs
  <*>iTotal hepta CDFs
  oOCDF
    Notes:  (1)  Concentrations of PCDDs, PCDFs, and detection
                 levels (DL) reported In parts per billion (ppb).
                          3.5   (0.039)  **
                           0.45  (0.06)
0.27 (0.007
0.32
0.24
4.0
75.0
375.0
0.067
0.067
0.9)
1.3)
0.027 (0.007
0.90
3.1,
15.4
8.6
0.14
0.13
0.38;
0.48

                                                                 .0*
                                                                  "*
                                                                                                         .131

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                                                          Attachment 2
                                                                DRAFT
           CHLORINATED DICKINS WORKGROUP POSITION DOCUMENT
                           March 16, 1985
    RISK ASSESSMENT PROCEDURES FOR MIXTURES OF CHLORINATED DIOXINS
                 AND -DIBENZOFURANS (CDDs and CDFs)*
I.   Summary
     EPA increasingly Is confronted with the need to determine the
risks inherent in exposure to materials such as soot, incinerator
flyash, industrial wastes, soils, etc.  These materials often involve
the potential for exposure to a mixture of chlorinated dibenzo-p-dioxins
(CDDs) and chlorinated dihenzofurans (CDFs).  In response,  the Chlorinated
Dioxins Work Group (CCWG) is proposing a method for assessing the
human health risks posed by mixtures of these chemicals.
     The CDWG has discussed several approaches for making such assessments
and has concluded that a direct biological assessment of the toxicity
of complex mixtures  of CDDs/CDFs is preferred.  Therefore,  research
to develop appropriate methods of this type should be supported.  In
the interim, however, the CDWG believes that a reasonable estimate
of the toxic risks can be made by taking into account the distribution
of CDD/DCF congeners or homologues that are estimated to have the
greatest toxic potential.  This document describes the recommended
procedure for generating the "2,3,7,8-TCDD equivalents" of complex
mixtures of CDDs/CDFs,  based upon congener- or homologue-specific
data and for using such information in assessing risk.
* Refer to Appendix for precise nomenclature used in this paper.

-------
                                  -2-
     The recommendations are summarized in the Table III.
     The CDWG acknowledges that this procedure is not based on a
thorougly established scientific foundation.  It represents a consensus
recommendation on science policy.  Consequently, assessors and risk
managers are urged to use informed discretion when deciding to what
situations the procedure can be appropriately applied.

II.  The Need for a Procedure for Assessing the Risk Associated with
         Exposure to Complex Mixtures of CDDs/CDFs
     During the late 1970s, the Agency was faced with assessing the
human health significance of exposure to 2,3,7,8-tetrachlorodibenzo-
p-dioxin (2,3,7,8-TCDD).  In preparation for the cancellation hearings
for the herbicide 2,4,5-trichlorophenol and silvex, the Agency's
Cancer Assessment Group generated a quantitative cancer risk assessment
for 2,3,7,8-TCDD.  This assessment was later adapted for use in the
Water Quality Criteria (WQC) Document for 2,3,7,8-TCDD.  In addition
to carcinogenicity concernes, the \JQC contains an assessment of
systemic toxicitv, based on reproductive effects produced by 2,3,7,8-TCDD.
The Agency's attention for CDDs and CDFs has expanded more recently.
For example, the current draft of the Health Assessment Document
prepared for the Air Program contains a quantitative risk assessment
for a mixture of hexachlorodibenzo-p-dioxins (HxCDDs), based upon
carcinogenicity studies conducted by the National Cancer Institute.
     However, as early as the late 1970s, it became clear that exposure
situations existed in the country which involved more than simply

-------
                                 -3-

 2,3,7,8-TCDD and/or the mixture of two HxCDDs, the only CDDs/CDFs
 for which toxicological data existed that lent themselves to Quantitative
 risk assessments.  Specifically, data on emissions from combustion
 sources  (e.g., hazardous waste and municipal waste incinerators) and
 contents of  waste from certain industrial production processes indicated
 that the majority of the 75 CDDs and 135 CDFs could be detected in
 the environment.
     Given the high potency and strong structure-activity relationship
 exhibited  in quantitative studies of CDDs and CDFs, the CDWG recognizes
 that the potential risks-posed by the congeners other than 2,3,7,8-TCDD
 and the  mixture of two isomers of HxCDD also need to be addressed.*  Detailed
 consideration of the toxicity the vast majority of the CDDs/CDFS is limited
 by  the lack  of long-term toxicology studies.  Further, it is
 unlikely that many expensive long-term test results will be available
 soon.  For example, research on 2,3,7,8-TCDD has been underway for
more than two decades at an estimated cost in the hundreds of millions
 of  dollars.  Although this chemical has been investigated to a much
greater  extent than any of the other CDDs/CDFs,  unanswered questions
remain.  As noted below, the CDWS believes that it would be unwise,
uneconomical and unnecessary to conduct such extensive testing on
each of the CDD/CDF congeners prior to conducting an assessment of
their risks.*
* In the early 1980s, the Agency developed an approximate method for
assessing the risks of the emission of 2,3,7,8-TCDD-like compounds
associated with the high temperature incinceration of PCBs and combustion
of municipal waste (USEPA, T980;  USEPA, 1981); cf. Table III.   The
procedure presented in this document is a refinement of that approach.

-------
                                 -4-

III.  Approaches to Hazard Assessment for CDD/CDF Mixtures
     A.  Overview.
         1. Preferred Practical Approach — Toxicity Assay of Mixtures
     In the first instance, an assessment of the toxicity of a mixture
of chemicals is best accomplished by direct evaluation of its toxic
effects, e.g., by determining the effects of chronic exposure in an
experimental animal.  Such an assessment is time consuming and costly
and would theoretically have to be performed for each of the many
mixtures of environmental importance.  Therefore, this idealized
approach is not likely to be achieved.
     An alternative, practical approach to hazard assessment of a
mixture is to have an assay that indirectly provides a measure of
the mixture's potential chronic toxicity.  In the case of mixtures
containing CDDs and CDFs, short term assays are under development
that directly determine the 2,3,7,8-TCDb-like response which can be
used as a measure of the toxicity of the mixture as a whole.  Such
assays, which take advantage of the similar toxic manifestations
induced by CDDs and CDFs, have been used to assess the potential
health hazards of exposure to CDD/CDF-contaninated soot from PCB
fires (Eadon, 1982; Gierthy, 1984; Gravitz, 1983), and predicting
the potential toxicity of incinerator flyash (Sawyer, 1983).  The
development of such "mixture assays" assays is progressing rapidly.
While additional work is required to more fully validate the assay
findings for specific toxic endpoints, especially chronic effects,

-------
                                 -5-
data have been presented that indicate correlations with subchronic
effects of CDDs/CDFs (Safe, 1984).  The CDWG recognizes the importance
of this approach in implementing its regulatory strategy for
2,3,7,8-TCDD-like chemicals and encourages research in this area.
        2. Alternative Approach — Additivity of Toxicity of Components
     In the absence of more fully developed "mixture assays", however,
the CDWG recognizes the viability of a second approach to assessing
the risk posed by a mixture of CDDs/CDFs.  First, components in a
mixture of CDDs and CDFs are identified and quantified.  Then, the
toxicity of the mixture is estimated by adding the toxicity of each
of its components.
     In the case of most environmental mixtures, however, this method
cannot be directly applied, since congener-specific analyses for
the 75 CDDs and 135 CDFs potentially present in the mixture are
seldom available.  In addition, there is generally little information
available on the in vivo toxic potency of most of these congeners.
        3. An Interim Approach — 2,3,7,8-TCDD Toxicity Bquivlance
                        Factors (TEFs)
     The CDWG recognizes a third alternative for estimating the risks
associated with exposure to complex mixtures of CDDs/CDFs.  First,
as in approach #2, information is obtained on the concentrations of
homologues and/or congeners present in the mixture.  Then, reasoning
on the basis of structure-activity relations and results of short
term tests, the toxicity of each of the components is estimated and
expressed as an "equivalent amount of 2,3,7,8-TCDD".  Combined with

-------
                                 -6-
esttmates of exposure and known toxlcity information on 2,3,7,8-TCDD,
the risks associated with the mixture of CDDs/CDFs can be assessed.
Key to the approach is the 2,3,7,8-TCDD Toxicity Equivalence Factors
(TEFs) are are derived below.
     The general approach of TEFs outlined here is not unique:
several organizations have used similar approaches; cf. Table III.

