United States EPA-905-R97-002h
Environmental Protection Agency May 1997
WASTE MANAGEMENT
Risk Assessment for the Waste Technologies Industries (WTI)
Hazardous Waste Incineration Facility (East Liverpool, Ohio)
VOLUME VIII:
Additional Analysis in Response to Peer Review Recommendations
U.S. Environmental Protection Agency - Region 5
Waste, Pesticides and Toxics Division
77 West Jackson Blvd.
Chicago, IL 60604
Prepared with the assistance of:
AT. Kearney, Inc. (Pnme Contractor; Chicago, IL);
with Subcontract support from:
ENVIRON Corp. (Arlington, VA),
Midwest Research Institute (Kansas City, MO)
and EARTH TECH, Inc. (Concord, MA)
under EPA Contract No. 68-W4-0006
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VOLUME vm
ADDITIONAL ANALYSIS IN RESPONSE TO PEER REVIEW
RECOMMENDATIONS
CONTENTS
I. INTRODUCTION 1-1
II. COMBUSTION ENGINEERING II-l
III. AIR DISPERSION AND DEPOSITION MODELING Ill-1
IV. ACCIDENT ANALYSIS IV-1
V. EXPOSURE ASSESSMENT V-l
VI. TOXICOLOGY VI-1
VII. ECOLOGICAL RISK ASSESSMENT VIM
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ATTACHMENTS
Attach. II-1 Expanded Evaluation of On-Site and Off-Site Fire Scenarios: Fire Emission
Modeling for Waste Technologies Industries.
Attach. II-2 U.S. EPA Memorandum Dated July 15, 1996: Calculation of Potential Increased
Emissions at WTI due to Process Upsets.
Attach. II-3 Plot of SO2 Emission Rate vs. Sulfur Feed Rate for WTI.
Attach. III-l Inhalation Cancer Risks and Hazard Quotients.
Attach. III-2 CALPUFF Modeling Results of Accidental Fire During Calm Wind Conditions.
Attach. III-3 Comparison of ISC-COMPDEP Modeling to CALPUFF Modeling for the Fire
Scenarios Considered in the WTI Accident Analysis.
Attach. IV-1 Evaluation of the Use of ERPG-2 Values vs. LOC Values in the Accident Analysis
for the WTI Facility.
Attach IV-2 Letter from the Hessisches Ministerium Fur Umwelt, Energie, Jugend, Familie und
Gesundheit.
Attach. IV-3 Evaluation of Emissions From Spills Under Extremely Low Wind Speeds.
Attach. VI-1 Literature References and Technical Reports on Health Effects of Hazardous
Waste Incineration.
Attach. VI-2 Toxic Release Inventory Data for Facilities Located in the Vicinity of WTI.
Attach. VII-1 Risk Characterization for Metals Emitted at the Permit Limits.
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I. INTRODUCTION
This Volume was prepared to address comments received from the scientific peer review
conducted on the draft of the comprehensive risk assessment for the WTI facility. That peer
review was organized by the United States Environmental Protection Agency's ("U.S. EPA")
Risk Assessment Forum to assist U.S. EPA Region 5 , the Office of Solid Waste and Emergency
Response, and the Office of Research and Development in completing the risk assessment and
ensuring that the assessment reflects sound science.
This peer review, the second of two peer reviews concerning the WTI risk assessment,
began in the winter of 1995. It included a face-to face meeting of the peer panel in Washington,
D.C., on January 11, 1996, and concluded with the publication of the report entitled REPORT
ON THE U.S. EPA TECHNICAL WORKSHOP ON WTI INCINERATOR RISK
ASSESSMENT ISSUES on May 2, 1996 (subsequently referred to in this document as the
"Report"). The peer review continued a process begun in 1993, when the Risk Assessment
Forum held a workshop to review the project plan for the WTI risk assessment. In that first peer
review workshop, 13 peer reviewers divided into work groups to discuss four major aspects of
the project plan: combustion engineering, meteorology/air dispersion, exposure assessment, and
toxicology. The workshop was attended by more than 100 observers. Workshop participants
recommended that the U.S. EPA expand the scope of the planned assessment to include more
facility performance data, use additional computer models, include a screening ecological risk
assessment, and provide an analysis of accident scenarios.
In 1994 and 1995, the U.S. EPA conducted the risk assessment for the WTI incineration
facility in accordance with the recommendations of the first peer review. For the second peer
review, the U.S. EPA Risk Assessment Forum added a fifth work group specializing in the area of
ecological assessment, and expanded the scope of the air dispersion work group to include
accident analysis. The number of reviewers was increased from 13 to 19, with many of the
original 13 reviewers participating in the second peer review. In this second peer review, the
U.S. EPA sought comments on the technical accuracy, completeness, and scientific soundness of
the WTI facility risk assessment.
The one-day workshop on January 11, 1996, provided a forum for the expert peer review
panel to discuss the elements of the draft WTI risk assessment. Unfortunately, inclement weather
prevented many members of the community surrounding WTI from traveling to and participating
in the review process.
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The reviewers were in general agreement on the overall quality of the assessment and
contributed useful suggestions for moving the process ahead to finalize the document. According
to the May 2 Report:
"Overall, comments on the draft WTI risk assessment were favorable.
Indeed, throughout the workshop, as the expert peer reviewers discussed the
assessment as a whole and specific parts of it, workshop participants repeatedly
prefaced suggestions for improvements with praise for the overall thoroughness,
quality, and integrity of the assessment. Noting that they had been quite critical of
the draft project plan for the assessment, the peer reviewers stated that by contrast
they were very impressed with the thoroughness, organization, and clarity of the
draft assessment - and with the seriousness and faithfulness with which EPA had
followed the comments and recommendations of the project plan peer reviewers.
Their most substantive comments pertained to three topics (accident scenarios,
cumulative risk, ecological risk) that were not covered in the initial project plan for
the assessment and thus had not benefitted from previous review. The peer
reviewers described most of their other comments as questions of clarification or
as other minor issues not likely to affect the overall results of the assessment."
In the May 2 Report, each of the five work groups summarized its comments in an
individual chapter or section. Each chapter summarized its findings with both "Near-Term
Recommendations" specifically addressing the WTI risk assessment, and "Long-Term
Recommendations" for consideration in future risk assessments conducted by the Agency. Each
chapter also contained a more detailed narrative providing the background for each of the
recommendations.
This Volume provides additional analysis and responds to each of the Near-Term
Recommendations in each of the subject-specific chapters, in the same order as presented in the
Report. Responses to the Section on Air Dispersion Modeling and Accident Analysis in the
May 2 Report have been split into two separate sections in this response document. Where it was
appropriate to make changes in the risk assessment itself, those changes are referenced.
Because the peer review panel's long-term recommendations generally addressed future
risk assessments, this document generally does not respond to those suggestions. However,
wherever the U.S. EPA risk assessment staff believed that either a long-term recommendation or
a specific element of a background narrative could benefit from an Agency response, this
document does provide such response. Those readers using this document as a guideline for a
risk assessment are encouraged to obtain a copy of the peer review report and review all of the
long term recommendations.
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H. COMBUSTION ENGINEERING
Near-Term Recommendations:
1. Chemical Emissions from Accidental Fire.
Comment: Change the chemical release model for the accidental fire scenario to include
the same chemicals and relative emission rate estimation procedures used for stack
emissions. An improved method for calculating the total emission rate from the fire
should be developed. Perhaps a range of overall destruction efficiencies (e.g., 90% to
99.99%) could be evaluated.
Response: This has been done.
Two additional approaches were investigated based on the suggested approach,
representing "worst case" waste and "typical" waste.
For the "worst case" waste scenario, a summary of actual wastes received at WTI
was evaluated, and a priority list of chemical constituents developed based on both
toxicity and relative quantity received (this was done by multiplying a measure of toxicity
for each constituent by its annual quantity). Based on this list, the ten most significant
chemical constituents were selected. The resulting mixture of these ten constituents was
assumed to be in proportion to the quantities of each received.
For the "typical" waste scenario, a list of wastes was selected based on the five
chemicals received in highest quantities, with the resulting mixture again assumed to be
proportional to the quantities of each of the five received.
A tank-rupture fire was then modeled as if the tank had been full of a waste
mixture which contained only these ten or five constituents respectively.
In order to evaluate organic emissions from the postulated fire, the fire model
evaluated the impact of the two different destruction efficiencies suggested by the Peer
Panel: 99%, and 90%. These translate into emissions of 1% and 10%, respectively, of
each of the constituents of the waste mixture being vaporized into the air. The 90%
destruction efficiency ("DE") would be the more conservative assumption, because the
assumed release would be ten times greater than with the 99% destruction assumption.
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In accordance with a comment in the Detailed Comments section of the Peer
Review Report, we also evaluated whether a commercially available model for predicting
combustion products would assist us in conducting the accident analysis. However,
because the actual calculation methods utilized by the model uses are considered
proprietary, we would not be able to verify the calculations or ascribe any certainty to the
results it would predict.
The detailed results are presented in Attachment II-1 to this Volume. In brief, the
results of the 90% DE analysis for the two assumed waste mixtures were that the acute
toxicities associated with the predicted ambient air concentrations of the hazardous
constituents would not increase the size of the total area found to be above the
IDLH/LOC level when compared with the original analysis (which only evaluated
phosgene and hydrochloric acid predicted to be formed in the fire). We have noted the
results of this additional analysis in the final accident analysis.
2. Particle Size Distribution Data.
Comment: Obtain actual particle size distribution data for stack emissions in order to
improve the risk assessment's estimates of gas-particle partitioning of PCDD/F and metals
and other PICs. If it can be demonstrated that the currently used assumptions are the
most conservative, the requirements for additional stack sampling can be omitted.
Response: The partitioning of semi-volatile organic compounds (SVOCs) between the
vapor and particle phases is estimated using the theoretical model presented by Junge:
ST
p°
(1)
V }
where:
= fraction of organic chemical adsorbed to particles, unitless;
Sr= particle surface area per unit volume of air, cm2/cm3;
p° = vapor pressure, atm;
c - molecular weight and heat of condensation factor, atm-cm.
In the HHRA, the surface area per unit volume of air (ST) is assumed to be
.5xlO~6 cm2/cm3, which corresponds to a value for "background plus local sources"
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(Bidleman 1988). This value was estimated to be appropriate for the
commercial/industrial area around the WTI facility.
In the Peer Review comments, it was pointed out that within the stack, the
concentration of particles available for vapor adsorption is much higher than in the
ambient air. Rough calculations provided in the Peer Review comments estimate particle
surface areas as high as 0.11 cm2/cm3, which is several orders of magnitude higher than the
value of ST used in the HHRA. As can be seen in equation (1), ifSr increases
substantially, the fraction of the SVOC adsorbed to particles will approach unity.
Within the stack, the temperature is greater than ambient conditions. Therefore,
the vapor pressure will be higher at the stack temperature than the vapor pressure at
ambient temperature. However, the incremental increase in vapor pressure is unlikely to
offset the several orders of magnitude increase in the particle surface area in the stack
compared to ambient conditions (see equation (1)).
Clearly, an unproved understanding of the vapor/particle partitioning at the
stack exit and in the immediate vicinity of the facility as the stack gas cools down and
is dispersed in the atmosphere is needed for an accurate estimate of the downwind
concentrations of SVOCs. However, by estimating the vapor/particle partitioning using
ambient conditions, as was done in the HHRA, the fraction of organic compounds
present in the vapor phase may be overestimated and the fraction present in the particle
phase may be underestimated. This method of estimation exerted a conservative effect
on the results of the WTI Risk Assessment. This is because the major contribution to
indirect exposure associated with organic chemicals that are persistent and
bioaccumulate (i.e., dioxins, furans, PAHs) is associated with organic constituents in
the vapor phase. The reason for this outcome is that the major pathway for the
transport of dioxins/furans into beef and milk appears to be via the air-to-leaf transport
pathway into pasture grass and other leafy crops (forage or silage) eaten by grazing
cattle. (Other transport pathways include root uptake from soil and direct particle
deposition onto plant surfaces.) The importance of the vapor phase contribution to total
exposure (and risk) has been demonstrated previously in the scientific literature
(Lorber1 et al. 1994). Specifically, the food chain model developed and validated by
Lorber et al. (1994) indicated that compounds in the vapor phase accounted for the
dominant source (80%) of final concentrations in beef when several different pathways for
transport of organic compounds into plants were considered.
'Lorber, M. et al. Development and validation of an air-to-beef food chain model for
dioxin-like compounds. The Science of the Total Environment. 156: 39-65.
Volume VIII II-3
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Because of the cost and long lead-times necessary to develop sampling and
analysis plans, conduct testing, analyze samples, etc., we have elected not to attempt to do
further testing prior to completion of the risk assessment. In addition, stack sampling for
particulate sizing has been attempted several times at this plant, and it has shown to be
very problematic.
Because of the conservative nature of the assumptions made in the risk assessment,
as described above, any refinement of the gas-particle partitioning assumptions at this
point would only serve to decrease the overall calculated risk from the WTI facility. We
have tried to prioritize our changes to the draft risk assessment by limiting them largely to
those which have the potential to increase the overall calculated risk.
3. Emissions During Abnormal Operations.
Comment: Adjust the estimate of normal PIC emission rates to reflect emissions during
abnormal operations (i.e., based on the percentage of operating time during which
emission violations or automatic waste feed cutoffs occur).
Response: We have done this.
The concern of the Combustion Engineering Work Group was that process upsets
or other combustion perturbations could possibly result in higher emissions of nondioxin
products of incomplete combustion ("PICs") than those measured during stack tests and
otherwise estimated in the risk assessment. The following analysis responds to that
concern.
In the case of an incinerator with one or more total hydrocarbon ("THC")
analyzers installed in the stack or ductwork, any process upset event which would result in
higher emissions of organic compounds out the stack would immediately show up as a
higher emission reading from the THC analyzer(s). The WTI plant does have such
instruments installed.
We believe that continuously-recorded THC values can be one of the most reliable
means of evaluating the variation in the emissions of nondioxin PICs. The THC
information should be a very good indicator of whether process upsets actually result in
higher than estimated emissions of nondioxin PICs, and if so to what extent. It should be
emphasized that since most of the organic mass being recorded by the THC analyzer will
Volume VIII H-4
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typically be such nontoxic compounds as methane and ethane, this is a very conservative
estimator2.
The purpose of this exercise was to determine whether the total hydrocarbon
(THC) values reported by WTI for the recent 1-year time period between April 1, 1995,
and March 31, 1996, indicate that such process perturbations may be resulting in higher
THC values than assumed. To the extent that actual THC values were higher than the
value assumed in the risk assessment, nondioxin PIC emissions could also be
proportionally higher than assumed in the risk assessment. For the purpose of this
analysis, emissions of nondioxin PICs were assumed to be directly proportional to the
relative values recorded by the in-duct THC analyzers.
During PIC testing and trial burns at WTI, THC values were generally observed by
EPA staff to be approximately 1 ppmv, normally varying from less than 1 ppm up to about
2 ppmv. Certain estimation techniques used in the risk assessment also used a THC value
of approximately 1 ppmv to base a projection of total organic emissions. However,
because the value of 1 ppm is at the extreme low end of the 0-200 ppmv range of the THC
instruments, and because markedly reduced accuracy can be expected for any such
instrument when reading less than 1% of full scale, these calculations assumed that there is
no real difference between a reading of 1 ppm and a reading of 2 ppm. Therefore, only
values above 2 ppm were considered to be above the baseline used in the risk assessment.
The present permit limit for THC at this plant is 100 ppm, and the data provided
by WTI indicates that this value is rarely exceeded. However, it was recognized that
values well below this compliance value of 100 ppm are important to this analysis. The
following analysis was therefore performed largely on THC emission values in the range of
2 ppm to 100 ppm, even though these values do not indicate a violation of any permit
standard.
Our analysis of this can be found in Attachment II-2 to this Volume. In brief,
recorded THC values were found to be 130% of baseline case for the year of data that
was analyzed, which implies that nondioxin PIC emissions could be 30% greater than
2The EPA cautions that because in-stack measured THC emission values may tend to
underestimate organic compounds (due to the analyzer's relative insensitivity to carbon-halogen
bonds), some low-biasing may be present in these calculations. However, we continue to believe
that the technique we used is the best presently available, and add that since our analysis
compared the ratio of "abnormal" THC emission values to "normal" THC emission values, and
since both of these values should be subject to similar low-biasing (i.e., both the "normal" value
and the "upset" values should be similarly biased low by a Certain percent, say 20%, due to the
average blend of carbon-hydrogen bonds and carbon-halogen bonds in typical waste), this bias
would exist in both the numerator and the denominator of the ratio, and hence the bias effect
might very well cancel itself out. ,.
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assumed in the baseline case of the risk assessment. Because the emissions of nondioxin
PICs accounts for a relatively small portion of the overall risk, the 30% increase would not
be expected to make a significant difference in the result of the risk assessment. If this
increase in PICs were conservatively assumed to facilitate a similar increase in dioxin/furan
emissions (because some of the PICs might act as precursors to the formation of
dioxins/furans within the emission control system), dioxin/furan emissions could be up to
30% higher than measured. A reference to this analysis has been included in Volume III
and in the uncertainty analysis of Volume V of the Risk Assessment.
4. Facility-Specific Sulfur Dioxide Removal Efficiencies.
Comment: Obtain actual facility-specific sulfur dioxide (SO2) removal efficiency data
over a wide concentration range so that the SO2 surrogate will better model the behavior
of Selenium.
Response: This comment was discussed during the combustion engineering break-out
session of the January 11, 1996, meeting of the Peer Panel. The representative of WTI
who was present at that meeting mentioned that WTI had additional information available
regarding the emissions of SO2 at varying sulfur feed rates. Based on the preliminary
comments from that meeting, we requested and obtained the information from WTI on
this issue. WTI provided us with sulfur feed rates versus recorded readings from the
installed in-stack sulfur oxides continuous emissions monitor ("CEM") for a typical period
of time (approximately 4 months in 1995). We analyzed that information, but were not
able to make any useful conclusions for the risk assessment, as described below.
The plots in Attachment II-3 illustrate the observed relationship between feed rate
and emission rate based on the data provided to us by WTI (note that only data in which
the sulfur concentration in the emitted gases is above an assumed detection limit were
plotted in this graph). The measured emission rate is essentially constant over the entire
period, even though the feed rate varied from 0 Ib/hr to approximately 700 Ib/hr. Nearly
all of the recorded sulfur emission rates are very close to the detection limit of the
continuous monitor. Because the emission rate was constant, the sulfur control efficiency
was a function of the feed rate, with the lowest control efficiencies observed during the
lowest non-zero sulfur feed rates. Based on this previously unavailable data, we have
limited confidence in the use of the S02 capture efficiency as measured by the CEM
system to estimate the selenium capture efficiency. We therefore recommend that
selenium capture efficiency be measured directly at the facility. This capture efficiency
should specifically be studied at a low feed concentration which is determined to
realistically represent expected feed concentrations.
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5. Fugitive Particles Different From Coal Dust.
Comment: Abandon the assumption that fugitive emissions particles are the same as coal
dust in favor of using actual fugitive emissions particle characterization for the WTI
facility.
Response: Particle emissions data for the baghouse associated with fly ash loading
operations at the WTI facility are not available. In lieu of actual monitoring data, a fly ash
emissions factor was developed by our consultant from field testing of fly ash emissions
from a similar process, coal-fired power plant with an ESP. This was used in the human
health risk assessment. We did not assume the fly ash particles were the same as coal
dust, but rather, assumed that ESP ash from the combustion of waste behaved similarly to
ESP ash from the combustion of coal. Coal dust would be a largely carbonaceous powder
resulting from the mechanical pulverizing of coal. ESP ash from the combustion of coal,
on the other hand, would predominantly be a much finer particulate matter comprised of
metal oxides and salts, generated as the residue from the combustion of pulverized coal.
To create a conservative margin of safety, the emission factor developed by our
consultant was increased by a factor often (the resulting ash emission rate was estimated
as being 28 pounds/year). Although there is significant uncertainty associated with this
estimated emission rate, the indirect risks associated with this emission were determined to
be insignificant (i.e., below 1 X 10~10), as estimated in the human health risk assessment.
The fly ash emission rate would therefore have to be more than 10,000 times higher
(i.e., more than 280,000 pounds/year) for this source of fugitive emissions to be
significant. Thus the risk assessment results indicate that a more refined analysis of this
fugitive emission source is not warranted.
RESPONSES TO SPECIFIC QUESTIONS FROM THE DETAILED COMMENTS
SECTION OF THE PEER REVIEW REPORT:
The Detailed Comments Section for the Combustion Engineering Work group essentially
expands either upon the Near-Term Recommendations listed above or upon the Long-Term
Recommendations. The Near-Term Recommendations have been responded to above. We have
elected not to respond to the Long-Term Recommendations in this document because those
suggestions were for the improvement of future risk assessments. However, there were several
additional comments and questions in the Detailed Comments Section that we would like to
respond to or answer in this document. These comments and responses are provided below.
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1. Metals Emissions Submicron Particles.
Comment: The Combustion Engineering Work Group infers that.... EPA's analysis
assumes:
-A large particle mode for ash particles;
-Condensation of vaporized metals to form a second (0.5 mm) mode;
-No submicron mode (a mode smaller than 1 urn) is present initially (on a mass
basis).
Most ash size distributions appear to be monomodal (on a mass basis), but that
does not mean that there could not be a large number of particles present that are
submicron and that may play a role in nucleation/condensation of metal vapors. Thus, the
apparent assumption that there are no submicron particles present initially, should be
justified. If all metals that vaporize subsequently condense to form 0.5 mm particles, their
density should be very different from the typical ash particles.
Response: The particle size distribution entering the flue gas cleaning system was
assumed to be bimodal with one mode above 1 jim and one at 0.5 urn (not 0.5 mm, as
stated3 in the report). It is possible that some submicron particles are formed from the
ash. There are laboratory data that suggest that fragmentation of particles (particularly
cenospheres) may create some particles around 1 um. However, the initial source of the
submicron material does affect the model's predictions. Because the surface area to mass
ratio is so large for the submicron particles, heterogeneous condensation will usually occur
primarily on the surfaces of these particles independent of the initial source of the
particles.
We do not assume that the condensing metals form 0.5 mm particles. We assume,
based on available data and theoretical considerations, that the metals that vaporize and
subsequently condense are found primarily on 0.5 jim particles. The density of these very
small particles may be different from that of typical ash particles. However, these particles
contain little mass and do not contribute significantly to the measured bulk properties of
ash.
3Because "mm" is used twice in the comment, we assumed that it is not a typographical
error. ,,
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2. Similarities Between Aluminum and Chromium.
Comment: Despite some modeling similarities between chromium and aluminum, the
former would seem to be a poor surrogate for the latter, since their chemistries differ.
Response: Aluminum was not actually used as a surrogate for chromium. Rather,
aluminum emissions were combined with the assumed entrainment rate to estimate the
ability of the flue gas cleaning device to remove particles with diameters greater than one
micrometer. Similarly, arsenic emissions data were used to estimate the ability of the flue
gas cleaning system to remove particles smaller than one micron. Calculations based on
the unique chemistry of chromium were used to partition chromium between the smaller
and the larger particles entering the flue gas cleaning system.
3. Vapor Pressures Used To Calculate Gas-Solid Partitioning
Comment: It does not clearly show how the results in Table IV-5 (Volume 5) were
obtained. What was the source of the vapor pressures of the different PCDD/PCDF
congeners in the subcooled liquid state?
Response: We believe that the Work Group is referring, in this comment, to the results
shown in Table IV-4 (of Volume V), titled: "Fraction of Substance Partitioning onto
Paniculate Matter." In order to obtain vapor pressures of the PCDD/PCDF congeners in
the subcooled liquid state, the following procedure was followed. First, the scientific
literature values for the vapor pressure of the various congeners at 25 °C were obtained
from Table 2-3 of Volume II of the U.S. EPA Dioxin Reassessment Document titled:
Estimating Exposure to Dioxin-Like Compounds (EPA/600/6-88/005Cb; June 1994).
Then these vapor pressures values were converted to the subcooled liquid state vapor
pressure values by using Equation 3-3 found in Volume III of Estimating Exposure to
Dioxin-Like Compounds (EPA/600/6-88/005Cc; June 1994). This equation may be
expressed as:
ln(PL/Ps)= ASf(Tm-T)/RT
Where: PL = subcooled liquid vapor pressure, atm
Ps = crystalline solid vapor pressure, atm
ASf= entropy of fusion, atm-m3/mole- °K
Tm = melting point, °K
T = ambient air temperature, °K
RT = universal gas constant, atm-m3/mole- °K
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4. Analysis of Fugitive Ash Emissions.
Comment: The Combustion Engineering Work Group assumes that the fly ash sample
must be some sort of a composite sample. We wonder how the sample was obtained, how
it was stored, and what the detection limits of the analytical methods were.
Response: The analytical laboratory sheets submitted by WTI indicate the detection
limits; this information has been summarized in a new table (Table IV-12) in Volume V of
the risk assessment. In addition, text has been added to Chapter IV of Volume V, in
Section C.3 as follows:
Modifications to Risk Assessment Report:
Volume V, Chapter IV, Section C.3, Paragraph 1:
"Emissions of specific substaaces metals-contained within the fugitive ash are
estimated based on the available data on ash composition. In 1994, WTI conducted
monthly sampling of ash from the ESP. WTI <5oltect& daily samplesI :oŁa&fe fitpttappers
associated with the air pollution control equipment TJte samples i& jrtijyejr&ed, Headed,
and the material is submitted for laboratory analysis, f fee^al|ti<^metkodsxise4inchide
SW-846, 8240,6010,7471, aad 7741, dependingoatlietjijesdf wastes fed to the
incinerator pn6f to sauiple collection. Analytical jfesults &cm12 d&Iy samples; One
sample collected froi» each moirtk m 1994, were reviewed &> estimate average
concentrations of constituents ta the fly ash, The samples of fly ash were analyzed by
WTI for 80 volatile and semi-volatile organic compounds, total and amenable cyanide, and
9 metals. None of the 12 samples indicated detectable levels of any of the 80 organic
compounds (detection limits for the substance analyzed are provided m Table IV-I2).
Organic compounds, therefore, are not evaluated further in the analysis of fly ash
emissions."
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. AIR DISPERSION AND DEPOSITION MODELING
1. Additional Calm/Stagnation Event Modeling.
Comment: The CALPUFF analysis was limited to "simple terrain" and a greatly
simplified meteorological data set due to data limitations. The work group recommends
performing the CALPUFF analysis using a realistic four-dimensional wind field over a
reasonable period of time to assess concentrations under adverse dispersion conditions
such as a calm/stagnation event. These results should then be compared with ISC-
COMPDEP to better understand the impact of calm/stagnation conditions on predicted
concentrations.
Response: In December, 1993, several recommendations were made by the
Meteorology/Air Dispersion peer review work group, one of which was to include an
analysis to realistically consider the adverse effects associated with plume fumigation
events and calm wind conditions. These results were to be compared to the
concentrations predicted by the ISC-COMPDEP model which the Agency had selected for
use in the indirect risk assessment. Hourly concentrations predicted by straight line
Gaussian plume models, such as ISC-COMPDEP, are inversely proportional to the wind
speed which can result in unrealistically high predicted concentrations for low wind speed
conditions. For this reason, the ISC-COMPDEP uses the U.S. EPA calm wind
procedures for light wind speed events. In these procedures, winds below the instrument
detection limit are considered calm. Hours with calm winds are ignored in the calculation
of multi-hour average concentrations. Hours with winds less than 1 meter/sec but greater
than the instrument detection threshold are reset to 1 meter/sec for modeling purposes, but
are included in the modeling as a non-calm hour. In addition, ISC-COMPDEP is a steady-
state model which does not allow it to adequately model fumigation events. In response
to the peer reviewers comments, the Agency agreed to look at alternative models which
would be better able to model calm/fumigation conditions to quantify the uncertainty in
the ISC-COMPDEP predictions.
The CALPUFF model is a non-steady state puff model which allows the plume to
grow as a function of time as well as distance and therefore is better able to model low
wind speed conditions. Additionally, it offers better modeling of plume fumigation. These
characteristics make CALPUFF a good candidate for addressing the uncertainty
associated with the ISC-COMPDEP estimates. CALPUFF was run for receptors only in
flat terrain using a one-year meteorological database from the 30-meter on-site tower
rather than generating a three dimensional wind field.
The Agency has analyzed the peer group's suggestion and determined that
rerunning CALPUFF as suggested by the peer reviewers is unnecessary for the following
reasons:
,<••
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A. A reassessment using a three dimensional wind field model will not alter the
conclusions from the assessment. The flow within the river valley, where
maximum impacts were predicted to occur, is controlled by the surrounding
terrain. The meteorological data from the 30-meter tower is representative of
conditions and prevailing wind flows in the vicinity of the WTI incinerator and
therefore was used in the modeling. For these relatively short travel distances, the
computed wind field would be dominated by the on-site tower and would predict
essentially the same flow pattern.
B. The inclusion of complex terrain receptors in the CALPUFF run does not increase
the concentration estimates over those from ISC-COMPDEP. Concentrations due
to plume impaction are typically greater than those due to plume fumigation.
While an analysis including the wind field may change the pattern of concentration,
the conservative screening level complex terrain algorithm in ISC-COMPDEP will
still produce higher concentration estimates than CALPUFF.
C. The U.S. EPA conducted an analysis of this issue and determined that the annual
concentrations predicted by the calm wind analysis would have to increase by a
factor of eight above the routine emissions to pose a human health risk. The calm
wind analysis showed annual concentrations far less than this. Thus, the inclusion
of a wind field analysis would not change this result.
In summary, while running CALPUFF with a three dimensional wind field would
improve the assessment, it would not change the conclusions of the assessment.
2. Re-evaluate Accident Scenarios Emissions During Calm Conditions.
Comment: The extended dispersion modeling performed for the accident scenario should
be re-examined in light of the CALPUFF calm/stagnation analysis. Accident scenario
concentrations should be re-computed based on the occurrence of an accident during the
meteorological event to assess whether ambient concentrations during such an event are
significantly exacerbated accident concentrations and vice versa.
Response: In response to the comment, a sensitivity analysis using the CALPUFF
model was performed to simulate calm wind impacts of vapor emissions from the on-
site and off-site fire scenarios identified in Volume VII (see Attachment III-2 of
Volume VIII). The CALPUFF model is a non-steady-state puff model that is well
suited for low wind speed and calm conditions. The CALPUFF model contains
buoyant plume rise calculations appropriate for simulating buoyant plume rise such as
those from the fires. In addition, the CALPUFF model contains complex terrain
algorithms and time-varying emissions durations.
>'
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The following scenarios were modeled with CALPUFF:
- On-site fire, Unmitigated Conservative (large fire, duration 7030 sec);
- On-site fire, Mitigated Conservative (large fire, duration 600 sec );
- On-site fire, Unmitigated Typical (small fire, duration 170 sec);
- Off-site fire, Unmitigated Conservative (large fire, duration 430 sec);
- Off-site fire, Unmitigated Typical (small fire, duration 170 sec)
The modeling methodology for this analysis is the same as presented in
Volume VII in that the fire was assumed to occur during a calm wind hour under very
stable (F stability) conditions. Following the calm hour, low wind speed, F stability
conditions were assumed to persist until the plume was transported completely across
the field of receptors. In addition, we chose to supplement the modeling methodology
with a scenario which combined calm winds and the SCREENS screening
meteorological conditions. Our concern was that moderate wind speeds may produce
higher concentrations for these buoyant plumes in the near-field. Therefore the 54
screening meteorological conditions were used to determine additional maximum
ground-level concentrations at different downwind distances.
The results show that, for the off-site typical fire scenario, the highest predicted
concentration of 1.22 micrograms per cubic meter (assuming a unit emission rate of
1 g/sec) occurs at 300 meters (see Tables IV and V in Attachment III-2) due to plume
impaction. For the off-site conservative fire scenario, a relatively low concentration of
0.15 micrograms per cubic meter occurs in the far-field. This is because the spill area
responsible for this fire scenario covered a larger area than the typical fire scenario. A
greater buoyancy flux will create a higher plume rise, thus limiting the possibility of
plume impaction. For the on-site scenario, the results show that the unmitigated
conservative fire scenario provided the highest predicted concentration overall (see Tables
VI, VII, and VIII of Attachment III-2). The maximum concentration was predicted to
occur relatively close to the fire under stable conditions with moderate wind speeds. This
is the result of enhanced vertical dispersion and lower plume rise with the higher wind
speeds producing a narrow plume in the horizontal but enough vertical mixing for it to
reach the ground in the near-field.
The results of the Accident Analysis have been characterized and ranked in terms
of both severity of consequence and the probability of occurrence. As defined in
Volume VII, the severity of consequence can be ranked as minor, moderate, major and
catastrophic, based on the distance over which predicted concentrations in potentially
inhabited areas could potentially exceed the NIOSH Immediately Dangerous to Life or
Health ("IDLH") and Level of Concern ("LOC") values. In addition, probability of
occurrence can be ranked as common, likely, reasonably likely, unlikely, or very unlikely
based on the likelihood of the accident event, composition of the waste and the
*•
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meteorological conditions.
The original scenarios for the accident analysis were performed for three
meteorological conditions, namely, a typical meteorological condition, conservative
conditions (based on the SCREENS meteorological data) and the calm/inversion
condition. The original fire scenarios were assessed only for the typical and conservative
conditions using the ISC-COMPDEP model because of limitations identified in
Volume VII when using a Gaussian model. The resulting one-hour averages from the
ISC-COMPDEP model were converted to 30-minute average concentrations and
compared to the IDLH and LOG values to determine the severity of consequence and
probability of occurrence ratings. Attachment III-3 of Volume VIII shows the resulting
distances to the IDLH and LOG values for the ISC-COMPDEP (conservative conditions)
and the new CALPUFF (calm/inversion) modeling.
As shown in Table 2 of Attachment III 3, for the typical on-site and off-site fire
scenarios and for the mitigated conservative on-site fire scenario, the IDLH and LOG
values are not exceeded by either modeling effort. For the unmitigated conservative
on-site fire scenario, the IDLH value for hydrogen chloride is predicted to be exceeded by
the CALPUFF modeling for a small area downwind of the fire. When ranked for the
severity of consequence (as defined in Chapter VI of Volume VII), the event would be
classified as "moderate" compared to the "minor" classification for the ISC-COMPDEP
results. The probability of occurrence would be "very unlikely" for both the
calm/inversion condition and the conservative meteorological conditions, however, the
frequency of occurrence is lower for the calm/inversion condition. For the unmitigated
conservative off-site fire scenario, the CALPUFF modeling results in concentrations which
do not exceed either the IDLH or the LOG values. By comparison, the ISC-COMPDEP
modeling resulted in concentrations exceeding both the IDLH and the LOG values
resulting in a change from "major", based on the ISC-COMPDEP modeling, to "minor"
based on the CALPUFF modeling. Similarly, the probability of occurrence would be
"very unlikely" in both cases.
The results given in Attachment III-3 of this Volume have been included in
Volume VII of the risk assessment.
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IV. ACCIDENT ANALYSIS
1. Pressurized Jet Release.
Comment: The accident analysis does not address all potentially important accident
scenarios. For example, pressurized jet releases from the incinerator containment might
occur and result in aerosol formation due to mixing of chemicals or heating by fire.
Although the accident analysis in the draft assessment provides a useful beginning for
assessing nonroutine emissions and accidents, it is not well developed and it lacks
precision and depth needed for reliable estimates of impacts.
Response: In response to the Peer Panel's concern, we re-evaluated the possibility of
such a pressurized aerosol jet scenario for inclusion in the accident analysis.
The pressurized aerosol jet scenario discussed by the Peer Panel involves the rapid release
of a large amount of hazardous liquid, at high velocity and high pressure, through an
orifice which would result in the atomization of much of the liquid. The EPA believes that
the analysis of such a scenario is extremely important because such an event could result in
a very large quantity of material being very quickly introduced into the environment. In
such a scenario, the atomized liquid could rapidly volatilize due to the large surface area of
the droplets, and there would also be a significant potential for a mist cloud.
The following discussion summarizes our analysis of the potential for such a scenario:
A. The waste storage tanks at WTI are all designed to be operated at atmospheric
pressure. None of the waste storage tanks at WTI are pressure vessels, and WTI
does not receive bulk pressurized gases. Review of the facility drawings and
inspection of the plant confirm that each tank has both a normal venting system
and a rupture disk, designed to prevent rupture of the tank. The rupture disks on
each of the waste storage tanks are calibrated to break at 15 psig, and this value
establishes the maximum pressure that a tank full of waste could experience. This
means that high tank pressures would not be involved.
B. Each waste tank has a combination vapor/overflow pipe which goes to an
overflow tank (e.g., the 20,000 gallon, 10,000 gallon, and 7,000 gallon waste
tanks all discharge to 2,000 gallon overflow tanks; the 2,500 gallon waste tanks
discharge to a 300 gallon overflow tank, etc.). The overflow tanks serve both to
collect liquid overflow and to act as a "knockout" for any liquid material
potentially suspended in gases coming from the associated waste tank. The
overflow tanks are connected via relief valves to the vapor collection system,
which actively draws gases either into the primary air system of the incinerator or
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into an activated carbon bed adsorption system. The venting system is not directly
vented to the atmosphere.
C. As mentioned above, each waste tank also has a rupture disk for the purpose of
saving the associated tank from rupturing if the primary vent system (i.e., the
immediate piping sections of the vapor/overflow collection system) should become
blocked or restricted. Under the present design, the rupture disk on each of the
storage tanks exhausts into a short length of pipe which then vents outside the
building, one pipe for each tank. Under certain very limited conditions, an
overpressurization of one of the tanks, as might be caused by mixing of severely
incompatible wastes, could result in a rupture of one of these rupture disks and the
expulsion of some waste material outdoors.
D. Because the wastes stored in the tanks are not pressurized, we believe that in the
event of a rapid tank pressurization (such as could conceivably occur upon mixing
of severely incompatible materials) which turned out to be greater than the primary
vent system could handle, any material expelled upon rupture of the rupture disk
would be in gaseous form. However, if gases evolved so rapidly within the tank as
to cause foaming of the liquid material, some amount of liquid might be entrained
with the escaping gas. Because of the relatively low pressures involved, however,
aerosols would not be expected.