     The CDWG recommends that the TEF procedure be adopted as a
matter of science policy on an interim basis.  The approach will
enable the Agency to deal with many, but not all, of its problems;
e.g., which Superfund sites should be given administrative priority,
to what extent a hazardous waste site should be cleaned up, which
manufacturing wastes can be delisted as EPA hazardous wastes, and how
to esimate the risks associated with the emission of CDDs/CDFs
from combustion sources.
     The remainder of this document discusses the TEF approach in greater
detail, illustrates its use in risk assessment, and identifies additional
research, the results of which would strengthen the basis of this interim
approach.

-------
                                 -7-
IV. The 2,3,7,8-TCDD Toxicity Equivalence Factors (TEFs) Approach
        to Assessing the Toxicity of Complex Mixtures of CDDs/CDFs
     2,3,7,8-TCDD is one of 75 CDDs.  Exceptionally low doses of
this compound elicit a wide range of toxic responses in many animals;
e.g., adverse reproductive effects, thymic atrophy, and a "wasting
syndrome" leading to death.  EPA's Cancer Assessment Group (GAG) has
determined that there is sufficient evidence to treat qxialitatively
2,3,7,8-TCDD as a potential human carcinogen and to estimate quantitatively
that it is the most potent animal carcinogen evaluated by the Agency
to date.  Limited data suggest that some of the 74 other CDDs may
have similar toxic effects, again at very doses.
     Moreover, these toxicity concerns are not restricted to CDDs.
Limited experimental data, supplemented by strong structure/activity
relationships in j.n vitro tests that are correlated wi.th in vivo
toxic effects of these compounds, indicate that some CDFs exhibit
"2,3,7,8-TCDD-like" toxicity (Bandiera,' 1984; Safe, 1984).
     Thft cellular biochemical mechanisms leading to the toxic response
resulting from exposure to CDDs and CDFs are not known in complete detail.
However, over the last few years experimental data have accumulated which
suggest that an important role is played by an intracellular protein,
the Ah receptor.  This receptor binds polycyclic aromatic molecules,
including CDDs and CDFs.  In animals, the binding of 2,3,7,8-TCDD
related compounds to this receptor has been correlated with the
expression of several systemic toxic effects including sensitivity
to acute toxic effects (LD5Q values), thymic involution, chloracnegenic

-------
                                 -8-
response, and the induction of several enzyme systems, some of which
have been linked to carcinogenic pathways (Poland.and Knutson, 1982;
Bandiera et al., 1984).
     Table I contains information on a variety of endpoints: acute
toxicity, carcinogenic!ty, reproductive effects, receptor binding,
enzyme induction, and in vitro cell transformations.  The data are
normalized to unity for 2,3,7,8-TCDD.  For example, 2,3,7,8-substituted
HxCDDs have about 5% the Ah receptor binding strength of 2,3,7,8-TCDD,
they are about 70% as potent in the ability to induce the enzyme
AHH; and their carcinogenic potency is about 4% that of 2,3,7,8-TCDD.
Note that for these effects the LOELs or NOELs for 2378-congeners
are a thousand-fold lower than those for the non-2378 congeners.
Kociba (1984) has recently presented similar data.
     The structure/activity generalizations based on the data in
Table I bear ait the generalizations in the literature concerning
the congeners that are most likely to be of toxic concern (Poland,
1982; Gasiewicz, 1982; Bandiera et al., 1984).  That is, congeners
which are substituted in the lateral 2, 3, 7, and 8 positions are
likely to exhibit toxic effects at lower doses than other congeners.
This includes the fifteen tetra-,  penta-, hexa- and heptachlorinated
CDDs and CDFs listed in Table II.*
*     The CDW3 is aware that certain investigators (Grant,  1977;
Olie, 1982; Commoner, 1983; and Ontario, 1983) have broadly defined
the congeners of conern to include all those tri- to hepta- congeners

-------
                                 -9-

which are substituted with at least three chlorines in the four
lateral (2,3,7 and 8) positions.  The CDWG has reviewed the toxicity
data and does not find it to argue strongly for this extended range
of concern.  Further, the increased level of complexity invoked by
including these additional congeners is to suggest a greater level
of accuracy and resolution than the CDWG believes is warranted.

     The CDWG is also aware that receptor binding data suggest a
relatively high toxicity for 1,2,4,6,7-PeCDF.  Examination
of stereochemial models point out that the 4/6 positions on CDFs are
arguably "more lateral" than the 2/8 positions (Bandiera et al, 1984),
However, this increased receptor binding acitivity is not reflected
in an increased ability of 1,2,4,6,7-PeCDF to act as an enzyme
inducer (cf. Table I), an endpoint which has been shown to correlate
with subchronic toxicity (Safe, 1984).  Therefore, the CDWG is not
treating 1,2,4,6,7-PeCDF as a "2378-congener" at this time; however,
additional data could lead to a change in this position.

-------
                                 -10-
     The associated "2,3,7,8-TCDD equivalent factors" were assigned
as follows.  The relative carcinogenicity responses (Table I) for
2,3,7,8-TCDD and the mixture of two 2378-HxCDDs* provide the TEF
for 2378-HxCDD.  The relative toxicity of 2378-PeCDD was taken to be
the root mean square of the 2378-TCDD and 2378-HxCDD values.  The
remaining assignments in Table II and Table III (righthand column)
are based on a rough assessment of the data in Table I, subject to
constraints:
  1. The CDFs are likely to be less toxic than their corresponding
      CDDs, based on compartive toxicity data of 2,3,7,8-TCDD and
      2,3,7,8-TCDF in various species (Moore, et al, 1979).
  2.  As a matter of judgment, the CDWG believes that the uncertainties
       in the procedure limit discrimination of relative toxicity to
       order of magnitude estimates.
In the sane vein, TEFs for the non-2378 isomers are assigned values
which are 1% of the TEFs of the 2378-isomers in the same homologous
group.
     While it could be argued that the hepta- congeners are of minimal
concern, the CDWG recognizes that in some mixtures the hepta congeners
are predominate; therefore, we have chosen not to exclude them entirely.
     The general approach of estimating relative toxicities discussed
here has been taken by other groups in reaching decisions regarding risk.
Table III lists the TEFs used by these other workers.
* Refer to Appendix for nomenclature

-------
                                 -11-
     The TEFs assigned  (except for the HxCDDs) do not rest on
 the results of long term animal studies.  Generally, they are based
 on  estimation of relative toxicity in in vitro tests whose relationship
 to  the chronic effects of concern is largely presumptive.  However,
 experimental results continue to supplement the view that the short
 term assays are providing important fundamental information on the
 toxicity of the CDDs/CDFs.  For example, for the higher chlorinated
 CDFs,  inducation of certain enzymes correlates rather well with
 thymic atrophy and body weight reduction noted in subchronic rat
 studies (Bandiera et al., 1984; Safe, 1984).
        It should also be noted that the structure/activity relationships
 are not universal and cannot be said to have established, at this
 point,  a causal relationship between the Ah receptor and all forms
 of  toxicity of CDDs and CDFs.  For instance, it has recently been
 noted  that die development of porphyria in mice does not correlate
with Ah phenotype and that genes other than Ah influence the development
 of 2,3,7,8-TCDD-induced hepatotoxicity in mice (Greig, 1984).
     In summary, in the view of the CDWG, there is a sufficient scientific
 support for the TEF approach to estimating risks associated with
 CDDs/CDFs that the Agency should adopt the approach, on an interim
basis, as a matter of science policy.