E. The Permittee is at the time of this writing pursuing two permit modifications
relative to the venting of these waste tanks. The first permit modification proposes
to increase the diameter of the tank overflow piping to better handle the flow of
liquid and gas. This system was designed to handle normal tank breathing and
routine vapor releases, as well as tank overflows, and this proposed change will
provide it with a greater flow capacity. Increasing the capacity of this system will
reduce the potential for activation of a rupture disk.
F. The second permit modification proposed by the Permittee involves piping all of
the rupture disk outlets together into a common 18" header, and routing that
header directly to the incinerator or carbon beds. These would therefore no longer
vent directly to the atmosphere. With this new system, if a tank rupture disk were
to rupture, the escaping gas or gas/liquid mixture would expand into the relatively
large volume header pipe. This would promote a rapid reduction in pressure and
reduction of flow velocity. Any ejected waste material would be captured and
would flow through the piping system, eventually being drawn into the incinerator
or carbon beds. At the time of this writing, it appears likely that both of these
permit modifications will be approved.
The EPA has concluded that with the installation of the new tank piping system described
above, the probability of a release of a pressurized aerosol jet of waste would be extremely
Volume VIII IV-2
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remote. Therefore, because the Permittee is taking measures which make the likelihood of
such an event remote, the EPA has decided to not analyze this hypothetical event further
at this time.
2. Mitigation Measures.
Comment: The predicted effectiveness (or failure) of mitigation measures needs to be
more clearly addressed.
Response: The effects of mitigation measures were addressed in the sensitivity analysis.
The sensitivity analysis shows that maximum downwind distance of the LOG
concentration decreases when active mitigation measures limit the emissions to a duration
of 10 minutes. The sensitivity analysis also indicates there is no change in the maximum
down wind distance should mitigation require 60 minutes. The purpose of the Accidental
Release Analysis was to identify the area surrounding the facility that may be impacted by
an accidental release. The effect of active mitigation measures is to decrease the affected
area.
3. Accident Severity And Consequence Information.
Comment: The accident analysis does not adequately communicate the expected value of
accident impacts, nor does it adequately explain the reliability of the estimates given.
Whereas the assessment conveys cancer risk estimates in terms of the likelihood of
detriment (i.e., less than one chance in a million per lifetime), it conveys accident severity
and consequence information in vague terms (e.g., "likely" or "unlikely" events,
"moderate" to "catastrophic" consequences). These estimates should be quantified more
rigorously.
Response: The numerical range associated with the terms have been incorporated into
Volume VII in the "Risk Analysis" paragraphs of the Introduction as well as throughout
the "Severity of Consequences and Probability of Occurrence" section.
4. Results as a Planning Guide.
Comment: The accident scenarios do not characterize in any quantitative fashion the
sequence of events that might result in an accident or the likelihood of these events. The
absence of this information hampers use of the accident analysis as a guide for planning to
reduce the incidence and consequences of accidents in an efficient and cost-effective
manner.
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Response: The purpose of the Accidental Release Analysis was not to conduct a Hazards
and Operability study, but rather, to identify the area surrounding the facility that may be
impacted by an accidental release regardless of specific cause. Accident scenarios were
selected to estimate the consequences of worst case and more typical accidents. The off-
site impact resulting from a worst-case or more typical release will not vary with the root
causes.
5. Use of IDLH Values.
Comment: The IDLH values used in the accident analysis are designed to provide short-
term protection to healthy workers and do not account for the greater variation in
sensitivity likely to exist in a non-occupational population that includes children. The peer
reviewers recommend that some other measure of accident health impacts be considered.
It was noted that the American Industrial Hygiene Association's Emergency Response
Planning Guidelines (ERPG) levels would probably have been more appropriate than
IDLH values for characterizing the severity of accident consequences.
Response: The Accident Analysis (Volume VII) has been modified to respond to this
concern. The Accident Analysis now uses the U.S. EPA's "Level of Concern," or "LOG"
values, which are equivalent to or more protective than ERPG-2 values. LOG values have
been peer reviewed by the EPA's Science Advisory Board, and are available for all the
chemicals of concern evaluated in the WTI Accident Analysis. A comparison between
ERPG-2 values and LOG values for chemicals selected for evaluation in the Accident
Analysis is presented in Attachment IV-1 to this Volume titled "Evaluation of the Use of
ERPG-2 Values vs. LOG values in the Accident Analysis for the WTI Facility." IDLH
values has been retained as a screening method to select the chemicals of concern that
should be entered into the quantitative analysis of accident scenarios. This is because the
IDLH value is the acute health benchmark available for the largest number of substances in
WTI's waste profile list (>300 chemicals).
6. Compare Safety Record to Other Facilities.
Comment: The accident analysis would be strengthened by an examination of the safety
record of other hazardous waste facilities such as the Biebesheim facility in Germany,
which is similar to WTI and has apparently reported two release incidents.
Response: Because there have been seven minor fires at the WTI facility either in the
waste pits or in the clamshell which handles the waste in those pits, the EPA is concerned
about the potential for a major fire in the waste pits. The fact that there had been a report
of several fires in the bunker at the Hessische Industriemull GmbH'("HIM") facility in
Biebesheim contributes in a general way to this concern, even though we are not
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convinced that events at HIM-Biebesheim create an appropriate model for predicting
events at the WTI plant. This is because we have had difficulty obtaining sufficient
information about the HEM facility, especially about the regulatory standards which the
waste bunker at HIM-Biebesheim meets (and how these compare to United States
standards), operating procedures, waste characterization requirements, the fire protection
systems installed, and the actual extent and nature of any emissions from the reported
events.
We wrote to the appropriate German governmental body regarding fires and other
accidents which have been observed at HIM-Biebesheim, and did not receive a reply until
early April, 1997. Because the appropriate technical portions of the WTI accident analysis
had essentially been completed by that time, we were not able to analyze in detail whether
changes to the WTI accident analysis would be appropriate based on this new information.
However, we did conduct an initial analysis and have provided the results of that analysis
below, and we will continue to evaluate the HIM information. We have included the
response from the Hessen Ministry for Environment, Energy, Youth, Family and Health as
Attachment IV-2 to this Volume.
The information provided by the Hessen government contains 75 entries spanning
from September 1985 through July 1995. Many of these entries describe mechanical or
electrical/electronic breakdowns, as opposed to accidents. There were approximately 15
bunker fires reported, but only one of these was in the second five years of operation. In
addition, the report indicates several electrical fires, one fire in the "funnel" (assumed to be
analogous to the internal solid waste hopper at WTI), and seven "explosions" in the slag
quench tank ("Nafientschlacker"), assumed to be the type of rapid steam expansions
commonly experienced when large pieces of hot slag fall into the slag tank. Despite these
events, the cover letter states that there were no recorded injuries either on-site or off-site,
but that there were some emissions in some cases.
It has been our preference in this detailed risk assessment to use site-specific and
facility-specific information instead of information from other sites and plants wherever
possible. Because it is possible that the results of any of the three sections of the WTI risk
assessment could be used for regulatory purposes, it is important to limit the use of data
collected at other facilities in this risk assessment. Although our comparison of drawings
of the two facilities implies that overall storage configurations do have similarities, we
were not able to compare operating practices, waste specifications, or equipment details.
Comparing the waste analysis protocols for the two facilities would seemingly be very
important, since the HIM information implies that incomplete characterization of the waste
could be the most common cause of these fires.
The accident analysis portion of the risk assessment utilized a process of
identifying possible types of release events, and then grouping them into similar categories
Then, the one event from each category which was determined to present the greatest
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potential off-site impact was selected and used to represent all scenarios in that category.
For example, all on-site spills were first evaluated as a group, and it was determined that
of all the evaluated spill scenarios, an outdoor spill from a large tank truck would result in
a greater emission rate than any indoor spills (this was because indoor spills are relatively
contained, resulting in less evaporation and dispersion, and hence a restricting of the
release) or any other outdoor spills (because of the smaller quantities of waste held in
outdoor tanks). Similarly, a fire associated with the release of 20,000 gallons of volatile
liquid waste in the WTI tank farm was determined to pose the greatest potential for
emissions of all plausible waste fires. The postulated tank farm fire best represents the
most conservative scenario of all plausible fire scenarios at WTI, including a significant
fire in the solid waste pits. In evaluating a postulated major fire in the waste pits anu
comparing this scenario to the postulated tank farm fire scenario, we considered the
following:
A. Because the pit wastes at WTI are not particularly volatile (per permit restriction),
and because it has been our on-site observation that these wastes often tend to be
low-hazard debris such as packing material, contaminated clothing and equipment,
filter media, and soils, any fires in this area should tend to spread more slowly and
be more controllable. This is not the case with the postulated scenario of
rupture/ignition of a 20,000 gallon tank of flammable volatile liquid in the tank
farm.
B. EPA expects that a pit fire would be contained within the associated building. The
postulated tank farm fire, on the other hand, was conservatively modeled as an
outdoor fire.
C. Because of the physical distance between the feed building (which houses the two
solid waste pits) and the buildings which are used to store containers and bulk
liquid wastes, it is very unlikely that a fire in the waste pits would be capable of
initiating a fire in the other waste storage areas.
A primary goal of this accident analysis has been to determine whether or not
additional preventive measures are warranted for each category of accident. Because of
the minor fires that have already occurred in the WTI waste pit areas, and because of the
concern of the public and regulatory agencies over this issue, the Ohio EPA and U.S. EPA
have already been engaged in the process of evaluating additional preventive measures
which the Permittee has proposed for this solid waste storage area.
As mentioned above, the information from the Hessen government came too late
to be considered in this report, but the EPA will continue to evaluate this information.
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7. Effect on Lifetime Exposures.
Comment: The accident analysis focuses on the acute impacts of the accident scenarios,
but does not address how chemical exposures during an accident could impact an
individual's lifetime exposures to chemicals from the WTI facility.
Response: This recommendation on the accident analysis seems to suggest that the EPA
should evaluate how the impact of an acute chemical exposure can affect the impact of an
individual's lifetime exposure to chemical emissions. Our interpretation of this
recommendation is that it would require combining the potential adverse health effects of
an acute exposure with the potential adverse health effects of chronic low dose exposure.
Potential health effects from these two types of exposures often occur through different
mechanisms of action even for the same chemical. Although the EPA wishes to be
responsive to this recommendation, the Agency is not aware of any specific methodology
for addressing this recommendation. However, the Agency wishes to offer the following
factors as reasons for why acute exposures from potential accidents were considered
separately from lifetime exposures to stack gas emissions:
A. The Agency believes that it is difficult to predict that the impact of an acute
chemical exposure (high intake, short-time) can be compared in a meaningful way
to the impact of a chronic lifetime exposure (low intake, long-time). For many
chemicals, the lexicological consequences or endpoints of an acute exposure to a
high concentration may be radically different from the consequences expected from
repeated exposures to a very low concentration. For example, some chemicals
which are respiratory or central nervous system irritants upon acute exposure
(formaldehyde, benzene) can exhibit carcinogenic potential when exposure to low
doses occurs over a long time period.
B. If the purpose of the recommendation is to compare the acute dose of a chemical
with the chronic dose, the general observation is that the acute dose (high intake,
short duration) could be predicted to be higher than the chronic lifetime dose (low
intake, long averaging time). Once again, the Agency is hesitant to suggest that a
useful lexicological conclusion can be drawn by comparing the magnitude of the
two doses. It would be more useful to compare each dose with its corresponding
health effect threshold (i.e., compare the acute dose to the acute effect threshold
and compare the chronic dose to the chronic health effect threshold).
C. If the purpose of the recommendation is to suggest addition of the acute intake to
the chronic intake to calculate a total lifetime intake, then some further
assumptions about the acute intake will need to be made. These assumptions
would include selection of the following parameters: a) Exposure duration and
intake rate; b) A specific location for the receptor; and c) Determination of the
chemical concentration at the receptor location. Some of these parameters cannot
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be selected in a straightforward manner. For example, some accidents may result
in the evacuation of the nearby populace before exposure to the highest
concentration can occur; some accidents may result in shelter-in-place so that
direct exposure to ambient air does not occur; and some accidents may occur at
times when certain population subgroups are not present (e.g., schoolchildren).
Because of the difficulty in defining these parameters, the WTI Accident Analysis
followed the FEMA and SARA Title HI recommendations for defining a "Zone of
Vulnerability" to locate all areas where the ambient air concentration of a chemical
could reach a level which would be a concern for acute exposure. Consequently,
the general observation may be made that individuals residing in the Zone of
Vulnerability for a specific accident will experience the highest ratio for acute
chemical intake compared to chronic (e.g., lifetime) chemical intake, assuming that
the chemical(s) involved in the accidental release are the same as those involved in
the stack emissions.
8. Concentration Ranges at East Elementary School.
Comment: The atmospheric dispersion analysis used in the accident analysis should
explicitly report the chemical concentration ranges expected to occur at the East
Elementary School under the various accident scenarios.
Response: It is our understanding that the Peer Panel believed that the local emergency
planning authorities would be interested in knowing the projected chemical concentrations
calculated to occur at the school under the various hypothetical accidents. To be
responsive to this suggestion of the Peer Panel, we did add such a study to the original
accident analysis, even though the panel did not articulate an intended use, and the
scientific basis of using these methodologies in this way might be questioned. This new
information is provided in Chapter VI of Volume VTI.
We urge caution in the use of such maximum concentrations because the original
analysis was conducted in a very conservative way, designed to err on the high side.
Because the intent of the original analysis was only to define vulnerability zones off site,
erring on the high side (that is, erring on the side of safety) was deemed to be entirely
appropriate when defining a vulnerability zone. But it must be remembered that such
overestimated values are high-end predictions, and not accurate estimates.
An example of the conservative nature of the original estimates is the plume
modeling generally used in this portion of the accident analysis. The modeling assumes
dense gases moving in flat terrain. Because the ground level of the school is
approximately 50 feet above the ground level of the plant, it is quite likely that in reality
the terrain would severely reduce the ability of dense gases from'actually getting to the
school.
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9. Fire Emissions Similar to Stack Emissions.
Comment: The chemical release model for accidental fires should be changed to include
the same chemicals and relative emission rate estimation procedures used for stack
emissions. In addition, an improved method for calculating the total emissions rate from
the fire should be developed.
Response: The analysis now includes such a fire scenario evaluation of a "worst-case"
and a more typical waste based on total volume received and toxicity as determined from
waste profiles received during the first year of operation. The chemical emission rates
have been determined for DRE values of 90 and 99%. For more information on this
analysis, see the response to Comment #1 in the Combustion Engineering section of this
Response to Comments.
10. CALPUFF Analysis of Calm/Stagnant Conditions.
Comment: The dispersion modeling performed for the accident scenarios should be re-
examined in light of the peer reviewers' recommendation that calm/stagnant conditions be
reanalyzed with a more appropriate data set in the CALPUFF model.
Response: See Chapter III of this Volume, response to Comment #2.
11. More Appropriate Model for Chemical Evaporation.
Comment: The model used to estimate the rate of chemical evaporation from spills is not
appropriate for calm conditions. More appropriate models are discussed in the report of
the work group on atmospheric dispersion.
Response: The conservative on-site and off-site spills have been re-evaluated in light of
the Rife and Gauss models recommended by the peer review panel. A detailed explanation
is given in Attachment IV-3 of this Volume.
12. Flood Scenario.
Comment: Because this facility is located in the flood plain of the Ohio River, the risk
assessment should include the likelihood that a flood of sufficient magnitude to inundate
the facility will occur and that hazardous material would be released during such a flood.
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Response: A flood scenario which would result in the release of hazardous waste from
this site was found to have a very low probability, and hence this scenario was not
evaluated further. Further discussion of this issue is presented below:
The U.S. Army Corps of Engineers is responsible for calculating the likelihood and
magnitude of various floods in river areas around the United States. Based on our
discussion with the Corps of Engineers, it is our understanding that such calculations are
based on several complex factors, including (1) tables of rainfall data, prepared by the
National Weather Service, which are based on historical and statistical analyses of
recorded rainfall, and (2) models which consider such factors as floodplain topography
and roughness, and the capacity for the soil to hold water. The end results of these
calculations are flood water elevations having expected probabilities such as 0.1 per year,
.01 per year, and .002 per year.
EPA contacted the Corps of Engineers to determine the lowest frequency flood
event which the Corps calculates. The Corps reported that the 500-year flood (i.e., the
flood water elevation having a probability of .002 per year) is the lowest frequency event it
calculates, and that the 500-year flood elevation for mile 41 of the Ohio River (just
upriver from WTI) is 694.5 feet above mean sea level.
All active hazardous waste operations on the WTI site are located above this
elevation for the 500-year flood. Thus, the probability of a release of hazardous waste due
to a flood would be less than .002 per year. Because of this low probability, this issue was
not analyzed further.
13. Deletion of Acetone.
Comment: Because acetone has now been deleted from the list of toxic chemicals used
for emergency planning, the peer reviewers recommend that it not be used as a sentinel
chemical for the accident analysis.
Response: Although the Agency understands the logic behind this comment, we believe
that acetone continues to be a relevant chemical to evaluate in accident scenarios for WTI.
As stated in EPA's Federal Register notice on this topic, acetone was deleted from the
EPCRA list of toxics because of its relatively low toxic potential from small doses by the
chronic exposure route. This notice did not address the potential acute toxic effect from a
single high dose of acetone caused by an accidental release. The Agency has reviewed the
Work Group's pre-meeting comments as well as the EPA's decision (Fed. Reg. 60: 31643;
June 16, 1995) to grant a petition to delete acetone from the list of toxic chemicals under
Section 313 of EPCRA. The Agency believes that the following observations are
pertinent:
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A. Section 313 of EPCRA requires certain facilities that manufacture, process, or use
listed toxic chemicals to submit annual reports (Toxic Release Inventory) of their
releases of such chemicals. Section 313(d) authorizes the Agency to add or delete
chemicals from the list, and establishes criteria for these actions. In its decision to
grant the petition to delete acetone, the Agency stated that there is insufficient
evidence to believe that the low levels of acetone expected in ambient air (8 ppb or
less), or in a typical release, would present an acute or chronic health concern.
The Agency further states that "acetone cannot be anticipated to cause significant
adverse acute human health effects at concentration levels that are reasonably
likely to exist beyond facility site boundaries as a result of continuous, or
frequently recurring releases" [emphasis added]. The Agency did not comment
on the potential acute adverse effects that might occur from a single accidental
release of a high concentration or high volume of acetone.
B. In its decision to grant the petition to delete acetone, the Agency stated that other
hazardous properties of acetone in addition to toxicity were not taken into
consideration. For example, acetone is a volatile, flammable solvent, but the
Agency stated that "flammability is not one of the criteria for listing a substance
under EPCRA Section 313." The Agency further stated that the primary focus of
Section 313 was not to provide information necessary for local response
authorities to develop emergency response plans. The data needed to develop
these plans is addressed in EPCRA Sections 302 - 312. Consequently, it is
apparent that Section 313 cannot be used to evaluate the full hazard potential of
many chemicals that might be encountered at a given facility. Also, deletion of a
chemical from Section 313 does not affect or alter other properties of a chemical
which may be needed to evaluate emergency planning for hazardous substances
under Sections 302 - 312. For example, the IDLH value and the LOC value for
acetone have not been changed by the Agency's action under Section 313.
C. In the Accident Analysis for WTI (Volume VII), the selection of chemicals to
evaluate in the accident scenarios is discussed in Chapter III "Chemicals of
Potential Concern." From the preliminary list of 309 toxic and acutely hazardous
chemicals, a subset of 139 chemicals was selected which represented the greatest
off-site risk for an accidental release in which acute toxicity would be expected.
To further select potential chemicals to evaluate quantitatively in each accident
scenario, chemicals were ranked using a combination of the following three
factors: acute toxicity (estimated by the IDLH value), volatility (estimated by
vapor pressure) and concentration (estimated as the average of maximum
concentrations reported in all waste streams at WTI). Formaldehyde was chosen
as the "worst-case" waste and acetone as the "typical" waste. Formaldehyde was
chosen primarily because of its very low IDLH (24.5 mg/m3) and its extremely
high vapor pressure (3883 mm Hg). Acetone was selected as the typical waste
primarily because of its high vapor pressure (180 mm Hg) and its high
Volume VIII IV-11
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concentration in waste (21% average in all waste streams). Other chemicals which
exhibit a lower IDLH than acetone have a lower vapor pressure and/or a lower
percent composition.
Based on the above observations and the stated goal of the Accident Analysis, the Agency
believes that there is adequate justification to retain acetone as one of the chemicals for
evaluating the on-site spill scenario.
Volume VIII IV-12
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V. EXPOSURE ASSESSMENT
1. Likelihood That Surrogate Selection Process Biased the Calculated Risk.
Comment: Consider the likelihood that a chemical with a significant contribution to risk
was omitted through the surrogate selection process for evaluating chemicals for indirect
risk. Perform a simple qualitative reality check.
Response: The Agency has performed a quantitative analysis to compare results of the
surrogate chemical selection process with the cancer risks and Hazard Index (HI) values
predicted for the subsistence farmer in the area of highest impact. (Only organic chemicals
enter into this analysis since all metals were selected for entry into the risk estimates). The
objective was to determine how well the surrogate ranking of the chemicals correlates
with their contribution to total organic risk. For carcinogens, this analysis indicated that
more than 90 percent of the total risk associated with the 29 organic chemicals selected as
surrogate chemicals was associated with the 16 chemicals with the highest surrogate
selection scores. The incremental addition to the total risk of the surrogate chemicals was
insignificant for the chemicals with the lowest surrogate selection scores. It is unlikely,
therefore, that chemicals screened out in the surrogate selection process would contribute
significantly to total cancer risk. Similar findings were observed in an analysis of the
surrogate chemicals with noncancer effects. A description of the analysis conducted and
the results has been included in Chapter VIII of the revised HHRA (Volume V) as a new
subsection of the risk characterization uncertainties (See new text below).
Modifications to Risk Assessment Report:
Volume V, Chapter Vm, Section H (New Subsection 4)
"4. Uncertainties Associated with the Selection of Surrogate Chemicals
"An initial step in conducting the human health risk assessment (HHRA) was to
identify the chemicals that may be released from the WTI stack and select a subset of these
chemicals for quantitative evaluation in assessing potential risks through indirect routes of
exposure, A suirogate chemical selection process was developed, as described iii Chapter
IV ofj&e HHRA, "wfc^ consisted of a spring-system usexl to rank the chemicals. The
ranking system was developed based on antindemaftdkgiioftfee key parameters that
infhienceestimates of chemical risk via indirect pathways of exposure, Chemicals likely to
account for most of the anticipated risk from the facility were selected based OB this
ranking process. As a conservative measure^ additional dtemicals that were not initially
retained based on the ranking system were also included based on professional judgment
Volume VIII "
V-l
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to ensure that potentially important chemicals were not inadvertently excluded in the
ranking process.
The lisks estimated it* tt*e tfek assessiaeM were oaeil lo investigate whether the
chemicals added to the surrogate cheaueailist based on professioaal judgment «r
chemicals that ranked low en the fist of selected surrogates contributed significantly to the
risk estimates. Figure ĄM-3 cojitaks a listing of the 29 carcinogens that were selected
for psatitatiw evaluation m tta HHRA. The cheailcals are ranked accottliag to the
score received from the surrogate diemical selection fatness'. Also shown in Figure Vffi-
3 is the! cumulative percentage of total risk contributed by these 2Ł chemicals, as estimated
from the results of the HURAfor the adult subsistence &rmer,
As evident torn Figure YOI-3» if tae wk assessosent were conducted for oijly the
top id jchenscals by rank, caneer risks woold be w$m. a %5tor of 2 of the estimated, risks
for aii $9 chemicak. If the Sst of chemieafe was reduced by half, risks would be within
applpximately 15 percent of the es&asted ilsks for 2^ chemicals. Thus, the bcremental
a4dgpji.of &e kst 10 to 15 <^ema?ais does nol mtof* sl^icast contribatlott to tfee
estima|ej:.1»tal risks. Based on ^s analysis, it cas.be ialerred tiiat although additional
chemiciis: could be subjected to quantitative risk evaluation, it is unlikely that chemicals
with Jo^er ranks thfca the selected surrogate chemicals would materially change the cancer
risk assessment results, As Indicated k Chapter IV, it shoeld be recognbed that the
ehe.mieial" Mid site-specMc parameters used in the sisrogate cheaacal selection process are
used wpth many otner chemical- and site-specific parameters ia complex equations in the
risk assessment Thus, t&e relative scores estimated using tfce scoring algorithm do not
necessarily select the relative risks estimated m the risk assessment
A similar analysis was conducted for the dhemlcals with soncaacer effects,
although the estimated hazard index (HI) lor the subsistence fanner in tfee subarea with the
maximum impact was several orders of is^gratude bejlow a ifevel of concern. C^fthe 8
chemicals selected for quantitative evaluation 0r noacaiaisr'f6^cts>;iie:la^ 5 racked
chemicals accounted fbr;99,7 percent of t^eestimated^M value % the site- It;is highly
unlikely that a chemical was excluded that would result in a total BX approaching levels of
concern/'
2. Clarify the Use of Exposure Descriptors and Exposure Factors.
Comment: Clarify the use of exposure descriptors (central tendency and high-end) and
the use of 90th percentile exposure factors.
Response: Text has been added in several locations in Chapter VII of the HHRA to
clarify the methodology used to estimate dose (See new text below). Further description
is contained in the response to Recommendation #3.
Volume VIII
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Modifications to Risk Assessment Report:
Volume V, Chapter VII, Section B.2, End of Paragraph 1
" ..... A further assessment of the variability of exposure to these individuals is described in
Chapter VIII, by applying &^c^m^^oft^c^wd'high-end exposure factor values, as
i^W1^^^^ A summary of $j?bsi &«d i)jgh-end
these-values is presented in Appendix V-8."
Volume V, Chapter VD, Section E.I, Paragraph 1 and Paragraph 2
"In order to estimate the range of risks within a subarea, tw$ es&sates of .dose are
developed iatfeis assessment: t) Area average dose, which represents the average
exposure wJthia a subarea; and 2) Maxteum <$ose, which is th$ estimated exposure at the
loeatbii of iis&X»raK5a modeled i»«oeiStlt^iOR W&Mtt a'&ibare& aveidge exposure for the
entire suDarca as ^vdi as exposure at ttie location 01 maximum impact ujrc estimated. i ne
average^ riSK or tiie population witnin a suoarca is repress ntcu oy tiie avcrd^c 01 typicai
OI CXpO&ui 4.
"To estimate area average typical-exposure....''
Volume V, Chapter VH, Section E.2
"The predicted dispersion and deposition factors summarized in Table VII-14 to
VII-17 are used in the fate and transport models described in Chapter VI to predict
contaminant media concentrations in each of the subareas. Estimated media
concentrations in each of the subareas are summarized in Appendix V-l 1. The-Area
average or typical exposure doses are ircalculated using the dose equations (LADD and
ADD), described earlier in this chapter. The dose equations combine use the media
concentrations {based at* average ^cei#kati0ttŁiii a sufeatea) s*jm»i»f«$ed in Appendix
V-l 1 and typkal the appropriate exposure factors in Appendix V-8. Area average Typical
exposure doses for each subgroup of the population and for each exposure pathway are
shown in Appendix V-l2. Maximum doses In addition, (LADDs and ADD&) for the
exposed population subgroups are estimated at the location of maximum concentration
impact within each subarea, as shown in Appendix V-13. An example of estimated
chemical-specific area average exposure doses (LADDs and ADDs) is provided in Tables
VII-18 and VII-19, for a subsistence farmer in subarea El."
Volume VIII
V-4
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3. Clarify How Chemical Concentration and Exposure Factors Were Combined.
Comment: Add a table or figure that summarizes how chemical concentrations and
exposure factors were combined to develop central tendency and high-end estimates of
exposure and risk.
Response: The text in Chapter Vm has been modified to clarify the process of combining
exposure factors, and a new table (Table VQI-2) has been added to the HHRA that
summarizes the two "risk descriptors"~area average and maximum—and the two
subgroups evaluated in the high-end sensitivity analysis (See new text below).
Modifications to Risk Assessment Report:
Volume V, Chapter Vm, Section C, Paragraphs 3-6
"For each of the two sets of subgroups listed above, inhalation cancer risks and
noncancer HQ values are estimated for more than 200 substances of potential concern in
each of the 12 subareas. For the indirect pathways of exposure, excess cancer risks and
noncancer HQ values are estimated for the 45 substances of primary concern, which
include metals, dioxin/furan congeners, organic chemical residues and PICs with the
greatest potential to accumulate in the food chain.
"In addition to these subgroups, excess cancer risks and noncancer HQ values are
estimated for the following four activities that may lead to significantly higher exposures,
out in. wxucn only a relatively small traction or tne population is expected to pai ticipcite.
• Consumption of locally caught fish by a subsistence fisherman;
* v^oflsumptiOD. oi deer n&rvcstCQ ioc3iiy Dy liuntcrsj
• Consumption of mother's milk by breast-feeding infants; and
* (^Giisuiiiptiuii oi Jioiiiegro\vii Iruits and vegetables 110111 residential gardens.
1 nc risKs associated witii direct and indirect exposures by tne seven population
subgroups are discussed below. C-alculated nsks are presented only tor average emission
rates for the substances of concern, and "average" or "typical" exposure factors, as
discussed in (Chapter Vll. I1 or eacn subarea, risks posed by average and maximum
concentrations, as dillerentiatcd Dy tne atmospneric dispersion modeling or average
emission rates, are presented. 1'ollowing tne discussion oi direct and indirect risks based
on average emissions and typical exposure, tne results oi a sensitivity analysis on tne
exposure lactois are presented. 1 ne impact 01 using Qign-end emission rates is evaluated
in Chapter IX.
The risks associated with direct and indirect exposure by the seven population
subgroups are discussed below. To represent potential variations of risks within
subareas, two *risk descriptors* are calculated based on the average aad maximum
doses calculated for each subarea. As indicated in Chapter VII, the average dose is
Volume VIII
V-5
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maximum dose is calculated based on the maximum concentration within a subarea.
Bach of these two mk descriptors Is based os average emission rates aad average
exposing fae&e, However, average dose is estimated based on the average at
concentration within a siibarea* asd &e amimmiJ dose is estimated based.oa. the
maxtemi air wjiceatratioa wi&i» a #ebarm
To evaluate the effects of potential wiatioss ia emission i»ceiaiid;e5q)dsure
factors out eut«aated mks, a sensitivity analysis was eojsttieted Hiis seaslitity
analysis looks at the ^arlafeillty in exposure for two *b$$Hsn&* sal>gi?otJpsV::^e
methodology ssed fa die «ensitivi analysis ^described k^ separate :sectid« later in
the two
sensitiviiy aaalysls;
Results are also presented for an analysis of the potential effects of lead
emissions from the incinerator, and the risks posed by the four activities identified
below above as potentially leading to higher exposures (i.e., ingestion of fish by a
subsistence fisherman, ingestion of deer hunted locally, consumption of mother's milk
by an infant, and consumption of homegrown vegetables).
!a*&$t$^^4iiM
HQ values are ^m&K^&i&yfm. i^lcJ^i^if^^lead to significantly
higher ep>!pcB«re!»Mtm is
expected: to
Cottsujiption of locally casght fii$f tiy ;a
* Consumption of m>thep*s milk- l^y hreaist-leedlst<:i]&fiiaisv aad
* Consumptiofi of homegrown frliits and vegetaftffes frdm residential gardens,
For some individoals, the risks estimated for these; specific activities could be an
incremental addition to: the pathways described earlier, Itishoald also be noted that
risks associated with mother's milk is estimated for residents* farmers, and subsistence
farmers.
Volume V, Chapter VHI, Section C: new Table VTH-2 (following page)
Volume VIII
V-6
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TABLE \TH-2
'varnafedintheSiensith-JFyAnah-sis
Emission
Rate
Facioira
ModeBng
Sensitiy^ At^sii^ of Exposure Piaam^teirs
Exposes Si&group
Atmospheric
»^n/l)«jpio
Modeling
Aduf sentence
- ifigfe-eod food ingesiEJM tttes
* Average etolsskm rates
Child of a
subsistence fanner*
• Average exposure values except:
- "Footf iagestiea rates,
# H^^id oaKSJori rates
coaceatrafloaaad
Note:
1 - lii the seasitivity snatysls of ejcposute VMi«b8fty» 6e two exjxMUf e paranwte** wjJS (he greatest eff«*
-------
4. Exposure to Household Dust.
Comment: Include a qualitative discussion about the contribution of household dust to
exposure.
Response: Text has been added to the soil ingestion section of Volume V Appendix V-8
that indicates that the soil ingestion rates used are based on estimates of ingestion of
outdoor soil and indoor dust (per U.S. EPA guidance). The added text also indicates that
it is assumed, for the purposes of the HHRA, that concentrations in outdoor soil and
indoor dust are equal. This assumption has been added to the Key Assumption table in
Volume V Appendix V-8.
Modifications to Risk Assessment Report:
Volume V, Appendix V-8, Section B.2.a: Append the following text to the end of the
section:
'e^ <&st US, BJ»A (I991):gap^^ii!
-------
5. Expand Table on Key Fate and Transfer Assumptions.
Comment: Expand Table VI-2 of Volume V on key assumptions for fate and transport
models to include more components about processes of biotransfer, diffusion, and
deposition.
Response: The Key Assumptions table that was prepared for Appendix V-7 (Fate and
Transport Model Equations and Parameter Values) is now used in place of the table
currently presented in Chapter VI. This "new" table provides more detail concerning fate
and transport modeling assumptions. A footnote has been added to the table that indicates
that Key Assumptions concerning diffusion and dispersion are summarized in Volume IV.
Modifications to Risk Assessment Report:
Volume V; Replace Table VI-2 with Table 38 from Appendix V-7 (following pages)
Volume VIII
V-9
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TABLE VI-2
Key Assumptions in Fate and Transport Modeling
Assumption
Fate and transport modeling accurately
reflects reality
Chemical-specific inputs are appropriate
Site-specific inputs are appropriate
The surrounding area in an agricultural
watershed that has a soil mixing zone of 10
cm
The chemicals mix completely within the soil
layer of interest (1, 10, or 20 cm)
The facility operates continuously for 30 years
Basis
The U.S. EPA-recommended (U.S. EPA
1990a, 1993, 1994a) models used in this
assessment are based on the best available data
(although somewhat limited). To account for
potential uncertainty associated with the use of
these data, conservative assumptions are
generally applied in developing these models.
Professional judgment on best available data.
Professional judgment on best available data.
U.S. EPA (1994a) guidance assuming an
agricultural watershed has some tilled and
some untilled soils.
U.S. EPA (1990a) guidance assuming tilling in
agricultural lands.
Conservative assumption although it is highly
unlikely that the facility will operate 100% of
the time for 30 years. The facility only
operated 53% of the time in the first year.
Magnitude
of Effect
high
high
low
low
low
low
Direction of
Effect
possible
overestimate
likely
overestimate
unknown
overestimate
overestimate
likely
overestimate
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V-10
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TABLE VI-2
Key Assumptions in Fate and Transport Modeling
Assumption
Volatilization losses do not occur once the
chemical is deposited
Degradation of organic contaminants in soil is
first-order
Fruits and vegetables are modeled as four
types of vegetable classes
Basis
Conservative assumption based on professional
judgment.
Simplifying assumption to explain a complex
process that is not necessarily first-order.
U.S. EPA (1990a and 1993) guidance.
Magnitude
of Effect
low
low
low
Direction of
Effect
overestimate
unknown
unknown
Volume VIII
V-ll
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TABLE VI-2
Key Assumptions in Fate and Transport Modeling
Assumption
Exposure to contaminants for aboveground
protected vegetables and root vegetables
occurs only through root uptake (i.e., does
not occur via direct deposition and air-to-
plant transfer)
Uptake transfer factors for root uptake and
air-to-leaf uptake are based on Kow
Inhalation and surface water ingestion by
animals are not evaluated
Meat biotransfer (Ba) and bioconcentration
(BCF) factors are appropriate
All chlorinated biphenyl compounds are
considered to be transported in the same
manner as the dioxin and furan congeners
Basis
U.S. EPA (1990a) guidance based on the
likelihood that these classes of vegetation are
not exposed to contaminants on depositing
particles or in vapor form.
U.S. EPA (1990a, 1993) guidance.
These pathways are considered insignificant
compared to fodder and soil ingestion (U.S.
EPA 1994a) based on a review of the
literature.
U.S. EPA (1990a and 1994a) guidance and
review of available models.
Conservative assumption based on professional
judgment.
Magnitude
of Effect
low
medium
low
high
low
Direction of
Effect
possible
underestimate
unknown
underestimate
unknown
unknown
Volume VIII
V-12
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TABLE VI-2
Key Assumptions in Fate and Transport Modeling
Assumption
Basis
Magnitude
of Effect
Direction of
Effect
For surface water:
-Soil concentrations within a watershed are
uniform
-Steady-state is achieved between
concentrations in the dissolved phase,
suspended sediment, and bottom sediment
U.S. EPA (1994a) guidance.
low
unknown
Of the total mercury in the water column,
25% exists in the methyl mercury form
U.S. EPA (1994c) guidance that concludes that
no more than 25% of the total mercury in the
water column exists in the methyl mercury
form and typically, less than 10% is observed.
low
overestimate
Volume VIII
V-13
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TABLE VI-2
Key Assumptions in Fate and Transport Modeling
Assumption
Basis
Magnitude
of Effect
Direction of
Effect
PAHs are evaluated as if no metabolism
occurs in fish
Conservative assumption since the literature
(ATSDR 1993b; Eisler 1987) suggests that
PAHs are readily metabolized in fish.
low
possible
overestimate
Inorganic compounds do not accumulate in
mother's milk
Inorganic compounds are generally not
lipophilic and would not tend to accumulate in
mother's milk.
low
underestimate
Notes'
Key Assumptions regarding dispersion and diffusion are summarized in Volume IV.
low = less than a factor of two
medium = a factor of two to ten
high = greater than a factor often
Volume VIII
V-14
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6. Evaluate the Effect of a Flood.
Comment: The WTI facility is located in a flood plane; EPA should evaluate the effect
of a flood on the potential for release of hazardous materials from the facility.
Response: This comment is addressed in Chapter IV of this Volume, in the response to
Comment 12.
7. Use ERPG-2 Values in the Accident Analysis.
Comment: Emergency Response Planning Guideline (ERPG) values would be more
appropriate than IDLH values for characterizing the consequences from accidental
releases. This is because IDLH values were designed for the healthy worker rather than
for the general population. LOG values would be better than EDLH values if ERPG values
are not available.
Response: This comment is addressed in Chapter IV of this Volume, in the response to
Comment 5.
8. Address the apparent deficiency of information on existing exposures to incinerator-
type contaminants in the area.
Comment: This deficiency is consistent with EPA risk assessment guidance, but raises
questions about cumulative or total exposures to a given contaminant in the area.
Although methodologies for evaluating cumulative exposures have not been fully
developed, the document should address the issue qualitatively.
Response: This comment is addressed qualitatively and quantitatively in Chapter VI of
this Volume, in the response to Comment 17.
9. Total risk from the facility.
Comment: Total risk encompasses exposure to continuing emissions from routine
operations, episodic exposures to fugitive emissions, and exposures resulting from
accidents. The derivation of risk numbers for these three sources should remain separate,
but the combined risk should be discussed together in the risk characterization.
Response: As suggested by the peer review work group, the risk assessment developed a
separate derivation of risk from the three sources of potential exposure. The Agency feels
Volume VIII
V-15
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that combining these distinct sources of risk into a single quantitative risk estimate is
beyond the scope of the current assessment and current risk assessment methodology.
Therefore, the combination of risks and the problems inherent in attempting to combine
the different sources of risk are discussed below in a qualitative fashion. Some of the
factors precluding straightforward combination of the risks from the various sources
include the following:
1) Each source of risk is based on a distinct assumption about the frequency for
occurrence and the identity of the chemicals associated with the source. For
example, the stack gas emissions and fugitive organic vapor emissions were
considered to be essentially continuous over the operating life of the facility. And
the identity of the chemicals associated with stack and fugitive emissions is
relatively well defined. This information together with the dose-response
assessment for each chemical can be used to derive a health risk value (cancer risk
or hazard quotient) that conveys the probability (i.e., frequency combined with
dose-response) for an adverse health effect from a given chemical. By contrast,
the frequency for accident occurrence is considered to be discontinuous and
sporadic. In addition, the chemical concentration of an actual accidental release at
a random point in time cannot be predicted with confidence. Therefore, the
accident analysis relies on "worst-case" and "typical" chemicals (in terms of
toxicity and volume) from the actual waste feed to represent a range of the
expected chemical composition. This information is useful for chemical emergency
planning.
2) There is presently insufficient information on the expected frequency for accidental
chemical releases to allow the assignment a probability of occurrence to a specific
accident. Also, because the actual duration of exposure to a specific accidental
release is not known, it was not possible to derive an exposure dose for the
chemicals modeled in each accident scenario. Therefore, the individual human risk
for an adverse health effect from the modeled accident scenarios is not determined.
Instead, the accident analysis estimates the maximum downwind distance for
chemical concentrations that are equivalent to the threshold concentrations for
observing adverse health affects in the general human population. While such
information does not define an individual human health risk, this information is
useful for chemical emergency planning.
3) The combined exposure and consequently the combined risk from the different
sources is highly dependent on the location of the exposed human receptors. For
example, the results from air dispersion modeling show that the highest impact
point for exposure to stack emissions and fugitive organic vapor emissions are
found at widely different locations. These locations were derived through
consideration of long-term average air concentrations and deposition rates for
these continuous emissions. In addition, the highest impact point for an accidental
^
Volume VIII
V-16
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chemical release may differ considerably from stack emissions or fugitive emissions
because the direction and downwind migration of the accidental release will be
highly dependent on the air dispersion characteristics (wind direction, wind speed,
buoyancy) prevailing at the time that an accident actually occurs. Consequently,
the combined exposure from all facility emissions cannot be defined without
specifying a specific receptor location and an actual time when each type of release
(stack, fugitive or accidental) is expected to occur. Our observation is that there
could be nearly an infinite number of receptor locations and time combinations.
Attempting to combine these sources into an estimate of total facility risk is a
highly uncertain process that will not convey useful information for understanding
potential risks from the facility.
Volume VIII
V-17
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VL TOXICOLOGY
1. Route-to-Route Extrapolation of RfDs.
Comment: Include a discussion of the uncertainty associated with employing
route-to-route extrapolation of RfDs.
Response: Route-to-route extrapolation for chemicals with noncancer health eifects is
discussed briefly in Chapter HI, Section D.2. This discussion has been expanded and
developed into a new section in this part of the HHRA (see new text below).
Modifications to the Risk Assessment Report:
Volume V; Chapter ED; Remove part of Section D.2
"2. Uncertainties in the Characterization of the Toxicity of Noncarcinogens
"To adjust for uncertainties such as those discussed above, U.S. EPA and
other regulatory agencies typically base the RfD or RfC (or other expression of the
acceptable daily intake) for Noncarcinogens on the most sensitive animal species,
i.e., the species that experiences adverse effects at the lowest dose. This dose is
then adjusted by the use of uncertainty and modifying factors to compensate for
various sources of uncertainty in the underlying toxicity data. The resulting
toxicity factor incorporates a substantial margin of safety, although the actual size
of this safety margin cannot be quantified with any certainty.
"For all verified RfD and RfCs, U.S. EPA does provide in IRIS a
qualitative statement of the confidence that the evaluators have in the RfD or RfC
itself, in the critical study upon which the RfD or RfC is based, and in the overall
data base."
U.o. Jj,r A guidance tor lii/iiJuus waste incinerators (^U.kb. lit A iyo9a) suggests tlidt
wnere a vcniieu oral I\XL» iicis oecii developed Dy U.o. JL/r A. Dut wneie tlicre is no verified
KJC for tliat suuStciiicc, tnc IviL/ sliould DC used to extrapolate to tlic inlimdtion IxAC/. As
noted by U.o. liFA (lyyyd), certain limitations drc introduced witn sucn route-to-route
extrdpoldtion witn respect to: \&) the appropriateness 01 cxtrdpoldtiiig wlicu a portcu or
entry is the critical target organ; (b) first pass effects; and (c) the effect of the route upon
uosmictry. i nc compounds lor wiiicii tliis^proccss is used to determine ixAx>s circ noted
in Tables III-l, III-4, and III-5.
In general, it is cxpcctcu tliat tlicsc assumptions will result m an ovei estimation 01 the
toxicity 01 ciieiiiicdls witli iioiicdrcniogcnic circcts.
/••
Volume VIII
VI-1
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Volume V, Chapter ED, add new Section D.3
"US, BPA guidance for hazardous waste Incinerators $JJ$, EPA
suggests that where a verified oral HID has been developed by ll,S. EPA but
there is no verified KC for that substance, the BID should be used to
extrapolate to the inhalation EAC. This extrapolation method may introduce
large uncertainties is the estimate of nancancer ejects from inhalation of these
substasces. As discussed is tl$, H»A guidance for derivation of RfCs (U,$,
EPA 1994J), &e ability to perform quantitative route-to-route extrapolations is
critically dependent on the availability of chemical-specific data on boHi the
capabilities of the chetsicai to reach, me target site for toxieity and the nature of
the toxic effect. In cases where these data are not available* the tise of default
assumptions to perform the route-to-*cute extrapolation results in increased
uncertainty associated with the derived HAC, Hie magnitude of the uncertainty
provided by the sapportisg database as to die res|>onse of the hanmn body to
route.:of .adminlstrlW^dil^ ieasdj»|il«e l
excretion)
propertied (&$»» disspclatltoftstate^soJubiiiry, .or.reactiyi.ty)k due. nature of the
exposure ; coscentrationi duration* orregiises), otJhephysioiogie
parameters- of tne exposed tissues (e.g,, metabolic capabilities, cell types, or
pH). Sitsilarly^ factors tnat affect the. distribution of tse chemical to die various
tissues is the body (erg,; solubility, chemical reactivity), the metabolism of the
chemical {e.g.* metabolic activation vs. metabolic detoxification* Metabolic
capabilities of exposed tissues), aad dxe exeretioB-of the chemical trom the body
-------
tils m turn may el&er increase or decrease the loxie response,
depending upoa whether tne liver detoxifies or activate the chetmeal, and what
tissue is susceptible to the toxic effects of the chemical A similar chain of
events may oeouf for inhalation exposures, where uietaboljsia of ihe Inhaled
enemieai may oecsr at sites alosg the resplraioiy trad* Hiei-eby prese^ilng the
«^» aijd» asKH»»l»g$ys»aile aljsojeptloa, reieoie ilssues witfe a
-inodiiled d»«aj|cali tlum, oue iscte^ that aaist be eoaKi4ere4 m
xtrapoMojas Is ^e u^taboUc capabilities of tbe tissues $m terms
of both <}8aa$ity mid type of metabolites produced) at the different portals of
entry,
If sulkiest daia are avaliable,: pfaysloJoglcaily-i«sed ph^nswsakisetic
fSM) MO^IS are ^ie preferred lae&od for perlorsjl«g rotite^o-roate
extrapc-kiioss,. lowever, FSPK, models should be tised in ootipiictb» with
siediMlstio data lo aesairately exfcapolaie oerwea differed exposi»» see8ario&.
For exaao|>let t» ^e &t $^m^%mtfa data tis« is relevant for chemicals
whose.ic^a^is»J of actloitj involves toxicity at a site rejnoie irom the poital of
e»try will be differed Irom coi«act-s^ toxicaijts wfeose toxicity is fcased on
high chemical reactivity to biological tissues,
Iu tee cases where sufficieat o»aittetric measures of bloavailabili^ via guidance, roote-tcbiotrte. extrapolation is
used in developing BACs, The compounds for which;^e proeed«re..of .irou^-to-
roub extrapolation is osed to deteriaiae RACs are noted:m Tables lIl-UIt-4,
aigHi-5."
New reference cited in Section D.3., and printed in Volume V, Chapter XI:
U.S. Em^M^II^^^
i^.t
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2. Uncertainty Associated with Unidentified and Uncharacterized Emissions.
Comment: Discuss the uncertainty associated with the possibility that not all chemicals in
stack emissions have been identified and their toxicities characterized.
Response: This issue is discussed in Volume V, Chapter 8, Section F.3. titled:
"Uncertainty Associated with the Uncharacterized Emissions." Rather than simply stating
that there is an uncertainty associated with unidentified emissions, this section states that
the characterized fraction of organic emissions from WTI accounts for approximately 40%
of total organic emissions. To provide an indication of the potential effect of this
unknown organic fraction, it was assumed to have a cancer risk potential equal to that of
the characterized fraction. Then to serve as a sensitivity analysis, the cancer risk from the
characterized fraction could be multiplied by 2.5 (100%/40%) to account for the
Uncharacterized fraction. This was illustrated using the organic chemical cancer risk for
the subsistence farmer in Subarea El. (The risks due to dioxins are not prorated upward
because all known toxic congeners are quantified in the stack emission by a specific
procedure.) A new paragraph has been added to Section F.3. to address the uncertainty
associated with variations in operation of the incinerator that may result in some emissions
of unknown composition.
Volume V; Append to end of Chapter VIH, Section F.3.
"An additional source of uncertainty exists when emissions of unknown
composition occur associated with abnormal operations oil the incinerator that in some
instances results In emission limit exceedances OJT automatic waste feed cutoffs, An
analysis of total hydrocarbon (THC) measurements froni: April 1,1995 to March 31,
1996 indicates that THC excursions above the I ppm level used in the risk assessment
occurred intermittently throughout the year. The annuallaverage THC value
incorporating the periodic fluctuations m 7 HC levels was estimated to be up to 30
percent higher than what was observed during stack tests. Although the emission
composition during abnormal operations is unknown* if it & assumed that ithe cancer
potency of constituents in emissions during abnormal operations is equal to the cancer
potency of constituents in normal emissions, ^.e overall-cancel risk wod
-------
3. Lead Slope Factor.
Comment: On an interim basis, the Toxicology Workgroup recommends using the slope
factor that California EPA has developed for lead in order to provide a sense of the
magnitude of the cancer risk from lead.
Response: The EPA's position on the toxicology of lead is adequately explained in
Chapter 3 (Section B.3.) of Volume V. EPA does not currently publish an RfD or an RfC
for lead because the Agency has not been able to establish a verifiable threshold exposure
level below which toxic effects can be ruled out. In addition, neurobehavioral effects in
children have been observed at blood lead levels far below those associated with cancer
induction in laboratory animals. Therefore, EPA has not developed a cancer slope factor
for lead. The Agency believes that neurobehavioral effects are the most sensitive
endpoint for the most sensitive subpopulation (children under 7-years old). This is the
reason why the EPA has developed an uptake/biokinetic model to evaluate the relationship
between lead exposure and lead blood level. The California EPA's slope factor for lead
could be employed to estimate a cancer risk from lead exposure. However, the EPA's
position will continue to be that a noncancer endpoint is the most sensitive one to evaluate
for lead exposure. This is the approach that was followed in the WTI risk assessment.
4. Noncancer Effects of Dioxins/Furans:
Comment: The WTI risk assessment does not quantitate the noncancer risks associated
with dioxms/furans because EPA has not yet verified the most sensitive toxic endpoint in
order to assign an RfD value. Some dioxin effects (reproductive, immunological) can
occur in experimental animals at lower exposure levels than those producing cancer. The
WTI risk assessment should discuss: 1) differences in how EPA estimates noncancer and
cancer risks (e.g., hazard index vs. slope factor, threshold vs. no threshold); and 2) the
cancer risk estimate [for dioxins] might be more conservative than a noncancer estimate
because the cancer slope factor assumes no threshold.
Response: The Agency believes that Point #1 is already thoroughly discussed in Chapter
3 (Section A) under "Toxicity Assessment Methods." This topic is further addressed in
Section D under the discussion of uncertainties in the characterization of toxicity. As for
point #2, for a given chemical, it is theoretically possible that the cancer slope factor
would predict that a specific cancer risk level (e.g., 1E-6) would be associated with a
lower intake dose than that associated with the reference dose (RfD) for noncancer
adverse health effects. This comparison only applies to chemicals which have both a
chronic cancer and a chronic noncancer endpoint. For dioxins in particular, it is not
possible to predict if the slope factor would be more conservative than the noncancer
estimate until an RfD for the most sensitive health endpoint is established. Since the
Toxicology Work Group appears to embrace the concept that some toxic effects of
/•
Volume VIII
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dioxins could occur in animals at doses lower than those that cause cancer, further
investigation of point #2 for dioxins seems to be unnecessary at this time.
5. Additivity versus synergy or antagonism.
Comment: Provide additional discussion and rationale for the assumption of additivity
versus assumption of synergy or antagonism for the toxicology of complex mixtures.
Response: Revised text, new text, and additional references have been added to Volume
V which indicate that additivity is presently the best model to employ after considering the
available data and the low doses that are expected from WTI emissions (See new text and
references below).
Modifications to the Risk Assessment Report:
Volume V; Chapter VHI, Section F.I, paragraph 2 and following paragraphs
As noted in section A of this chapter, there is some uncertainty associated with
additive risks (i.e., summing cancer risk estimates and hazard quotients across chemicals
and exposure pathways). The HI approach for the noncarcinogenic effects of chemicals
assumes that multiple sub-threshold exposure could result in an adverse effect and that a
reasonable criterion for evaluating the potential for adverse effects is the sum of the hazard
quotients for individual chemicals. This ^approach is presented; in^&e:.ll:S; EPA
guidelines for assessing rMs of chemical pixtares (1JUSL; EBA 1986b>, which conclude
that the dose*addkiye approach is appropriate for evaluating noncaneer effects of
mixtures when the: chemical constituents are present at low doses and also induce the
same toxic effect in the same organ by the same mechanism of action.
This approach has been supported by several recent studies conducted; to
examine me relationship between the development of toxicity and dose using mixtures
of chemicals with exposures at or near me NOABL and LQAEL values for individual
components of the mixture* Jonker et aL (1990) tested a group of eight arbitrarily
selected: chemicals in rate and foand that when administered at dosages of 1/3 to 1/10
of their respective MQAEL&, no adverse effects were observed. In this same; study,
when the chemicals were administered at the levels of individual NOABLs, mild
toxkity%as"'f^'e^^"\iiti»ft'teii(^ tbbe; of mmor toxicblogical significance. A range
of responses was observed when chemicals; were administeredi-.at me iadividiial L0ABL
values, iSomeeffects were more severe thantfeose obser^^wheij^e compounds were
administered singly at the same doses, while others :were..liffi5s::se.yere.: Certain effects
observed when compounds were given mdividually.alffle:LOAB:L; level were not
induced by the mixture while other effects; not seen after treatment with the individual
chemicals were caused by administration of ihe mixtare.
/*
Volume VIII
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ta * follow up stady &om this laboratory {Chrotem et ah 1994), a group of nine
arbi&Myelected elbi&icals were admirfl&ered to rats for four weeks, In Ms study,
when die individual chemicals were givem at 1/5 of their N0AEL levels, w adverse
signs of toxicity were observed. When aniaials were adaiiaisiered
-------
magnitude below the NOAIUS and/or LOABLs observed for the compounds. If tie
hazard quotient of a chemical is greater thai one, ifeen there is potential concern for
noncancer health effects due to the presence of that ohsmicat This approach is clearly
more heal & protective Chan comparing estimat#Mxposures Co the measured toxicify
threshold for contaminants. Hence Che additivity assumption Is appropriate for the
HUM,
In contrast to Che mechanisms of action for noncancer health effects which are
assumed to save thresholds, it is assumed chat tee Is no threshold for most genotoxic
careinogeas, There are a number of examples of mteraetive effects of two or more
chemicals In inducing cancer. For esssjnple, synergism was observed between tobacco
smoking and occupational e^ossre to asbestos m inducing cancer in worJters. Of die
large number of studies of potential interaction among carcinogenic constituents of a
mixture, most have used doses of the individual componeRls known to increase tumor
inc&em?es above those seen In «oi&rols* O»ly a few, studies of cnennkal rotares have
examined the issue of low-level exposure to ISSOWK carckogens. As an example* Ito et
& (1991} gave Iwe heteroc^oMe amities to rats w their alecs lor m weeks at lewis of
J/5th aiitd I/25ch of the o^e known to cause liver tamor .formation for each Individual
atnine. A slight increase k glutathbne S-ttansferase placenta! form (GST-F) positive
foci was observed in fats led the mixtures as compared to rats fed the mdmdual
compounds, The researcher* otetevlecause: u|^#^
probability distributions are not strictly additive;, the total :eanc^:tl^;estimate:can
be«mje.arti^cyis.eioi!e:consef^ are added.
Secondly,' cl*e.af^roaeltout^^
carcinogens eqn^Jy* regardless of t1ie;plgfeWid^W-c1a^;:t^ is
assigned. Bach-class Is iglvM:eq«al:We^t^
considered equal to prbbabl^ and p^sible: carcinogens (classes B said C) in the
summation of risks,: Finaliy;:the/mech^nlsm of toMcity:of any :tvi?o chemicals may not
f
Volume VIII
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be the sa&e tn^^^io^-a^Stw^be i^fapeftigiC' Cttelat^c^^:mk estimates
assun^ sij»te;iiechasisms ;of actioa. and. t&af iiidi^of d^i^i^l^ act
ai&agonistlcatly or syuergistlcall^. Although deviation from an additive response has
been demonstrated at high exposure levels im bo& laboratory wimti nwdels and
epidembloglcal studies, it bas been suggested tnat rislcs may be additive at tow doses.
His concept is supported by behavior of botfe the multistage and two-stage donai
expansion models of earelnogenesis, me additive-background nsodel, and the
multiplicative relative risk model {Klrewski and Itiomas 1^3), Hie National Research
Council has concluded that m die absence of specific information on dteimcal
interactions at relevant doses* tie prineip> of low dose addltmtsr of ris&s coatinues to
offer the best approach to caucer risk assessment for nrixiares (NKC 1988), This
mctfiodoio^y, iioAvcvcr, is most cviQcncc clciss to
wliicli SL cdicmogcn is dssigiicd. ij.Ecn cldss is given ccjuil wciglit, known cdi ciiiogcns
^cldss A) ire coiiSmcrcu ccjudl to probdblc And possible carcinogens (classes 13 diiu C/J 111
tnc suiiiiiidtion or OSKS.
- Finally, the mechanism of toxicity of any two chemicals may not be the same and,
in fact, might not be independent. Cumulative risk estimates assume similar mechanisms
or dction and tnat mixtures or cncniicciis do not cict dutd^onisticculy or syncr^isticcilly^ 1 lie
combined risk of antagonistic chemicals is expected to be less that the sum of the
indiviciiicii nsKs, wiiereiSj tne tot^i risk iioni syncr^istic ciicuucdls couiu DC srcdter tncin
the sum of the individual risks. Data and methods to quantitatively assess these types of
intcrdctions, however, are not readily
New references cited in Section F.I., and printed in Volume V, Chapter XI:
Chapin, J^i|^'JX;.j^E!iy^''^.A. Scliwartz et^l 19^9, To^colog^ studies of a cfeemical
^^|W^^^^dw8*»'contaa^»t8l lit M$te fegrod^ttpnVtady in B6C3F}
mice, Mffid Apjtf. TexicoL, 13:3SS*98,
Groten, IJP., F.C. Kyper, E.0, Schoen, et al. 1994, Suba&te tvxicity studies of a
&fnine chemicals in nas. Poster presentation at the Second Annual
Volume VIII
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Raleigh, K3!
Basegawa, It^, E/MtyMa, M, Fyiakuclti ^t at. 1994, Synergis^c
foci development fry confined treatment of rats -with 10 Jjeteroeyclic amines in low
Carcm&gpn&sis 15: 1037-41*
Ita, It, Hasegawa, R.., Sham, T,» Pukashima, S^.I^PiE* Takaba, K » Iwa&afd, $.,
WakabayasbJ, XL, Nagao, ML, and Sugtmara, T, (1991). Maacsement of GST-P
positive liver ibci IXI Svendsgaard eit al. i$94*,:Tpxicobgy studies of a
chemic^Huxtujreof 25 grouiidwater coataii$^ts^^ assessment,
respond to carbon
water restrictioiL J. Toxicol. Ewimn. Health,
Volume VIII
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Yangj&SJHL, TJ. Goehl, MX Brown, et at 1989. TosacoJogy ladies of a chemical
nsxttire of 25 groaadw^^ coRtanHiiaats>
6. Rationale and Impact of Relating PAH Potency to Benzo[a]pyrene.
Comment: The risk associated with PAHs is based on 7 PAHs expressed as their potency
relative to benzo[a]pyrene. The other PAHs are not included. This introduces uncertainty
into the risk estimate. The Work Group recommends that EPA briefly explain the
rationale and impact of this risk estimation procedure.
Response: The risk estimation procedure for PAHs is described in chapter 3 (Section
B.2.) Of Volume V. As pointed out in this section, all the known PAH animal carcinogens
are included on this list. The relative potency approach is used because cancer study data
are insufficient to assign a specific slope factor for each PAH. This approach is consistent
with current EPA guidance. We have obtained a copy of a memo (dated Oct. 28, 1994)
from the California EPA which indicates that this Agency also subscribes to the use of the
relative potency approach based on the carcinogenicity of benzo[a]pyrene.
Additional PAHs that were included in the WTI risk assessment were naphthalene,
acenaphthene, anthracene, fluoranthene, fluorene, and pyrene. This latter group was
evaluated as noncarcinogenic chemicals since reference doses have been established, but
oral or inhalation cancer slope factors are not available. As alluded to by the Work
Group, there are other PAHs which might have been included. There were three
additional PAHs which were assigned emission rates in the emission characterization study
(Volume III). These were 2-methyl naphthalene, benzo[g,h,i]perylene, and
dibenzo[a,h]fluoranthene. These three PAHs do not have verified EPA toxicity values in
either the IRIS or HEAST databases. The first chemical, 2-methyl naphthalene, was
actually detected during stack testing at WTI. The other two chemicals were analyzed in
stack testing, but if present, were below the detection limit. Therefore, the detection limit
was used as the emission rate. Consequently, there is considerable uncertainty associated
with assessing risk for these three chemicals; currently, no risk is assigned to them.
However, the Agency is confident that the risk assessment evaluates all of the PAHs for
which verified toxicity factors are available.
7. Health Effects Studies from Other Similar Facilities.
Comment: The Work Group suggests that EPA include health effects data from facilities
similar to WTI; the Work Group recommends that EPA include in the final version a list
of data sources examined and what was found in each.
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Response: The human health risk assessment for the WTI incinerator was designed to be
a site-specific investigation of potential adverse health effects from stack emissions of
toxic or hazardous chemicals. Although the Agency recognizes that the potential for
adverse health effects from the hazardous waste incineration process is an important issue,
a serious examination of this complex issue is beyond the scope of the site-specific
assessment undertaken for WTI. Also, because there are many different types of
incineration and combustion facilities, there would be considerable uncertainty and
potential limitation if the search were directed only to facilities "similar to WTI."
Consequently, the Agency has performed a search of data sources and literature reports
that would be applicable if a full scale investigation of incinerator health effects were to be
undertaken. The following discussion is a description of the scientific literature and
technical reports that the Agency believes would be relevant to an investigation of
potential health effects from hazardous and chemical waste incineration.
A. Literature Searches and Sources
The search of data sources included several electronic databases such as
MEDLINE, TOXLINE, ENVIROLINE, Pollution Abstracts, National Technical
Information Service (NTIS), and the Exerpta Medica Database (EMBASE). Key
words used individually or in combination were: incinerator, emissions,
combustion, health, effects, toxicity, disorders, epidemiology, participate
matter, Biebesheim, hydrogen chloride, and air pollution.
The search was also expanded to include technical literature and reports from
other federal government agencies. For example, some literature references on
occupational exposures were obtained directly from the National Institute for
Occupational Safety and Health (NIOSH). The Agency for Toxic Substances and
Disease Registry (ATSDR) provided additional studies that were published as
government documents that do not appear in the standard scientific literature
sources.
Health departments from several state agencies were also contacted. One of these
state contacts led to the discovery of a very comprehensive list of references on the
potential health effects from hazardous waste incineration. These references are
contained in a State of Florida report titled: Evaluation of the Health Impacts
Associated with Commercial Hazardous Waste Incinerators (November 1994).
This report was prepared for the Florida Department of Environmental Protection
by the Florida Center for Solid and Hazardous Waste Management (Gainesville,
FL). In addition to the references on potential health effects of waste incineration,
this report also contains a review and critique of the information found in each
reference. These reviews were prepared by experts in epidemiology, toxicology,
public health, and biostatistics from the University of Florida, University of South
Florida, Florida State University, and Miami University.
>'
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B. Major Results of Literature Searches
The general findings of the U.S. EPA search and the State of Florida report are
that very limited epidemiological data exists in the literature concerning the health
impacts of hazardous waste incinerators. Only a handful of epidemiological
studies were retrieved, of which only a few are directly related to hazardous waste
incineration. The remainder are related to municipal waste incinerators and other
facilities which have been categorized as "chemical waste incinerators," "industrial
incinerators," and "unspecified incinerators." The State of Florida report presents
the following conclusion regarding the availability of studies on the potential health
impacts of waste incineration:
"At the outset, it was anticipated that the literature search would reveal a
significant number of studies on this topic. However, the health impacts of
hazardous waste incineration, as compared to municipal waste incineration, have
not been extensively investigated, at least in part due to the relatively small
number of facilities that have been constructed to accomplish that purpose in the
last 15 years. With possibly two exceptions (The Caldwell Systems incinerator
and the ThermalKEM incinerator), the majority of the studies which were
identified were not completely applicable. This is because they were either not
designed to answer the question of whether exposure to emissions from hazardous
waste incineration was associated with adverse health effects, or because the
study was not large enough or not specific enough to answer the question. "
Another review of the health effects of waste incineration was published by the
German Federal Union of Physicians (Bundesarztekammer 1993; cited in Pleus et
al., 1993). This review addressed reports of adverse health effects from
incineration as follows:
"....occasionally expressed claims that certain illnesses, such as deformities and
cancer cases, occur frequently in the region surrounding waste incineration
facilities, have not yet been able to be confirmed or verified. Individual
observations are not yet able to support causal connections.... According to our
best available knowledge, none of the reported illnesses can be causally linked
with emissions from waste incineration facilities. " (Quote derived from State of
Florida report).
Therefore, at present, there does not appear to be sufficient evidence for serious
health effects in persons residing in the proximity of hazardous waste incinerators.
The State of Florida report further concludes that the lack of evidence of serious
health effects from waste incineration does not mean that some association
between emissions and health effects does not exist, or that adverse consequences
will never be found in the future. At present, there is likely an insufficient number
rf*
Volume VIII
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of reliable studies to identify a causal connection between incinerator emissions
and adverse health effects.
Attachment VI-1 of this Volume contains a list of all references and reports found
in the EPA literature search. Also included in this Attachment are: 1) a list of all
references to incinerator health effects and incinerator emissions as presented in
the State of Florida report; and 2) the written reviews and critiques of incinerator
health studies as presented in the State of Florida report.
C. Additional Information
In addition, it should be noted that the National Academy of Science/National
Research Council (NAS/NRC) has commissioned a Committee on Health Effects
of Waste Incineration. This committee will assess the relationships among
various aspects of waste combustion and estimates of human health risk. The
Statement of Task (October 1994) for the Committee states that it will consider
the following issues for the combustion of hazardous, nonhazardous, and hospital
wastes:
• Relationships between human health risk estimates and various design,
siting, and operating conditions at waste combustion facilities, including
incinerators, cement kilns, industrial furnaces, and industrial boilers.
• Operating practices at combustion facilities and technologic expectations
regarding the release of hazardous substances.
• Appropriate methods for assessing the siting, design, and operation of
combustion facilities.
• Appropriate health-based performance criteria for demonstrating that a
combustion facility meets and maintains agreed upon health-risk tolerance
levels.
• Types of scientific, technical, and other information that should be
provided to government officials, industry managers, and the general public
to help them understand and weigh the risks associated with waste
combustion and its alternatives including innovative ways of oxidizing
waste.
• Public perceptions of waste combustion and their bases.
The sponsors of this Committee are the U.S. EPA, the ATSDR, and the U.S. Department
of Energy.
j* *
Volume VIII
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8. Include List of Noncancer Endpoints.
Comment: Include a list of noncancer endpoints for chemicals addressed in the risk
assessment.
Response: A table summarizing the target organs for noncancer effects associated with
the surrogate organic chemicals and metals evaluated in the HHRA has been added to
Chapter VIII (See new text and table beiow).
Modifications to the Risk Assessment Report:
Volume V; Chapter Vffl, Section B.2, end of paragraph 3
"....In cases where the overall HI exceed unity, chemicals are segregated by target organ
effect and mechanism of toxicity to derive HI values for each type of effect, as
recommended by U.S. EPA(1986b) &:sbiii!!^^
of potential concern iratfrpdfigia^^ Table VJH-1 ."
Volume V; Chapter VTU, add Table VHI-1:
Target Organ{s) forNoncancer Endpolnts of Substances :of Potential Concern
Compound
Target Qrgan(s)
PICs and Residua! Organic Compounds
Bis(2-etJiyllicxyl)pMialale
Carboa tetradhforide
Di(a)ociyf pteflaM*
ifeptacMot
HexacWsrobenzeae
fJexachiorofautadieoe
HexactooiocveJoDsastelkgae
j J-.
Hexacnlotopueae
liver
liver, Iddaey, CNS
CKS, liv«r
CNS, ttver
liver, skia
kidney
respifaiory tract, gastrointestinal tract
cm
M«tals
Volume VIII
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Target Grgaa&) &r Noncancer Endpohrfs of Safastanc^s tf •fbtengai Coac«ra
: Compound
Anttaoay
Ajtseaie
Barium
Berylfiym
Cadmium
Chromium (hexavalent)
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
..r. ' •.::.;..-l%rgctOrgai»(S}
ttspw&aty o»«at1: Iteart, blood
c^aun
«s|8Bttniry tract, <«ftSKw^«tbiir system
ttsgaatbfy ^traef
Wdw,«spir^ryased oa No Obsetvatfle Advetsfi Effects Level
(NOAEL).
Target organ indicated ia bold is eHdpoiat osed to develop RfD/RfC.
Sources:
Integrated Risk information System (IRIS)
Agency for Toxic Substances and Disease Registry (AT$DR}> Pu&fic Heal^a Service. 1987-1995,
Toxicotogt&ti profiles.
Clayton, G.D. and F.E. Clayton, eds. (1994). Patty's mdmtrial frygiene and toxicology. . 4& edition,
John Wiley &. Sons, Inc,( New York.
9. Identify Chemicals Detected.
Comment: Identify the chemicals which were actually detected in stack emissions.
Response: This information is currently contained in Volume III, Appendix III-3 titled:
"Products of Incomplete Combustion Analyzed and Detected in the Trial Burn and
Volume VIII
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Performance Tests." In the final version of Volume III, this Appendix will have a cover
page showing this title.
10. Exposure to Metals via Breast Milk Pathway.
Comment: Clarify why the risk assessment does not address exposure to metals
(especially methyl mercury) by the breast milk pathway.
Response: Although the scientific literature indicates that metals, such as lead, cadmium,
and mercury, have been detected in the breast milk of lactating women, methods for
modeling the partitioning of inorganic compounds into breast milk have not been
developed, and, at present, EPA guidelines do not include this as a potential pathway of
exposure to inorganic compounds.
An analysis was conducted to compare relative concentrations of contaminants in
cows' milk to provide an indication of the potential partitioning of metals into human
breast milk. Based on a one gram per second emission rate, the cow milk concentration of
the chemicals of potential concern was estimated for the subarea of maximum impact
(Subarea El). The relative concentrations of 2,3,7,8-TCDD, benzo[a]pyrene, arsenic,
beryllium, and mercury were compared. Based on partitioning of contaminants into cows'
milk, as estimated in the HHRA, the partitioning of metals, such as arsenic, beryllium, and
mercury, is more than 1,000 times lower than the partitioning of organic compounds, such
as 2,3,7,8-tetrachlorodibenzo-p-dioxin and benzo[a]pyrene.
Organic forms of mercury (e.g., methylmercury) are more likely to partition into
fat (e.g. milk) than inorganic metals; however, exposure to organic forms of mercury was
not estimated to be significant in the HHRA. Organic forms of mercury are most likely
associated with surface water, drinking water derived from surface water bodies, and fish
caught locally. As indicated in the HHRA, the potential pathways of exposure associated
with these sources are not estimated to be significant.
Although transport of metals (inorganic and organic forms) into breast milk is
possible, the partitioning is expected to be significantly less than the organic compounds
evaluated in the HHRA and the sources of exposure are not estimated to be significant.
Therefore, it is unlikely that exposure to metals would constitute a significant source of
risk for breast-feeding infants.
Volume VIII
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Modifications to the Risk Assessment Report:
Volume V; Chapter VHI, Section F (New Subsection 5)
"§. Uncertainties Associated with CharacterizingiJrfcast Milk Jngestion Risks
i sources.
For example, ;sf^p j»\& Jndi^ed:brea& milk concentrations of lead from. exposure to
tap water, .aBd;e|iy|iftK| .ir^ :^piBteei« 'and the metallutgicai industry (Kaeew 1994,
l. 1987,
, At
present, howe^'t 1994a) guidelines do not provide a
methodology -for es;ti%^M the;ttansport of metals into breast milk. This potential route
of exposure, therelofilwas B.o^%ahi^ed in the BHRA.
To evaluate the potential uncertainty associated Tvith not evaluating exposure to
metals la breast milk, an analysis was conducted to compare relative concentrations of
contaminants in cows1 ualfc to provide: am Indication: of tfee potential partittoning of metals
into httiaa» bfeast t»ilk< Based on a OM gram per second ea&sfon tate, the cow milk
coaceatration of tie dsemieais of potential eoneem was estimated ^>r the subarea of
maximam impact (Sutoarea El); -the relative coacgntrataais of 2,3,7, 8-TCDD,
benzo[a]pyrene, arsenic,! Ijeryllium, and mercury were cOnipaTed.
summarises the relatiyeconce^trations of three
mercury— as compared to 2>3,?,8»TCt>t> and b^zotalpyrene, assuming a unit emission
rate from the facility. As indicated in Table VBX-29, the partitioning of these metals is
more than 1,000 tunas lower that the partittoning of the organic compounds into cows'
milk,
"It should be noted; that organic forms of mercury (e.g., methylmercury) are more
likely to partition into fat (e.g. milk&t) than inorganic metals; however, exposure to
organic forms of mercury was not estimated to be significant is this assessment, Organic
forms of mercury are most likely associated with surface water» drinking water derived
from surface water bodies, and ish caught locally, AS indicated in this assessment, the
potential pathways of exposure associated with these sources are not estimated to be
significant
'In summary, although transport of metals (inorganic and .^rganie forms) into
breast milk is possible, % partitioning is expected to be signMcantly less thanithe organic
compounds evaluated tnithls assessment and the sources, bf^posttre are not estimated to
be significant Therefore, it is unlikely that exposure to metlk would constitute a
significant source of risk for breast-feeding infants**
Volume VIII
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Volume V; Chapter Vm, add Table Vm-29:
Relative
&*&****
Substance
Caw Milk Coiiesntratfoji {n»g&g)
Based on Unit Emission Rate
10
Arsenic
5,0x10*
Berylliurn
Mercury
New references cited in Section F.5., and printed in Volume V, Chapter XI:
Eyn0n» ckt et al Same studies of maternal and infant lead
, Umv, Dep, Med, West. Infirm., 27(2):H3-22;
Namihira, D., L. Saldivar, R Pasttftnik., et al. Lead in human blood and nattd frotn nursing
women living near a smelter in Mexico City, J, ToxicoL Environ. Health;
Volume VIII
VI-19
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Radiseh,:B., W. Luck, and H. Nan. Cadnium OHicentr^tiofis in laiifc and biocxJ of
f&d; :&?#Vii
1 19^5;:: tTojdas: and fcaditj.0ji: The impact ^f'f^d-chmn coMamination of
Mitt of northed Quebec:; €mtMe& Assoc. '3'Ł l$i(Ł):1237~4CK
11. Acronyms for "Maximum Concentration" and "Area Average Exposure."
Comment: Use better terms or acronyms for "maximum concentration" and "area
average exposure."
Response: No changes are planned for these terms, since they were considered
acceptable by the Exposure Assessment Work Group. Further explanation for how these
values were derived and what the distinction is between them was presented in the
response to Recommendation #3 from the Exposure Assessment Work Group (See
Chapter V of this Volume).
12. Expand Discussion of Endocrine Disrupters.
Comment: Expand the discussion of endocrine disrupters to indicate which chemicals are
endocrine disrupters and what biological effects could be caused by endocrine disruption.