-------
                                 -12-
V.  Applications to Risk Assessment
     In general, an assessment of the risk to human health of a
mixture of CDDs and CDFs involves the following steps:
  1. Analytical determination of CDDs. and CDFs in the sample.
  2. Multiplication of congener concentrations by the TEFs in Table III.
  3. Stagnation of the products in step 2 to obtain the "2,3,7,8-TCDD
       equivalence" of the sample.
  4. Determination of human exposure to the mixture in question,
       expressed in terms of equivalents of 2,3,7,8-TCDD.
  5. Combination of exposure from step 4 with toxicity information
       on 2,3,7,8-TCDD (usually carcinogenicity and/or reproductive
       effects) to estimate risks associated with the mixture.
     In cases in riiich the concentrations of the fifteen congeners
of concern are known:
2,3,7,8-TCDD Equivalents -   3) (TEF of each 2378-CDD/CDF congener
                          x the concentration of the respective congener)  +
                              "2 (TEF of each non-2378 CDD/CDF congener
                          x the concentration of the respective congener)
Examples of this calculation for several environmental mixtures
are provided in Table IV.
     In cases where only the concentration of homologous groups is
known; i.e., no isomer-specific data available, different approaches
are possible.  For example, the assumption that the 2378-congeners
of concern constitute all of the CDDs and CDFs present in the mixture is
likely to provide an upper bound estimate of the toxicity.  Alternatively,
one could assume that the occurrence of each of the congeners in the
mixture has equal probability (01 le, 1982; Qommoner, 1982).  For

-------
                                 -13-
instance, 2,3,7,8-TCDD is one of 22 possible TCDDs and would
constitute about 4 % of a mixture of equally probable isomers.
In other situations, particular knowledge of chemical reaction parameters,
process conditions, and results fron related studies, (e.g., congener
distributions in emissions from combustion sources) might enable one to
estimate the relative occurrence of 2378-congeners.  However, one
must be careful to explicitly explain and justify whatever assumptions
are made.
     The calculated "2,3,7,8-TCDD equivalents" can then be used to
assess the health risk of a mixture.  As an explicit example, consider
a municipal solid waste (MSW) combustor whose particulate emissions,
the CDD/CDF mixture in question, were exactly like the electrostatic
precipitator (ESP) catch cited in columns 5 and 6 of Table IV.   The
sample is estimated to contain 70 ppb 2378-TCDD equivalents; i.e.,
70 picograms of 2378-TCDD equivalents per milligran of mixture.
Suppose that an exposure analysis indicates that a person living
downwind frcm the incinerator receives an average daily dose of 1 ng
of the mixture/kg body weight.  This exposure estimate is combined
with the carcinogenic potency of 2,3,7,8-TCDD (1.6 x H)5 per rog/kg-day
(U.S.  EPA 1984)) to generate the upper bound of the excess
risk of developing cancer for a person living downwind frcm the
facility emitting the mixture under consideration, assuming lifetime
exposure:
  Upper limit of
    excess cancer risk = [potency] x [exposure]
                       - [1.6 x 105 per mg TCDD/kg-day] x [69.6 pg TCDD/
                           mg mixture x 10*9 mg TCDD/pg TCDD x 10-3 ng
                           mixture/kg-day x 1(H> mg mixture/ng mixture
                           - 10-8

-------
                                 -14-
     Use of the different assumptions regarding relative toxicities
(see Table III) influence the calculation of 2,3,7,8-TCDD equivalents
only slightly.  For example, using analytical data from an Agency
study on emissions from a particular municipal waste combustor (EPA
1984), the 2,3,7,8-TCDD equivalents calculated using the assumptions
listed in Table III are generally within an order of magnitude.

VI. Comparisom with Other Approaches to Determining 2.3.7,8-TCDD
         Equivalents
     When the TEF approach is compared with several in vitro and in
vivo bioassays for directly determining 2,3,7,8-TCDD equivalents in
complex mixtures of CDDs/CDFs (the prefered approached discussed in
Section II above), the results are found to be in general agreement.
Eadon (1982) noted that CDD/CDF-contaminated soot from a PCB transformer
fire contained 58 ug 2,3,7,8-TCDD equivalents/gm soot (estimated by
an in vivo assay of the acute toxicity of a soot extract).  This is
to be compared to an estimate of its toxicity using the TEFs shown
in Table III of 37 ug 2,3,7,8-TCDD equivalents/g.
     In another study, Sawyer et al. (1983) and Hutzinger et al.
(1981) developed three estimates for the 2,3,7,8-TCDD equivalents in
a MSW flyash sample: 3.9, 4.6, and 32 ppb, using two different enzyme
induction assays, and the Ah receptor binding assay, respectively.
The use of TEF approach gives a 2,3,7,8-TCDD equivalence of 1.6 ppb.
Recently, Safe has noted a stronger correlation of toxicity with the
enzyme inducition assays than with the receptor assay.  Therefore,
the TEF result is within a factor of 3 best short term assay estimates.

-------
                                 -15-
VII. Research Needs
     As noted above, the CDWG recommends that research be conducted
to develop bioassays that will directly assess the toxicity of complex
mixtures of CDDs/CDFs.  In addition, research should be conducted
which will provide a firmer basis for the TEF approach and guide
appropriate modifications thereof.  This research should be aimed at
  1. Validating and completing the entries in Table I.
  2. Investigating additional short term assays which can test the
       mechanistic hypothesis which underlies the TEF approach.
  3. Investigating correlations between the short term assays and
       results of longer term assays.

-------
                             -/fc-
VI.  REFERENCES.

Bandiera, S. et al., 1983.  Competetive binding of the cytosolic
tetrachlorodibenzo-p-dioxin receptor.  Biochem. Pharmacol.
32: 3803-3813.

Bandiera, S. et al., 1984.  Polychlorinated dibenzofurans (PCDFs):
Effects of structure on binding to the 2,3,7,8-TCDD cytosolic
receptor protein, AHH induction and toxicity.  Toxicol. 32:131-144.

Bradlaw, J. et al., 1979. Induction of enzyme activity in cell
culture: A rapid screeen for detection of planar polychlorinated
organic compounds.  J. Assoc. Off. Anal. Chem. 62: 904-916.

Bradlaw, J. et al., 1980.  Comparative induction of aryl hydro-
carbon hydroxylase activity in vitro by analogues of dibenzo-ฃ-
dioxin.  Cosmet. Toxicol. 18: 627-635.

Commoner, B. et al., 1984.  Environmental and economic analysis
of alternative municipal solid waste disposal technologies.  I. An
assessment of the risks due to emissions of chlorinated dioxins
and dibenzofurans from proposed New York City incinerators.  Center
for the Biology of Natural Systems, Queens College, CUNY, Flushing,
New York.  May 1 .

Cooper Engineers, 1984.  Air emissions and performance testing of
a dry scrubber (quench reactor) dry venturi and fabric filter
system operating on flue gas from combusion of municipal solid waste
at Tsushima, Japan.

Czuwa, J.M., and R. Hites, 1984.  Environmental fate of combustion-
generated polychlorinated dioxins and furans.  Environ. Sci.
Technol. 16: 444-450.

Des Rosiers, P., 1984.  PCBs, PCDFs, and PCDDs resulting from
transformer/capacitor fires: An overview.  Proc. 1983 PCS
seminar. Research project 2028, Electric Power Research Institute.
Palo Alto, California.

Eadon.G. et al., 1982.  Comparisons of chemical and biological
data on soot samples from the Binghamton State Office Building.
New York State Department of Health (Unpublished report).

EPA, 1984.  Assessment of emissions of specific compounds from
a resource recovery municipal refuse incinerator.  Office of
Toxic Substances.  EPA 560/5-84-002.  June.

Gierthy, J. F. and D.  Crane. 1984.  Reversible inhibition of in
vitro epithelial cell proliferation by 2,3,7,8-tetrachlorodibenzo-
ฃ-dioxin.  Toxicol. Appl. Pharmacol. 74: 91-98.

Gierthy, J.F., and D.  Crane. 1985.  In vitro bioassay for dioxin-
like compounds.  A.C.S. meeting, Miami, FL. April (preprint
extended abstract).

-------
                             -17-
Grant, D.L.,  1977.  Proc. 12th annual workshop on pesticide residues
analysis.  Winnipeg, Canada, p. 251.

Gravitz, N. et al.,  1983.  Interim guidelines for acceptable
exposure levels in office settings contaminated with PCB and
PCB combustion products.  Epidemiological Studies Section, California
Department of Health Services. Sacramento. November 1.

Greig, J.B. et al., 1984. Incomplete correlation of 2,3,7,8- tetra-
chlorodibenzo-ฃ-dioxin hepatotoxicity with Ah phenotype in nice.
Tox. Appl. Pharmacol. 74:17-25.

Harding, D.H. 1982.  Chlorinated dioxins and chlorinated dibenzo-
furans ambient air guideline.  Health Studies Service, Ministry
of Labor.  December.

Hassoun, E.,  et al. 1984.  Teratogenicity of 2,3,7,8-tetrachloro-
dibenzofuran in the mouse.  J. Tox. Envl. Health 14:337-351.

Hutzinger, 1981.  Polychlorinated dibenzo-p-dioxins and dibenzo-
furans: A bioanalytical approach.  Chemosphere 10: 19-25/

Knutson, J.,  and A. Poland, 1980.  Keratinization of mouse
teratoma cell line XB produced by 2,3,7,8-tetrachlorodibenzo-ฃ-
dioxin: An in vitro model of toxicity.  Cell 22:27-36.

Kociba, R.J.  and 0. Cabey.  1984.  Comparative toxicity and biologic
activity of chlorinated dibenzo-p-dioxins and furans relative to
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD).  Presented at the
Fourth International Symposium on Chlorinated Dioxins and
Related Compounds, Ottawa, Canada.  October.

Lamparski, L.L. et al. 1984.  Presence of chlorodibenzodioxins
in a sealed 1933 sample of dried municipal sewage sludge,
Chemosphere 13: 361-365.

McKinney, J., and E. McConnell, 1982. Structural specificity and
the dioxin receptor.  Perg. Ser. Env. Sci. 5:367-381.

Murray, F.J.  et al., 1979. Three-generation reproduction study of
of rats given 2,3,7,8-tetrachlorodibenzo-ฃ-dioxin in the diet.
Toxicol. Appl. Pharmacol.  50:241-252.
National Cancer Institute (NCI).  1980a.  Bioassay of 2,3,7,8-Tetra-
chlorodibenzo-ฃ-dioxin for possible carcinogenicity (gavage study).
Carcinogenesis Testing Program.  DHHS pub. no. (NIH) 80-1765.
National Cancer Institute (NCI).  1980b.  Bioassay of a mixture
of 1,2,3,6,7,8- and 1 ,2 ,3,7 ,8,9-hexachlorodibenzo-j>-dioxlns
for possible carcinogenicity (gavage study).  DHHS pub. no.
(NIH) 80-1754.

Neal, R.A., et al., 1982.  The toxicokinetics of 2,3,7,8-tetra-
chlorodibenzo-p-dioxin in mammalian systems.  Drug Metab. .Rev.
13: 355-385.

-------
Olle, K., et al., 1983.  Formation and fate of PCDD and PCDF
froo combustion  processes.  Chemosphere 12: 627-636.

Poland, A., et al., 1976. 3,4,3*,4'-tetrachloro azoxybenzene and
azobenzene: Potent indueera of aryl hydrocarbon hydroxylase.
Science 194: 627-630.

Poland,A. and J. C. Knutson, 1982.  2,3,7,8-Tetrachlorodebenzo-
2-dioxin and related halogenated aromatic hydrocarbons: An
examination of the mechansim of toxicity.  Ann. Rev. Pharmacol.
Toxlcol. 22: 517-554.                      	

Rappe, C., 1984. Analysis of polychlorinated dioxins and furans.
Env. Science and Techno1. 18: 78A-90A.

Rizzardini, M., et al., 1983.  Toxicological evaluation of
urban waste incinerator emissions.  Chemosphere 12: 559-564.

Safe, S., et al., 1984.  Polychlorinated dibenzofurans:
chemistry, biochemistry, and toxicology.  Presented at the
Fourth International Symposium on Chlorinated Dioxins and
Related Compounds.  Ottawa, Canada. October 1984. (Abstract).

Sawyer,!., et al., 1983.  Bioanalysis of polychlorinated dibenzo-
furan and dibenzo-p-dlioxin mixtures in fly ash.  Chemosphere
12: 529-534.	

Schwetz, B.A. et al., 1973. Toxicity of chlorinated dibenzo-p_-
dioxins.  Env. Health Persp. 5:87-89.

Swiss Government (Bundesamt fur Umweltschutz, Bern), 1982. [Envi-
ronmental pollution due to dioxins and furans from chemical rubbish
incineration plants]. Schriftenreige Umweltschutz, No. 5.

Tong, H.Y. et al., 1984.  Identification of organic compounds
obtained from incineration of municipal waste by HPLC and GC/MS
J. Chromatographv 285:423-441.

USDHHS.  1983.  Levels of concern for hexa- (HCDD), hepta- (HpCDD)
and octachlorodibenzo-p-dioxins (OCDD) in chicken and eggs.
Memorandum from N. Bolger and 6.N. Biddle to J. Taylor. April 29.

USEPA, 1981. Interim evaluation of health risks associated with
emissions of tetrachlorinated dioxins from municipal waste resource
recovery facilities.   Office* of the Deputy Administrator.  November 19,

USEPA, 1984a.  Health Assessment Document for Polychlorinated
Dibenzo-2-dioxins.  External Review Draft.   May.  EPA 600/8-84-014A.

USEPA, 1984b.  Thermal degradation products from dielectric fluids.
December.  EPA 560/5-84-009.

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                             -14-


v.d. Berg, M.,  et al., 1983.  Uptake arid selective retention In rats
of orally administered chlorinated dioxins and dibenzofurans
from fly ash and fly ash extract.  Chemosphere 12:537-544.

Weber, H., et al., 1984.  Teratogenicity of 2,3,7,8-tetrachloro-
dibenzofuran (TCDF) in mice.  Toxicol. Letters 20: 183-188.

-------
                                    POTENCIES Of PIPKINS RELATIVE TO 2,3,7,8-TCDD
CHEMICAL
CDOs:
Mono thru tri
2378-TCDD
TGDDs
2378-PeCDD
PeCDDs
2378-HxCDDs
HxCDDs
2378-HpCDDs
HpCDDs
OQDD
CDFs;
Mono thru tri
2378-TCDF
TCDFS
2378-PeCDF
12467P6CDF
PeCDFs
2378-HxCDFs
HxCDEs
2378HpCDFs
HpCDFs
GUINEA PIG
<10-*(e)
1 (a)
<.001(a)
.67 (a)
.002(a)
.03 (a)
.004(a)
.002(a)
—
—
.28;.5(a)

.017(a)


CARCINO- REPROD. TER. RECEPTOR ENZYME INDUCTION CELL FIAT (XB)
GENICm EFFECTS BINDING AHH EROD KERATIN. CELL ASSAY
(ref) (ref) (ref) (ref) (ref) (ref) (ref ) (ref)
— — .OOl-.Ol(e) <.001(f) — .Ol(e) —
Kb) l(c) l(i) l(e) l(e) Kg) l(e) l(j)
— <.001(k) <.01-.16(e) <.001-.02(g) — <.001-.01(e)
— — Ke) .02-.2(g) — .5(e) —
— — — <.001(g) — — —
,04(b) .01(c) .05(e) .001-. Kg) — ,005(e) —
— — — <.001(g) — —
— — — .002-.004(g,f)— — —
— — — <.001(f) — —
•— <.00001(k) — <.001(f) — — —
— — ฃ.001-.02(d,h)<.001(d) <.001(d) <.001(e)
.03-.13(i,k) .3/.25(e/h) .01-.04(frh) ,l(h) .05(e) ,l(j)
— — .001-.05(d,e) COOKd) _<.005(d) — —
— .13/.7/.6(d/e/h) <.3(d) .l(d) —
.15(h) ,002(h) <.001(h) — —
.001-.l(d,e) ฃ.001(d) <.001(h) —
.04-.5(e,h) .05-.2(h) ,l-.5(h) — —
— .001(e,h) .002(h) ,006(h) —
,004(g) — — —
— — <.001(h) <.001(f) — — _
a.  McKinney and McConnell, 1982;   b. USEPA 1984a;   c.  Murray et al.,  1979;  Schwetz et al.,  1973;
Wfeber et al., 1984.;   d. Bandiera et al., 1983;   e.  Knutson and Poland, 1980; f.  Bradlaw et al.,  1979;
g.  Bradlaw et al., 1980;  h. Bandiera et al., 1984;   i.  Hassoun et al., 1984;  j.  Gierthy and Crane,  1985;
k. Weber et al., 1984;