Response: In response to the first part of this recommendation, additional language has
been added to Chapter III of Volume V in order to identify chemicals which the EPA
suspects could act through endocrine disruption. The second half of the Work Group
request cannot be fully answered at this time. It has been suggested that certain
physiological and pathological observations in humans (e.g., decreased sperm counts and
increases in breast cancer rates in industrialized nations) could result from exposure to
environmental endocrine disrupters. However, discovering and verifying the actual
biological effects in humans caused by endocrine disruption is one of the chief goals of the
scientific research in this area. This is a new area of scientific research, and many of the
critical studies are in their initial phases. At this time, we can only refer to biological
observations in wildlife and ecosystems which are suspected to stem from endocrine
disruption. We have covered this topic in our existing language in Chapter III of
Volume V.
Modifications to Risk Assessment Report:
Volume V, Chapter HI, Section D.5. (Revision of original Section D.3.)
"Uncertainties Associated with Endocrine Disrupters
Volume VIII
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:An environmental endocrine disruptor may be defined as an exogenous agent that
«ri& l&e j^&esi^ oriete^ioiJ of natural
homebstask, :Łe$&x$id% '^svikxptf
"The term "endocrine disrupters" (sometimes referred to as "environmental
hormones") applies to any number of a broad class of chemical compounds with the ability
to perturb or interfere with the finely-tuned endocrine system that is fundamental to
normal function and homeostasis in cells, tissues and organisms rat a variety; of levels of
btolojpga! orgaaizB&QJL : Isxampfes oŁdies»cals suspected of bm&g eadocrine disrupters
, (The
n
"The current concern about endocrine disrupters stems from a body of diverse
historical information and more recent findings which have been integrated into a working
hypothesis. The central theme of the hypothesis. ..."
Add the following sentence to last paragraph of Section D.5.
"However, the Agency.jand other federal ibealth regulatory f^d researelt agencies are
sponsoring significant iaapuats of tesean^i to better endersiand th:€:p1iiBOineiiO!B of
13. Replace Acetone as a Surrogate Chemical.
Comment: Because acetone has been deleted from EPA's list of toxic chemicals under
EPCRA, the Toxicology Work Group recommends that EPA select a different chemical
for the accident analysis.
Response: This comment is addressed in Chapter IV of this Volume, in the response to
Comment 13.
14. Use of ERPG-2 Values.
Comment: IDLH values are inappropriate for assessing the consequence of accidents;
the use of LOG values or ERPG-2 value would be better.
Response: This is essentially the same recommendation as the one from the Exposure
Assessment Work Group. This comment is addressed in Chapter IV of this Volume, in
the response to Comment 5.
Volume VIII
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15. Potential for Accidental Exposures to Impact or Add to Lifetime Exposures.
Comment: The risk assessment does not address how chemical exposures from an
accident might impact an individual's lifetime exposure to chemicals from the WTI plant.
Response: This comment is addressed in Chapter IV of this Volume, in the response to
Comment 7.
16. Worst Case Concentrations at East Elementary School.
Comment: Perform an appropriate modeling and dispersion analysis to determine the
worst case concentrations of chemicals that could be encountered at the East Elementary
School as the result of accidents.
Response: This comment is addressed in Chapter IV of this Volume, in the response to
Comment 8.
17. Consider WTI Emissions Against Background Emissions.
Comment: To evaluate the potential impact of the WTI facility on human health, it is
necessary to consider the facility's emissions against existing exposures. EPA should
quantitatively or qualitatively evaluate releases from other facilities or "other data on
existing emissions."
Response: The Agency agrees that in order to evaluate the potential contribution of
emissions from the WTI facility on human health, it would be useful to compare WTI's
emissions to documented releases from other emission sources. This response will
consider available information on: 1) data for reported chemical releases in the vicinity of
WTI; and 2) ambient monitoring data on dioxin/furan levels in the vicinity of WTI.
PART 1: Comparison of WTI Releases to Toxic Release Inventory Data in the
Vicinity of WTI
In order to provide a meaningful comparison of WTI emissions to other emission sources
in the area around WTI, data from EPA's Toxic Release Inventory (TRI) was compiled.
The TRI is a database which provides information to the public about releases of
potentially toxic chemicals from manufacturing facilities. TRI was established under the
Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 and expanded
under the Pollution Prevention Act of 1990. Chemicals which are required to be reported
Volume VIII
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under TRI are listed in Section 313 of EPCRA. Facilities report their TRI information
annually to EPA and to the State in which they are located.
A facility must report TRI data if: 1) it conducts manufacturing operations within
Standard Industrial Classification (SIC) codes 20 through 39 (See Figure VI-1); 2) it has
10 or more full-time employees; and 3) it manufactures or processes more than 25,000
pounds or uses more than 10,000 pounds of any listed chemical during the calendar year.
For each chemical that a facility manufactures, processes, or transfers in excess of
reporting thresholds, it must submit a separate report form called a "Form R." (For the
reporting year of 1993, nearly 80,000 Form Rs were submitted by more than 23,000 U.S.
facilities.)
Information reported by facilities includes: 1) maximum amount of the chemical present
on-site during the reporting year; 2) amounts of each chemical shipped from the facility to
other locations for recycling, energy recovery, treatment, or disposal; 3) types of activities
conducted using each chemical; 4) amounts of each chemical recycled, burned for energy
recovery, or treated at the facility; and 5) amounts of each chemical released to the
environment during the reporting year.
A release is defined as any on-site discharge of a potentially toxic chemical to the
environment. This encompasses emissions to air, discharges to water bodies, releases to
land, and disposal into underground injection wells. In order to make appropriate
comparisons to WTI emissions, this analysis will focus on air releases. Releases to air are
reported as either a stack emission or a fugitive emission. Stack emissions are releases to
air that occur through confined air streams such as stacks, vents, ducts, or pipes. Fugitive
emissions include all other releases to air that do not involve a confined air stream. These
include equipment leaks, evaporation losses from spills and surface impoundments, and
releases from building ventilation systems.
It should be emphasized that TRI data alone cannot be used to predict the magnitude of
exposure and risk that chemical releases pose to human health and the environment. A
determination of exposure and risk depends on many factors including: the size and
atmospheric dispersion of the emission, the location of potentially exposed populations,
and the toxicity of the chemicals. However, TRI data are useful as a starting point for
evaluating potential risks in a geographic area and for comparing data from different
facilities and geographic areas. TRI data are also a useful tool for tracking regional and
national progress in achieving pollution prevention and waste reduction.
Volume VIII
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Standard Industrial Classification
(SIC) Codes
20 Food and kindred products
21 Tobacco products
22 Textile mill products
23 Apparel and other finished products made from fabrics
and similar materials
24 Lumber and wood products, except furniture
25 Furniture and fixtures
26 Paper and allied products
27 Printing, publishing, and allied industries
28 Chemicals and allied products
29 Petroleum refining and related industries
30 Rubber and miscellaneous plastics products
31 Leather and leather products
32 Stone, clay, glass, and concrete products
33 Primary metal industries
34 Fabricated metal products, except machinery and
transportation equipment
35 Industrial and commercial machinery and computer
equipment
36 Electronic and other electrical equipment and
components, except computer equipment
37 Transportation equipment
38 Measuring, analyzing, and controlling instruments;
photographic, medical and optical goods; watches
and clocks
39 Miscellaneous manufacturing industries
FIGURE VI-1
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For comparison to WTI, TRI data on air releases were compiled for the four county area
in the vicinity of WTI. These counties are: Beaver, PA; Hancock,"WV; Columbiana,
OH; and Jefferson, OH. Within each county, reporting facilities are also listed by U.S. zip
code. For this analysis, all reporting facilities located in zip codes either fully or partially
situated within a 15 mile radius of WTI were identified. The applicable zip codes were
obtained using Figure VII-2 from Volume V of the risk assessment.
Air releases from the facilities identified by the above procedure were compiled to
generate the data tables shown in Attachment VI-2. The listed TRI releases are for the
year 1994, the most recent year for which complete data on each facility is available. The
final table in Attachment VI-2 lists stack and fugitive air releases from WTI for the same
chemicals reported as TRI data from the other facilities. For comparison to TRI data,
emission rate data for releases from WTI (Volume HI) were converted to "annualized"
release rates using the conservative assumptions that WTI is in continuous operation at the
waste feed rates used in Volume III. (WTI is not required to submit TRI reports because
it is not a manufacturing facility which generates or processes pure chemicals in excess of
the reporting thresholds. Other industrial facilities which are not required to report TRI
data are mines, oil and gas drilling operations, electric power plants, warehouses, and
waste treatment and disposal facilities. The EPA has the statutory authority under
EPCRA to bring additional facilities under TRI reporting requirements, and has issued
proposals that most of the industries identified above, including commercial waste
treatment facilities and landfills, should be subjected to TRI reporting.)
A review of the data presented in Attachment VI-2 leads to the following observations:
1. TRI air releases were reported for 37 chemicals from 27 facilities within a 15 mile
radius of WTI. The chemicals included organics, nonmetallic inorganics, and
metals.
2. The chemicals reported as the top 10 stack air releases are shown below:
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CHEMICAL
Zinc
Toluene
Methyl Ethyl Ketone
Styrene
Hydrochloric acid
Sulfuric acid
Nitric acid
Lead
Manganese
Trimethylbenzene
3. The chemicals
CHEMICAL
Trichloroethylene
Zinc
Toluene
Methyl Ethyl Ketone
Sulfuric acid
Styrene
Number of
Facilities
4
3
1
2
4
6
2
2
5
2
reported as the top 10
Number of
Facilities
1
4
3
1
7
1
Chlorodifluoromethane 1
Methanol
Lead
Copper
1
4
3
Total
(Pounds)
433,400
106,780
83,000
49,350
45,044
43,612
27,250
8,180
8,170
8,005
fugitive air releases are
Total
(Pounds)
168,700
156,301
80,200
69,000
61,000
53,000
19,875
15,883
5,600
4,260
Highest Repor
(Pounds)
421,000
100,000
83,000
49,000
38,594
36,000
27,000
8,000
7,000
8,000
shown below:
Highest Report
(Pounds)
168,700
155,000
76,000
69,000
46,000
53,000
19,875
15,883
4,000
4,000
Volume VIII
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4. For stack air emissions, the chemical reported most frequently was chromium (9
facilities); for fugitive air emissions, the chemicals reported most frequently were
chromium (7 facilities) and sulfuric acid (7 facilities).
5. For comparison with the chemicals shown in observation #2, the stack air
emissions from WTI were: toluene (42.5 pounds), styrene (1.6 pounds), lead (2.9
pounds), and zinc (8.3 pounds). Consequently, based on annualized emission
rates, WTI is not a major contributor to stack emissions of these chemicals to the
ambient air in the vicinity of East Liverpool, OH.
6. For comparison with the chemicals shown in observation #3, the fugitive air
emissions from WTI were: methanol (37 pounds), toluene (11 pounds), and lead (1
pound). Consequently, based on annualized emission rates, WTI is not a major
contributor to fugitive emissions of these chemicals in the ambient air in the
vicinity of East Liverpool, OH.
7. WTI also has stack air releases of a few of the TRI chemicals not listed in
observation #2. The most significant projected releases were for xylene (53.1
pounds), ethylbenzene (34.6 pounds), and mercury (97.1 pounds). For all facilities
reporting TRI stack air release data on these compounds, the total releases were:
xylene (6,170 pounds; 2 facilities), ethylbenzene (10 pounds; 1 facility), and
mercury (90 pounds; 1 facility). Consequently, based on annualized emission rates
derived from data reported in Volume III, WTI could be projected to be a major
contributor to stack emissions of ethylbenzene and mercury in the ambient air in
the vicinity of East Liverpool, OH. It should be pointed out that the human health
assessment for WTI (Volume V) did not find significant hazard quotient (HQ)
values associated with these emission rates for ethylbenzene and mercury;
therefore adverse health effects were not predicted for exposure to these chemicals
as emissions from WTI.
8. WTI also has fugitive air releases of a few of the TRI chemicals not listed in
observation #3. The only significant projected release was for xylene (2.5
pounds). For all facilities reporting TRI fugitive air release data on this chemical,
the total releases were 2,820 pounds (2 facilities). Consequently, based on
Volume VIII
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annualized emission rates, WTI is not a major contributor to fugitive emissions of
this chemical in the ambient air in the vicinity of East Liverpool, OH.
REFERENCES
U. S. Environmental Protection Agency. 1993. 1993 Toxics Release Inventory, Public
Data Release. Office of Prevention and Toxics; Washington, D.C. (EPA 745-R-95-010;
March 1995).
Code of Federal Regulations, Volume 40, Part 372 - Toxic Chemical Release Reporting:
Community Right-To-Know.
PART 2: Ambient Air Monitoring Data for Dioxins/Furans
In response to local citizen concerns about emissions from WTI, a group known as the
Tri-lateral Environmental Committee was formed for the purpose of designing and
implementing an environmental monitoring program for the area around East Liverpool,
Ohio. The primary goal of the program is to monitor levels of dioxins/furans, toxic
organics and heavy metals in ambient air; and heavy metals in local homegrown
vegetables and fruits. An additional goal of the program is to determine if emissions from
WTI could be posing an adverse long-term impact on the quality of local air and food.
The current core members of the Committee are the North Ohio Valley Air Authority
("NOVAA"), the East Liverpool Community Advisory Council, and Von Roll (Ohio).
The U.S. EPA - Region 5 is assisting the Committee by providing analytical services for
quarterly dioxin/furan ambient air sampling. The U.S. Food and Drug Administration is
assisting the Committee by performing analysis of food samples.
At the time of this writing, the results were available from the first, second, and third
rounds of quarterly dioxin/furan air sampling which were conducted on
October 30/31,1995, March 27/28, 1996, and July 2/3, 1996. These samples were taken
at five monitoring stations set up by NOVAA in and around East Liverpool, Ohio. The
24-hour samples were taken on NOVAA's air samplers, and the collected samples were
subsequently analyzed by a laboratory contracted by the EPA.
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A description of each sampling station is given below, along with the measured
dioxin/furan value in Toxic Equivalents ("TEQ") compared to 2,3,7,8-tetrachlorodibenzo-
p-dioxin (See Volume V for a full explanation of TEQ). The overall TEQ values have
been calculated such that any congener which was not detected is conservatively assumed
to be present ai one-half the detection limit for that specific congener. This is the same
basis as that used in the EPA Draft Dioxin Reassessment document.
For the purpose of comparison, the EPA's Draft Dioxin Reassessment document lists a
calculated national average "background" value for dioxin/furan TEQ of 0.095
picograms per cubic meter ("pg/m3") (See page 4-47 of Volume II of Estimating
Exposure to Dioxin-Like Compounds, June 1994). This value was reported as the average
of 84 samples taken from different areas of the U.S. considered to be pristine, rural, or
non-impacted urban (that is, urban areas that are not expected to be impacted by industrial
point sources). According to the Draft Dioxin Reassessment document, this value of
0.095 pg/m3 is very similar to the mean of the midpoint values reported in European
studies (i.e., 0.10 pg/m3).
Monitoring Locations and Results of the 10/95, 3/96, and 7/96 Sampling Events:
EM-1: This sampling station is located on the roof of the East Elementary School,
which is about 0.3 mile NW of the WTI incinerator. Dioxins/furans
measured .031 pg/m3 TEQ at this location in 10/95, .083 pg/m3 TEQ in
3/96, and .011 pg/m3 TEQ in 7/96 (non-detect, reported at V2 the detection
limit).
EM-2: This sampling station is on Stage Coach Road, generally downwind from
WTI, approximately 1.9 miles NNE of the incinerator. The location is
surrounded by agricultural land used both for crops and dairy farming.
Dioxins/furans at this location measured 0.031 pg/m3 TEQ in 10/95,
0.030 pg/m3 TEQ in 3/96, and 0.029 pg/m3 TEQ in 7/96 (non-detect,
reported at l/2 the detection limit).
EM-3: This sampling station is on the edge of Grandview Park in Lawrenceville,
West Virginia, 1.25 mile SE of the incinerator. This area is reportedly in
the downwind direction from WTI under certain weather conditions. No
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dioxin/furan congeners were positively detected at this location in 10/95,
but the assumed value based on one-half of the congener detection limits
was .014 pg/m3 TEQ for 10/95. Some positive detections were found in
the 3/96 sampling, and the reported value was .034 pg/m3 TEQ. In July
1996, no dioxin/furan was detected, yielding a ^-detection limit value of
.021 pg/m3 TEQ.
EM-4/6: This sampling station is on the roof of East Liverpool City Hall,
approximately 2 miles SW of the incinerator. This location is generally
upwind of WTI. For the purposes of quality control, two identical
samplers were run side-by-side simultaneously at this location. A trip blank
and a field blank were also analyzed along with the field samples.
Dioxins/furans measured 0.095 pg/m3 TEQ in EM-4 and 0.094 pg/m3
TEQ in EM-6 in 10/95. The dioxin/furan values for both samplers were
0.084 pg/m3 TEQ in 3/96. The higher of the two recorded values in 7/96
was .044 pg/m3 TEQ (the lower value represented '/2 the detection limit
since no dioxin/furan was detected in that sampling event).
EM-5: This sampling station in Wellsville, Ohio, is considered to be a control
(or background) location because of its distance (approximately 6.5 miles
SW) from the incinerator and because it is generally upwind from WTI.
Dioxins/furans at this location measured .040 pg/m3 TEQ in 10/95 and
.056 pg/m3 TEQ in 3/96. No dioxin/furan was detected in 7/96, and the
assumed value (i.e., Vz the detection limit) for the 7/96 event would be
.039 pg/m3 TEQ.
To compare WTI's dioxin/furan emissions to the existing "background" concentrations of
these same contaminants, the Agency performed an analysis which compared the highest
average dioxin/furan air concentrations predicted to occur from the WTI facility to the
dioxin/furan concentrations actually measured in and around East Liverpool. The range of
dioxin/furan concentrations recorded in and around East Liverpool were also compared to
the national background dioxin/furan concentration reported in the draft Dioxin
Reassessment document. By doing this, the relative comparison of WTI to the overall
Volume VIII
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existing air concentrations for this pollutant could be evaluated. All values were
converted to TEQ for the sake of comparison.
An average dioxin/furan emission rate of 9.2 X 10"10 grams TEQ per second, as measured
in the WTI stack over a 1-year period3, was multiplied by the highest predicted dispersion
factor4 from the dispersion modeling described in Volume IV of this risk assessment. This
calculation yields a predicted maximum ground-level concentration from the known stack
emissions. The resulting predicted value, 0.00084 picograms per cubic meter (pg/m3),
was then compared to the measured background range of 0.04 - 0.095 pg/m3 determined
from air sampling/analysis in and around East Liverpool. This comparison showed that
WTFs contribution would not be more than 1-2 percent of the ambient background value
at the point of maximum impact, and would be much less than this at other areas around
the plant. (It should be noted that the WTI incinerator was in operation and burning
wastes on a routine schedule during the collection events described above.)
As mentioned previously, the national background value reported in the draft Dioxin
Reassessment is 0.095 pg/m3. This value would be at the upper end of the 0.04 to 0.095
pg/m3 range measured in and around East Liverpool. Therefore, based on the data from
the first two sampling rounds, it appears that ambient air levels of dioxins/forans during
the sampling periods did not exceed the U.S. average for areas unimpacted by industrial
sources.
At the time of this writing, the Tri-lateral Committee has also performed initial sampling
for heavy metals in ambient air and local vegetables (lead and mercury) during time
periods when WTI was in operation and burning wastes. Full data reports on these
sampling events are expected in the future.
3 This is the same one year period used in the risk assessment, constituting 26 test runs from
August 1993 through August 1994.
4 Specifically, a dispersion factor of 0.91 micrograms per cubic meter per gram per second was
used. This value predicts the highest average ground-level impact at the point of maximum
impact. Most areas around the plant would be expected to experience much lower ground-level
concentrations than those predicted at the maximum impact point.
Volume VIII
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REFERENCES:
U.S. Environmental Protection Agency. 1994. Estimating Exposure to Dioxin-Like
Compounds; Volume II: Properties, Sources, Occurrence and Background Exposures.;
Review Draft; Office of Research and Development; Washington, D.C.; (EPA/600/6-
88/005Cb; June 1994).
Volume VIII
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Vn. ECOLOGICAL RISK ASSESSMENT
Near-Term Recommendations
1. Goals and Purpose Not Clear.
Comment: As stated by the peer review panel, "(t)he principal problem with the SERA is
that its goals and purpose are not clear. As result, the implications of the results of the
assessment and the appropriateness of possible recommendations are unclear."
Response: The text describing the purpose and scope of the SERA has been revised and
expanded in Volume VI. This includes a new section on "Goals and Objectives of the
SERA" which clearly states the goals of the document along with the primary and
secondary objectives. Numerous sections within this volume have been revised to clearly
restate these goals and objectives. In Volume VI, Chapter 1, Pages 3-5, the opening
paragraphs for the primary and secondary objectives now read as follows:
"Thus, the primary objective of the WTI SERA is to identify those
combinations of chemicals, exposure routes, exposure pathways, and receptors for
which a potentially significant risk could exist under normal (routine) facility
operating conditions. If any such chemical-exposure-receptor combinations are
found, the SERA would then provide the basis for conducting a more focused
assessment (PERA or DERA), or for implementing mitigating measures (such as
chemical-specific permit limits), as deemed appropriate by the risk manager(s)."
"A secondary objective of the WTI SERA is to evaluate potential
ecological risks associated with existing permit limits for the emission of metals
from the WTI facility stack. At present, the RCRA permit imposes hourly limits
on the emissions often metals, and at least two additional metals are being
evaluated for regulation under the final permit."
The above revisions will help resolve other related peer review panel concerns,
Comments 2 through 6, and present the SERA as a tool for the risk managers during the
permit development process.
Volume VIII
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2. Assessment Should Suggest Additional Data Needs.
Comment: "When ... chemicals in certain scenarios are retained by the screen, the
assessment should suggest what additional data collection or analysis will be preformed to
resolve those issues."
Response: Revised SERA text for "Risk Analysis" (Section VII. H) and "Summary and
Conclusions" (Chapter IX) provides a discussion for the few ECOC's with hazard
quotients above 0.1. The point of maximum impact for many of these ECOC's occur at
developed industrial/ urban sites with degraded habitat for the ecological receptors (i.e.,
exposure pathway is fragmented or incomplete). With regard to the primary objective of
the SERA, low to negligible risks to ecological receptors are predicted and further study
at the PERA or DERA level is not warranted.
3. Ecological Accident Analysis.
Comment: "The lack of an accident analysis in the SERA concerned the work group
because such an analysis might contribute to a determination of the acceptability of the
incinerator." "... EPA should consider whether an accident analysis is needed for the
SERA and present the results of that consideration. If EPA has a good reason for
omitting an accident analysis, this should be presented."
Response: The SERA is designed to evaluate risk for the protection of populations and
communities (not individuals). Similar to the human health risk assessment (Volume V),
the SERA (Volume VI) does not address catastrophic accidents. Non-routine operations
are discussed in the new section "Scope of the SERA" (I.E.2). The primary factor for
omitting a specific ecological accident analysis is that there is no known method at this
point in time for performing such an accident analysis. This factor was also recognized by
the peer reviewers in the statement "The work group knows of no precedent or guidance
for this accident analysis ..."). In addition, the purpose of the EPA accident analysis in
Volume VII of the risk assessment is two fold:
A. To determine the categories of accidents on the plant site which have the potential
for significant off-site impacts.
B. To predict the areas off-site which appear to be most vulnerable to these plant
accidents.
The information from "A." can assist in evaluating on-site preventive and mitigative
measures, and in determining where additional measures might be warranted, and the
information from "B." can assist the surrounding community and local emergency planners
in understanding and planning for potential accidents. However, in the case of the
>•
Volume VIII
VII-2
-------
postulated ecological risk assessment, emergency planning would not be involved (because
there is no way that plants and animals could be evacuated in an emergency). Therefore,
only the first purpose listed above would apply. But since the categories of accidents
which have the potential for significant off-site impact have already been determined under
the existing accident analysis, the eco-accident analysis would be redundant.
4. Permit Limit Scenario Inconsistent.
Comment: "The permit limit scenario, which seems to drive the SERA, does not appear
in the human health risk assessment. The work group wonders if this reflects a judgement
on the part of EPA that only health risks will contribute to the decision concerning
acceptability of the facility—and that ecological risk considerations will be considered only
to refine permit limits."
Response: The EPA has not made a judgement that only human health risks will
contribute to a potential decision concerning the acceptability of the WTI incinerator.
Both human health risks and ecological risks will be considered in decisions regarding
permit renewal and permit limits. To ensure consistency between the SERA and the
human health risk assessment (HHRA), the HHRA is being revised to evaluate the
potential risks from metals emitted at the current permit limit.
5. Nonstandard Operating Conditions and Nonatmospheric Emissions.
Comment: "Briefly address ... other nonstandard operating conditions ..." and "explain
why the assessment fails to include nonatmospheric emissions."
Response: A new evaluation of abnormal operations is provided in the response to peer
review comments from the combustion engineering workgroup. In brief, the results of
that analysis are that process upsets could potentially result in an increase in the annual
quantity of non-dioxin PICs by 30 percent over the steady state value used in the draft risk
assessment. Because non-dioxin PICs were not a major contributor to ecological risks, no
change is necessary.
In Volume VI, Chapter 1, the text was revised to address the issue of
nonatmospheric emissions in the new Section (I.B.2), "Scope of the SERA" as follows:
"Nonatmospheric releases to the environment, such as sludge disposal and waste
water discharges, are not planned in the vicinity of the WTI facility. Ash will be
disposed of at a remote location outside of the Ohio-West Virginia-Pennsylvania
area in accordance with applicable laws and regulations. All plant wastewaters are
recycled into the plant as process water and are not discharged, except for
#•
Volume VIII
VTI-3
-------
noncontaminated rainwater. For these reasons, potential nonatmospheric releases
from the WTI facility are not evaluated in the SERA."
6. Model for Future Assessments.
Comment: "... a nonmanagement purpose of the SERA might be to develop methods for
this type of assessment and to serve as a model for future assessments."
Response: The text describing the purpose and scope of the SERA has been revised and
expanded in Volume VI. This includes a clarification that the WTI SERA is not intended
to serve as a model.
7. Improve Text Clarity.
Comment: "Edit the SERA to tighten it up and to make it more accessible to
stakeholders."
Response: The entire SERA text has been revised to improve clarity, including
appropriate cross references to other Volumes of this WTI risk assessment and redundant
text has been removed.
8. Indicate Key Uncertainties that Influence Conclusions
Comment: "Indicate in the uncertainty analysis which uncertainties are most important to
the conclusions."
Response: Chapter VIII, Uncertainty Analysis, underwent significant revision and
provides a discussion of key uncertainties expected to influence ecological risk. The
sections on uncertainty of Chapters IV through VII were also revised, along with Tables
IV-11, V-33, VI-58, to clarify the importance to risk conclusions.
Long-Term Recommendations
1. Background Contamination.
Comment: The Ecological Risk Assessment Work Group recommends addressing the
issue of background contamination in the SERA.
Volume VIII
VII-4
-------
Response: The text for Section V.G. (Estimation of Environmental Concentrations) was
revised for background concentrations of air, soil and surface water/ sediment. No data
were available at the time of this writing to estimate background concentrations of
ECOC's in ambient air near the WTI facility. Likewise, no assessment area-specific data
were available describing existing background soil conditions. Only generic background
soil concentrations for metals within the eastern United States are available (Table V-13).
Recent surface water background data are available for metals (except thallium) at
Tomlinson Run and only one organic (chloroform) in the Ohio River.
Estimated soil concentrations under the expected stack and fugitive scenarios for metals
were below mean background concentrations. Portions of the assessment area will have
metal and organic soil concentrations that exceed natural background levels due to other
anthropogenic activities. Estimated surface water concentrations were generally orders of
magnitude less than measured concentrations (or detection limits) for all ECOC's where
data were available (Table V-20) for all exposure scenarios. No data were located
describing sediment concentrations for water bodies at this WTI facility. Existing
monitoring data for three water bodies in the project area is provided in Table V-20. This
data shows concentrations of several metals in surface waters exceed the chronic surface
water benchmarks (described in Chapter VI) and/or monitoring detection limits used were
higher than chronic benchmarks.
2. Impact of Data Gaps.
Comment: "The work group recommends that EPA attempt to analyze the implications
of the (ecotoxicological) data gaps on the reliability of the SERA."
Response: The text describing the purpose and scope has been revised and includes a
clarification that the WTI SERA is not intended to serve as a model. EPA is developing
guidance for ecological risk assessment and other related information will be made
available through bulletins such as the ECO Update.
Revised text in Section VI. H. (Uncertainties in the Characterization of Ecological Effects)
and Chapter VIII (Uncertainty Analysis) provides discussion concerning the effect of
toxicological data gaps on the risk assessment.
Volume VIII
VII-5
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ATTACHMENT H-l
Expanded Evaluation of On-Site and Off-Site Fire Scenarios: Fire Emission Modeling for
Waste Technologies Industries
Volume VIII
-------
EXPANDED EVALUATION OF
ON-SITE AND OFF-SITE FIRE SCENARIOS:
FIRE EMISSION MODELING
WASTE TECHNOLOGIES INDUSTRIES
EPA ID NO. OHD980613541
TASK 03A DELIVERABLE
Submitted to
Dr. Mario Mangino
Work Assignment Manager
U.S. Environmental Protection Agency
Region V
77 West Jackson Boulevard
Chicago. Illinois 60604
Submitted by
A.T. Kearney, Inc.
222 West Adams Street
Chicago, Illinois 60606
and
ENVIRON International Corporation
4350 North Fairfax Drive
Arlington, Virginia 22203
Work Assignment No. ; R05002
Contract No. : 68-W4-0006
Kearney WAM : AnivAnderson
Telephone No. : 312/223-6230
EPA WAM : Mario Mangino
Telephone No. ; 312/886-2589
June 26, 1996
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TECHNICAL MEMORANDUM
R05002 — TASK 03A
EXPANDED EVALUATION OF
ON-SITE AND OFF-SITE FIRE SCENARIOS:
FIRE EMISSION MODELING
WASTE TECHNOLOGIES INDUSTRIES
INTRODUCTION
The Waste Technologies Industries (WTI) Accident Analysis (USEPA 1995a) evaluated the
potential for acute health effects that may result from various accident types which could occur
at the WTI facility. The potential for adverse human health effects associated with fires was
evaluated by assessing two products of combustion (hydrogen chloride and phosgene) that
could possibly be formed during an accidental waste fire. Emissions of uncombusted residues
from waste constituents that are not completely destroyed in the fire were not evaluated. In
the Peer Review Panel comments, it was suggested that the analysis of the fire scenarios be
expanded. Specifically, the Panel recommended that EPA investigate additional approaches
for predicting the constituents and constituent emission rates resulting from waste fires.
To supplement the WTI Accident Analysis (USEPA 1995a), an alternative approach is
employed in this expanded evaluation to examine emissions of waste constituents that are not
completely destroyed in the hypothetical fire. A range of destruction efficiency (DE) values
for open burning of the waste are assumed to predict emission rates for residuals of
uncombusted organics in the waste. Specifically, emissions of "typical" and "worst case"
waste constituents are estimated assuming a DE value of 90% and 99%, reflecting the extent
of combustion that might be expected in an open fire.
This technical memorandum presents the additional emission scenarios and examines the
associated off-site impacts, categorized according to the following subtasks:
-------
Suhtask 1: Evaluate fire scenarios involving a "worst case" waste mixture, with
chemical emission rates predicted for individual waste constituents using DE
values of 90% and 99%
Suhtask 2: Evaluate fire scenarios involving a "typical" waste mixture, with chemical
emission rates for individual waste constituents using DE values of 90 Tr and
99%
The "worst case" waste mixture for Subtask 1 is assumed to consist of the ten most potentially
hazardous chemicals in pumpable waste, ranked according to acute toxicity and the total
quantity reported in waste profile data for the first nine months of operation at the WTI
facility. The "worst case" waste mixture is assumed to contain the ten chemicals in quantities
proportional to the reported quantities in the waste profile data.
The "typical" waste mixture in Subtask 2 is defined to consist of the top five specific
chemicals received in largest quantities in pumpable waste, according to the profile data. The
"typical" waste mixture is assumed to contain these five chemicals in quantities proportional to
the reported quantities in the waste profile data.
The methods for selecting the "typical" and "worst case" waste constituents are described
below.
SELECTION OF CHEMICALS OF CONCERN
"Worst Case" Waste (Subtask 1)
The "worst case" waste represents a mixture of chemicals that are each among the most
hazardous expected to be handled routinely at the facility. Thus, the likelihood of a mixture
similar to the "worst case" waste being involved in a fire is relatively low. In order to select a
"worst case" waste mixture to be evaluated in the expanded fire scenario, a ranking system
similar to the ones used in the Accident Analysis (USEPA 1995a) is developed. This ranking
is based on acute toxicity and quantity, as described below:
-2-
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. Acme toxicirv and quantity. Chemicals are ranked as follows:
IDLH
D = ..
Q
where IDLH (Immediately Dangerous to Life and Health) values represent acute
toxicity and Q represents the quantity of the chemical in pumpable waste, as reponed in
waste profile data for the first nine months of operation of the WTI facility. The
chemical with a combination of a low IDLH value and high quantities received would
have the lowest R value, and thus be the most highly ranked. This ranking identifies
chemicals that are of concern with respect to acute toxicity that are received in
significant quantities at the facility.
Based on this ranking system, the ten most highly ranked chemicals are summarized in
Table 1. These ten most highly ranked chemicals are selected to represent the "worst case"
waste for this analysis. The composition of the "worst case" waste is assumed to be
proportional to the total quantity of each of these ten chemicals, and is summarized in
Table 2.'
It would also be possible to include "combustibility" of chemicals in the ranking scheme,
to identify chemicals which are likely to have the lowest "DE" values, and thus pose the
highest risk as a waste residual in the fire emissions. However, there are only limited data
available for estimating the "combustibility" of chemicals in an open fire. Thus, the approach
taken in this evaluation is to evaluate a range of possible DE (90% to 99%) values regardless
of potential " combustibility."
1 The quantity of two of the ten most highly ranked chemicals—toIuene-2,4-djisocyanate and tolucne-2,6-
diisocyanaie—were listed together as total toluene diisocyanate on WTT's inventory of quantities received
during the first year of operation. Therefore, these two chemicals are considered together in this analysis, and
Table 2 lists only nine chemicals.
-------
"Typical" Waste (Subtask 2)
The "typical" waste represents a mixture of chemicals that are expected to be routinely
handled at the facility. The five chemicals reported in the largest quantities in waste profile
data for the first nine months of operation of the WTI facility are selected to represent a
-typical" waste for this analysis. These five chemicals are cresols, toluene, methyl ethyl
ketone, methanol, and acetone. The composition of the "typical" waste is proportional to the
total quantities of each of these five chemicals, and is summarized in Table 3.
FIRE SCENARIOS
Except for waste composition, the fire scenarios evaluated in this expanded analysis are the
same as the ones used in the Accident Analysis. For the on-site fire scenario, a 20,000-gallon
storage tank is assumed to rupture in the Organic Waste Tank Farm and the contents are
assumed to spill into the secondary containment area (180 m2) in the presence of an ignition
source, resulting in a pool fire. For the off-site fire scenario, the contents of a 5,000-gallon
tanker truck are assumed to spill along a local access road in the presence of an ignition
source; the size of the pool is assumed to reach 735 m2 prior to ignition.
Both fire scenarios are assumed to occur under the conservative meteorological condition.
As defined in the Accident Analysis (USEPA 1995a), the conservative meteorology is
determined by examining all 54 combinations of wind speed and atmospheric stability (the
EPA screening meteorologies) used in the SCREEN2 air dispersion model. Based on the
previous ISC-COMPDEP ah- dispersion modeling results, the conservative meteorology for
most downwind receptors is low wind speed (1 m/sec) and stable atmosphere (F-stability)
except for receptors located very close to the fires. For receptors close to the fires, the
conservative meteorology that would result in maximum downwind concentrations is a neutral
atmosphere (D-stability) with moderate wind speeds (5 m/sec).
Using the same fire modeling equations used in the Accident Analysis (FEMA 1993), the
burning rate, heat flux, buoyancy flux, flame height, and flame temperature for the pool fire
are determined for the waste mixtures. Chemical and physical properties of the mixtures
(e.g., molecular weight, boiling temperature, liquid density) are determined using the methods
summarized in the Accident Analysis. The critical fire parameters that affect air dispersion
-4-
-------
modeling (i.e.. buoyancy flux, flame height, and flame temperature) are summarized in
Tables 4 and 5. Tables 4 and 5 also compare the fire parameters with those of the fire
scenario modeled in the Accident Analysis, which involved a mixture of 15%
perchloroethylene (i.e., tetrachloroethene) in a toluene solution.
It is assumed that a fraction of each waste constituent will be destroyed by the fire, with
the remainder transported downwind by the fire plume. Two DE values were assumed: 90%
and 99%. Table 6 shows the emission rates of each chemical for two DE values under
Subtask 1 and Subtask 2.
ESTIMATION OF OFF-SITE AIR CONCENTRATIONS
To determine potential off-site impacts, the emission rates for the waste constituents evaluated
in Subtasks 1 and 2 are multiplied by the air dispersion coefficients (estimated air
concentrations per unit emission rate) previously developed in the Accident Analysis.
Applying the previously developed dispersion coefficients (from the ISC-COMPDEP air
dispersion modeling) to this expanded analysis is considered appropriate and conservative. It
is considered appropriate because, except for the effective plume height, all air dispersion
modeling parameters (such as source area, receptor locations, terrain elevations, and
meteorological conditions) specified in this expanded fire analysis are the same as those used
in the original Accident Analysis. It is considered conservative because the expanded fire
scenarios would release more heat and, consequently, result in more plume dispersion and less
off-site impacts than the original fire scenarios. The conservatism is shown in the plume
height analysis described below:
Plume Height Analysis
The effective plume height for each fire scenario is determined from the following equations
(U.S. EPA 1995b, Briggs 1975):
for unstable or neutral atmospheric condition:
He = Hs + 21.425 Fb 3/4 / u , if Fb < 55
-5- ' •
-------
or
Hc = Hs + 38.71 Fb 3/s / u , ifFb > 55;
for stable atmospheric condition:
He = Hs + 2.6 (Fb / u s)1/3 ,
where
He = Effective plume height, m;
Hs = Flame height, m;
Fb = Buoyancy flux, mVsec3 ;
u = Ambient wind speed, m/sec;
s = Stability parameter, I/sec2 , s = g(d6/8z)/T,;
Ta = Ambient temperature, K;
dQ/dz = Temperature gradient, 0.02 K/m (USEPA 1995); and
g = Gravitational acceleration, m/sec2
The formula for the effective plume height in a stable environment is not satisfactorily
developed because of the lack of data (Hanna et al 1982). Specifically, the empirical
coefficient 2.6 could result in an underestimation of the actual plume rise, (and thus an
overestimation of maximum off-site concentrations) based on comparisons made between the
model predictions and field observations (Hanna et al 1982). Nevertheless, the formula is well
known and is used in the USEPA-recommended ISC-COMPDEP air dispersion model, and
can be used to provide a conservative estimate of off-site dispersion.