-------
                           TABLE II

            CDD/CDF ISOMERS OF MOST TOXIC CONCERN3/
        DIOXIN
Isomer
TEFb/
                  DIBENZOFURAN
Isomer
TEF
2,3,7,8-TCDD            1

1,2,3,7,8-PeCDD         0.2
1 ,2,3,6,7,8-HxCDD       0.04
1 ,2,3,7,8,9-HxCDD       0.04
1 ,2,3,4,7,8-HxCDD       0.04
1 ,2,3,4,6,7,8-HpCDD     0.001
            2,3,7,8-TCDF        0.1

            1 ,2,3,7,8-PeCDF     0.1
            2,3,4,7,8-PeCDF     0.1

            1,2,3,6,7,8-HxCDF   0.01
            1 ,2,3,7,8,9-HxCDF   0.01
            1,2,3,4,7,8-HxCDF   0.01
            2,3,4,6,7,8-HxCDF   0.01

            1,2,3,4,6,7,8-HpCDF 0.001
            1 ,2,3,4,7,8,9-HpCDF 0.001
a/  In each homologous group the relative toxicity factor for the
    isomers not listed above is 1/100 of the value listed above.
b/  TEF ป toxic equivalency factor = relative toxicity assigned.

-------
                            TABLE III




SOME APPROACHES TO ESTIMATING RELATIVE TOXICITIES OF PCDDS and
PCDFS
BASIS/ SWISS3 GRANT5 NEW YORK ONTARIO^
COMPOUND/ OLIEC STATEฎ
COMMONER!
(Basis) enzyme
Mono and di
237-TrCDD
other TrCDDs
2378-TCDD
other TCDDs
2378-PeCDDS
otherPeCDDs
2378-HxCDDs
other HxCDDs
2378-HpCDDs
other HpCDDs
OCDD
2378-TCDFs
other TCDFs
2378-PeCDFs
other PeCDFs
2378-HxCDFs
other HxCDFs
2378HpCDFs
other HpCDFs
OCDF
0
0
0
1
0.
0.
0.
0.
0.
0.
0.
0
0.
0.
0.
0.
0.
0.
0.
0
0
*: congeners with


01
1
1
1
1
01
01

1
1
1
1
1
1
1

0
0.1*
0
1*
0
0.1*
0
0.1*
0
0.1*
0
0
0.1*
0
0.1*
0
0.1*
0
0.1*
0
0
chlorine
**: these isomers were
a = Swiss government,
b ป Grant, 1977
c - 01 ie et al., 1982;
d - Commoner, 1984
e = Eadon, 1982
not
1982
1983
LD50
0
0
0
1
0
1
0
0.03
0
0
0
0
0.33
0
0.33
0
0.01
0
0
0
0
atoms at
considered
f =
g •
h =
i -
FDA9
CAh EPA1 EPA
1982 Current
Recommend .
various various
effects effects


0
0
0
0

0
0
0
0
0
0
0
0

3 of
.
0
1*
0
1*
.01
1*
.01
1*
.01
1*
.01
0 <0.
.02*
.0002
.02*
.0002
.02*
.0002
.02*
.0002
0
0
0
0
1
0
_**
_**
0.02
0.02
0.005
0.005
00001
0
0
0
0
0
0
0
0
0
the 4 lateral


0
0
0
1
0
1
0
1
0
1
0
0
1
0
1
0
1
0
1
0
0
Care in.
0
0
0
1
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0


0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
1
.01
.2
.002
.04
.0004
.001
.00001
0
.1
.001
.1
.001
.01
.0001
.001
.00001
0
positions.




Ontario, 1982
USDHHS, 1983
California, 1982
USEPA, 1981

-------


ISOMER


TCDDS
PeCDDs
HxCDDs
HpCDDS
OCDD
TCDFs
PeCDFs
HxCDES
qpCDFS
OCDF
Total TCDD



AIR PARTICS.
St. Louis 5
TEF Gone. TCDD
Eqts.
(ppb)
1 0.2 0.2
0.2 1 0.2
0.04 1.2 0.048
0.001 25 0.05
0 170
0.1
0.1
A -
0.001
0
Eqts. 0.5

1. USEPA 1984b.
2. Cooper Engineers, 1984.
3. Rappe, 1984.
TABLE IV
PCDDS/PCDFS IN SOME ENVIRONMENTAL SAMPLES
MSW LAKE 1982 MSW FLYASH 6
ESP DUST 5 SEDIMENT 5 MILORGANITE 4 ONTARIO OSLO
Cone. TCDD Cone. TCDD Cone. TCDD Cone. TCDD Cone. TCDD
Eqts. Eqts. Eqts. Eqts. Eqts.
(ppb) (ppb) (ppt) (ppt) (ppt)
550 0 206 206 541 541 ND -
10 2 0.1 0.02 - - 467 93 11 2.2
160 6.4 0.34 0.014 2768 110.7 591 24 51 2
120 0.24 0.5 0.001 7600 15.2 434 0.9 119 0.2
260 - 1.3 - 60000 - 467 - 186 -
40 4 0.13 0.013 -
80 8 0.14 0.014 -
280 28 0.38 0.038 -
160 0.16 1.13 0.001 -
40 - 0.14 -
70 0.10 332 &59 5

4. Lanparski et al., 1984 7. des Rosiers, 1984.
5. Czuwa and Hites, 1984.
6. Tong et al., 1984

-------
TABLE IV (Continued)
THERMAL DEGRADATION PRODS.
FROM DIELECTRIC FLUIDS *
run
8-13-40
ISOMER
TEF Cone.
(ng)
TCDDs
2378
other
PeCDDs
2378
other
HxCDDs
2378
other
HpCDDs
2378
other
OCDD
TCDFS
2378
other
PeCDFs
2378
other
HxCDFs
^^ 2378
other
HpCDFs
2378
other
OCDF

1
0.01

0.2
0.002

0.04
0.0004
0.01
0.0001
0

0.1
0.001

0.1
0.001
oS
o/boi
0.001
0.00001
0
0


0


0


0

0
690


43


7
0

0
Total TCDD Eqts.
TCDD
Eqts.
0


0


0


0

0
69


4.3


0.7
0

0
75
JAP. MSW^
Run Pt. A TEF Pt. B
8-30-61 ASKL
Cone.
(uq)
0


0


0


330

37
1400


6400


910
29

3.4

TCDD Cone. TCDD Cone.
Eqts. Eqts.
(lb/MMBTU(xlO:ฑ))
0


0


0


0.66

0
140


640


91
0.029

0
872
0.1 0


0.07 0


0.04 0


0.02 <

0.01
1.31 0


0.38 0


0.06 0
0.01 <

0.004
0
.1


.014


.002


.001

0
.131


.038


.006
.001

0
.3
0.58


0.47


0.36


0.08

0.04
1.25


0.46


0.06
0.02

0.01

TEF
TCDD
Eqts.
0.58


0.094


0.014


<.001

0
0.125


0.046


0.006
<.001

0
0.87
COMMERCIAL CPs SOOT FROM PCB
PCS FIRE!
246TCPJ PCP3
Cone. TCDD Cone. TCDD Gone

. TCDD
Eqts. Eqts. Eqts.
(ppn) (ppm) (ppn)
< .1 - < .1 -
1.6
1.6
<.l - <•! -
2.5
2.5
<1 - 2.5 0.1
1.1
3.6
<1 - 175 0.35
7
7
<1 - 500 -
1.5 0.15 <.l -
16
12
17.5 1.75 <.l -
358
312
36 3.6 <.3 -
670
295
4.8 0.005 19 0.019
288
172
<1 - 25 - 40
5.5 0.5

1.6
.016

.5
.005

.044
.001
.007
0
—

1.6
.012

35.8
.312
67
.295
.288
.017
•
107

-------
                             APPENDIX
     The following terminology and abbreviations are used in this
document:
1. The term "congener" refers to any one particular member of
    the same chemical fanily; e.g., there are 75 congeners of
    chlorinated dibenzo-ฃ-dioxins.
2. The term "homologue" refers to a group of structurally related
    chemicals which have the sane degree of chlorination.  For example,
    there are eight homologues of CDDs, monochloroinated through
    octochlor inated.
3. The term "isoroer" refers to substances which belong to
    the same homologous class.  For example, there are 22 isoners
    that constitute the hcnologues of TCDDs.
4. A specific congener is denoted by unique chemical notation.
    For example, 2,4,8,9-tetrachlorodibenzofuran is referred
    to as 2,4,8,9-TCDF.
5. Notation for homologous classes is as follows:
     Dibenzo-g-dioxin              D
     Dibenzofuran                  F
     No. of Halogens            Acronym        Example
           2                       D            2,4-DCDD
           3                       Tr
           4                       T            1,4,7,8-TCDD
           5                       Pe
           6                       Hx
           7                       Hp
           8                       0
       1 through 8            CDDs and CDFs

-------
                             -2-
6. Dibenzo-ฃ-dioxins and -dibenzofurans that are chlorinated
    at the 2,3,7 and 8 positions are denoted as 2378 congeners;
    e.g., 1,2,3,7,8-PeCDF and 2,3,4,7,8-PeCDF are both referred
    to as "2378-PeCDFs".

-------
EXHIBIT I

-------
Study of
DIOXIN  &other
TOXIC POLLUTANTS
Midland, Michigan
U.S. EPA Region 5
April 1985

-------
DIOXIN
A generic term for a group of
75 related compounds known
as polychlorinated dibenzo-
p-dioxins. The most toxic
compound of this group is
2,3,7,8-tetrachloro-dibenzo-p-
dioxin (2378-TCDD). A num-
ber of the dioxins, including
2378-TCDD, are formed as
inadvertent  byproducts dur-
ing  the  manufacture of or-
ganic chemicals, particularly
chlorinated  phenols. Certain
combustion sources such as
municipal  and industrial
waste incinerators and acci-
dental electrical transformer
fires have been shown to be
sources of  2378-TCDD and
other dioxins. The levels of
2378-TCDD  from  these
sources have been relatively
low compared to levels from
chlorinated  phenols produc-
tion. 2378-TCDD is very per-
sistent in the  environment.
It does  not readily degrade
into less toxic chemicals.
Tests on laboratory animals
indicate 2378-TCDD is one of
the most toxic chemicals
made by man.  Based on its
estimated carcinogenic po-
tency, cancer risks of individ-
uals who consume fish con-
taminated with high levels of
2378-TCDD  could be signifi-
cant. Exposure  to  Dioxin
contaminated soils could
also significantly increase
cancer risk.
As part of its National Dioxin
Strategy, the  U.S. EPA  has
begun a national dioxin study
to determine  the  extent of
dioxin contamination in the
environment. The results of
that study  are expected by
the end of 1985.
'JSl frfe Saate of MWhfesfl's request, the U.S. Environ-
. ti#nfe& Pr(|teotl^;^erv5y,,ltias been  conducting
 ^^refiet^ye ewwrtieh^rt stupes in the City of
 Midland,  inside the Dow Chemical Midland plant,
     at companion sites across th$ Midwest. While
 the primary focus of the studies was on possible
          78-TCl30rtoontstmifiatten In the Midland
      EPA also sampled for Other toxic chemicals.
 F|isujts show that;
> Current dtoxin levels in surface soils away from
   the Dow Chemical plant are welt tetow one part
   p&r billion (ppb). According  to  the Centers for
   Disease Control, one ppb is the level at which
   some  action  must be considered  to  prevent
   human exposure to the dfoxin-eontaminated soil
   in residential areasii Current levefs of dioxln in the
   Midland  area, therefore, do  not pose an unac-
   ceptable public health risk.
 * Inside  the Dow Chemical plant, EPA found con-
   centrations as high as 36 ppb in surface soils.
   (P0W Ghe|rfc?al; rafted cohp^ntratJons as high
   af ง1  p^yc^n60ifra^tl0ha  insUe the plant are
   generally in the lower range of levels found at
   similar chemical manufacturing and disposal sites
   in other parts of the country, EPA, the State of
   Michigan, and Dow Chemical have entered into a
   proposed consent order to provide interim cover-
   ing of  surface areas  that have high concentra-
   tions inside the plant. A publfe comment  period
   on the consent order began  on March 20,1985
   and will last until April 17, 1985.
 • Concentrations  of dioxin found in the City of
   Midland away from the Dow ptetnt are significantly
   higher than the trace levels found In  A  few
   samples taken in other cities. Most samples from
   these  comparison sites,and all samples from
   natural areas,dld not contain  dioxin at detectable
   levels.
 • Air emissions  from the Dow Chemical plant are
   the likely source of dioxin  contamination in the
   Midland area.
 * Current levels of toxic organic pollutants, other
   than dioxins, in Midland soils are at levels found
   elsewhere in the environment and do not pose an
   unacceptable  public health risk.
 • Because of high dioxin levels in fish taken from
   the Tittabawassee River, a warning on eating fish
   — particularly bottom-feeding fish such as carp
   and catfish — should be continued.

-------
INTRODUCTION
This report presents a brief history of dioxin findings in the
Midland area, a description of EPA's soil study, the soil
study results, and conclusions from the Centers for
Disease Control (CDC) and EPA about health risks from
exposure  to contaminated soils. In addition, data from
other  locations, including cities that also have chemical
manufacturing plants and disposal sites, are compared to
data from Midland. Results and conclusions from fish
sampling in the Tittabawassee River are also presented.

The study in Midland has been incorporated into the
National Dioxin Strategy. The National Dioxin Strategy is
examining potential sources and risks of dioxin in the envi-
ronment.  It is organized  into seven tiers or categories
ranging from sites where dioxin was most likely to be found
(Tiers 1  and 2) to sites  where contamination  is not
suspected (Tier 7).
HISTORY OF DIOXIN FINDINGS
In June 1978, Dow Chemical advised the Michigan Depart-
ment of Public  Health (MDPH) that it had found dioxin
(2378-TCDD) in fish caught from the Tittabawassee River.
The MDPH immediately issued an advisory against eating
fish from the  river. That advisory is still in effect today.
Subsequently,  the  Michigan Department of Natural
Resources (MDNR), in cooperation with EPA, sampled fish
from  the  Tittabawassee River and confirmed Dow's
findings.

The agencies attempted to determine if Dow Chemical's
wastewater discharges, which flow into the Tittabawassee
River, contained the dioxin that was  accumulating in the
fish.

However,  at that time,  regulatory agencies could not
detect dioxin  at ultratrace levels in water because
analytical methods had not yet been developed that were
able  to detect dioxin at very low levels.

In the fall of 1981, MDNR and EPA conducted a caged-fish
study in the Tittabawassee  River to determine if Dow
Chemical was the source of the dioxin. Catfish were kept
in cages for 28 days both upstream and downstream of
Dow Chemical  and  directly in the plume of Dow's dis-
charge in the  river. An experimental method of ultratrace
analysis for dioxin in water was also developed as part of
that study.

The preliminary results released in  March 1983 demon-
strated that Dow Chemical's wastewater was the source
of dioxin.  Subsequent analyses by  Dow Chemical have
confirmed that finding.

In the spring of 1984, the State of Michigan, with EPA's
concurrence,  issued a wastewater discharge permit and
an administrative order to Dow Chemical that limits the
discharge  of 2378-TCDD. The order also requires the con-
struction of wastewater treatment systems as a first step
in reducing dioxin discharges.