Based on the critical fire parameters calculated for the "typical" (Subtask 2) and "worst
case" (Subtask 1) waste mixtures, the effective plume heights for the expanded fire scenarios
are estimated and compared to that calculated in the Accident Analysis' Table 7 compares the
effective plume heights computed for the two expanded fire scenarios to that estimated for the
original fire scenario discussed in the Accident Analysis. The critical wind speeds that yield
-6-
-------
the highest ground level cc.icentrations (5 m/sec for the unstable/neutral stability and 1 m/sec
for the stable stability), as determined from previous ISC-COMPDEP air dispersion modeling
in the Accident Analysis, are used in the plume height calculations.
As shown in Table 7, Lie effective plume heights for the expanded fire scenarios are
greater than their respective values evaluated in the Accident Analysis. The off-site ground
level concentration decreases as the effective plume height increases, because 1) the maximum
ground-level concentration .s roughly proportional to the inverse square of the effective plume
height (Hanna et al. 1982); and 2) all effective plume heights exceed the highest point of the
nearby elevated terrain at the WTI facility. Thus, using the air dispersion coefficients
previously developed in the Accident Analysis for this expanded analysis is conservative since
they would tend to overpredict actual chemical concentrations in air.
Concentration Estimates and Off-site Impact Zones
Subtask 1: "Worst Case" Waste Fire
The results of Subtask are summarized in Tables 8 through 16. Tables 8a and 8b
present the predicted off-site toluene diisocyanate concentrations for the unmitigated on-
site and off-site fire see larios, respectively, involving open burning of the hypothetical
"worst case*" waste mb rure. Table 8c presents the estimated average off-site toluene
diisocyanate concentrat jns resulting from an on-site fire that is controlled or mitigated in
10 minutes. Tables 9a inrough 16c show the predicted off-site air concentrations for the
other chemicals identified in the characterization of the "worst case" waste mixture. The
distances to the concentrations of potential concern are displayed in Tables 17 and 18 for
DE=99% and 90%, resoectively. As shown, the potential impact zones defined by the
expanded fire scenarios are smaller than those previously defined in the Accident Analysis
if at least 90% of the chemical constituents of the "worst case" waste mixture are
destroyed by the fire.
The "worst case" waste fire scenarios addressed in this expanded analysis are
considered to be conservative since pool fires are assumed to occur under the worst-case
screening meteorology (worst case meteorology among the 54 possible combinations of
-7-
-------
wind speed and atmospheric stability at each downwind distance) immediately after the
spills reach their maximum spill sizes. Furthermore, the effective plume heights of the
fires due to plume rise (which would increase the plume dispersion and reduce the off-site
impacts) are conservatively assumed to be the same as those originally developed in the
Accident Analysis.
Based on the chemical properties of the "worst case" waste, the ARCHIE hazard
assessment and consequence analysis model (FEMA 1993) is used to calculate the radius
of the circular zone around a liquid pool fire in which unprotected and/or unsheltered
individuals may experience injuries or lethal burns due to thermal radiation exposure. All
major assumptions of the pool fire model are kept the same as those used in the Accident
Analysis.
The ARCHIE outputs for potential heat effects associated with the on-site and off-site
"worst case" waste fire scenarios are included in Attachment A-l. The fatality zone and
the injury zone defined by the on-site "worst case" waste fire scenario both increase from
that defined in the Accident Analysis by approximately 10 m due to the heat output of the
"worst case" waste. These zones (30 m and 40 m in radius for the fatality zone and
injury zone, respectively) are well within the minimum distance (75 m) from the Organic
Waste Tank Farm area to off-site inhabited areas. Thus, neither fatalities nor injuries
would be expected off-site, although on-site impacts might occur.
The fatality zone and injury zone defined by the off-site "worst case" waste fire
scenario both increase from those defined in the Accident Analysis by approximately 20 m
(to 60 m and 80 m in radius for the fatality zone and injury zone, respectively). Although
the fatality and injury zones defined by the expanded off-site fire scenario increase slightly
from those defined by the original off-site fire scenario, injuries due to heat effects for the
expanded fire scenario are predicted to be limited to a distance of less than 100 m into the
off-site inhabited areas. Thus, the expanded off-site fire scenario is assigned the same
severity of consequence ranking of moderate as for the original off-site fire scenario,
according to the ranking criteria discussed in the Accident Analysis.
-8-
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ftnhtask 2: "Typical" Waste Fire
Tables 19 through 23 show the predicted off-site chemical concentrations for the on-site
and off-site fire scenarios for a "typical" waste. Tables 24 and 25 compare the potential
impact zones for "typical" waste to the scenario considered in the Accident Analysis. For
all on-site scenarios in the expanded analysis, the LOG and IDLH values will not be
exceeded off-site if at least 90% of the chemical constituents in the waste are destroyed by
the fire. For the off-site fire scenario, the impact zones defined by the "typical" waste in
the expanded analysis are found to be much smaller than those defined in the original
Accident Analysis.
Attachment A-2 lists the ARCHIE outputs for potential heat effects associated with the
on-site and off-site "typical" waste fire scenarios. The fatality zone and the injury zone
defined by the on-site "typical" waste fire scenario both to increase from that defined in
the Accident Analysis by approximately 5 m. These zones (25 m and 35 m in radius for
the fatality zone and injury zone, respectively) are well within the minimum distance
(75 m) from the Organic Waste Tank Farm area to off-site inhabited areas. Thus, neither
fatalities nor injuries would be expected off-site, although on-site impacts might occur.
The fatality zone and injury zone defined by the off-site "typical" waste fire scenario
both increase from those defined in the Accident Analysis by approximately 10 m (to 50 m
and 70 m in radius for the fatality zone and injury zone, respectively). Although the
fatality and injury zones defined by the expanded off-site fire scenario increase slightly
from those defined by the original off-site fire scenario, injuries due to heat effects for the
expanded fire scenario are predicted to be limited to a distance of less than 100 m into the
off-site inhabited areas. Thus, the expanded off-site fire scenario is assigned the same
severity of consequence ranking of moderate as for the original off-site fire scenario,
according to the ranking criteria discussed in the Accident Analysis.
01-3999C WPM373 1 WPD
-0-
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REFERENCES
Bnggs, G.A. 1975. Plume Rise Predictions, in Lectures on air pollution and environmental
impact analyses. Workshop Proceedings, Boston, Mass.. Sept. 29 - Oct. 3. 1975.
pp. 59-111, American Meteorological Society, Boston. MA.
Federal Emergency Management Associate (FEMA). 1993. Handbook of chemical hazard
analysis procedures. NTIS PB93-158756.
Hanna. S.R.. G.A. Briggs. and R.P. Hosker. Jr. 1982. Handbook on atmospheric diffusion
U.S. Department of Energy, DOE/TIC-11223.
National Institute for Occupational Safety and Health (NIOSH). 1994. Pocket guide to
chemical hazards. DHHS (NIOSH) Publication No. 94-116. U.S. Department of Health
and Human Services. Washington, D.C. June.
United States Environmental Protection Agency. 1995a. Risk Assessment for the Waste
Technologies Industries (WTI) Hazardous Waste Incinerator. Volume VII. Accident
Analysis.
United States Environmental Protection Agency (U.S. EPA), Office of Air Quality Planning
and Standards. 1995b. User's guide for the Industrial Source Complex (ISC3) dispersion
models Volume II - Description of model algorithms. EPA-454/B-95-003b. Research
Triangle Park, NC.
01-3999C WPM373 1 WPD
-10-
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TABLE 1
Ranking of Chemicals of Potential Concern for Subtask 1
Substance
Toluene-2.6-diisocyanate
Formaldehyde
Toluene-2 ,4-diisocyanate
Hydrogen fluoride
Dimethyl sulfate
Dtmethylhydrazine
Cresols
2-Nitropropane
Hydrazine
Toluene
Quantity Received
flb/yr)'
50.3504
100.677
50.3504
30,768
37.304
34.261
998.281
321.555
38.412
770.291
IDLH:
(g/mj)
0.009
0.0245
0.0178
0.0245
0.0360
0.0370
1.10
0.364
0.0655
1.88
Rank1
(IDLH. Q)
1
->
j\
4
5
6
7
8
9
10
Notes:
1 Quantity reported in waste profile data for the first nine months of operation at WTI facility.
2 Immediately Dangerous to Life and Health (IDLH) value (NIOSH 1994). For chemicals without an IDLH
value, but for which a Level of Concern (LOC) value has been established, the IDLH value was provided by
USEPA (199S) as 10 times the LOC.
3 Ranked according to the IDLH value divided by the quantity.
4 Quantity of total toluene diisocyanate received.
-11-
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TABLE 2
Chemicals in "Worst case" Waste (Subtask 1)
Substance
Quantity
Received
db/yr)
Mass
Fraction
Molecular
Weight
(kg/kgmol)
Mole
Fraction
Liquid
Densin
(kg/m1)
Boiling
Temperature
(K)
Toluene diisocyanate'
50,350'
0.021
174
0.01
1.220
524
Formaldehyde
100,677
0.042
30.0
0.12
815
254
Hydrogen fluoride
30,768
0.013
20.0
0.05
1.000
29?
Dimethyl sulfaie
37.304
0.016
126.1
0.01
1.330
461
Dimethylhydrazine
34.261
0.014
60.1
0.02
790
335
Cresols
998,281
0.419
108
0.32
1.030
475
2-Nitropropane
321.555
0.135
89.1
0.13
990
393
Hydrazine
38,412
0.016
32.1
0.04
1.010
386
Toluene
770,291
0.323
92.1
0.29
870
384
WORST CASE WASTE
1.00
83.7
1.00
966
sir
Notes:
1 Quantity of total toluene diisocyanate received (i.e., both toluene-2,4-diisocyanate and toluene-2.6-
dhsocyanate). Properties listed are for toluene-2,4-diisocyanate because the Antoine's constant for toluene-2,6-
diisocyanate is not available in literature.
2 Assumed to be 1,1-dimethylhydrazine.
3 Estimated using Antoine's equation. Antoine's constants for some chemicals obtained from Basic physical
properties of pure organic compounds, Laboratory manual, Volume 40-19-1976 (Union Carbide Corporation)
and Lange 's handbook of chemistry (11th Edition). Antoine's constants for chemicals for which these constants
were not available were estimated using vapor pressure data from Hazardous Substance Data Bank (HSDB):
Oil and Hazardous Materials/Technical Data System (OHM/TADS); National Institute of Occupational Health
and Safety (NIOSH) Pocket Guide; and Vershueren's Handbook of environmental data on organic chemicals
(2nd Edition).
4 Assumed to be m-CresoI.
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TABLES
Chemicals in "Typical" Waste
Substance
Crcsols'
Toluene
Methyl ethyl keione
Metnanol
Acetone
Quantity
Received
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TABLE 4
Comparison of Critical Fire Parameters
Calculated for "Typical" and "Worst case" Wastes1 and PCE/Toluene: Mixtures
(On-Site Fire Scenario, Subtasks 1 and 2)
Parameter
Subtask 2
Typical Waste
(Expanded Fire
Scenario)
Subtask 1
Worst case
Waste
(Expanded Fire
Scenario)
PCE/Toluene
(Original Fire
Scenario)
Notes
Chemical/Physical Properties
MW (kg/kgmol)
TipOC)
p (kg/m3)
P,(Pa)
65.4
348
868
10,600
83.7
311
966
57,700
98.7
384
935
2,840
molecular weight
boiling temperature
liquid density at Ta
vapor pressure at Ta
Calculations
dm/dt (kg/m2/s)
H(m)
QH/Ap (kW/m2)
F (m4/sj)
T(K)
«»un,(S)
:atality zone radius (m)
injury zone radius (m)
0.0493
19.7
65.0
104
1.040
7,400
24.5
35.1
0.0836
27.3
85.4
137
1,110
4.860
28.7
41.1
0.0560
21.3
44.3
70.9
942
7,030
19.8
28.4
mass burning rate per unit area
flame height
heat emission rate per unit area
buoyancy flux
average fire temperature
time of burning
pool fire fatality zone radius
pool fire injury zone radius
Other Parameters
Ao(m2)
A, (m2)
H, (m)
d^M
Ts(K)
Ta(K)
Pa (Pa)
V,,,, (m3)
T,,, (s)
AP (m2)
depth (m)
0.0186
12.4
6.10
3.98
293
293
1.01E+5
75.7
600
180
0.421
area of hole
cross sectional area of tank
height of storage tank
tank diameter
storage temperature
ambient temperature
ambient pressure
volume of spill (20.000 gal)
spill time (10 min)
size of containment area
pool depth
*iotes:
1 "Typical" mixture of cresols, toluene, MEK. methanol. and acetone and "worst case" mixture of toluene
diisocyanaie, formaldehyde, hydrogen fluoride, dimethyl sulfate, dimethyl hydrazine, cresols, 2-mtropropane,
hydrazine, and toluene:
2 15% perchloroethylene/85% toluene solution previously 'used in Accident Analysis fire scenarios
-14-
-------
TABLES
Comparison of Critical Fire Parameters
Calculated for "Typical" and "Worst case" Wastes1 and PCE/Toluene; Mixtures
(Off-Site Fire Scenario, Subtasks 1 and 2)
Subtask 2
Typical Waste
(Extended Fire
Subtask 1
Worst case
Waste (Expanded
Fire Scenario)
PCE/Toluene
(Original Fire
Scenario)
Notes
Chemical/Physical Properties
MW (kg/kgmol)
T^OC)
p (kg/m3)
P,(Pa)
dm/dt (kg/m2/s)
H(m)
QH/Ap (kW/m2)
F (tnVs3)
T(K)
i*»
-------
TABLE 6
Estimated Emission Rates
for the Expanded Fire Scenarios (Subtasks 1 and 2)
Fire Scenario
Assumed Destruction
Efficiency (%)
Emission Rate (g/sec)
On-Site Fire
99
90
Off-Site Fire
99
90
"Worst-Case" Waste (Subtask 1)
Toluene -diisocyanate
Formaldehyde
Hydrogen Fluoride
Dimetnylsulfate
Dimeihylhydrazine
Cresols
2-Nitropropane
Hydrazine
Toluene
3.17e+00
6.36e+00
1.94e-(-00
2.36e+00
2.16e+00
6.30e+01
2.03e+01
2.42e+00
4.86e+01
3.17e+01
6.36e+01
1.94e-»-01
2.36e+01
2.16e+01
6.30e+02
2.03e+02
2.42C+01
4.86e+02
l.SOe+01
2.60e-i-01
7.93e-(-00
9.65e+00
8.85e+00
2.58e+02
8.30e+01
9.90e-(-00
1.99e+02
1.30e-»-02
260e*02
7.93e-*-01
9.65e+01
8.85e-(-01
2.58e-»-03
8.30e+02
9.90e+01
1.99e-i-03
"Typical" Waste (Subtask 2)
Cresols
Toluene
Methyl Ethyl Ketone
Methanol
Acetone
2.47e+01
1.90e+01
1.67e+01
1.45e+01
1.37e-i-01
2.47e+02
1.90e+02
1.67e+02
1.45e+02
1.37e+02
l.Ole-t-02
7.78e+01
6.83e-t-01
5.92e+01
5.61e+01
l.Ole-i-03
7.78e+02
6.83e-i-02
5.92C-I-02
5.61e+02
-16-
-------
TABLE?
Comparison of Effective Plume Heights Calculated
for the Expanded and Original Fire Scenarios (Subtasks 1 and 2)
Hs(m)
Fb (m4/s3)
T(K)
He(m)
Neutral, u = 5 m/s
Stable, u = 1 m/s
On-Site Fire Scenario
New Fire
Scenario
"Typical"
Waste
(Subtask 2)
19.7
104
1040
"Worst
case" Waste
(Subtask 1)
27.3
137
1110
145.3
159.4
175.5
180.5
Original
Fire
Scenario
21.3
70.9
942
121.1
A44.3
Off-Site Fire Scenario
New Fire
Scenario
"Typical"
Waste
(Subtask 2)
32.2
425
1040
"Worst
case" Waste
(Subtask 1)
44.4
559
1110
Original
Fire
Scenario
34.7
288 |
941
324.5
255.6
389.0
289.2
266.2 1
230.9 |
Notes: |
Hs: Flame height
Fb: Buoyancy flux
u: Ambient wind speed
Neutral: Atmospheric stability
Stable: Atmospheric stability
-17-
-------
TABLE 8a
Maximum Toluene diisocyanate Concentrations
for the Conservative Unmitigated On-Site Fire Scenario (Subtask 1)
Downwind
(Distance
<*)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
II 3000
II 4000
I! 5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration1 (ppm)
DE = 99%
O.OOe-i-00
O.OOe+00
2.26C-05
6.32e-04
1.36e-03
1.53e-03
1.43e-03
3.19e-02
2.71e-02
2.36e-02
1.73e-02
1.34e-02
1.09e-02
8.99e-03
7.43c-03
6.48C-03
4.73e-03
3.13e-03
2.38e-03
1.42e-03
9.17e-04
5.47e-04
3.78e-04
2.25e-04
1.57c-04
1.19c-04
DE = 907,
O.OOe-t-00
O.OOe+00
2.26e-OU
6.32e-03
1.36e-02
1.53e-02
1.43e-02
3.19e-01
2.7le-01
2.36e-01
1.73e-01
1.34e-01
1.09e-OJ
8.99e-02
7.43e-02
6.48e-02
4.73e-02
3.13e-02
2.38e-02
1.42e-02
9. 17e-03
5.47e-03
3.78e-03
2.25e-03
1.57c-03
1.19c-03 ||
Note:
Concentration = emission rate x concentration factor x 1.15 x
0.024
MW
-18-
-------
TABLE 8b
Maximum Toluene diisocvanate Concentrations
for th > Conservative Off-Site Fire Scenario (Subtask 1)
Downwind
(Distance
100
200
300
1400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
1 40000
| 50000
Concentration
Factors
(ug/mj)/(g/s)
218.08
72.278
41.282
34.118
34.857
28.975
23.247
21.615
19.16
20.693
14.095
11.294
9.602
9.11
8.585
7.888
6.39
4.437
3.547
2.156
1.445
0.886
0.708
0.563
0.463
0.39
Concentration1 (ppm>
DE = 99%
4.49e-01
1.49e-01
8.51e-02
7.03e-02
7.18e-02
5.97e-02
4.79e-02
4.45e-02
3. 956-02
4.26c-02
2.90e-02
2.33e-02
1.98e-02
1.88e-02
1.77e-02
1.63C-02
1.32e-02
9.14C-03
7.31e-03
4.44e-03
2.98e-03
1.83e-03
1.46e-03
1.16e-03
9.54e-04
8.04C-04
DE = 909,
4.49e->-00
1 49e-i-00
8.51e-01
7.03e-01
7.18e-01
5.97e-01
4.79e-01
4.45e-01
3.95e-01
4.26e-01
2.90e-01
2.33e-01
1.98e-01
l.88e-01 I!
1.77e-01
1.63e-01
1.32e-01
9.14e-02
7.31e-02
4446-02
2.98e-02
1.83e-02
1.466-02
1.166-02
9.546-03
8.046-03
Note:
Concentration = emission rate x concentration factor x 1.15 x
0.024
MW
-10-
-------
IV
for the Cc
======
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
TABLE 8c
laximum Toluene diisocyanate Concentrations
mservative Mitigated On-Site Fire Scenario (Subtask 1)
Concentration
Factors
(ug/m3)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration' ippm)
DE = 99%
O.OOe+00
O.OOe+00
3.77e-06
1.05e-04
2.26C-04
2.56e-04
2.38e-04
5.31e-03
4.52C-03
3.93e-03
2.88c-03
2.23e-03
1.82C-03
1.50e-03
1.24e-03
1.08e-03
7.89e-04
5.22C-04
3.96e-04
2.37C-04
1.53e-04
9.11e-05
6.31e-05
3.75C-05
2.62e-05
1.98e-05
DE = 909r
O.OOe-t-00
O.OOc-00
3.77e-05
1.05e-03
2.26e-0?
2.56C-03
2.38e-03
5.31e-02
4.52e-02
3.93e-02
2.88C-02
2.23e-02
1.82C-02
1.50e-02
1.24e-02
1 .08e-02
7.89e-03
5.22e-03
3.96e-03
2.37e-03
1.53e-03
9.11e-04
6.31e-04
3.75C-04
2.62e-04
1.98e-04
Note:
, ,. 0.024 10
Concentration = emission rate x concentration factor x 1.15 x x
MW
60
-20-
-------
TABLE 9a
Maximum Formaldehyde Concentrations
for the Conservative Unmitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
1 30000
I 40000
| 50000
Concentration
Factors
(ug/mVtg/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.7%
12.892
9.424
6.233
4.733
2.327
1.826
1.088
0.753
0.448
0.313
0.237
Concentration1 ippm)
DE = 99*
O.OOe+00
O.OOe-fOO
2.63e-04
7.35e-03
1.58e-02
1.78C-02
1.66e-02
3.71c-01
3.16C-01
2.74e-01
2.01e-01
1.56c-01
1.27e-01
1.05e-01
8.65e-02
7.54e-02
5.51C-02
3.64e-02
2.77e-02
1.65e-02
1.07e-02
6.36e-03
4.40e-03
2.62e-03
1.83c-03
1.39e-03
DE = 907,
O.OOe+00 I
O.OOe+00 I]
2.63e-03 II
7.35e-02 |
1.58e-01 I!
1.78e-01 II
1.66e-01 II
3.71e-t-00 I!
3.16e+00 [I
2.74e+00 II
2.01e+00 ||
1.56e+00 [I
1.27e+00 [I
l.OSe+00 |
8.65e-01 II
7.54C-01 II
5.51e-01 1
3.64e-01 |
2.77e^)l 1
1.65e-01
1.07e-01
6.36C-02
4.40e-02
2.62c-02
1.83e-02
1.39e-02
Note:
Concentration = emission rate x concentration factor x 1.15 x
0.024
MW
-------
TABLE 9b
Maximum Formaldehyde Concentrations
for the Conservative Off-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
-------
TABLE 9c
Maximum Formaldehyde Concentrations
for the Conservative Mitigated On-SUe Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
1 300
400
500
600
700
800
II 900
1000
1250
1500
1750
2000
2250
12500
3000
4000
5000
7500
10000
15000
20000
30000
40000
[ 50000
Concentration
Factors
Concentration' tppm)
DE = 99%
O.OOe+00
O.OOe+00
4.38e-05
1.22e-03
2.63e-03
2.97e-03
2.77e-03
6.18e-02
5.26e-02
4.57e-02
3.35C-02
2.59e-02
2.12e-02
I.74e-02
1.44e-02
1.26e-02
9.18e-03
6.07e-03
4.61e-03
2.75e-03
1.78e-03
1.06e-03
7.34e-04
4.36e-04
3.05e-04
2.31e-04
0.024 10
MW 60
DE = 909,
O.OOe+00
O.OOe+00
4.38e-04
1.22e-02
2.63e-02
2.97e-02
2.77e-02
6.18e-01
5.26C-01
4.57e-01
3.35e-01
2.59e-01
2.12C-01
1.74C-01
1.44e-01
1.26e-01
9.18e-02
6.07e-02
4.61C-02
2.75e-02
1.78e-02
1.06e-02
7.34e-03
4.36e-03
3.05e-03
2.31e-03
-------
TABLE lOa
Maximum Hydrogen Fluoride Concentrations
for the Conservative Unmitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Note:
' Concentration = emission rate x concentration factor
Concentration' tppm)
DE = 99%
O.OOe+00
O.OOe+00
1.20e-04
3.37e-03
7.23e-03
8.17e-03
7.60e-03
1.70c-01
1.45e-01
1.26e-01
9.20e-02
7.12e-02
5.82e-02
4.79C-02
3.96e-02
3.45e-02
2.52e-02
1.67e-02
1.27C-02
7.57e-03
4.89e-03
2.91e-03
2.02e-03
1.20e-03
8.38e-04
6.35e-04
, ,c °-024
MW
/*
DE = 909f
O.OOe+00
O.OOe+00
1.20c-03
3.37e-02
7.23e-02
8.17e-02
7.60e-02
1.70e-(-00
1.45e+00
1.26C+00
9.20e-01
7.12e-01
5.82e-01
4.79e-01
3.96e-01
3.45e-01
2.52e-01
1.67e-01
1.27e-01
7.57e-02
4.89e-02
2.91C-02
2.02C-02
1.20e-02
8.38C-03
6.34e-03
-24-
-------
TABLE lOb
Maximum Hydrogen Fluoride Concentrations
for the Conservatiye Off-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
130000
40000
50000
Concentration
Factors
-------
for
TABLE lOc
Maximum Hydrogen Fluoride Concentrations
the conservative Mitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration1 (ppm)
DE = 99%
O.OOe+00
O.OOe+OQ
2.01C-05
5.61e-04
I.20e-03
1.36e-03
1.27e-03
2.83e-02
2.41e-02
2.09e-02
1.53e-02
1. 196-02
9.69C-03
7.99e-03
6.60c-03
5.75e-03
4.21C-03
2.78e-03
2.11e-03
1.26e-03
8.15e-04
4.85e-04
3.36C-04
2.00e-04
1.40e-04
1.06C-04
DE = 90*
0.00e*00 1
O.OOe-00
2.01e-04
5.61c-03 1
1.20e-02
1.36e-02
1.27e-02
2.83e-01
2,41e-01 II
2.09e-01
1.53C-01
1.19C-01
9.69e-02
7.99e-02
6.60e-02
5.75C-02
4.20e-02
2.78e-02 II
2.11e-02
1.26e-02 ||
8.15e-03
4.85C-03
3.36e-03
2.00C-03
1.40c-03
1.06e-03
Note:
Concentration
emission rate x concentration factor x 1.15 x —: x —
UW 60
-26-
-------
TABLE lla
Maximum Dimethylsulfate Concentrations
for the Conservative Unmitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration1 (ppml
DE = 99%
O.OOe-f-00
O.OOe-t-00
2.32e-05
6.49e-04
1.39e-03
1.58e-03
1.47e-03
3.27e-02
2.79e-02
2.42e-02
1.77e-02
1.37e-02
1.12e-02
9.24e-03
7.64c-03
6.66e-03
4.87e-03
3.22e-03
2.44c-03
1.46e-03
9.43e-04
5.62C-04
3.89C-04
2.31e-04
1.62e-04
1.22e-04
DE = 909,
O.OOe-rOO
O.OOe-t-00
2.32e-04
6.49e-03
1.39e-02
1.58e-02
1.47e-02
3.27e-01
2.79e-01
2.42e-01
1.77e-01
1.37C-01
1.12e-01 II
9.24e-02 II
7.64e-02 I!
6.66C-02
4.87e-02 |
3.22e-02
2.44e-02
1.46e-02
9.43C-03
5. 62e-03
3.89e-03
2.31e-03
1.62e-03
1 22e-03
^otc:
, r, - . 0.024
Concentration = emission rate x concentration factor x 1 15 x
MW
-------
TABLE lib
Maximum Dimethylsulfate Concentrations
for the Conservative Off-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
-------
TABLE lie
Maximum Dimetbylsulfate Concentrations
for the
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
140000
50000
Concentration
Factors
-------
TABLE 12a
Maximiini Dimethylhydrazine Concentrations
for the Conservative Unmitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mVtg/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration' ippm)
DE = 99%
O.OOe+00
O.OOe+00
4.46c-05
1. 25e-03
2.68e-03
3.03e-03
2.82e-03
6.29C-02
5.36e-02
4.65e-02
3.41e-02
2.64C-02
2.15e-02
1.78e-02
1.47e-02
1.28e-02
9.35e-03
6.18e-03
4.69e-03
2.80e-03
1.81e-03
l.OSe-03
7.47e-04
4.44e-04
3.10e-04
2.35e-04
DE = 90*
O.OOe+00
O.OOe+00
4.46e-04
1.25C-02
2.68e-02
3.03e-02
2.82e-02
6.29e-01
5.36e-01
4.65e-01
3.41e-01
2.64e-01
2.15e-01
1.78e-01
1.47C-01
1.28e-01
9.35e-02
6.18e-02
4.69e-02
2.80e-02
1.81e-02
l.OSe-02
7.47e-03
4.44e-03
3.10C-03
2.35e-03
Note:
Concentration = emission rate x concentration factor x 1.15 x
0.024
MW
-30-
-------
TABLE 12b
Maximum Dimethylhydrazine Concentrations
for the Conservative Off-She Fire Scenario (Subtask 1)
Downwind
Distance
-------
TABLE 12c
Maximum Dimethylhydrazine Concentrations
for the Conservative Mitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
-------
TABLE 13a
Maximum Cresol Concentrations
for the Conservative Unmitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
12250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration' (ppm)
DE = 99%
O.OOe+00
O.OOe+00
7.24e-04
2.02e-02
4.34e-02
4.91e-02
4.56e-02
1.02C+00
8.69e-01
7.54e-01
5.52e-01
4.28e-01
3.49e-01
2.88e-01
2.38e-01
2.07e-01
1.52e-01
l.OOe-01
7.61e-02
4.55e-02
2.94e-02
1.75C-02
1.21e-02
7.20C-03
5.03C-03
3.816-03
Note:
Concentration = emission rate x concentration factor x 1 15 x — '
MW r
DE = 90*
O.OOe^OO I
O.OOe-1-00 I
7.24e-03 11
2.02e-01 ||
4.34e-01 j|
4.9le-01 |
4.56e-01 [I
1.02C4-01 1
8.69e-i-00
7.54e+00
5.52e+00
4.28e-(-00
3.49c-KX) |
2.88e-t-00
2.38e+00
2.07C-I-00
1.52e+00
l.OOe+00
7.61e-01
4.55e-01
2.94e-01
1.75e-0l
1.21e-01
7.20e-02
5.03e-02
3.81e-02
-------
TABLE 13b
Maximum Cresol Concentrations
for the Conservative Off-Site Fire Scenario (Subtask 1)
Downwind
Distance
tm)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
218.08
72.278
41.282
34.118
34.857
28.975
23.247
21.615
19.16
20.693
14.095
11.294
9.602
9.11
8.585
7.888
6.39
4.437
3.547
2.156
1.445
0.886
0.708
0.563
0.463
0.39
Concentration1 (ppm)
DE = 99%
1.43e+01
4.75e+00
2.71e+00
2.24e+00
2.29e+00
1.91e+00
1.53e+00
1.42e+00
1.26e+00
1.36e-fOO
9.27e-01
7.43e-01
6.31e-01
5.99C-01
5.64c-01
5.19e-01
4.20e-01
2.92e-01
2.33e-01
1.42e-01
9.50e-02
5.83c-02
4.65e-02
3.70e-02
3.04e-02
2.56e-02
DE = 909f
1 43e+02
4.75e+01
2.71C--01
2.24e+01
2.29e+01
1.90e+01
1.53e+01
1.42e+01
1.26e+01
1.36e-f01
9.27e-i-00
7.43e-(-00
6.31e+00
5.99e-f-00
5.64e+00
5.19e-fOO
4.20e-f-00
2.92e+00
2.33e+00
1.42e-t-00
9.50e-01
5.83e-01
4.65c-01
3.70c-01
3.04e-01
2.56e-01
Note:
Concentration = emission rate x concentration factor x 1.15 x
0.024
MW
-34-
-------
TABLE 13c
Maximum Cresol Concentrations
for the Conservative Mitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
I! (m)
II 100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration1 (ppm)
DE -99%
O.OOe+00
O.OOe-t-00
1.2le-04
3.376-03
7.24e-03
8.18e-03
7.616-03
I.70e-01
1.45e-01
1.266-01
9.21e-02
7.136-02
5.826-02
4.80e-02
3. 97e-02
3.45e-02
2.53e-02
1.67e-02
1.27e-02
7.58e-03
4.89e-03
2.92e-03
2.02C-03
1.20e-03
8.39e-04
6.35e-04
DE = 909r
- O.OOe-'-OO
O.OOe+00
1.21C-03
3.37e-02
7.24C-02
8.18e-02
7.616-02
1. 70c-t-00
1.45e-t-00
1.266+00
9.216-01
7.13e-01
5.82e-01
4.806-01
3.97e-01
3.456-01
2.53e-OI
1.67e-01
1.27e-01
7.58e-02
4.896-02 I
2.92e-02
2.026-02
1.206-02
8.396-03
6.35e-03
| Note:
Concentration = emission rate x concentration factor x 1.15 x °'024 * —
1 MW 60
-------
TABLE 14a
Maximum 2-Nitropropane Concentrations
for the Conservative Unmitigated On-She Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mV(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration' (ppm)
DE = 99*
O.OOe+00
O.OOe+00
2.83e-04
7.90e-03
1.70e-02
1.92e-02
1.79e-02
3.99e-01
3.406-01
2.95C-01
2.166-01
1.676-01
1.37e-01
1.136-01
9.306-02
8.116-02
5.93e-02
3.926-02
2.986-02
1.78e-02
1. 15e-02
6.84e-03
4.74e-03
2.826-03
1.97e-03
1.49e-03
DE = 90*
O.OOe+00 |
O.OOc+00 |
2.83e-03 I
7.90e-02
1. 70e-01 |j
1.92e-01
1.79e-01
3.99e+00
3.406+00
2.95e+00
2.16e+00
1.67e+00
1.376+00
1.13e+00
9.30e-01
S.lle-Ol 1
5.936-01
3.926-01
2.986-01
1.786-01
l.lSe-01
6.846-02
4.74e-02
2.82e-02
1.97c-02
1.49e-02
Note:
„
Concentration = emission rate x concentration factor x 1.15 x
0.024
-
MW
-36-
-------
TABLE 14b
Maximum 2-Nitropropane Concentrations
for the Conservative Off-Site Fire Scenario (Subtask 1)
1 Down wind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
12250
2500
3000
4000
5000
7500
10000
15000
20000
II 30000
| 40000
[| 50000 _
Concentration
Factors
(ug/mj)/(g/s)
218.08
72.278
41.282
34.118
34.857
28.975
23.247
21.615
19.16
20.693
14.095
11.294
9.602
9.11
8.585
7.888
6.39
4.437
3.547
2.156
1.445
0.886
0.708
0.563
0.463
0.39
Concentration' (ppm)
DE = 99%
5.6le+00
1.86e+00
1.06e+00
8.77e-01
8.96e-01
7.45e-01
5.98e-01
5.56e-01
4.93e-01
5.32e-01
3.62e-01
2.90e-01
2.47e-01
2.34e-01
2.21C-01
2.03C-01
1.64e-01
1.14e-01
9.12e-02
5.54e-02
3.72e-02
2.28e-02
1.82e-02
1.45e-02
1.19e-02
l.OOe-02
Note:
Concentration = emission rate x concentration factor x 1 15 x
====__=========_ ' MVf
DE = 909,
5.61e-0l ]
-H
1.86e-r01
1.06e*0l I
8.77c*00
8.96C+00 |
7.45e+00 |
5.98e-fOO II
5.56e+00
4.93C4-00
5.32e-<-00
3.62C4-00
2.90e+00
2.47e-t-00
2.34e+00
2.21e-t-00
2.03C-I-00
1.64e-t-00 11
1.14C+00 |
9.12e-01
5.54e-01
3.72C-01
2.28e-01
1.82e-01
1.4Se-01
1.19e-01
l.OOe-01
77
-------
TABLE 14c
Maximum 2-Nitropropane Concentrations
for the Conservative Mitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Note:
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
on rate x concentration factor
Concentration1 (ppm)
DE = 99%
O.OOe+00
O.OOe+00
4.72C-05
1.32e-03
2.83e-03
3.20e-03
2.986-03
6.65e-02
5.66e-02
4.92e-02
3.60e-02
2.79e-02
2.28e-02
1.88c-02
1.55c-02
1.356-02
9.88C-03
6.53c-03
4.96e-03
2.96e-03
1.91e-03
1.14e-03
7.89e-04
4.70e-04
3.286-04
2.48e-04
xllSx °'°24 * 10
MW 60
DE = 90*
O.OOe+00
O.OOe+00
4.72e-04
1.32e-02
2.83e-02
3.20e-02
2.98e-02
6.65e-01
5.66C-01
4.92e-01
3.60e-01
2.79e-01
2.28e-01
1.88e-01
1.55e-01
1.35e-01
9.88e-02
6.53e-02
4.96e-02
2.96e-02
1.91e-02
1.14e-02
7.89e-03
4.70e-03
3.28e-03
2.48e-03
-38-
-------
TABLE 15a
Maximum Hydrazine Concentrations
for the Conservative Unmitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1 1500
1750
| 2000
I! 2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
-------
TABLE 15b
Maximum Hydrazine Concentrations
for the Conservative Off-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
218.08
72.278
41.282
34.118
34.857
28.975
23.247
21.615
19.16
20.693
14.095
11.294
9.602
9.11
8.585
7.888
6.39
4.437
3.547
2.156
1.445
0.886
0.708
0.563
0.463
0.39
Concentration1 (ppml
DE = 99%
1.86e-t-00
6.16e-01
3.52e-01
2.91C-01
2.97e-01
2.47e-01
1.98c-01
1.84e-01
1.63e-01
I.76e-01
1.20e-01
9.63e-02
8.19e-02
7.77e-02
7.32e-02
6.72c-02
5.45e-02
3.78e-02
3.02e-02
1.84c-02
1.23e-02
7.55e-03
6.04e-03
4.80c-03
3.95e-03
3.32e-03
DE = 90*
1.86et-01
6.16e-t-00
3.52e+00
2.91e*00
2.97e-i-00
2.47e+00
1.98e+00
1.84e+00
1.63e-t-00
1.76e+00
1.20e+00
9.63e-01
8.19C-01
7.77e-01
7.32C-01
6.72e-01
5.45e-01
3.78e-01
3.02c-01
1.84e-01
1.23e-01
7.55e-02
6.04e-02
4.80e-02
3.95e-02
3.32e-02
Note:
Concentration = emission rate x concentration factor x 1.15 x
0.024
MW
-40-
-------
TABLE 15c ||
Maximum Hydrazine Concentrations
for the Conservative Mitigated On-Site Fire Scenario (Subtask 1) ||
Downwind
Distance
I (m)
11 10°
200
300
400
500
600
700
800
900
11000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mV(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.7%
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration' tppm)
DE~99%
O.OOe-i-00
O.OOe-t-00
1.56e-05
4.37e-04
9.38e-04
1.06c-03
9.86e-04
2.20e-02
1.88e-02
1.63e-02
1.19e-02
9.24eX)3
7.55e-03
6.22e-03
5.14e-03
4.48c-03
3.27C-03
2.16e-03
1. 646-03
9.82e-04
6.34e-04
3.786-04
2.62e-04
1.56e-04
1.09e-04
8.23e-05
Note:
1 Concentration = emission rate x concentration factor x 1.15 x °'02* x —
1 MW 60
DE = 909r
O.OOe-rOO II
O.OOe+00
1.56e-04
4.37e-03
9.38e-03
1.06C-02
9.86e-03 I
2.20e-01
1.88e-01 I
1.63e-01
1.19e-01
9.24e-02
7.55C-02
6.22e-02
5.14C-02
4.48e-02
3.27e-02
2.16e-02
1.64e-02
9.82e-03
6.34e-03
3.78e-03
2.62e-03
1. 566-03
1.096-03
-41.