In March 1983,  the State of Michigan formally requested
EPA  to conduct a comprehensive study  of dioxins and
other toxic pollutants at Dow Chemical's Midland plant, in
the Tittabawassee River, and in the City of Midland. The
state and EPA planned the study in the spring of 1983. Soil
sampling was conducted in Midland, at Dow Chemical,
and at the comparison sites during 1983 and 1984. Dow
incinerator  emissions, ambient air samples,  Dow brine
system and  wastewater samples, drinking  water  well
samples, and river sediment samples were also collected
in 1984.
SOIL STUDY

Study Objectives
The principal objective of the soil study was to determine
whether concentrations of dioxins and other toxic pollut-
ants in Midland surface soils could pose unacceptable
public health risks. The study was also conducted to deter-
mine the likely source or sources of ambient levels of diox-
ins in Midland; if levels found in Midland are comparable to
levels found  in other industrial areas with  combustion
sources and process operations different from those at
Dow Chemical; and whether levels found in  Midland  are
significantly different from background levels generally
found in the environment.

Conduct of the Study
The investigation of dioxin  and other toxic pollutants in the
Midland area  is one of the first and most comprehensive
studies conducted by EPA in which laboratory methods
capable of detecting 2378-TCDD  at the  low  parts  per
trillion (ppt) range were used.

(One ppt is 1,000 times less than one part per billion (ppb)
which is the level in residential soils at which CDC believes
some action to limit human  exposure needs to be con-
sidered.)
Throughout this study, elaborate quality assurance controls
were used to ensure that accurate data were produced.
Field work was thoroughly documented.  Duplicate  soil
samples were obtained at certain locations. Clean,  dis-
posable sampling  equipment was used for each sample.
Each  sample  was  coded with a unique identification
number. The samples were thoroughly blended in a labora-
tory before extraction and analysis.

All samples were then analyzed on a blind basis, that is,
EPA laboratories  at  Bay St.  Louis, Mississippi,  and
Research  Triangle Park,  North Carolina,  did  not know
where the samples had been taken or the identity of the
samples they were analyzing. Control and blank samples
were also submitted to the laboratories on a random, blind
basis. In addition,  EPA provided split samples to Dow
Chemical  on  a blind basis  for comparative  analyses.
Dow's analyses confirmed EPA's results.

EPA believes that the data obtained accurately reflect sur-
face soil conditions  in Midland, at Dow Chemical, and at
the comparison sites. This set of high quality data is suffi-
cient to evaluate health risks to Midland residents from
exposure to current levels of 2378-TCDD and other pollut-
ants in Midland soils.

-------
    acres) of, native pr-aMe, to
    Itasca Wilderness
    pine-dominated fo
    logged. Bluestem
    ftath$aซjtiปetn
FIGURE  1
MAP OF EPA  REGION 5
SHOWING  LOCATIONS
OF SOIL STUDY SITES
    .Th$ principal
    cess vents and some combustion sources.
    There .are no' 'tier 1 -or Tier ,8-, sffiss its'
    cJeftfterfbyfiPA's, National Dfoxlr* Strateg
    fn the Heftr^,.; yiteof^ area, Hemy>
    rwpufatton Qf atooirt 2,?CXJ,
. .
                  , OWo, area.

-------
Soil Study Results
The study results for 2378-TCDD for each site are sum-
marized in Table 1. The Dow Chemical and City of Midland
data are highlighted in the centerfold of this summary
report.
Figure 2 compares the ranges of dioxin levels found in sur-
face soils at each of the comparison sites with levels found
in Midland. The data show that levels of dioxin in Midland
away from the Dow plant are well below the  1 ppb level of
concern established by CDC for residential soils. One sam-
ple obtained near the east fence line of the Dow plant had
a dioxin concentration of 2.03 ppb. Supplemental sampling
conducted by Dow Chemical around the site showed the
2.03 ppb concentration to be isolated to a small area. Dow
Chemical has extended its fencing around that site to pre-
vent public access.
The next highest sample obtained near the perimeter of
the Dow plant contained less than 0.55  ppb of dioxin. Fre-
quent and prolonged exposure of the public to soils around
the perimeter of the Dow plant is not likely.

Figure 2 also shows that, while levels  of dioxin found in
Midland are well below CDC's level of concern for residen-
tial areas, those levels are higher than found around other
industrial sites and in natural areas.
Figures 3, 4 and 5 present the dioxin data for Midland
public use and residential areas, the  perimeter of the Dow
plant, and inside the Dow plant. The data in Figure 3 show
that most values of 2378-TCDD in Midland public use and
residential areas are at or  less than 0.10 ppb. All values
were less than 0.30 ppb.
Four out of the five highest values in the city were found at
residential downspouts, indicating that airborne emissions
from Dow Chemical are the likely sources of  dioxin. Down-
spouts can be good indicators of atmospheric contamina-
XI
a
Q
Q
O
I-
 I
00
N
CO
M
              FIGURE 2
              COMPARISON OF
              MIDLAND SOIL DATA
              TO OTHER SITES
                      Geometric Mean
                      Arithmetic Mean
CDC LEVEL OF CONCERN
FOR RESIDENTIAL SOILS

-------
2378-TCDD
SURFACE SOIL CONCENTRATIONS
MIDLAND, Ml
                                 DOW   •*
                                 CHEMICAL
                                 COMPANY

-------
                                 1+
                                 0.5-1.0
                                 0.1-0.6
                                 0.05-0.10
                                 0.001-0.05
                                 OPEN AREA SAMPLE
                                  DOWNSPOUT SAMPLE
CORNING

-------
s

3

7
  3

  2

  1

  0

     nil
FIGURE 3
PUBLIC USE AND
RESIDENTIAL AREAS
MIDLAND, Ml
                  2378-TCDD (ppb) in
                  SURFACE SOILS
         .05    .10   .15
              .20    .25
              Concentration (Parts Per Billion)
                                     ?$JSS$r ;"ฃ\
                         in

                         o


                         I
                                     FIGURE 4
                                     PERIMETER DOW CHEMICAL
                                     MIDLAND PLANT
                                                 2378-TCDD (ppb) in
                                                 SURFACE SOILS
                                        O.5  1.2     1.5

                                         Concentration (Part* Per Billion)
  5r
&
  0
                      FIGURE 5
                      DOW CHEMICAL
                      MIDLAND PLANT
                                2378-TCDD (ppb) in
                                SURFACE SOILS
                   1.0 3.0      3.5      4.0

                         Concentration (Part* Per Billion)
                                4.5 35.5
                                                      36.0

-------
tion because airborne particles tend to collect on exposed
surfaces such as building  roofs. These  particles  are
washed from  the  roofs by  rain and deposited in soils
around the downspouts.

Figure 4 shows that although one value of  2.03 ppb was
found on the perimeter of the Dow plant, the next highest
value is less than 0.50 ppb. Data presented in Figure 5 indi-
cate that most values found inside the Dow Chemical plant
have  less than 0.50 ppb of 2378-TCDD. A  few sampling
locations inside the Dow plant had concentrations in the 3
to 5 ppb range and one location had a dioxin  concentration
of 36 ppb. Supplemental sampling by Dow Chemical indi-
cates that most of the Dow plant had dioxin concentrations
less than 1 ppb, although one sample had a value of 51 ppb.

CDC  has  stated that,  based on experience at  similar
facilities, it  is doubtful whether significant dioxin exposure
to workers would occur at the plant unless the soil was
disturbed because  of construction or similar activities.

EPA,  the State of Michigan, and Dow Chemical have
entered into a proposed consent order by which Dow
Chemical will provide interim covering of the two identified
high concentration areas with asphalt to minimize expo-
sure to plant  workers  and prevent migration  of  dioxin
offsite.
Consideration of Health Risks
The data from this study were reviewed by CDC to deter-
mine  whether levels of dioxin  and other pollutants in
Midland soils  might  pose unacceptable health risks to
Midland residents.

CDC concluded that levels of 2378-TCDD in Midland soils
are well below the 1 ppb level at which some action to limit
human exposure to residential soils needs to be consid-
ered;  and, that levels found in residential soils, including
downspout areas, do not represent a significant health risk
to either the persons living there or the public at large.

The levels of other dioxins, furans, and other toxic
chemicals, which are all less toxic than 2378-TCDD, do not
represent  an unacceptable public health risk. CDC also
concluded that levels of other toxic chemicals are within
the range of levels found generally in the environment.
CDC also states that its  assessment is based upon current
environmental data, and no comment can be made about
past environmental levels and potential risks.

EPA's Chlorinated Dioxins Work Group at EPA Headquart-
ers in Washington, D.C., also evaluated the data and came
to the same conclusions as CDC.
Comparison with Other Dioxin Sites
Figure 6 compares data obtained at Dow Chemical and in
Midland with data from  other  chemical  manufacturing
sites and  disposal sites  where dioxin  has  been found.
These are Tier 1 and Tier 2 sites for EPA's National Dioxin
Strategy. These data show that the levels of 2378-TCDD
found at Dow Chemical are, for the most part, in the range
of, or lower than, levels found at other Tier  1 and Tier 2
sites.
     1000
      120
    g 100


   Q  8O
   O

   00  •<>
   rป
   w
   C4  40
       20
R
x

"**
M.

ซ*


•*"


tf:
>
$-
•'ปป
,

; -,.. . -r,/ ,^^f '^J^A^t^fi^Vfe'A^'. ;•'-."., ^-^iS^1 l"i*.IM* ,s ปi*
FIGURE 6
MAXIMUM 2378-TCDD AT SELECTED „
TIER 1 AND TIER 2 SITES
Onsite/Offsite Concentrations in
Surface Soils(in ppb)


,-S
/A
f-r
I
ui ui
^ ป
O) 0)
o ฐ
^O


/*
T O*
^

LEGEND
>1000= Greater than
•71
/ NA
/ NO





r

"~^~Tl
/*A

-------
FISH STUDY
During the summer of 1983, MDNR collected fish from the
Tittabawassee River and several other Michigan rivers for
dioxin analyses.
For most rivers, samples of bottom-feeding fish such as
carp and catfish were collected  along with samples of
game fish including  walleye  and bass. The  fish  were
analyzed by U.S. EPA's Environmental Research Labora-
tory  in Duluth, Minnesota. The results for the  Tittaba-
wassee River, which are  summarized  in Table 2,  were
originally released to the public by MDNR in October  1984:

Whole fish composite samples of carp from 11  other
Michigan  rivers had  levels of  2378-TCDD ranging from
none detected to 8.6  ppt.

Figure 7 presents data obtained for the 25 carp fillets and
5 walleye fillets from the Tittabawassee River. The concen-
trations of 2378-TCDD in carp are much higher than con-
centrations in walleye. As  shown  in Table 2, the average
carp fillet concentration is about 50 ppt, while the average
for walleye is about 4 ppt.

The Food and Drug Administration recommends that fish
with more than 50 ppt of 2378-TCDD not be eaten and fish
in the range of 25 to 50 ppt be consumed only on a limited
basis. Based  upon the data obtained from this study, both
CDC and EPA recommend that the MDPH warning on con-
sumption of fish from the Tittabawassee River be main-
tained.

As a result of a March 1984 consent decree with EPA, Dow
Chemical has agreed to analyze dioxin levels in fish from
the Tittabawassee River every 2 years beginning in 1985
and lasting until 1991. This program has been approved by
EPA and MDNR and will be monitored by the agencies.
The purpose of the  program is to determine whether
wastewater treatment systems now being installed by Dow
Chemical to control dioxin are having a beneficial  impact
on dioxin levels in Tittabawassee River fish.
                                   FIGURE 7
                                   1983 FISH COLLECTION
                                   IN  TITTABAWASSE  RIVER
                                   NEAR  MIDLAND. Ml
                                                      2378-TCDD  (ppt)
                                                                          Carp
                                                                          (skinless fillet)
                                                                          Walleye
                                                                          (skin on fillet)
                 10      20      30     4O     50      60     70      80     90
                                      Concentration (Part* Per Trillion)
                                            530

-------
                                                  TABLE 2
                                       FISH STUDY RESULTS
                                                                              2378-TCDD
                                                       	(Results in Parts Per Trillion)
            Tittabawassee River Fish
            (August-September 1983)
   Carp — whole fish composite (5 fish)

   Carp — individual skinless fillets

   Catfish — skinless fillet composite (5 fish)

   Smallmouth Bass — skin-on fillet
     composite (5 fish)

   Walleye — individual skin-on fillets
                                           Number of
                                         Measurements

                                               1

                                              25

                                               1


                                               1

                                               5
        Range

         190 ppt

      12-530 ppt

          75 ppt


         5.1 ppt

      2.8-5.1 ppt
 Mean
 50 ppt
3.9 ppt
   Note: A composite fish sample is made up of a number of individual fish blended together prior to analyses.
        Bottom-feeding fish were sampled because they are more likely to pick up contamination In river sediment.
EPA'.,—i U.S, Environmental Protection Agency -
GDC — Centers for Disease Control
iylDNft ™ Michigan Department of Natural
M0PH — Michigan Department of Public Health
PPB— Parts Per Stilton                -       •   -. ,'
PPT — Parts Per Trillion                         •'
2378-TCDD — dioxin or 2,3,7,8 teirachlorodibehzo-p^lioxln
GLOSSARY
Ambient Air — Air outside the property limits "of industrial or
other types of facilities.
Administrative Order — An order Issued by an EP"A adminis-
trator in accordance with congressional authorization trjirt r&-
quires a party to correct environmental problems!,
Background Levels — Concentrations of chemicals that are
found in the  environment away from manmade pollution
sources.
Carcinogen
cancer.
A substance or agent that produces or incites
National  Dioxin Strategy  — In December  1083, EPA
announced a National Dioxin Strategy to determine the extehl
of dioxin contamination throughout the country. The Strategy
provides a framework under which the Agency wflK
ซ Study the nature  of dioxin contamination throughout the
  United States and the risks  to people and the environment
                                                               ^Ili^rfi^ Biat thf eaten public health
                                                                        co^wtfnaHon:
                                                                              existing dioxin.
                                                                          EPA established seven cate-
                                                                	,  	Igatton and study. These sites
                                                                are most probably contaminated (Tiers 1
                                                                ~"*-~-"tB no expectation of contamination
                                                                     than 80_percent of the dioxin in the
                                                                     ijtjrf^fter 1 and 2 sites. The other
                                                                    I EPA s National Dioxin Study, which
                                                                      "'"" .and is scheduled for com-
                                                                       O/ie part per billion, the levtl at
                                                                         considered to prevent human
                                                                    , „__ jntial; soils, is equivalent to one
                                                                    :. A part per trillion is one thousand
                                             ซausf,
                                             periods
  To-enswre ihe accuracy of laboratory
  re often divided and sent to different labo-
ative analyses.
  Any of a number of chemicals considered
regulatory attention because of the adverse
     $ ean nave on man, animal life, or the
     Marty are lethal in single high doses or
    if administered at tow doses over longer
  AVAILABLE INFORMATION
  For more information about EPA's dioxin  studies in the Midland area, please review the information repositories at
  the following locations:
  Grace A. Dow Memorial Public Library
  1710 W. St. Andrews Drive
  Midland, Ml 48640
  (517)835-7151

  Dr. Winifred Oyen, Director
  Midland Health Department
  125 W. Main Street
  Midland, Ml 48640
  (517) 832-6655

  Ingersoll Township Hall
  c/o Kurt Shaffner, Supervisor
  4400 Brooks Road
  Midland, Ml 48640
  (517)835-5289
                                          For additional information, please contact:
                                          Vanessa Musgrave
                                          U.S. EPA Community Relations Coordinator
                                          230 South Dearborn Street
                                          Chicago, IL 60604
                                          (312) 886-4359
                                          1-800-621-8431 (toll free, 8:30 a.m.-4:30 p.m., Central Time)

                                          Gary A. Amendola
                                          U.S. EPA Project Manager
                                          Michigan Dioxin Studies
                                          U.S. EPA Eastern District Office
                                          25089 Center Ridge Road
                                          Westlake, OH 44145
                                          (216) 835-5200

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