-------
TABLE 16a
Maximum Toluene Concentrations
for the Conservative Unmitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
-------
TABLE 16b
Maximum Toluene Concentrations
tor the Conservative Off-Site Fire Scenario (Subtask 1)
Downwind
Distance
-------
TABLE 16c
Maximum Toluene Concentrations
for the Conservative Mitigated On-Site Fire Scenario (Subtask 1)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.7%
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration' (ppm)
DE = 99%
O.OOc+00
O.OOe+00
1.09c-04
3.05e-03
6.55c-03
7.41C-03
6.89c-03
1.54e-01
1.31e-01
1.14e-01
8.34e-02
6.46e-02
5.27e-02
4.35e-02
3.59e-02
3.13e-02
2.29e-02
l.Slc-02
1.15e-02
6.86e-03
4.43c-03
2.64c-03
1.83e-03
1.09c-03
7.60c-04
5.75e-04
DE = 90%
O.OOe+00
O.OOe-rOO
1.09e-03
3.05e-02
6.55e-02
7.41C-02
6.89e-02
1.54e+00
1.3le+00
1.14e+00
8.34e-01
6.46e-01
5.27e-01
4.34e-01
3.59e-01
3.13c-01
2.29c-01
l.Sle-01
l.lSe-01
6.86e-02
4.43c-02
2.64C-02
1.83e-02
1.09c-02
7.60e-03
5.75e-03
Note:
1 Concentration = emission rate x concentration factor x 1.15 x — x —.
60
-44-
-------
Co
Emission Scenario
__-jJ?g!!!!!!a^ — . .
Original On-Sitc Fire
Original On-Site Fire
Expanded On-Site Fire
Fxpanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Sitc Fire
Expanded On-Sitc Fire
Expanded On-Site Fir-
Expanded On-Site Fire
Expanded On-Site Fire
Original On-Site Fire
Original On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
E ipanded On-Site Fire
mparison of the "Worst c,
^ —
Chemicals of Concern
HCI
Phosgene
To!uene4-diisocyanate
Formaldehyde
Hydrogen Fluoride
Dimethylsulfate
Dimethylhydrazine
Cresols
2-Nitropropane
Hydrazine
Toluene
HCI
Phosgene
Toluene4-diisocyanate
Formaldehyde
Hydrogen Fluoride
Dimethylsulfate
Dimethylhydrazine
use" Waste R
1 —
Emission
Scenario
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
«^E ^HS5SB5H5Z5S5S
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
TABLE
esults to the *
Meteorology
^^^^^^^^^^*TTf*
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
17
Occident Anal
Emission
Duration
======
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
ysis Results, DE = 99% (Subtask 1)
LOC
(ppm)
9.9
0.2
1.0
9.6
1.9
1
4.8
24.4
226
7.5
196
9.9
0.2
1.0
9.6
1.9
1
4.8
IDLII
(ppm)
49.1
2.0
2.5
19.6
29.4
6.9
14.8
244
98.2
49.1
491
=======
49.1
2.0
2.5
19.6
29.4
6.9
14 8
Max. Dlst. to
LOC (m)
675-1.125
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
=====
NO
NO
NO
NO
NO
NO
NO
Max. l)isl. In
IDLII (in)
NO1
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
•— 1 •. 11.11, „ [••••gB^B.
NO
NO
NO
NO
NO
NO
NO
-45-
-------
TABLE 17 (Continued)
Comparison of the "Worst case" Waste Results to the Accident Analysis Results, DE = 99% (Subtask 1)
Emission Scenario
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Original Off-Site Fire
Original Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Chemicals of Concern
Cresols
2-Nitropropane
Hydrazine
Toluene
HCI
Phosgene
Toluenc4-diisocyanate
Formaldehyde
Hydrogen Fluoride
Dimethylsulfate
Dimethylhydrazine
Cresols
2-Nitropropane
Hydrazine
Toluene
Emission
Scenario
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Meteorology
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Emission
Duration
Mitigated
Mitigated
Mitigated
Mitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
LOC
(ppm)
24.4
226
7.5
196
9.9
0.2
1.0
9.6
1.9
1
4.8
24.4
226
7.5
196
IDLII
(ppm)
244
98.2
49 1
491
49.1
2.0
2.5
19.6
29.4
6.9
14.8
244
98.2
49.1
491
Max. Disl. to
LOC (m)
NO
NO
NO
NO
2,100
1,100
NO
NO
130
NO
NO
NO
NO
NO
NO
Max. Dist. to
IDLII (m)
NO
NO
NO
NO
275
125
NO
NO
-------
TABLE 18
Comparison of the "Worst case" Waste Results to the Accident Analysis Results, DE=90% (Subtask 1)
Emission Scenario
Original On-Site Fire
Original On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Original On-Site Fire
Original On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Sitc Fire
Expanded On-Site Fire
Chemical of Concern
HCI
Phosgene
Toluene4-diisocyanate
Formaldehyde
Hydrogen Fluoride
Dimethylsulfale
Dimethylhydrazine
Cresols
2-Nitropropane
Hydrazine
Toluene
HCI
Phosgene
Toluene4-diisocyanate
Formaldehyde
Hydrogen Fluoride
Dimethylsulfate
Dimethylhydrazine
Emission
Scenario
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Meteorology
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Emission
Duration
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
LOC
(ppm)
9.9
0.2
1.0
9.6
1.9
1
4.8
24.4
226 .
7.5
196
9.9
0.2
1.0
9.6
1.9
1
4.8
IDMI
(ppm)
49.1
2.0
2.5
19.6
29.4
6.9
14.8
244
98.2
49.1
491
49.1
2.0
2.5
19.6
29.4
69
14 8
Max. Uist. to
LOC (in)
675-1,125
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
Max. Dist. to
11)1, II (m) ||
NO1
NO
NO
NO
II
NO
NO
NO
NO |
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO 1
-47-
-------
TABLE 18 (Continued)
Comparison of the "Worst case" Waste Results to the Accident Analysis Results, DE=90% (Subtask 1)
Emission Scenario
Expanded On-Site Fire
Expanded On-Sile Fire
Expanded On-Sile Fire
Expanded On-Si(e Fire
Original Off-Site Fire
Original Off-Site Fire
Expanded Off-Site Fire
Exnanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Sile fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Chemical of Concern
Cresols
2-Nitropropane
Hydrazine
Toluene
HCI
Phosgene
Toluene4-diisocyanate
Formaldehyde
Hydrogen Fluoride
Dimethylsulfate
Dimethylhydrazine
Cresols
2-Nitropropane
Hydrazine
Toluene
Emission
Scenario
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Meteorology
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Emission
Duration
Mitigated
Mitigated
Mitigated
Mitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
LOC
(ppm)
24.4
226
7.5
196
9.9
0.2
1.0
9.6
1.9
1
4.8
24.4
226
7.5
196
IDLH
244
98.2
49.1
491
49.1
2.0
2.5
19.6
29.4
6.9
14.8
244
98.2
49.1
491
Max. Disl. to
LOC (m)
NO
Nf)
NO
NO
2,100
1.100
275
315
1,125
280
170
360
NO
190
< 100
Note:
' NO = Do not occur.
Max. Disl. to
NO
NO
NO
NO
275
125
220
190
-------
TABLE 19a
Maximum Cresol Concentrations for the
Conservative Unmitigated On-Site Fire Scenario (Subtask 2)
=======
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration1 tppm)
DE = 99%
O.OOe+00
O.OOe+00
2.84e-04
7.92e-03
1.70C-02
1.92e-02
1.79c-02
4.00e-01
3.40e-01
2.96e-01
2.16e-01
1.68C-01
1.37e-01
1.13e-01
9.32e-02
8.12e-02
5.94e-02
3.93C-02
2.98C-02
1.78e-02
1.15e-02
6.86c-03
4.74e-03
2.82e-03
1.97C-03
1.49e-03
DE = 90*
O.OOe-00
O.OOe-^00
2.83e-03
7.91e-02
1.70e-01
1.92e-01
1.79e-01
3.99c+00
3.40e+00
2.95e+00
2.16e+00
1.67e+00
1.37e-i-00
1.13e+00
9.31e-01
8.12e-01
5.93e-01
3.92e-01
2.98e-01
1.78C-01
l.lSe-01
6.85e-02
4.74e-02
2.82e-02
1.97e-02
1.49e-02
Note:
0.024
Concentration = emission rate x concentration factor x 1.15 x .
MW
-------
TABLE 19b
Maximum Cresol Concentrations for the
Conservative Unmitigated Off-Site Fire Scenario (Subtask 2)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/m*)/(g/s)
218.08
72.278
41.282
34.118
34.857
28.975
23.247
21.615
19.16
20.693
14.095
11.294
9.602
9.11
8.585
7.888
6.39
4.437
3.547
2.156
1.445
0.886
0.708
0.563
0.463
0.39
Note:
1 Concentration = emission rate x concentration factor ;
Concentration' ippm)
DE = 99*
5.6U+00
1.86C+00
1.06e+00
8.770-01
8.96e-01
7.45C-01
5.98e-0l
5.56e-01
4.93C-01
5.32e-01
3.62e-01
2.90e-01
2.47C-01
2.34e-01
2.21e-01
2.03e-01
1.64e-01
1.14e-01
9.12e-02
5.54e-02
3.72e-02
2.28e-02
1.82e-02
1.45e-02
1.19e-02
l.OOe-02
, ,. 0.024
r 1 1 *» T
MW
DE = 90*
5.61e*0l
1.86e+0l
1.06e*0l
8.77e+00
8.96c+00
7.45e-t-00
5.98e-t-00
5.56e-(-00
4.93c-i-00
5.32e-nOO
3.62e-t-00
2.90c+00
2.47e+00
2.34e+00
2.21e+00
2.03e+00
1.64e-i-00
1.14e+00
9.12e-01
5.54e-01
3.72C-01
2.28e-01
1.82e-01
1.45e-01
1.19e-01
l.OOc-01
-50-
-------
TABLE 19c
Maximum Cresol Concentrations for the
Conservative Mitigated On-Site Fire Scenario (Subtask 2)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
12000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
I 50000
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.7%
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration' (ppm)
DE = 99%
O.OOe+00
O.OOe+00
4.73e-05
1.32e-03
2.84e-03
3.20C-03
2.98e-03
6.66e-02
5.67e-02
4.93e-02
3.61e-02
2.79e-02
2.28e-02
1.88e-02
1.55e-02
1.35e-02
9.90e-03
6.55e-03
4.97e-03
2.97e-03
1.92e-03
1.14e-03
7.91e-04
4.70e-04
3.29e-04
2.49e-04
Note:
Concentration = emission rate x concentration factor x 1.15 x 9'024 * —
MW 60
DE = 90*
O.OOe-00
O.OOe-t-00
4.72e-04
1.32e-02
2.83e-02
3.20e-02
2.98e-02
6.65e-0l
5.67e-0l
4.92e-0l II
3.60e-0l
2.79e-01
2.28e-0l
1.88e-01
1.55e-01
1.35e-01
9.89e-02
6.54e-02
4.97e-02
2.97C-02
1.92C-02
1.14e-02
7.90e-03
4.70e-03
3.28e-03
2.49e-03
-------
TABLE 20a
Maximum Toluene Concentrations for the
Conservative Unmitigated On-Siie Fire Scenario (Subtask 2)
Downwind
Distance
-------
TABLE 20b
Maximum Toluene Concentrations for the
Conservative Unmitigated Off-Site Fire Scenario (Subtask 2)
1 Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
11750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
218.08
72.278
41.282
34.118
34.857
28.975
23.247
21.615
19.16
20.693
14.095
11.294
9.602
9.11
8.585
7.888
6.39
4.437
3.547
2.156
1.445
0.886
0.708
0.563
0.463
0.39
Note:
Concentration = emission rate x cnnrcnrmrinn f..™/-..- *
Concentration1 (ppm)
DE = 99%
S.OSe+OO
1.68e+00
9.62e-01
7.95e-01
8.12e-01
6.75e-01
5.42e-01
5.04e-01
4.46e-01
4.82e-01
3.28e-01
2.63e-01
2.24e-01
2.12e-01
2-OOe-Ol
1.84e-01
1.49e-01
1.03e-01
8.26e-02
5.02e-02
3.37e-02
2.06e-02
1.65e-02
1.31e-02
1.08e-02
9.09c-03
aBSSaaaBSSBSEOaa^^^
, ,. 0.024
DE = 90?r
5.08e-^01
1.68e-t-0l
9.62e-fOO
7.95e+00
8.12et-00
6.75e+00
5.42e-t-00
5.04e-t-00
4.46C-I-00
4.82e-(-00
3.28C-I-00
2.63e-t-00
2.24e+00
2.12e+00
2.00e+00
1.84e-fOO
1.49e-t-00
1.03e-i-00
8.26e-01
5.02C-01
3.37e-01
2.06e-01
1.65e-01
1.31e-01
1.08e-01
9.09C-02
=E=3S=[=«====:^==B__
-------
TABLE 20c
Maximum Toluene Concentrations for the
Conservative Mitigated On-Site Fire Scenario (Subtask 2)
Downwind
Distance
(ml
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.7%
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration1 ippra)
DE = 99%
O.OOe+00
O.OOe+00
4.28e-05
1.20e-03
2.57e-03
2.90e-03
2.70e-03
6.03C-02
5.14e-02
4.46e-02
3.27e-02
2.53e-02
2.07c-02
1.70e-02
1.41e-02
1.23e-02
8.96c-03
5.93e-03
4.50e-03
2.69e-03
1.74e-03
1.03e-03
7.16e-04
4.26C-04
2.98e-04
2.25e-04
DE = 90<7r
O.OOe+00
O.OOe^OO
4.28e-04
1.20e-02
2.57e-02
2.90e-Q2
2.70e-02
6.03e-01
5.14C-01
4.46c-01
3.27e-01
2.53e-01
2.07e-01
1.70e-01
1.41e-01
1.23e-01
8.96e-02
5.93e-02
4.50e-02
2.69e-02
1.74C-02
1.03e-02
7.16e-03
4.26e-03
2.98e-03
2.25e-03
Note:
Concentration = emission rate x concentration factor x 1.15 x
'
iŁ
60
-54-
-------
TABLE 21a
Maximum Methyl Ethyl Ketone Concentrations for the
Conservative Unmitigated On-Site Fire Scenario (Subtask 2)
Downwim
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/m3)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
- 4733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration1 ippm)
DE = 99%
O.OOe+00
O.OOe-i-00
2.88e-04
8.05e-03
1.73e-02
1.95c-02
1.82e-02
4.06e-01
3.46e-01
3.00e-01
2.20e-01
1.70e-01
1.39e-01
l.lSe-01
9.47e-02
8.25e-02
6.03e-02
3.99e-02
3.03e-02
1.81e-02
1.17e-02
6.96e-03
4.82e-03
2.87e-03
2.00e-03
1.52e-03
DE = 90
-------
TABLE 21b
Maximum Methyl Ethyl Ketone Concentrations for the
Conservative Unmitigated Off-Site Fire Scenario (Subtask 2)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Note:
Concentration
Factors
(ug/m')/(g/s)
218.08
72.278
41.282
34.118
34.857
28.975
23.247
21.615
19.16
20.693
14.095
11.294
9.602
9.11
8.585
7.888
6.39
4.437
3.547
2.156
1.445
0.886
0.708
0.563
0.463
0.39
on rate x concentration factor
Concentration' (ppm)
DE = 99%
5.70e-fOO
1.89e+00
l.OSe+00
8.92C-01
9.11e-01
7.57e-01
6.07e-01
5.65e-01
S.Ole-01
5.41C-01
3.68e-01
2.95e-01
2.51C-01
2.38e-01
2.24e-01
2.06e-01
1.67e-01
1.16e-01
9.27e-02
5.63e-02
3.78e-02
2.32e-02
1.85C-02
1.47C-02
1.21e-02
1.02e-02
i ,< °'024
MW
DE = 907r
5.70e+01
1.89e-t-01
1.08e*01
8.92e+00
9.11e+00
7.57e+00
6.07e-t-00
5.65e+00
5.01e-t-00
5.41e-fOO
3.68e+00
2.95e-t-00
2.51e+00
2.38e+00
2.24e+00
2.06e+00
1.67e-i-00
1.16e-t-00
9.27e-01
5.63e-01
3.78C-01
2.32e-01
l.SSe-Ol
1.47e-01
1.21e-01
1.02e-01
-56-
-------
Maxi
Consei
.
Downwind
Distance
(m)
=======
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
TABL
mum Methyl Ethyl Ke
rvative Mitigated On-S
Concentration
Factors
(ug/mj)/(g/s)
===s=sssj —
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
E21c
tone Concentrations for the
ite Fire Scenario (Subtask 2)
Concentration' ippm)
DE = 99%
O.OOe+00
O.OOe+00
4.80e-05
1.34e-03
2.88e-03
3.26e-03
3.03e-03
6.76e-02
5.76e-02
S.Olc-02
3.66c-02
2.84e-02
2.32e-02
1.91C-02
1.58c-02
1.38e-02
l.Ole-02
6.65e-03
5.05e-03
3.02e-03
1.95e-03
l.loe-03
8.03e-04
4.78e-04
3.34C-04
2.53C-04
DE = 909f
O.OOe-i-00
O.OOei-00
4.80e-04
1.34c-02
2.88c-02
3.26c-02
3.03c-02
6.76e-01
5.76e-01
S.Ole-01
3.66e-01
2.84e-01
2.32e-01
1.91c-01
1.58e-01
1.38e-01
l.Olc-01
6.65e-02
5.05C-02
3.02c-02
1.95C-02
l.loc-02
8.03e-03
4.78e-03
3.34e-03
2.53C-03
Note:
Concentration
. , . .,. 0.024 10
emission rate x concentration factor x 1.15 x x
UW
60
-------
TABLE 22a
Maximum Methanol Concentrations for the
Conservative Unmitigated On-Site Fire Scenario (Subtask 2)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
.15000
20000
30000
40000
50000
Concentration
Factors
-------
TABLE 22b
Maximum Methanol Concentrations for the
Conservative Unmitigated Off-Site Fire Scenario (Subtask 2)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/m^/Cg/s)
218.08
72.278
41.282
34.118
34.857
28.975
23.247
21.615
19.16
20.693
14.095
11.294
9.602
9.11
8.585
7.888
6.39
4437
3.547
2.156
1 445
0.886
0708
0.563
0463
039
Concentration1 (ppm)
DE = 99%
l.lle-t-01
3.69e+00
2.11C+00
1.74e+00
1.78e-i-00
1.48e+00
1.19e+00
1.10e+00
9.78e-01
1.06e+00
7.20e-01
5.77e-01
4.90e-01
4.65e-01
4.38e-01
4.03C-01
3.26e-01
2.27e-01
l.Sle-01
l.lOc-01
7.38e-02
4.52e-02
3.62C-02
2.87C-02
2.36e-02
1.99C-02
DE = 90
-------
TABLE 22c
Maximum Methanol Concentrations for the
Conservative Mitigated On-Site Fire Scenario (Subtask 2)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Note:
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
ion rate x concentration factor
Concentration' ippml
DE = 99%
O.OOe-t-00
O.OOe+00
9.39e-05
2.62e-03
5.63e-03
6.37e-03
5.92e-03
1.32e-01
1.13e-01
9.79e-02
7.17C-02
5.55e-02
4.53e-02
3.73e-02
3.09e-02
2.69e-02
1.97C-02
1.30e-02
9.87e-03
5.90e-03
3.81e-03
2.27e-03
1.57e-03
9.34e-04
6.53e-O4
4.94e-04
, ,. 0.024 10
XI 1 ^ T ,.__.. ... T
MW 60
DE = 90^
O.OOe^OO
O.OOe-^00
9.39e-04
2.62e-02
5.63e-02
6.37e-02
5.92e-02
1.32e+00
1.13e-fOO
9.79e-01
7.17e-01
5.55e-01
4.53e-01
3.73e-01
3.09e-01
2.69e-01
1.97e-01
1.30e-01
9.87e-02
5.90e-02
3.81e-02
2.27e-02
1.57e-02
9.34e-03
6.53e-03
4.94e-03
-60-
-------
TABLE 23a
Maximum Acetone Concentrations for the
Conservative Unmitigated On-Site Fire Scenario (Subtask 2)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mVtg/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1.088
0.753
0.448
0.313
0.237
Concentration1 tppm)
DE = 99%
O.OOe+00
O.OOe+00
2.94C-04
8.20e-03
1.76e-02
1.99e-02
1.85e-02
4.14e-01
3.53e-01
3.06e-01
2.24e-01
1.74e-01
1.42e-01
1.17e-01
9.66e-02
8.41C-02
6.15e-02
4.07e-02
3.09e-02
1.85e-02
1.19e-02
7.10e-03
4.91e-03
2.92e-03
2.04e-03
1.55e-03
DE = 909r
O.OOe+00
0.00e*00
2.94e-03
8.20e-02
1.76e-01
1.99e-01
1.85e-01
4.14e+00 J
3.53e+00
3.06c+00
2.24e+00
1.74e+00 I!
1.42e+00
1.17e+00 11
9.66e-OI
8.41e-01 11
6.15c-01
4.07e-01
3.09C-01
1.85e-01
1.19e-01
7.10e-02
4.91C-02
2.92e-02
2.04e-02
1.55e-02
Note:
1 Concentration = emission rate x concentration factor x \ 15 x —
MW
-------
TABLE 23b
Maximum Acetone Concentrations for the
Conservative Unmitigated Off-Site Fire Scenario (Subtask 2)
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Note:
Concentration
Factors
(ug/m3)/(g/s)
218.08
72.278
41.282
34.118
34.857
28.975
23.247
21.615
19.16
20.693
14.095
11.294
9.602
9.11
8.585
7.888
6.39
4.437
3.547
2.156
1 445
0.886
0.708
0.563
0.463
0.39
on rate x concentration factor
Concentration' (ppm)
DE = 99%
S.Sle-i-OO
1.93e-t-00
1.10e+00
9.09e-01
9.29e-01
7.72c-01
6.20e-01
5.76e-01
S.lle-Ol
S.Sle-Ol
3.76e-01
3.01e-01
2.56c-01
2.43e-01
2.29e-01
2-lOe-Ol
1.70e-01
l.lSe-01
9.45c-02
5.75e-02
3.85e-02
2.36c-02
1.89c-02
l.SOc-02
1.23C-02
1.04e-02
, ,c °-024
MW
DE = 909,
5.81e-r01
1.93e + 01
l.lOe+01
9.09e-t-00
9.29e+00
7.72e-i-00
6.20e-t-00
5.76e+00
5.11e-t-00
5.51e+00
3.76e+00
3.01e+00
2.56e+00
2.43e+00
2.29e+00
2.10e-HOO
1.70e+00
1.18e+00
9.45e-0l
5.75C-01
3.85e-0l
2.36e-01
1.89c-01
l.SOc-01
1.23C-01
1.04e-01
-------
TABLE 23c
Maximum Acetone Concentrations for the
Conservative Mitigated On-Site Fire Scenario (Subtask 2)
Downwind
Distance
(Rl)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
2250
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration
Factors
(ug/mj)/(g/s)
0
0
0.045
1.257
2.7
3.052
2.839
63.414
54.02
46.921
34.352
26.604
21.724
17.9
14.796
12.892
9.424
6.233
4.733
2.827
1.826
1 088
0.753
0.448
0.313
0.237
Note:
Concentration = emission rate x concentration factor
Concentration1 (ppm)
DE = 99%
O.OOe-i-00
O.OOe+00
4.90C-05
1.37e-03
2.94e-03
3.32C-03
3.096-03
6.90e-02
5.88e-02
5.10C-02
3.74e-02
2.89e-02
2.36e-02
1.95e-02
1.61e-02
1.40e-02
1. 03e-02
6.78e-03
5.15e-03
3.08e-03
1. 996-03
1.18e-03
8.19e-04
4.87e-04
3.41e-04
2.58e-04
U 15 x °'024 , 10
MW 60
DE = 90^
O.OOe-00
O.OOe+00
4.90e-04
1.37e-02
2.94e-02
3.32e-02
3.09e-02
6.90C-01
5.88e-01
S.lOe-01
3.746-01
2.89e-0l
2.366-01
1.95e-01
1.61e-01
1.40e-01
1.03e-01
6.78e-02
5.156-02
3.08C-02
1.996-02
1.18e-02
8.19e-03
4.87e-03
3.406-03
2.58e-03
-------
TABLE 24
Comparison of the "Typical" Waste Results to the Accident Analysis Results, DE = 99% (Subtask 2)
Emission Scenario
Original On-Site Fire
Original On-Site Fire
Expanded On-Site Fire
Expanded On-Sile Fire
Expanded On-Sile Fire
Expanded On-Site Fire
Expanded On-Sile Tire
Original On-Site Fire
Original On-Site Fire
Expanded On-Site Fire
Expanded On-Sile Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Original Off-Site Fire
Original Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fjre
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Chemical of Concern
HCI
Phosgene
2-Cresol
Toluene
Methyl Ethyl Kelone
Methanol
Acetone
HCI
Phosgene
2-Cresol
Toluene
Methyl Ethyl Ketone
Methanol
Acetone
HCI
Phosgene
2-Cresol
Toluene
Methyl Ethyl Ketone
Methanol
Acetone
Emission
Scenario
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Meteorology
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Emission
Duration
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
UnmiligiileJ
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
LOC
(ppm)
9.9
0.2
24.4
196
299
2,487
1 ,960
9.9
0.2
24.4
196
299
2,487
1,960
9.9
0.2
24.4
196
299
2.487
1,960
IDLII
(ppm)
49.1
2.0
244
491
2,994
5,987
2,442
49.1
2.0
244
491
2,994
5,987
2.442
49.1
2.0
244
491
2,994
5.987
2,442
Max. Uist. to
LOC (m)
675-1,125
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
2,100
1,100
NO
NO
NO
NO
NO
Max. Dist.
In IDI II
(m)
NO1
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
275
125
NO
NO
NO
NO
NO
Note:
1 NO = Do not occur
-64-
-------
TABLE 25
Comparison of the "Typical" Waste Results to the Accident Analysis Results, DE=90% (Subtask 2)
Emission Scenario
Original On-Sitc Fire
Original On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
I'.xpandud On-Sile I'irc
Expanded On-Site Fire
Expanded On-Silu Fire
Original On-Sile Tire
Original On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Expanded On-Site Fire
Original Off-Site Fire
Original Off-Siie Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Expanded Off-Site Fire
Chemical of Concern
HCI
Phosgene
2-Cresol
Toluene
Methyl Ethyl Kelonc
Melhanol
Acetone
MCI
Phosgene
2-Cresol
Toluene
Methyl Ethyl Ketone
Methanol
Acetone
HCI
Phosgene
2-Cresol
Toluene
Methyl Ethyl Ketone
Methanol
Acetone
Emission
Scenario
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Meteorology
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Conservative
Emission
Duration
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
Mitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
Unmitigated
LOC
(ppm)
9.9
0.2
24.4
196
299
2,487
1 ,960
9.9
0.2
24.4
1%
299
2,487
1,960
9.9
0.2
24.4
196
299
2,487
1.960
IDIJI
(ppm)
49.1
2.0
244
491
2,994
5,987
2,442
4') 1
2.0
244
491
2,994
5,987
2.442
49.1
2.0
244
491
2.994
5,987
2,442
Max. Dist. to
LOC (m)
675 1,125
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
2,100
1,100
185
NO
NO
NO
NO
Max. Dist. to
IDLH (m) |l
NO1 |
NO
11
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
275
125
NO
NO
NO
NO
NO
Note:
' NO = Do not occur
JQ99C WPM373 I WPD
-65-
-------
ATTACHMENT H-2
U.S. EPA Memorandum Dated July 15,1996: Calculation of Potential Increased Emissions
at WTI due to Process Upsets
Volume VIII
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 West Jackson Boulevard
Chicago Illinois 60604
DATE: July 15, 1996
SUBJECT: Calculation of Potential Increased Emissions at WTI due
to Process Upsets.
FROM: Gary Victorine, Engineer
TO: WTI Risk Assessment File
A) Information submitted by WTI1 for April 1, 1995 through
March 30, 1996:
-THC > 2 ppm for 14,702 minutes
-THC > 10 ppm for 3,605 minutes
-THC > 20 ppm for 1,648 minutes
-THC >100 ppm for 39 minutes (per excess emissions
reports of 1/95 - 3/96)
-Total minutes in analyzed year = 527,040 minutes
B) Assumptions used in this analysis:
1) For the amount of time the THC emission concentration
was reported as >2 ppm but <10 ppm, we assumed an
average emission concentration of 5 ppm (i.e., half of
the 10 ppm value).
2) For the amount of time the THC emission concentration
was reported as >10 ppm but <20 ppm, we assumed an
'All values of THC and other information are per May 20,
1996, letter from Bill Bailey of WTI to Gary Victorine, except
for amount of time above the compliance level of 100 ppm, which
is from excess emission reports submitted by WTI, received
April 19, 1996
-------
-2-
average emission concentration of 15 ppm (i.e., half
way between the values).
For the amount of time the THC emission concentration
was reported as being >20 ppm but <100 ppm, we assumed
an average emission concentration of 50 ppm.
For the amount of time the THC emission concentration
was reported as being >100 ppm, we assumed a value of
120 ppm, based on review of excess emission reports.
C) Calculations:
1) In order to convert recorded time of 14,702 minutes at
greater that 2 ppm into total time in the range of 2
ppm to 10 ppm, subtract all recorded time above 10 ppm
from the 14,702 minutes. Therefore, this would be
14,702 - 3605 = 11,097 minutes in the range 2 ppm < THC
< 10 ppm.
2) In order to convert recorded time of 3,605 minutes at
greater that 10 ppm into total time in the range of 10
ppm to 20 ppm, subtract all recorded time above 20 ppm
from the 3,605 minutes. Therefore, this would be
3605 - 1,648 = 1,957 minutes in the range 10 ppm < THC
< 20 ppm.
3) In order to convert recorded time of 1,648 minutes at
greater that 20 ppm into total time in the range of 20
ppm to 100 ppm, subtract all recorded time above 100
ppm from the 1,648 minutes. Therefore, this would be
1,648 - 39 = 1,609 minutes in the range 20 ppm < THC <
100 ppm.
4) Normal THC readings assumed in the risk assessment
would be roughly 1 ppm. For the amount of time that
the incinerator were emitting, say, 5 ppm, nondioxin
PIC emissions was assumed to be five times that of
baseline emissions assumed in the risk assessment.
5) In order to properly weight time and concentration,
this analysis first multiplied "THC-concentration" by
"time" (i.e., [THC-concentra'tion] X [time]). In these
calculations, this yielded values which have the units
"ppm-minutes". These were then summed, and the sum
compared to the baseline case of [1 ppm] X [527,040
minutes] = 527,040 ppm-minutes.
-------
-3-
6) Using the midrange assumptions and calculations listed
above:
120 ppm X 39 minutes = 4,680 ppm-minutes
50 ppm X 1,609 minutes = 80,450 ppm-minutes
15 ppm X 1,957 minutes = 29,355 ppm-minutes
5 ppm X 11,097 minutes = 55,484 ppm-minutes
1 ppm X (527,040 - 14,702) = 512,338 ppm-minutes2
7) Grand total of above values = 682,308 ppm-minutes
8) Comparison to baseline case:
(682,308 ppm-minutes)/(527,040 ppm-minutes) = 1.30
Therefore, recorded THC values for the analyzed year
are calculated to be 130% of the annual THC value
assumed in the baseline case.
D) Conclusion, and Additional Discussion
1) Recorded THC values were found to be 130% of baseline
case for the year of data that was analyzed, which
implies that nondioxin PIC emissions could be 30%
greater than assumed in the baseline case of the risk
assessment.
2) Effect on emission of PCDDs/PCDFs:
While higher THC values might be directly related to
higher emissions of nondioxin PICs, it is not believed
that higher THC values would relate to higher emissions
of PCDDs/PCDFs. This is for the following reasons:
2This represents the remainder of the time, i.e., the amount
of time at 1 ppm or below. This analysis is additionally
conservative because it assumes operation and 1 ppm THC emissions
at all times, not taking into account normal downtime or the fact
that normal emissions may actually be well under 1 ppm. Normal
downtime would be at least 15%.
-------
-4-
a) THC and nondioxin PICs are formed in the
combustion zone from the incomplete combustion of
the organic wastes fed into the incinerator. On
the other hand, PCDDs/PCDFs are generally3 formed
well after the combustion zone, from the
reformation of organic PICs allowed to remain in
contact with particulate ash in the gas stream.
The rate of this post-combustion formation is most
strongly related to temperature in certain
portions of the pollution control system, and
present research has not demonstrated a strong
relationship of PCDDs/PCDFs to the amount of
organic PICs in the combustion gas stream.
Therefore, emissions of PCDDs/PCDFs are not
believed to vary to any great degree as the THC
emissions vary.
b) At the WTI incinerator, much more stack testing
has been conducted for PCDDs/PCDFs than for
nondioxin PICs, and the typical PCDDs/PCDFs
emissions from this plant are therefore considered
to be far better characterized. At the time of
this writing, 40 tests have been conducted, each
being 4 hours long. It is believed that any
short-term variability has been taken into account
by the many hours of testing conducted. In
addition, the average emission rate of the highest
set of test runs was used in the risk assessment,
to ensure a conservative assessment.
Relating carbon monoxide exceedances to increased
emissions of nondioxin PICs:
As an additional analysis, the recorded carbon monoxide
exceedances the same year (from April 1, 1995, to March
30, 1996) were analyzed. The number of minutes when
the CO value was above the compliance limit of 100 ppm
was totaled, and found to be 4,005 minutes, or 0.76% of
the year. In order to relate these excedances to THC,
the operator of the plant provided computer generated
'Although results of some research has indicated that
PCDDs/PCDFs can be formed in the higher temperature (1000+°F)
sections of an incinerator train if high concentrations of
chlorinated phenols are present in the gas stream as PICs, it is
not believed that high concentrations of these compounds would
frequently be present in the WTI combustion gas.
-------
-5-
plots of THC emissions against CO emissions for all CO
exceedances for an arbitrary month in 1996.
The plots show that because each CO exceedance results
in an automatic cessation of hazardous waste fed to the
incinerator (as required in the RCRA permit), the
exceedances are generally short lived. The plots also
show that while these CO exceedances are occurring, the
THC emissions commonly rises to a value of 1-5 ppm
simultaneously with or shortly after the CO value goes
over 100 ppm. Typically, the THC then quickly falls
back to baseline before the CO comes back down to 100
ppm.
We conservatively assumed that the THC was 4 ppm
anytime the CO was recorded as exceeding the 100 ppm
limit, implying that the THC emissions would be four
times normal (where normal is again assumed to be 1
ppm) for 0.76% of the time. Relating these THC
emissions to emissions of nondioxin PICs, as was done
in the earlier analysis, this implied that the CO
exceedances related to a four-fold increase in
nondioxin PICs for 0.76% of the time, or a 3% overall
increase over baseline.
This analysis predicted a smaller increase than the
previous analysis presented above, but they look at two
different situations. The 3% value addressed potential
increased emissions of PICs due to regulatory
exceedances of the CO limit, whereas the 30% value
addressed all perturbations, whether or not a
regulatory limit was exceeded. Either of these can be
useful in the conduct of the risk assessment. For the
purposes of this risk assessment, it was decided to use
the more conservative 30% potential increase.
Because the emissions of nondioxin PICs accounts for a
relatively small portion of the overall risk, the 30%
increase would not make a significant difference in the
result of the risk assessment. A reference to this analysis
had been included in the uncertainty analysis of Volume V of
the Risk Assessment
-------
ATTACHMENT H-3
Plots of SO2 Emission Rate vs. Sulfur Feed Rate for WTI
Volume VIII
-------
jy
75
Ł
c
g
'w
0)
Ł
HI
100 200 300 400
Feed Rate, Ib/hr
500
600
VOO
-------
Control Efficiency
CD
(O
00
b
—T—
(O
00
en
—r-
(O
(D
(D
0)
••••
(D
O
O
O
O
O)
O
o
o
en
o
o
o>
o
o
o
o
-------
ATTACHMENT IH-1
Inhalation Cancer Risks and Hazard Quotients
Volume VIII
-------
WTI Risk Assessment: Inhalation Cancer Risks and Hazard Quotients
The highest impact area for vapor concentration was Subarea El (3 km quadrant directly east of
incinerator). This was the quadrant with Average Vapor Dispersion of 0.29 ug/m3 -g/sec and
Maximum Vapor Dispersion of 0.91 ug/m3-g/sec.
For the Average Vapor case, the cumulative cancer risks and HQs for all chemicals were the
following:
RECEPTOR
Adult
Child
School Child
Farmer
CANCER RISK
3.2E-8
7.9E-8
4.8E-8
7 1E-8
HAZARD QUOTIENT
0.012
0.046
0.028
0.012
For the Maximum Vapor case, the cumulative cancer risks and HQs for all chemicals were the
following:
RECEPTOR
Adult
Child
School Child
Farmer
CANCER RISK
l.OE-7
2.5E-7
1.5E-7
2.2E-7
HAZARD QUOTIENT
0.039
0.14
0.087
0.039
Based on the above, the Maximum Vapor Dispersion would need to increase by a factor of 4.0 in
order to increase the Child Cancer Risk to 1E-6. Such an increase would raise the cancer risk to
the low end of the threshold for cancer risk concern from a single source. An increase of 4.0
would raise the HQ for the Child to 0.56; this level is still below the threshold for concern over
adverse health effects. An increase by a factor of 8.0 would raise the HQ to >1 and the Cancer
Risk to 2E-6. This would raise the HQ above the threshold for an adverse health concern.
Therefore, an increase in Maximum Vapor Dispersion by a factor of about 8.0 would appear
to be the critical value.
-------
ATTACHMENT ffl-2
CALPUFF Modeling Results of Accidental Fire During Calm Wind Conditions
Volume VIII
-------
CALPUFF MODELING RESULTS
OF ACCIDENTAL FIRE DURING
CALM WIND CONDITIONS
WASTE TECHNOLOGIES INDUSTRIES
EPA ID NO. OHD980613541
TASK
Submitted to:
Ms. Pani Blakley
Work Assignment Manager
US Environmental Protection Agency
Regions
77 West Jackson Boulevard
Chicago, Illinois 60604
Submitted by:
A.T. Kearney, Inc.
222 West Adams Street
Chicago, Illinois 60606
and
ENVIRON International Corporation
4350 North Fairfax Drive
Arlington, Virginia 22203
Work Assignment No. : R05001
Contract No. : 68-W4-0006
Kearney WAM : Ann Anderson
Telephone No. : 312/223-6230
EPA WAM : Ms. Pam Blakley
Telephone No. : 312/886-4447
August 29, 1996
-------
I. CALPUFF MODELING OF ACCIDENTAL FIRES
DURING CALM WIND SCENARIOS
A. Introduction
In previous accidental release modeling of the WTI facility, the SLAB model was used
to evaluate the impacts of vapor emissions from non-buoyant release scenarios The ISC-
COMPDEP model was used to simulate the effects of on-site and off-site accidental fire
scenarios during non-calm wind conditions. Neither model, however, is suitable for
evaluating the fire scenarios during calm wind conditions, because SLAB does not include a
buoyant plume rise algorithm and ISC-COMPDEP's steady-state plume formulation has an
inverse wind speed dependency that breaks down under calm wind conditions
In response to comments of the Peer Review Panel, the CALPUFF model (Scire et al.,
199S) has been used to simulate calm wind impacts of vapor emissions from the on-site and
off-site fire scenarios identified in Volume VH of the WTI Risk Assessment. The CALPUFF
model is appropriate for this type of analysis for the following reasons:
CALPUFF is a non-steady-state puff model that is well-suited for low wind
speed and calm wind conditions. Calm wind dispersion and "build-up" of
pollutants during calm wind periods are simulated by the model.
CALPUFF contains buoyant plume rise calculations appropriate for simulating
buoyant plumes such as those from fires.
The model contains algorithms accounting for the aerodynamic effects of
buildings and other structures on plume dispersion, which is important for the
on-site fire scenario involving a fire in the Organic Waste Tank Farm.
1-1
-------
CALPUFF contains complex terrain algorithms allowing for the impact of the
fire emissions to be evaluated at receptors above as well as below the source
release height.
CALPUFF can simulate time-varying emissions over short time periods such as
those involved in the fire scenarios.
B. Modeling Methodology
Dispersion modeling with CALPUFF was performed for three emission durations for
the on-site fire and two emission durations for the off-site fire. In all of the simulations, the
fire was assumed to occur during calm wind conditions. Following a one hour calm, a variety
of wind speeds and stability conditions were assumed to persist until the plume was
transported completely across the field of receptors.
1. Source Configuration
Two source scenarios were modeled. The first scenario involved an on-site
release resulting from a rupture of a storage tank in the Organic Waste Tank Farm It
was assumed the rupture resulted in a spill of approximately 180 square meters, which
then ignited. The second (off-site) scenario involved a truck accident on a road
segment near the corner of Pennsylvania Avenue and Virginia Street in East Liverpool,
Ohio. This location is northeast of the WTI facility. It was assumed a spill occurred
covering an area of approximately 735 square meters that was then ignited. Table I
contains a listing of the source parameters used in the modeling.
A total of five different release tunes were simulated for the fire scenarios (167
s, 600 s, and 7030 s for the on-site fire and 167 s and 432 s for the off-site fire).
Constant emission rates and buoyancy parameters were assumed during the duration of
the fires, and zero emissions were assumed afterwards. The pollutant release height
was taken as the flame height, and the sources were modeled as buoyant point sources.
1-2
-------
Table I
Source Parameters Used in CALPUFF Modeling
Case
1
2
3
4
5
Source
Off-site unmiti-
gated small fire
Off-site unmiti-
gated large fire
On-site unmiti-
gated small fire
On-site mitigated
large fire
On-site unmiti-
gated large fire
Duration
(sec)
167
432
167
600
7030
Spill Area
(m2)
37.9
735
75.7
180
180
Spill
Diameter (m)
6.95
30.59
9.82
15.14
15.14
Fire
Temp. (K)
942
942
942
942
942
Flame
Ht. (m)
12.4
34.8
15.8
21.3
21.3
Buoyancy Flux
(mVs5)
14.9
290
29.8
70.9
70.9
Vertical Vel.
(mis)
0 183
0.183
0 183
0.183
0.183
Base lit.
(m)
2164
2164
212 1
212 1
212 1
Amb.
Temp. (K)
293
2l>3
293
293
293
' A unit emission rate (1 g/s) was used for modeling purposes. Resulting concentrations may be scaled from these results by
multiplying the predicted pollutant concentrations by the actual emission rates.
1-3
-------
In the case of the on-site release, it was assumed that aerodynamic effects resulted
from a structure 17.37 m (57 ft) high and 18.23 m (60 ft) wide Consideration of
aerodynamic downwash effects from a buoyant source is conservative because it results
in lower plume rise and higher near-field impacts.
CALPUFF was run with a basic time step of 10 seconds (s), so the emission
times shown in Table I were rounded in the model to the nearest 10 s For example.
the off-site fire of 167 s and 432 s were modeled as 170 s and 430 s releases,
respectively.
2. Receptors
A worst-case receptor grid was used in the calm wind simulations A line of
26 receptors were placed from 100 m to 50 km from each of the fires. The maximum
terrain height within a 360° ring from the receptor distance to the next farther receptor
ring was assigned to the inner receptor. Thus, high terrain elevations were always
modeled at or closer to the actual distance of the source to the terrain peaks. Terrain
elevations were derived from data available from the United States Geological Survey
(USGS). The terrain elevations used for the on-site fire were derived from the radial
receptor grid centered on the main WTI incinerator stack. The receptor elevations
used for the off-site fire were centered at the UTM coordinates of the assumed truck
accident. Table n shows the receptor locations and terrain elevations for each fire
scenario.
3. Meteorological Conditions
A combination of calm winds and SCREENS screening meteorological
conditions were employed in the CALPUFF simulations. Calm (zero wind speed)
conditions were assumed from the beginning of the emission release to one hour. This
was followed.
1-4
-------
TABLE II
Receptor Distances and Terrain Elevations
Downwind
Distance (m)
100
200.
300.
400.
500.
600.
700.
800.
900.
1,000.
1,250.
1,500.
1,750.
2,000.
2,250
2,500.
3,000.
4,000.
5,000.
7,500.
10,000.
15,000.
20,000.
30,000.
40,000.
50,000.
Receptor Elevation (m)
On-Site Fire
213.4
225.6
231.6
231.6
268.2
304.8
323.1
353.6
353.6
353.6
359.7
365.8
365.8
371.9
384.0
384.0
408.4
420.6
415.4
408.4
426.7
420.0
420.0
420.0
420.0
420.0
Receptor Elevation (m)
Off-Site Fire
292.6
304.8
328.0
347.5
359.7
359.7
356.6
359.7
359.7
371.9
384.0
396.2
396.2
396.2
371.9 •
408.4
408.4
420.6
415.4
408.4
426.7
420.0
420.0
420.0
420.0
420.0
1-5
-------
by a wind speed and stability class condition that persisted until the plume passed by
the most distant receptor. Emission releases were modeled under stability classes B.
C, D, E and F. Stability classes for non-calm hours of dispersion modeling were
conservatively assumed to change by no more than one stability class from the calm
hour toward a more unstable stability class (i.e.., B to A, C to B, D to C, E to D, and
F to E). For example, an hour of calm winds with F stability was followed by hours
with E stability, 1.0 m/s. Stability class F wind speed combinations were also
considered in combination with a stability class F calm wind as a potential worst-case
scenario. SCREENS wind speeds and mixing heights were used for each non-calm
hour of modeling. Mixing heights for wind speeds below 4 m/s for stability classes A
through D were reset to 1400 meters to prevent the plume from rising above the
mixing height, resulting in potential underestimates of ground level concentrations
The ambient temperature was taken to be 293.1 K. The meteorological conditions are
summarized in Table HI.
1-6
-------
Table III
Meteorological Data Summary*
(a) Wind speed/stability class combinations
Calm Hour Non-Calm Hour Wind Speed (m/s)
Stability Class Stability Class
B
C
D
E
F
F
A
B
C
D
E
F
1,
1,
1,
1,
10
1,
1,
1-5,
1
1
1
1
1
-5,
-5,
^
15,
5
2, 2.5, 3
2, 2.5, 3,
2, 2.5, 3,
2253
20
2253
? 75 3
3.5, 4,
3.5, 4,
3.5, 4,
3.5, 4,
3.5, 4
4
.5, 5
4.5, 5, 8, 10
4
4
5, 5 8
5, 5
(b) Wind speed/mixing height combinations
Wind Speed Mixing Height
(m/s) (m)**
1
1.5
2
2.5
3
3.5
4
4.5
5
8
10
15
20
1400
1400
1400
1400
1400
1400
1280
1440
1600
2560
3200
4800
6400
* Based on SCREEN3
** Mixing heights for stability classes A through D. Stability classes E and F
have mixing heights of 10,000 meters for all wind speeds. ''
1-7
-------
4. CALPUFF Model Options
The following model options were selected for the fire scenario modeling A
complete set of model options can be found in the control file listings provided in
Attachments A (off-site fire) and B (on-site fire).
Rural PG dispersion curves
Buoyancy-induced dispersion
Transition plume rise
Single-station meteorological winds (ISC3 format)
Partial plume path terrain adjustments (plume path coefficient 0.35)
Elongated puff (slug) sampling option
Puff emission time - 10 seconds (360 puffs/hour)
Concentration averaging time - 1 hour
Near-field Gaussian distribution
Minimum (calm wind) ov = 0.5 m/s, aw = 0.016 m/s
ISC3 rural wind shear power law exponent (0.55 for F stability)
Aerodynamic downwash effects assumed for the on-site release
No chemical transformation, wet deposition, or dry deposition
C. Modeling Results
The predicted peak one-hour average concentrations for the off-site fire scenarios are
shown in Tables IV and V for release durations of 170 seconds and 430 seconds, respectively
The highest predicted concentration from the off-site scenarios was 1.22 jig/m3 This occurred
during the 170 second duration fire at a receptor 300 meters from the source. The maximum
concentration for the 430 second duration fire was 0.15 /xg/m3 at a receptor 4000 meters
downwind from the fire. In this case, the spill responsible for the fire covered a much larger
area than the 170 s fire (735 m2 vs. 38 m2). A higher flame resulted and the buoyancy flux
from the 430 second fire was nearly a factor of 20 larger than that of the 170 second fire.
Thus, although the emissions from the longer duration fire were larger, the higher buoyant
1-8
-------
plume rise caused the modeled plume to pass over the relatively lower terrain close to the site
of the spill, and produced an overall peak concentration lower than the short duration release
Generally speaking, the worst-cast meteorological conditions for each receptor.
demonstrated a tendency toward low wind speeds (1.0, 1.5 m/s) and stable conditions (E and
F stability). Close to the fire, the peak concentrations tended to be associated with a F
stability calm hour followed by 1.0 m/s winds with E stability. These conditions allow the
pollutant material to accumulate with little vertical dispersion during the calm hour but dunns:
the subsequent E stability conditions, mix vertically to the ground, resulting in higher near-
field ground-level impacts. Farther away from the source, a calm hour with F stability
followed by F stability 1.0 m/s winds produced the peak concentrations.
The modeling results for the on-site fire scenarios are shown in Tables VI, VII, and
VIII for release durations of 170 s, 600 s, and 7030 s, respectively. The maximum
concentration for the 170 second fire (0.23 ng/m3) and the larger 600 second fire (0.60 /xg/m3)
occurred at 1750 meters and 2250 meters, respectively. Except close to the stack, the worst-
case meteorological conditions for these scenarios were associated with a F stability calm hour
followed by E or F stability light wind speeds.
The 7030 second on-site fire provided the highest predicted concentrations of any of
the scenarios. The maximum concentration of 201.6 jtg/m3 was predicted at 100 meters from
the fire under stability class F and a wind speed at 3.5 m/s after the 1-hour calm during the
release. For this scenario, a build-up of pollutant material during the calm hour combined
with the poor horizontal dispersion conditions, enhanced vertical dispersion (due to downwash
effects), and lower plume rise with the higher 3.5 m/s winds after the first hour to produce a
narrow plume in the horizontal but enough vertical mixing for it to reached the ground a
distance of 100 meters from the source.
1-9
-------
TABLE IV
Case One
Worst Case One-Hour Average Concentrations (|ig/m3)
for the Off-Site Fire Scenario (170 second duration)
Downwind
Distance (m)
100
200.
300.*
400.
500.
600.
700.
800.
900.
1,000.
1,250.
1,500.
1,750.
2,000.
2,250.
2,500.
3,000.
4,000.
5,000.
7,500.
10,000.
15,000.
20,000.
30,000.
40,000.
50,000.
Receptor
Elevation (m)
292.6
304.8
328.0
347.5
359.7
359.7
356.6
359.7
359.7
371.9
384.0
396.2
396.2
396.2
371.9
408.4
408.4
420.6
415.4
408.4
426.7
420.0
420.0
420.0
420.0
420.0
Emission
170s
0.94
0.83
1.22
0.81
0.56
0.39
0.27
0.28
0.28
0.29
0.30
0.30
0.30
0.30
0.29
0.29
0.27
0.19
0.24
0.19
0.22
0.16
0.10
0.11
0.07
0.05
Duration
Stability
Class
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/t
F/E
F/E
F
F
F
F
F
F
F
F
F
F
F
F
F
Hour 2. 3
Wind
Speed (m/s)
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.5
1.0
1.0
1.0
1.0
1.5
1.0
1.5
1.5
* Receptor with maximum concentration
1-10
-------
TABLE V
Case Two
Worst Case One-Hour Average Concentrations (u.g/m')
for the Off-Site Fire Scenario (430 second duration)
Downwind
Distance (m)
100.
200.
300.
400.
500.
600.
700.
800.
900.
1,000
1,250.
1,500.
1,750.
2,000.
2,250.
2,500.
3,000.
4,000. *
5,000.
7,500.
10,000.
15,000.
20,000.
30,000.
40,000.
50,000.
. * Receptor with
Receptor
Elevation (m)
292.6
304.8
328.0
347.5
359.7
359.7
356.6
359.7
359.7
371.9
384.0
396.2
396.2
396.2
371.9
408.4
408.4
420.6
415.4
408.4
426.7
420.0
420.0
420.0
420.0
420.0
maximum concentration
Emission
430s
0.07
0.05
0.06
0.08
0.07
0.05
0.03
0.03
0.03
0.05
0.07
0.09
0.09
0.09
0.06
0.12
0.13
0.15
0.11
0.13
0.13
0.11
0.10
0.07
0.07
0.04
Duration
Stability
Class
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/t
F/E
F/E
F/E
F/E
wt
F/E
F/E
F/E "
F/E
IVt
F/E
F/E
F/E
F
F
Hour 2. 3.
Wind
Speed (m/s)
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.5
Ml
-------
TABLE VI
Case Three
Worst Case One-Hour Average Concentrations (ng/m3)
for the On-Site Fire Scenario (170 second duration)
Downwind
Distance (m)
100.
200.
300.
400.
500.
600.
700.
800.
900.
1,000.
1,250.
1,500.
1,750.*
2,000.
2,250.
2,500.
3,000.
4,000.
5,000.
7,500.
10,000.
15,000.
20,000.
30,000.
40,000.
50,000.
* Receptor with
Receptor
Elevation (m)
213.4
225.6
231.6
231.6
268.2
304.8
323.1
353.6
353.6
353.6
359.7
365.8
365.8
371.9
384.0
384.0
408.4
420.6
415.4
408.4
426.7
420.0
420.0
420.0
420.0
420.0
maximum concentration
Emission
170s
0.004
0.005
0.005
0.01
0.03
0.08
0.12
0.21
0.21
0.22
0.23
0.23
0.23
0.23
0.23
0.22
0.21
0.17
0.15
0.18
0.14
0.13
0.12
0.09
0.07
0.04
Duration
Stability
Class
E/D
F/E
B/A
B/A
B/A
F/E
F/E
F/E
F/E
F/E
Wt
F/E
F/E
F/E
F/E
b/h
F
F
F/E
F
h
F
F
F
F
F
Hour 2. 3. .
Wind
Speed (m/s)
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.5
1-12
-------
TABLE VII
Case Four
Worst Case One-Hour Average Concentrations (u,g/m3)
for the On-Site Fire Scenario (600 second duration)
Downwind
Distance (m)
100.
200.
300.
400.
500.
600.
700.
800.
900.
1,000.
1,250.
1,500.
1,750.
2,000.
2,250.*
2,500.
3,000.
4,000.
5,000.
7,500.
10,000,
15,000.
20,000.
30,000.
40,000.
50,000.
* Receptor with
Receptor
Elevation (m)
213.4
225.6
231.6
231.6
268.2
304.8
323.1
353.6
353.6
353.6
359.7
365.8
365.8
371.9
384.0
384.0
408.4
420.6
415.4
408.4
426.7
420.0
420.0
420.0
420.0
420.0
maximum concentration
Emission
600s
0.01
0.01
0.01
0.01
0.02
0.08
0.13
0.32
0.33
0.35
0.42
0.49
0.49
0.55
0.60
0.59
0.57
0.49
0.39
046
0.37
0.35
0.32
0.26
0.20
0.10
Duration
Stability
Class
E/D
E/D
F/E
B/A
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/E
F/E
h/t
F/E
F
F
F
F
F
F
F
F
F
Hour 2. 3.
Wind
Speed (m/s)
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
2.0
1-13
-------
TABLE VIII
Case Five
Worst Case One-Hour Average Concentrations (u,g/m3)
for the On-Site Fire Scenario (7030 second duration)
Downwind
Distance (m)
100.*
200.
300.
400.
500.
600.
700.
800.
900.
1,000.
1,250.
1,500.
1,750.
2,000.
2,250.
2,5UU.
3,000.
4,000.
5,000.
7,500.
10,000.
15,000.
20,000.
30,000.
40,000.
50,000.
* Receptor with
Receptor
Elevation (m)
213.4
225.6
231.6
231.6
268.2
304.8
323.1
353.6
353.6
353.6
359.7
365.8
365.8
371.9
384.0
384.U
408.4
420.6
415.4
408.4
426.7
420.0
420.0
420.0
420.0
420.0
maximum concentration
Emission
7030 s
201.6
107.1
43.7
24.1
104.3
154.4
136.4
123.4
111.0
100.6
81.2
67.4
56.4
48.2
41.8
35.9
26.8
24.9
25.6
15.9
10.7
6.0
4.6
3.9
3.4
1.9
Duration
Stability
Class
F
F
F
E/D
F
F
F
F
F
F
h
F
F
F
F
J-
F
F
F
F
F
F
F
F
F
F
Hour 2. 3.
Wind
Speed (m/s)
3.5
4.0
4.0
10.0
3.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
I.U
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.5
1-14
-------
4. References
Scire, J.S., D.G. Strimaitis, R.J. Yamartino, and X. Zhang, 1995 A User's Guide for
the CALPUFF Dispersion Model. EARTH TECH, Inc Report No 1321-2.
Prepared for the USDA Forest Service, Cadillac, MI
1-15
-------
ATTACHMENT A
CALPUFF Input File
(Off-Site Fire)
-------
Off-site Fire
WTI Truck Accident OM-Site, Screen Modeling -- OFFSITE
1 Point source. 26 receptors up to SO KM •way. Vapor
CALPUFF MODEL CONTROL FILE
INPUT GROUP 0 -- Input and Output File
Default ttmmf Type
CALHZT.DAT
File
ISCMTT.DAT
or
PLMIET.DAT
or
FROPILE.DAT
SURFACE. EAT
input
input
input
ISCDAT -SCREEN.MET
PRFDAT -
SFCDAT -
CALPUFF.LST output ! PUFLST -Calpuf f . l»t !
CONC.DAT output .' CONDAT -conedat.con .'
DFLX.DAT output • DFDAT - •
WFLX.DAT Output • WFDAT - •
VISB.DAT output • VISDAT • •
Eaxiacion Piles
PTEMARB.DAT input • PTUAT - •
VOLEM.CAT input • VOLDAT - •
BAEMARB DAT Input • AJtDAT -
Other Files
OZONE DAT input • OZOAT »
VD.DAT input • VEOAT « •
CHEM.DAT input • CHEHDAT-
Hll^L.DAT input • HILDAT* •
HILLRCT.DAT input • RCTUAT«
DEBUG DAT output • DEBUG «
All file names will be converted to lower caae if LCFZLCS - T
Otherwise, if LCFILES = F. file nmmfs will be converted to OFFER CASE
T = lover case ' LCFILES « T '
F * UPPER CASE
NOTE (1) file/path names can be up to 70 characters in length
'END'
INPUT GROUP 1 — General run control parameters
Starting date year *IBYR) -- No default
Month (IBMOl -- No default
IBYR
IBMO
93
1
-------
Day (IBDY) --No default ' ZBDY * 1
Hour (IBHR) -- No default ' IBKR * 1
Length of run (hours) C> -- No default ' IRUZ « 20
Number of chemical species (NSPEC)
Default: S ' NSPEC - 1
Number of chemical species
to be emitted (NSE) Default: 3 ! NSE « 1 •
Flag to stop run after
SETUP phase (XTEST) Default: 2 ' ZTEST - 2
(Used to allow cheeking
of the model inputs, files, etc.)
XTEST * 1 - STOPS program after SETUP phase
ITEST « 2 - Continues with execution of program
after SETUP
Meteorological Data Format (MTTPM)
Default: 1 ! METni • 2
METPH - 1 - CAUCET binary file
-------
Near-field puffs modeled as
elongated 0 (HSLOGI
0 = no
1 - yes (slug model used)
Default. 1
Trajisitional plvote rise Modeled ?
(MTRAMS) Default : 1 ! KTHAMS - 1
0 * no (i.e.. final rise only)
1 - yea (i.e.. transitional rise computed)
Stack tip downw«sh-> (HTTP) Default: 1 ! IOTP - 0 (
0 - no (i.e.. no »tack tip dovnwuh)
1 - yea (i.e.. use (tack tip downwesh)
Vertical wind shear modeled above
stack top' (MSHEAP) Default: 0
0 • no (i.e.. vertical wind shear not modeled)
1 - yes (i.e.. vertical wind shear and* led)
I KSKEAK - 0
Puff splitting allowed? ("SPLIT)
0 « no (i.e., puffs not split)
1 - yes (i.e.. puffs are split)
Default: 0
! KSPLTT - 0
Chemical mechanism flag (NCKBO Default: 1
0 • chemical transformation not
modeled
1 - transformation rates computed
internally (KESOPOFP II scheme)
2 « user-specified transformation
rates used
.' HCHEM - 0
Default: 1
Dry deposition modeled ? (HDRVi
0 « no
1 * yes
(dry deposition net hod specified
for eacb species in Input Group 3)
Method us«d to cat-put*
-------
Sigm«-v/sio»*-th«ta. sioma-w Measurements used^> (HTURBWn
(Used only it 1OISP - 1 or 5> Default 3 ' MTURBVW « 0
1 - use sioaia-v or siosw-theta Measurements
frovi PROFILE.DAT to coepute sigma-y
(valid (or KETfX - 1. 2. 3. 4)
2 • use SIOBS-W •easuriamts
from PROFILE. DAT Co compute sioma-z
(valid for METFM - 1. 2. 3. 4)
3 - uae both aiga«-(v/theta) and «IOM*-V
treat PROFILE. DAT to coHpute aigaa-y and sigBa-z
(valid for KETTM - 1. 2. 3. 4)
4 - uae aioaa-tbeta •eaaureaent*
from PLHKET.DkT to coapute aigaw-y
(valid only if HETFM - 3)
Back-up Method uaad to covpute diaperaion
whan BNWsurad turbulence data are
miaauig (KDISP2I Default: 4 > MDISF2 - 4 !
Cuaed only if HDISP - 1 or 5)
2 - diaparaion coefficient* froa\ internally calculated
aioBM v, aioMa w •••*"g •icroawteoroloa.ical variables
(u*. v*. L, etc.)
3 - PC diapersion coefficients for KDRA1* areas (cosKTutad uaing
the ZSCST Mulli injaMinr approxiaation) and HP coefficients in
urban areas
4 • aaaw as 3 except PC coefficients computed using
the MESOPUPF II egns .
PC Slgw-y, i adj . for roughneaa? Default : 0 ! HKOUGH - 0 •
dOtOOOH)
0 « no
1 - yu
Partial pluBtc penetration of Default: 0 ". HPARTL « 0 \
elevated inversion7
(MPARTL)
0 • no
1 - y«
Test options specified to see if
they conform to regulatory
value*? (KRDG) Default: 0 ! KREC « 0 !
0 * HO checks are
1 * Tvchnical options Bust conform to USEPA values for
short-range modeling (e.g. ISC-type applications)
2 « Technical options must conform to USEPA values for
long-range modeling (e.g. visibility-type applications)
3 * Other constraints
INPUT GROUP: 3 — Species list
The following species are modeled
-------
SPECIES
KAMI
ILuut 12
Characters
in length}
MODELED
(O.NO. 1-YES)
EMITTED
(0-HO, 1'YES)
Dry
DEPOSITED
(0-NO,
1-COMPUTED-GAS
2-COKPUTED-PARTICXŁ
3-USER-SPECIFIED)
INPUT GROUP: 4 — Grid control parameters
METEOROLOGICAL grid:
No. X grid cells (NX) No default ! NX • 2
No. Y arid cells (NY) Ho default ! NY - 2
No vertical layers (NZ) No default ! HZ • 1
Grid (pacing (DCXXDKM)
No default
Units: k»
DGRIDKM • 25.5
Cell face heights
(ZrACE(nx*D)
! ZFACE • 0.. 5000
Reference Coordinates
of SOUTHWEST comer of
grid POIWTI1, 1)
No defaults
Units: •
X coordinate (XORIGKM) No default
Y coordinate (YORICKM) No default
Units: km
' XORIGKM m 0. '
>. YORIOXM - -25.5
UTM lone (IUTHZN)
No default
Reference coordinates of CENTER
of the domain (used in the
calculation of solar elevation
angles)
Latitude (deg.l (XLAT) No default ' XLAT « 45
Longitude Idea ) (XLONG) No default < XLONG - 90
Time lone (XTZ) No default ' XTZ =60
-------
The computational grid is identical to or a sufcsel oi the MET grid
The lower left (LL) corner of the computational grid is at grid point
(IBCOHP. JBCOMP) of the KET grid The upper right (URI comer of the
computational grid is at grid point (lECOrlP. JECOHP) of the HFT grid
The grid spacing of the computational grid is the same as the MET grid
X index of LL comer (IBCCMP)
(1 <- IBCOHP <- MX)
No default
Y index of LL comer (JBCOHF)
(1 <- JBCOMP <• NY)
No default
X index of UK corner (lECOHPI
(1 <- IECOMP <- NX)
Ho default
IECOMP - 2
Y index of UR comer (JECOMF)
(1 <« JECOMP <- KYI
No default
JECOMP . J
SAMPLIMC GRID (GRIDOED RECEPTORS) •
The lover left (LL) corner of Che saoplxng grid is at grid point
(XBSAMP. JBSAMP) of the KET. grid. The upper right (UK) corner of the
Mapling grid n at grid point IIESAMP. JESJUXP) of the KET. grid.
The saopling grid nust be identical to or a subset of the computational
grid. It mmy be a nested grid inside the coa^putational gxid
The grid spacing of the sasE>ling grid is DGRZDKK/KESHDH.
Logical flag indicating if gridded
receptors are used (LSAMPI Default: T
r«no)
X index of LL comer (IBSAHP)
I IBCOHP <- IBSAMP <« IECOHP)
Ho default
IBSAMP - 0
Y index of LL corner (JBSAHP)
(JBCOHP « JSSAMP <- JECOMP)
No default
X index of UK comer (IESAHF)
(IBCOHP <- IESAKP <- IECOHP)
Ho default
IESAMP - 0
Y index of UR corner (JESAKP)
(JBCOHP <" JESAMP <- JECOHP)
No default
JESAMP . 0
Nesting factor of the sampling
grid (MESHDN)
(HESKDN is an integer >* 1)
Default 1
KESHDN = 1
INPUT GROUP 5 -- Output Options
-------
DEFAULT VALUE
VALUE THIS RUN
Concentrations (ICON) 1
Dry Fluxes IIDRY) 1
Wet Fluxes IWFRQ • 1 '
Meaaages tracking progress of Default: 1
run written to the screen ?
(IHESGI -- o«no. l»yes
I
SPECIES LIST FOR OUTPUT OPTIONS
CONCENTRATIONS DRY FLUXES
SPECIES
HAKE PRINTED ' SAVED ON DISK ' PRINTED ? SAVED ON DISK ?
WET FLUXES
PRINTED ? SAVED ON DISK 1
FUGITIVE . 1. 1. 0. 0.
OPTIONS FOR PRINTING -DEBUG' QUANTITIES ISUCh output)
0.
Logical for debug output
(UDEBUG)
Default. F ' LDEBUC * F
Number of puffs to track
INPFDEB1
Default 1 • NPFDEB - 1
Met period to start output
(NN1)
Default 1 ' NN1 = 1
Met period to end output
(NN2)
Default 10 ' NN2 * 10
-------
INPUT GROU1P: 6a. 6b. 4 6c — Subgrid scale coBplex terrain inputs
Subgroup < 6*)
Number of terrain features (KHILL) Default- 0 .' HULL - 0 !
Miaber of special complex terrain
receptors (NCTREC) Default; 0
Terrain and CTSG Receptor data for
CISC hilla input in CTDM format ?
(MHTLLI No Default ! XHILL - 0 !
1 • Hill and Receptor data created
by CTDN proceaaori t r«ad from
HILL. DAT and HTLLHCT.DAT files
2 - Hill data created by OF7HILL I
input below in Subgroup (fib);
Receptor data in Subgroup (6c)
Factor to convert horizontal dl*encionc Default: 1.0 ! XHTLL2M « 1. !
to vetera >1)
Factor to convert vertical diBenaioiu Default: 1.0 I ZRZLL2M • 1. !
to cetera (KnTLL-l)
of CTDH myfttm relative to Ho Default I ICimim - O.OEOO I
CALPUFF coordinate cyeteei. la Kiloewterx 1)
Y-orlgin of CTDM lyxten relative to No Default ' YCTDHTM - O.OEOO '
CALPUFF coordinate system, in Kilometers (KHIIX>1)
Subgroup (fib)
X
HILL information
YC THETAH ZCRID RELIEF EXPO 1 EXPO 2 SCALE 1 SCALE 2 AHAX1 AHAX2
()<>>) (deg.) (m) (ml (ml (ml (ml (ml (ml (ml
Subgroup (6c)
COMPLEX TERRAIN RECEPTOR INFORMATION
XRCT yscr
(km) (km)
-------
1
Description of complex Terrain Variables:
xc, YC - Coordinates of center of hill
TKETAH - Orientation of ms}or axis of hill (clockwise from
North)
ZGRID - Height of the 0 of the arid above mean set
level
RELIEF - Height of the crest of the hill above the grid elevation
EXPO 1 - Mill-shape exponent for the major axis
EXPO 2 - Hill-shape exponent for the major axis
SCALE 1 • Honxontal length scale along the major axis
SCALE 2 • Horixontal length scale along the minor axis
AMAX - HT-'r— allowed axis length for the major axis
BKAX - "-•"—— allowed axis length for the major axis
XRCT, YRCT - Coordinates of the complex terrain receptors
ZRCT - Height of the ground (stSL) at the complex terrain
Receptor
XHH - Hill number associated with each complex terrain receptor
(MOTE: MOST BE ENTERED AS A REAL NUMBER I
NOTE: DATA for each hill and CTSE receptor are treated as a separate
input subgroup and therefore sust end with an input group teninator.
INPUT GROUP: 7 — Chemical parameters for dry deposition of gsses
SPECIES DIFFUSIVITY ALPHA STAR REACTIVITY MESOPHYU. RESISTANCE HENRY'S LAW COEFFICIENT
NAME Is/cml (dimensionlessl
INPUT GROUP- 8 — Sice parameters for dry deposition of particles
SPECIES GEOMETRIC MASS MEAN GEOMETRIC STANDARD
NAME DIAMETER DEVIATION
(microns) (ucrons)
-------
rNPUT GROUP 9 -- Miscellaneous dry deposition
Reference cuticle resistance (RCUTR)
-------
Nighttime HMO3 formation race IRNITE3I
in percent/hour Default. 2.0
INPUT GROUP: 12 — Misc. Dispersion and Computational Psrameters
Horizontal miff of puff <•) beyond which
time-dependent dispersion equations (Heffter)
are used to determine sigma-y and
sigma-z (SYTDEP) Default: 550. ! SYTDEP • 1.0E04
Switch for using Meffter eojuatioa for sigma z
mi above (0 - Mot use Heffter; 1 • use Heffter
(MHTTSZ) Default: 0 ! HHFTSZ • 0 !
Stability claaa uaed to determine
orowtb rates for puffs above the boundary
layer (JSUP) Default: 5 ' JSUP - 5 !
Vertical dispersion constsnt for stable
conditions OU in Eqn. 2.7-3) (COMK1) Default: 0.01 ! CCW1U - 0.01
Vertical dispersion constant for neutral/
unstable conditions (fc2 in Eijn. 2.7-4)
(CCHK3) Default: 0.1
Factor for determining Transition-point from
Schulman-Scire to Huber-Snyder Building Dovnwasb
scheme (SS used for Hs < Hb * TBD • ML)
(TBDI Default. 0 5 ' TBD "0.5 '
TBD < 0 •«> always use Huber-Snyder
TBD - 1 5 ••> always use Schulman-Scire
TBD • 0.5 -•> ISC Transition-point
Range of land use categories for which
urban dispersion is assumed
(IURB1. IDRB2) Defsult 10 ' HJRB1 « 10 '
19 .' IUKB2 « 19 '
Site characterization parameters for single-point Met dats files
(needed for HETPM • 2.3.4)
Land use category for modeling domain
(ILAMDUINI Default 20 • ILANDUIN = 20
Roughness length In) for modeling domain
(ZOIN> Default 0.25 • ZOIN = 0 25 •
Leaf area index for modeling domain
(XLAIOI) Default 3.0 • X1AIIN . 3 •
Specialized information for interpreting single-point Met data files
-------
nnratrwrrrr height <•>) lUsed only if KETFH •= 2,3)
(ANQOTTI Default 10 < AWEMHT * 1C
For* of lateral turbulence data in PROFILE.DAT file
(Used only if MCTTH * t or MTURBVW * 1 or 3 !
(XSIQtAV) Default. 1 • ISIGHAV . 2
0 - read sigaia-theta
1 - read aio»a-v
Choice of auxing heights (Used only if MZTTM • 4)
(XMXXCmf) Default: 0 ! ZKZXCHM • 0
0 - read PREDICTED suxing height*
1 • read OBSOWTO mixing height*
Ms-Trios* length of a slug (s«t. grid units)
(JMXLZJJ) Default: 1.0
*m~imm~, travel distance of a puff /slug
-------
' PLJCO - 0 07, 0.07. 0 10 0 15 0.35. 0 55
Default potential te*K?erature gradient
for stable classes E. F (degK/n)
(PTGO(2)1 Default 0.020. 0.035
! PTGO « 0.020. 0.035 '
Default pluaw path coefficients for
each stability class (us«d when option
for partial plume height terrain adiuscswnt
is selected — MCTADJ-3)
(PPC(6U Stability Class : A B C D E F
Default PPC : .50, ,50. .50, .50, .32. .35
! PPC « 0.5. 0.5, 0.5, 0.5. 0.35. 0.35
Slug-to-puff transition criterion factor
to sigma-y/ length of dug
F) Default: 100. ! SL2FF * 100. '
Puff-splitting control variables
Nus&er of puffs that result every tisie a puff
is split - nsplit«2 •aam that 1 puff splits
into 2
(NSPLIT) Default. 3 ' NSPLIT - 3
Tiav> exceeds a minimum value
(2ISPLIT) Default 100 ' ZISPLIT = 100
Split is allowed only if ratio of last hour's
B\ixi.ng ht to the fni>jTir"Bi mixing ht experienced
by the puff j.* less than a nar'Tiir* value (this
postpones a split until a nocturnal layer develops)
(ROLDMJUC) Default 0-25 ' ROLCKVX = 0.25
INPUT GROUPS 13a, 13b, 13c --
Subgroup {13a)
Number of point sources with
-------
constant emission parameters (NPT11 No default ' KPT1 « 1
er of point sources with
variable emission parameters 0. the variable point
source emissions are read from
the file: FTEHARB.DAT)
Subgroup (13b)
POINT SOURCE DATA FOR SOURCES WITH CONSTANT EMISSION PARAMETERS
b C
Source X OTH V OTH Stack Baae Stack Exit Exit Bldg. Emission
No. Coordinate Coordinate Height Elevation Diameter v«l. Tessp. Dwuh Rate«
(km) (km) <•) (•) <•) <•/•) 1
-------
Subgroup < Ha)
Number of polygon area sources with
constant emission parameters (HARD No default ' NAR1 - 0
Number of buoyant polygon are* sources
with variable location and emission
parameters (NAX2) No default ' NAR2 - 0
(If NAR2 > 0. ALL variable area source
data are read from tbe file: BAEMARB.DAT)
!END!
Subgroup (Kb)
a
AREA SOURCE MIA FOR SOURCES WITH COKSTAMT EKISSXGN PARAMETERS
b
Source Effect. Base Initial Emission
No. Height Elevation Sigma z Rates
In) (•)
-------
Subgroup (ISa)
Number of buoyant line sources (KLINES) No default •. HUMES « 0 '
i nuaber of segments used to model
each line (MZNSBG) Default: 7 • KXHSBG - 7 !
The following variable* are required only if KLINES > 0. Ttoey are
used in tne buoyant line source plume rise caleulationa.
Number of distances at which Default. C I NUUSZ - f 1
transitional riae is cosfxited
Average line aource length (XL) Ho Default ! XL • 0. !
(in si"4/s*«3)
Subgroup (15b)
BUOYANT LINE SOURCE DATA
Source Beg. X Beg. Y End. X End Y Release Base Emission
No Coordinate Coordinate Coordinate Coordinate Height Elevation Rates
-------
XMFUT GROUPS 16« ' 16b -~ Volue* source parameters
Subgroup (16«)
Number of volume sources with
constant emission parameters (HVU) No default < HVU > 0
mo default t IGJUTVL • o
Cridded volume source data
uaed ? (IGKDVL)
0 - no
1 - yes (gridjded volume aource
emission! read tram the file:
VOLEM.DAT)
The following parameters apply to the data in the
gridded volume aource emiaaions file
- Effective height of emiasions
(VEPPHT) in meters No default ( VEFFBT - 0. !
Initial aigma y (VSIGYI) in
No default ! VSIGTI - 0. !
- Initial sigma i (VSIC2I) in
meters No default ! VSIGZI - 0. <
Subgroup
-------
Subgroup (17a»
NuBfcer of non-gridded receptors (NREC) No default • MREC - 26
Subgroup (17b)
R«cept<
No.
1
2
3
4
5
6
7
t
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
HON-G
jr C
! X -
! X •
1 X -
! X -
1 X -
! X -
! X -
! X -
1 X «
1 X -
I X -
1 X -
1 X -
1 X -
! X -
! X •
! X -
' X -
! X •
• X >
! X -
! X -
! X -
! X -
1 X -
1 X -
KIDOCD (DISC*
X UTM
oordiMte O
(kB)
0.1.
0.2.
0.3.
0.4.
0.5.
0.6.
0.7.
0.8.
0.9.
1..
1.25.
1.5.
1.75,
2.,
2.25.
2.5,
3..
4. .
5.,
7.5.
10..
IS..
20..
30..
40..
50..
ETE) UCEP
y um
oordinate
(to.)
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..
•
TOR DATA
Ground
Elevation
(•1
292. COO!
304. *00 !
321.000!
347.500!
359.700!
359.700!
356. COO!
359.700!
359.700!
371.900!
314.000!
3*6.200!
396.200!
396.200'
371.900'
408.400'
408.400'
420.600'
415.400'
408 400'
426.700'
420.000'
420.000'
420.000'
420.000'
420.000'
IBID!
IBTO!
IBID!
IBID!
HMD!
IBID!
IBID!
IBID!
IBID!
IBID!
IBD!
IBID!
IBID!
IBID!
IBID!
!BID'
!BID'
•END:
!END'
'END'
!BID'
!EMD!
IEND!
•EMC'
!BID!
!EMD'
Data for ««ch receptor are treated as a separate input subgroup
and therefore »«ist end with an input group terminator
-------
ATTACHMENT B
CALPUFF Input File
(On-Site Fire)
-------
On-nte Fire
HTI on-slte fir*. Screen Modeling
1 Pome source: 26 receptor* up to 50 KM avay. Vapor
Hun title (3 lined
CALPUPF MODEL CSMTROL FILE
INPUT GROUP: 0 -- Input and Output rile Nanei
Default Nane Type
CAUIET.DAT input
ISCMET.DAT input
or
PLMKET.DAT input
or
PXOFTLZ.DAT input
SURPACE.DAT input
ISCDAT -SCREEN.MET
• PRPDAT •
• SPCDAT -
CALPUPF.LST output I PUTLST -calpuff.LST
COMC.DAT output ! CONDAT •cancdat.CON
DFLX.DAT output * DFDAT -
MPUC.DAT output * WFDAT -
VZSB.DAT output • VXSOIT -
EBiaaion Piles
PTEMMlB.IMkT input ' PTI*T -
VOLEM.DAT input • VDUMT -
BAZMXRB.DAT input • ARDAT '
Other FilM
OZOME.DAT input • OZDKT -
VD.DAT input • VDDKT -
CKEM.EAT input • CHEXEAT-
HILL.DAT input * HILOAT- '
HIUJtCT.DAT input • RCTDAT" •
DEBUG.MT output • DEBUS •
All file n*M> will be converted to lover cue if LCFILES - T
OthervUe, if LCTILES - T. til* n*m»* will be converted to UPPER CASE
T - lower cue ! ICFILCS - T !
F - UPPER CASE
NOTE- (1) file/path MuftM can be up to 70 character* in lanpth
INPUT GROUP: 1 — General run control parameters
Starting date: year (IBYK) — No default
Month (IBMO) — No default
.' IBYX - 93
> IBMO • 1
-------
Day IIBDYI -- Ho default ' IBDY • 1
Hour (IBHBJ -- No default ' IBHR - 1
Length of run (houri) (IRLCI -- Ho default ' IRLG - 10
Number of chemical species (NSPEC)
Default: 5 > NSPEC - 1
Number of chemical species
to be emitted I USE I Default. 3 ' NSE - 1 !
Flap to stop run after
SETUP phase (ITEST) Default: 2 • ITEST - 2
(Used to allow checking
of the model inputs, files, etc.I
ITEST - 1 - STOPS program after SETUP phase
ITEST » 2 - Continues with execution of program
after SETUP
Meteorological Data Format (HETPM)
Default: I '. HETPM - 2
KETFM > 1 - CALKET binary file (CALMET.MET)
METFM - 2 - ISC ASCII file (ISOtET.MET)
KZmc - 3 - AUSPUME ASCII file IPLIMET.MET)
HETPM . t - CTDM plus tower file (PROFILE.EAT) and
aurface parameters file (SURFACE.DAT)
Averaging Time (minutes) (AVCT)
Default: 60.0 ! AVET - CO. •
PC sigma-y is adjusted by the equation
(AVET/60.0 >••(>. 2
INPUT GROUP: 2 — Technical options
Vertical distribution used in the
near deld INQAUSS) Default. 1 I MOAUSS - 1 '
0 • uniform
1 • Gauaaian
Terrain adjustment method
(MCTADJI Default: 1 ' HCTADJ - 3 !
0 • no adjustment
1 • ISC-type of terrain adjustment
2 • sia^le. CALPUFF-type of terrsin
adjustment
3 * partial plume path adjustment
Subgrid-scale cooplex terrain
flag (MCTSG) Default: 0 ! MCTSG • 0 I
0 • not modeled
1 - modeled
-------
Near-field puffs Modeled as
elongated 0 (MSLUG)
0 « no
1 * yes (slug model u>ed)
Default 1
Transitional plume rue Modeled ?
(MTRANS) Default 1
0 ft no (i.e.. final rise only)
1 * yes (i.e., transitional rise computed)
MTRAMS • 1
Stack tip downwash? (MTIP) Default. 1
0 * no (i.e., no stack tip downwash)
1 * yes (i.e., use stack tip downvash)
Vertical wind shear Modeled above
stack top* JMSHEAR) Default: 0
0 * no (i.e., vertical wind shear not Modeled)
1 * yes (i.e., vertical wind shear sod*! ad)
XSXEAR
Puff splitting allowed? (MSPLZT)
0 * no (i.e., puffs not split)
1 - yes (i.e., puffs are split)
Default: 0
MSPLXT • 0
Chemical mechanism flag (MCHBM)
0 » chemical transformation not
modeled
1 * transformation rates computed
internally (MESOPUFF XI scheme)
2 • user -specified transformation
rates used
Default: 1
HCKBM - 0
Wet removal modeled ? (MHET)
0 • no
1 - yes
Default: 1
Dry deposition modeled ? (MDRY) Default: 1
0 » no
1 * yes
(dry deposition method specified
for each species in Input Croup 3)
Method used to compute dispersion
coefficients (MDISP) Default: 4
MDISP - 3
1 * dispersion coefficients computed from measured values
of turbulence, sigma v, sigma w
2 • dispersion coefficients from internally calculated
sigma v, sigma w using micrometeorological variables
(u*. w*, L, etc.)
3 • PC dispersion coefficients for RURAL areas (computed using
the ISCST multi-segment approximation) and HP coefficients in
urban areas
4 » same as 3 except PG coefficients computed using
the MESOPUTT II egns.
5 • CTDM sigmas used for stable and neutral conditions .
For unstable conditions, sigmas are computed as in
MDISP • 3, described above. MDISP • S assumes that
measured valuea are read
-------
5igma-v/sigaa-theta, sigma-w measurements used** (KTURBVW)
(Used only if KDISP • 1 or 5} Default. 3 ' KTURBVW • 0
1 * use aigma-v or sigsu-theca measurements
from PROPILE.DAT to compute sigma-y
(valid for KEITH - 1, 2, 3. 4)
2 • use aigma-w measurements
from PROPILE.DAT to compute sigma>z
(valid Cor KETPM " 1, 2, 3, 4)
3 - use both sigma-fv/theta) and sigma-w
from PROPILE.DAT to compute sigma-y and signa-z
(valxd for KETPM • 1, 2. 3, 4)
4 • use sigma-theta measurements
from PLMMET.DAT to compute aigma-y
(valid only if KETPM • 3)
Back-up nethod used to compute dispersion
when Measured turbulence data are
missing (KDZSP2) Default: 4 ! KDZSP2 * 4 >
(used only if KDISP . 1 or 5)
2 • dispersion coefficients fron internally calculated
aioju v, sigvta w using aucraaMteoroloffical variables
(u", w, L, etc.)
3 - PG dispersion coefficients for RURAL areas {computed uaing
the ISCST multi-segment approximation) and HP coefficients in
urban areas
4 • saaw as 3 except PG coefficients coaputed using
the KESOPUPP ZI eqns.
PG signaa-y,z adj. for roughness? Default: 0 ! MROUGH • 0 '
(MROUGH)
0 • no
1 • yes
Partial plune penetration of Default: 0 ' KPARTL * 0 !
elevated inversion?
(KPARTL)
0 « no
1 • yes
Test options specified to see if
they conform to regulatory
values?
-------
SPECIES
HAKE
(Limit: 12
Character!
in length}
MODELED EMITTED
10-MO, l-YES) (0-HO. 1'YESI
Dry
DEPOSITED
(0-NO,
1-CCMPUTED-GAS
2-COMPUTED-PARTICLE
3-tfSER-SPECIfIEDI
INPUT GROUP.- 4 — Grid control para
METEOROLOGICAL arid:
No. X grid cella (MX) Ho default ! NX • 2 !
No. Y grid c«ll. (NY) No default I NY • 2 !
No. vertical layera (HZ) No default I MZ • 1 !
Grid spacing (DGRIDKM)
No default
unit*: k»
DGRIDKM -25.5 !
Call face baighta
-------
The computational grid it identical to or • subset of the HCT. arid
The lover left ILL) comer of the computational arid im at arid point
(IBCOMP, JBCOMPI of the HET. arid. The upper naht (OKI comer of the
computational arid is at arid point (IECOKP, JECOHPI of the MET. grid
The arid spacing of the computational arid is the sam* as the MET. arid
X indue of LL cort.j. (IBCOMPI No default ' IBCOMP « 1
(1 <• IBCOMP <• MX)
Y index of LL corner IJBCCMV) No default ' JBCOMP • 1 '
(I <- JBCCMP <• NY)
X index of UR corner (IECOMP) No default ' IECOKP • 2
(1 <- IECOHP <• NX)
Y index of UR corner (JECOMP) No default ! JECOMF « 2
(1 <• JECOMP <» NY)
SAMPLINC GRID (GRIDOED RECEPTORS) :
The lower left (LL) corner of the lulling grid n at grid point
(IBSAMF. JBSAKP) at the MET. arid. The upper right (UR) corner of the
saavllna arid i» at arid point (IESAKP, JESAMP) of the MET. grid.
The Mailing grid auat b« identical to or a aubaet of the cueoutational
grid. It Hay be a nested grid inside the computational grid.
The grid spacing of the aeaK>ling arid is DGRIOKM/MESHDM.
Logical flag indicating if ffridded
receptors are used (LSXMP) Default: T ! LSAMP • P i
P«no)
X index of LL corner (IBSAMP) No default
(IBCOMP <- IBSAMP <- IECOHP)
Y index of LL corner (JBSAMPI No default ' JBSAXP - 0
IJBCCNP <. JBSAMP <• JECOMP)
X index of UR corner (IESAMP) No default ! IESAMP > 0
(IBCOKP <- IESAMP <- IBCOMP)
Y index of UR comer (JESAMP) No default ' JESAMP • 0
(JBCOHP <- JESAMP <- JECCMP)
Nestine factor of the aaepling
arid (MESKDN) Default: 1
(MESHDN is an integer >» 1)
INPUT GROUP: 5 — Output Options
-------
DEFAULT VALUE
VALUE THIS RUN
Concentrations (ICON) 1
Dry Fluxes (IDRYI 1
W«t Fluxes (iwm 1
Relative Humidity (IVISI 1
(relative humidity file is
required for visibility
analysis)
Use data compression option in output file0
(LCOHPRS) Default: T
ICOK * 1
IDKY • 0
WET « 0
IVIS * 0
LCOMPRS • T
0 - Do not create file, 1 - create file
LINE PRINTER OUTPUT OPTIONS:
Print concentrations (ICPRT) Default: 0
Print dry fluxes CIDPRT1 Default: 0
Print wet fluxes (INPUT) Default: 0
10 • Do not print. 1 - Print)
! ICPRT • 1
> IDPKT - 0
! IKPRT - 0
Concentration print interval
(ICFRQ) in hours Default: 1
Dry flux print interval
(IDPRQ) in hours Default: 1
Wet flux print interval
(IWTROI in hours Default: 1
! icnto - i
! IDFRO - 1
! IWPRQ - 1
Messages tracking progress of Default: 1
run written to the screen ?
(DfESC) — 0-no, l«yes
' DIESG - 1
SPECIES LIST FOR OUTPUT OPTIONS
CONCENTRATIONS DRV FLUXES
SPECIES
NAME PRINTED ? SAVED ON DISK T PRINTED ? SAVED ON DISK ?
WET FLUXES
PRINTED ? SAVED ON DISK 7
FUGITIVE - 1.
OPTIONS FOR PRINTIM; 'DEBUG- QUANTITIES isuch output)
Logical for debug output
(LDEBUG)
Default: F ' LDEBUG - F
Number of puffs to track
(NPFDEB)
Default: 1 ! NPFDEB - 1
Net. period to start output
(NN1)
Default: 1 ' NN1 - 1
Met. period to end output
INN2)
Default: 10 ' KN2 - 10 !
-------
INPUT GROUP 6a, 6b. fc 6c -- Subgnd scale cos*?lex terrain inputs
Subgroup (6a)
Default. 0
Nunber of special complex terrain
receptors (HCTREC)
Default: 0
NCTREC • 0
Terrain and CTSG Receptor data Cor
CTSG hills input in CTm fonat 7
(KHILL)
1 - Hill and Receptor data created
by CTEH proceaaors 4 read Iron
HILL.DAT and HILLRCT.DAT files
2 - Hill data created by OPTHILL t
input below in Subgroup <6b) ;
Receptor data in Subgroup (6c)
No Default
! MHXLL • 0
Factor to convert horizontal distensions
to eaters (MHILL-1)
Default: 1.0 ! XHILL2H -
Factor to convert vertical dimensions Default: 1.0 ! ZHILL2M - 1. !
to meters (MHILL-1)
x-oriain of CTDH systesi relative to No Default ! XCTOKXM - O.OEOO :
CALPUPP coordinate system, in Kilometers (MHILL-1)
Y-ongin of CTDM system relative to No Default ! YCTDMKM • O.OEOO '
CALPUPF coordinate aysten, in Xilosietera (MHILL*!)
! END !
Subgroup (6b)
1 ••
KILL inforaation
HILL XC YC TKETAH ZGRID RELIEF EXPO 1 EXPO 2 SCALE 1 SCALE 2 AHAX1 AHAX2
N0- (•"» l>"l (deg.l (•) la) la) {•) (m) (B) (m| (m|
Subgroup (6c)
COMPLEX TERRAIN RECEPTOR INFORMATION
XRCT
(km)
YRCT
(km)
ZRCT
(si)
-------
escription of Complex Terrain Variables:
XC, YC - Coordinates of center of hill
TKZTAH • Orientation of major axis of bill (clockwise from
North)
ZCRID - Height of the 0 of the grid above Man •••
level
RELIEF > Height of the crest of the hill above the grid elevation
EXPO 1 « Hill-chape exponent for the ma^or axil
EXPO 2 « Kill-shape exponent for the ms?or axis
SCALE 1 - Horizontal length scale along the major axis
SCALE 2 • Horizontal length scale along the minor axis
AMAX • "»«'—"* allowed axis length for the major axis
BMAX - Man mum allotted axis length for the major axis
XRCT, YRCT - Coordinates of the complex terrain receptors
ZRCT • Height of the ground (NSL) at the complex terrain
Receptor
XKH - Hill number associated with each complex terrain receptor
(NOTE: MUST BE ENTERED AS A REAL NUMBER)
NOTE: DATA for each hill and CTSG receptor are treated as a separate
input subgroup and therefore must end with an input group terminator.
INPUT GROUP: 7 -- Chemical parameters for dry deposition of gases
SPECIES DIFFUSIVITY ALPHA STAR REACTIVITY NZSOPHYLL RESISTANCE HENRY'S LAM COEFFICIENT
NAME (cm'*2/s) Is/cm) (dimensionless)
INPUT GROUP. B — si>e parameters for dry deposition of particles
SPECIES GEOMETRIC MASS MEAN GEOMETRIC STANDARD
NAME DIAMETER DEVIATION
(microns) (microns)
-------
INPUT GROUP 9 -- Miscellaneous dry deposition parameters
Reference cuticle resistance (RCUTR) (S/CB) ' KCUTR « 30
Reference ground resistance (RGIU (a/cmj ' RGR » 5
Reference pollutant reactivity (REACTR) ! REACT* - 8
Number of particle-sixe intervals used to
evaluate effective particle deposition velocity
(HINT) Default: 9 ' MINT - 9
vegetation state in unirrigated areas (ZVEG) ! XVEG • 1
ZVEG*1 Cor active and unstressed vegetation
IVBGB2 Cor active and stressed vegetation
tVEG>3 Cor inactive vegetation
INPUT GROUP: 10 — Wet Deposition Parameters
Scavenging Coefficient — Units: (seel" (-11
Pollutant Liquid Precxp. 7rox«n Precip.
I END!
INPUT GROUP: 11 — chemistry Parameters
Oione data input option (HOII Default: 1
(Used only if MCHOt • 1)
0 • use a constant background ozone value
1 • read hourly oxone concentrations frcn
the OZONE.OAT data file
MOZ » 0 >
Background oxone concentration
(BCK03I in ppb Default: 80.
(Uaed only if HCHBH - 1 and
MOZ - 0 or (MOZ - 1 and all hourly
O3 data suaaing)
BCKO3 • 80. >
Background aanonia concentration
(8CKNH3) in ppb Default: 10.
Bcnou • 10.
Nighttime S02 loas rate (UNITED
in percent/hour Default: 0.2
RNITE1 - 0.2 I
Nighttime NOx loss rate IRNITE2)
in percent/hour Default: 2.0
RNITE2 - 2.
-------
Nighttime HNO3 formation rate IRNITE3)
in percent/hour Default 2.0 ' RUTTED • 2
INPUT GROUP- 12 — Misc. Dispersion and Computstional Parameters
Horizontal sire of puff (at) beyond which
time-dependent dispersion equations (HeffterI
are used to determine sigms-y and
aigma-z (SYTDEP) Default: 550. i SYTDEP - 1.0E04
Switch for using Heffter equation for sigma z
aa above (0 - Not use HefCter; 1 - use Heffter
(MHFTSZ) Default: 0
Stability class used to determine plus*
growth rstes for puffs above the boundary
layer (JSUP) Default: S ! JSUP • 5 !
Vertical dispersion constant for stable
conditions (kl in Eqn. 2.7-3) (COH1C1) -Default: 0.01 ! CCMK1 - 0.01 !
Vertical dispersion constant for neutral/
unstable conditions always use Huber-Snyder
TBD • 1.5 ••> slwaya use Schulman-Scirc
TBD • 0.5 ••> ISC Transition-point
Range of land use categories for which
urban dispersion is assuawd
(IURB1. IURB2) Default: 10 ! IURB1 - 10 !
19 > IURB2 « 19 '
Site characterization parameters for single-point Met data files
(needed for METTM - 2,3,4)
Land use category for modeling domain
(ILANDUIN) Default: 20 ! IUNDUIN - 20 '.
Roughness length (m) for modeling domain
(ZOOI) Default: 0.2S ' 10IN " 0.25 !
Leaf area index for modeling domain
(XLAIIN) Default: 3.0 .' XLAXIN • 3. !
Specialized information for interpreting aingle-pomt Met data files
-------
eter height ,») (Used only it ME1TN * 2.3)
IANOIHTI Default 10 ' ANEMHT • 10 >
Porn of later*! turbulence data m PROFILE.DAT file
(Uaed only if METFM • 4 or HTURBVW - 1 or 3 1
(ISIQIAV) Default. 1 .' ISIGKAV « 2 '
0 • read sigau-theta
1 - read aigva-v
Choice of mixing heights (Uaed only if METPM • 4}
(DtlXCTDM) Default: 0 ' DtZZCTCH - 0
0 • read PREDICTCD mixing heights
1 • read OBSERVED coxing heighta
Msyiimim length of a alug (met. grid units)
(XMXLEN) Default. 1.0 > XKXLEN - 1 '
Hi-minim travel distance of a puff /slug (in
grid units) during one sampling step
(XSAKLEN) Default: 5.0 ! XSAKLEN - 1. '.
Mar i mum Nuvber of slugs/puffs release from
one source during one tisw step
IKXHEH) Default: 99 '. KXNEH • 360 '
Maximin Nmber of saavling steps for
one puff/slug during one tuae step
(MXSAK) Default: S I KX5MI - 360 !
Minianim sigaa y for a new pufC/slug (at)
ISYMDI) Default: 0.01 ! SYIOM • 0.01 !
Hiniaum sigeta i for a new puff/slug (•)
(SZKIN) Default: 0.01 '. SZKIN - 0.01 !
turbulence si0aw-v (a/s)
(SVMIN) Default. O.SO ' SVMTN - 0.5 !
MiniamuB turbulence signa-w (a/s)
(SVMIN) Default- 0.016 ! SHKIM - 0.016 '.
Miniaaia wind speed (»/al allowed for
non-calA conditions . Also used as auniasiB
speed returned when using power-law
extrapolation toward surface
(WSCALM) Default. 1.0 ! HSCAU4 - 0.5 !
MSTfiaiiwi nixing height in)
(XKMCZI) Default: 3000. ' XXAXZI - 3000. '
Minima aujcing height (•)
IXMINZI) Default: 20. ' XMINZI - 20. '
Default wind speed profile power-law
exponents for stabilities 1-6
IPUCOiei) Default : ISC RURAL values
ISC RURAL : .07, .07, .10, .15. .35. .55
ISC URBAN : .15. .15. .20, .25, .30, .30
Stability Claaa .-A B C D E p
-------
1 PLXO « 0.07. 0.07, 0.10, 0 15, 0.35. 0.55
Default potential tescmrature gradient
for •table classes E, F
-------
constant emission parameters IMPT1) No default ' NPT1 • 1 '
•r of pome aources with
variable emission parameter* (HPT2) Mo default > NPT2
(IE NPT2 > 0. the variable point
source emiasions are read from
the file PTEMARB.DAT)
Subgroup (13b>
POINT SOURCE DATA FOR SOURCES WITH CONSTANT EMISSION PARAMETERS
b c
Source X UTM Y UTK Stack Baae Stack Exit Exit Bldg. Emission
No. Coordinate Coordinate Height Elevation Diameter Vel. Temp. Dwash Rates
Ikx) (KB) (•) (ml (m) (m/s) Ideg. K) (g/sl
1 I X • 0., 0., 15.8, 212.1. 9.12, 0.183, 942.. 1., 1.00 !
-------
Each pair of width and height values la treated «s a aeparate input
subgroup end therefore must end with an input group terminator
INPUT GROUPS: 14a. 14b, He — Area aouree parameters
Subgroup (14a)
Number of polygon area aourcea with
conatant eeuaaion parameters (NAR1) No default '. NAK1 • 0
Number of buoyant polygon area aoureea
with variable location and emiaaion
parameters INAR2) No default ' HAR2 • 0
IIf NAR2 > 0, AIA variable area aouree
data are read from the file: BAEMARB.DAT)
Subgroup '14bl
a
AREA SOURCE DATA FOR SOURCES WITH CONSTANT HUSSION PARAMETERS
b
Source Effect. Baae Initial Emiaaion
No. Height Elevation Sigma i Rates
(») (ml !•) fg/s/B-2)
Data Cor each source are treated as a aeparate input subgroup
and therefore auat end with an input group terminator.
b
1 enuaaion rates must be entered (one for every pollutant) .
Enter emission rate of zero for secondary pollutants.
Subgroup (He)
COORDINATES (UTM-km) FOR EACH VERTEXI4) OP EACH POLYGON
Source a
No. Ordered list of X followed by liat of Y, grouped by aource
-------
Data for «ach aource are treated as a separate input subgroup
and therefore Must end with an input group terminator.
INPUT GROUPS: 15*, 15b — Line source parameters
Subgroup (15a)
Number of buoyant line sources (NLINES) No default ! NLINES - 0
number of segments used to model
each line (KXNSEG) Default: "I ! KXNSEG > 7
The following variables are required only if KLINES > 0. They are
used in the buoyant line source plume rise calculations.
Number of distances at which Default: 6 ! NLRISE - 6
transitional rise is computed
Average line source length (XL) No default ! XL • 0. '
(in meters)
Average height of line source height (KBL) No default ! KBL • 0. '
(in metera>
Average building width (MBL) No default ' WBL • 0. '
(in meters)
Average line source width (HML) No default ! WML • 0, '
(in meters)
Average aeparation between buildings (DXL) No default ! OXL • 0 .'
(in meters)
Average buoyancy parameter (PPRDCEL) No default ' PPRIMKL • 0.
(in m*M/s**3)
Subgroup (15b)
BUOYANT LINE SOURCE DATA
Source Beg. X Beg. Y End. X End. Y Release Base Emission
No Coordinate Coordinate Coordinate Coordinate Height Elevation Rates
<>»> <*») <*•>> (km) <•) (m) <0/,(
-------
Data for each «ourc« are treated as a separate input aubgroup
and therefore must end vith an input group terminator
1 emission rates Must be entered (one for every pollutant)
Enter emission rate of xero for eecondary pollutanta.
INPUT GROUPS: 16a t 16b — volume source parameters
Subgroup (16a)
NuBbar of volume aourcea with
constant emission parameters (NVL1I No default ! NVL1 - 0
Gridded volume aource data
uaed ? (IGRDVL)
0 » no
1 • yee (ffridded voluew aource
eeiiaaiona reed froei the file:
VOLBI.DAT)
HO default ! ICRDVL • 0
The following paraaetera apply to the data in the
gridded volume aource eauaaiona file (VOLIK.DKT!
Effective height of emissions
(VEFPHT) in meters
No default ! VEFFHT
- Initial aigsia y (VSICYI) in
meters
No default ! VSICYI - 0. !
- Initial aigma I (VSICZI) in
neters
No default ! VSIGZI • 0. '
Subgroup (1Kb)
VOLUME SOURCE DATA — CONSTANT HUSSION PARAMETERS
X UTH Y UTM If feet. Base Initial Initial
Coordinate Coordinate Height Elevation Sigma y Sigma i
(km) (tat} (•) (m) (•} In)
b
Emission
Ratea
(g/s)
-------
Dmt* tor each source are treated u • separate input subgroup
and therefore Bust end with an input group terminator
b
1 .suasion rates must be entered (on« tor every pollutant I .
Enter emission rate of zero for secondary pollutant!.
INPUT GROUPS: 17a t lib -- Non-gridded (di»cr«t») receptor information
Subgroup (17a)
Number of non-gridded receptor! (NRECI No default ' NREC • IS
'.BID'.
Subgroup (I7b)
HOW-CKIDOED (DISCRETE) RECEPTOR DATA
X trm Y DIM Ground
Receptor Coordinate Coordinate Elevation
Ho. I")
1 ! X - 0.1. 0., 213.400! !EHD!
2 < X • 0.2. 0.. 225.«00! 'END'
3 ! X - 0.3. 0.. 231.600' .'END!
4 > X • 0.4, 0.. 231.600' 'END'
SIX- 0.5. 0.. 268.200! !END'
6 ! X - 0.6, 0., 304.100' IBID'
7 ! X - 0.7. 0., 323.100' !END!
8 ! X • 0.8, 0.. 353.600! !EHD'
9 ! X - 0.9. 0.. 353.600! !END!
10 ' X - 1.. 0., 353.600' 'END'
11 ! X • 1.25, 0.. 359.700! !END>
12 ! X • 1.5. 0., 365.800! !EWD>
13 ! X - 1.75, 0.. 365.800' !END'
14 ! X • 2., 0., 371.900.' .'END'
15 ! X • 2.25, 0.. 384.000' !END'
16 ! X - 2.5. 0., 384.000' !END>
17 I X - 3., 0., 408.400! IEND'
18 ! X " 4., 0., 420.600! IEND!
19 ! X - 5.. 0., 415.400! !END!
20 ! X - 7.5, 0., 408.400! !END!
21 ! X - 10., 0., 426.700' IEND!
22 I X • 15., 0., 420.000! I END'
23 ! X - 20., 0., 420.000! !END!
24 ! X - 30., 0.. 420.000' 'END!
25 ' X - 40.. 0., 420.000' !END'
26 I X - 50., 0., 420.000' !END!
-------
Data for each source are created as a separate input subgroup
and therefore auat end with an input group terminator.
b
1 emission rates aust be entered lone for every pollutant) .
Enter emission rate of L--O for secondary pollutant!-
INPUT GROUPS: 17a fc 17b — Non-gridded (diacrete) receptor information
Subgroup (17a)
Number of non-gridded receptor! IHREC) No default '. NREC > 26
SEND!
Subgroup U7b)
HON-GRIDDED (DISCRETE) RECEPTOR DATA
X DTN Y DTM Ground
Receptor Coordinate Coordinate Elevation
No. I km) (km) (•)
1 I X - 0.1, 0.. 213.400! !END'
2 ! X • 0.2. 0., 229.600! !EHD!
3 ! X - 0.3, 0., 231.600! !EHD'
< ! X - 0.4. 0., 231.600! .'END'
SIX- O.S. 0., 268.200! 'END!
6 ! X - 0.6. 0., 304.800! IEND!
7 ' X - 0.7, 0.. 323.100' !ESD!
8 ! X • 0.8. 0., 353.600! !EHD>
9 ! X - 0.9. 0., 353.600! IEND!
10 ! X • 1., 0., 353.60u' IEND'
11 ! X . 1.25. 0., 359.700! !END!
12 ! X - 1.5, 0., 365.800! !END'
13 ! X - 1.75, 0., 365.800! IEND!
14 ! X - 2., 0., 371.900! !EHD!
15 ! X - 2.25, 0., 384.000! !END<
16 ! X - 2.5. 0.. 384.000! IEHD!
17 I X - 3.. 0., 408.400! IEND'
18 I X - 4., 0., 420.600! IEND!
19 I X - 5.. 0.. 415.400! IEND!
20 ! X - 7.5, 0., 408.400! IEND!
21 I X - 10., 0., 426.7001 (END!
22 I X - IS., 0., 420.000.' (END!
23 I X - 20., 0., 420.000! IEHD!
24 ! X - 30., 0., 420.000! .'END!
25 ! X - 40.. 0.. 420.000! !END!
26 ! X - 50.. 0., 420.000! IEND'
-------
D*ta for each receptor are treated *s • eeparate input subgroup
*nd therefore Bust end with en input group terminator
-------
ATTACHMENT IH-3
Comparison oflSC-COMPDEP Modeling to CALPUFF Modeling for the
Fire Scenarios Considered in the WTI Accident Analysis
Volume VIII
-------
September 12, 1996
MEMORANDUM
To: Ann Anderson, A.T. Kearney
From: Steve Washburn, ENVIRON
Lynne Fosberry, ENVIRON
Subject: Comparison of ISC-COMPDEP Modeling to CALPUFF Modeling for the
Fire Scenarios Considered in the WTI Accident Analysis (Revised)
We have reviewed EARTH TECH's CALPUFF modeling of calm/inversion meteorological
conditions for the fire scenarios considered in the External Review Draft of the WTI Accident
Analysis, and have compared the results to the ISC-COMPDEP modeling of conservative
meteorological conditions, as previously conducted by EARTH TECH. We propose that this
comparison be incorporated into Chapter Vn (Uncertainties) of Volume VII.
4. Effect of Emissions from Fire Scenarios under Calm/Inversion Meteorological
Conditions
As discussed in Chapter V, the ISC-COMPDEP model was used to evaluate off-site
concentrations resulting from accidental fires under both typical and conservative
meteorological conditions. However, ISC-COMPDEP is not appropriate for use when
evaluating atmospheric dispersion of releases from accidental fires under calm/inversion
conditions, because the basic Gaussian steady-state assumptions of the model become invalid.
In order to evaluate the potential effect of emissions from the WTI fire scenarios under
calm/inversion meteorological conditions, as recommended in the Peer Review Panel
comments (U.S. EPA 1996), a sensitivity analysis was performed using the CALPUFF model
(Scire et al., 1995). The CALPUFF model is capable of modeling buoyant releases under
calm meteorological conditions, as well as accounting for complex terrain, building wake
effects and time-varying emissions. A more detailed description of the CALPUFF model, and
its use in evaluating calm/inversion conditions for tie fire scenarios, is presented in
Volume VIII. As discussed in Volume VIE, the following fire scenario's were modeled using
CALPUFF assuming calm/inversion meteorological conditions:
-------
-2-
• On-Site Fire, Unmitigated Conservative (Large Fire);
• On-Site Fire, Mitigated Conservative (Large Fire);
• On-Site Fire, Unmitigated Typical (Small Fire);
• Off-Site Fire, Unmitigated Conservative (Large Fire); and
• Off-Site Fire, Unmitigated Typical (Small Fire).
The calm/inversion meteorological conditions are represented by the CALPUFF model as zero
wind speed for the first hour followed by a screening meteorological condition of 54
combinations of wind speed and stability for the remaining duration of the fire. This
representation of the calm/inversion meteorology for the fire scenarios is slightly different than
for the spill and mixing of incompatible waste scenarios, which involved vapor accumulation
for one hour followed by a low wind speed for the remaining duration of emissions. The
screening meteorology was used for the fire scenarios due to the possibility that higher wind
speeds may bring a buoyant plume down to ground-level more quickly, and thus result in
higher off-site concentrations.
The maximum one-hour average concentration factors O^g/m3 per g/s) for the CALPUFF
modeling under the calm/inversion conditions are compared to the results of the ISC-
COMPDEP modeling under conservative meteorological conditions in Table VII-11.
Concentration factors for the CALPUFF modeling are presented as a function of downwind
distances hi Earth Tech's "CALPUFF Modeling of Accidental Fires During Calm Wind
Scenarios." The concentration factors can be multiplied by the chemical-specific emission rate
to obtain the maximum one-hour average off-site air concentration. The one-hour average
concentrations are then multiplied by a factor of 1.15 (as discussed in Section E.6 (b) of
Appendix VII-4) to convert a one-hour average concentration to a 30-minutes average
concentration so that a direct comparison can be made to the IDLH and LOC values. The
resulting distances to the IDLH and LOC values for the ISC-COMPDEP (for conservative
meteorological conditions) and CALPUFF (for calm/inversion meteorological conditions)
modeling are summarized hi Table VII-12.
As shown in Table VII-12, for the typical (small) on-site and off-site fire scenarios and for the
mitigated conservative (large) on-site fire scenario, IDLH and LOC values are not exceeded by
concentrations modeled using either the ISC-COMPDEP (for conservative meteorological
conditions) or CALPUFF (for calm/inversion meteorological conditions). Therefore, the
severity of consequence ranking for these scenarios would be "minor" under both the calm/
inversion and conservative meteorological conditions.
For the unmitigated conservative (large) on-site fire scenario, the IDLH value for hydrogen
chloride is predicted by the CALPUFF modeling to be exceeded for a small area within a
down-wind distance of approximately 120 meters of the fire. Since the distance from the fire
to the fenceline is approximately 75 meters, the distance beyond the fenceline for which the
IDLH value for hydrogen chloride may be exceeded is 45 meters. This event would thus be
classified as having a "moderate" severity of consequence ranking. The ISC-COMPDEP
modeling of conservative meteorology did not result in concentrations exceeding IDLH values,
-------
-3-
corresponding to a "minor" severity of consequence ranking. The probability of occurrence
for both the conservative and the calm/inversion meteorological conditions is "very unlikely,"
however, the frequency of occurrence would be lower for calm/inversion conditions than for
conservative meteorological conditions. The area over which LOC values are predicted to be
exceeded is larger for the CALPUFF modeling of calm/inversion conditions than for the
ISC-COMPDEP modeling of conservative conditions.
For the unmitigated conservative (large) off-site fire scenario, the CALPUFF modeling under
calm/inversion meteorological conditions results in off-site air concentrations which do not
exceed either the IDLH or the LOC values. By comparison, the ISC-COMPDEP modeling of
conservative meteorological conditions resulted in concentrations exceeding both IDLH and
LOC values. Thus, the severity of consequence ranking for this scenario would change from
"major", based on the ISC-COMPDEP modeling, to "minor" based on the CALPUFF
modeling.
Table VII-13 summarizes the severity of consequence ranking for the fire scenarios under
calm/inversion meteorological conditions, based on the CALPUFF modeling.
01-3999CWP\2479 2.WPD
-------
-4-
TABLE VIM1
Summary of Maximum Concentration Factors Modeled by the
ISC-COMPDEP and CALPUFF Models for the Fire Scenarios
Scenario
On-Site Fire, Unmitigated
Conservative (Large Fire)
On-Site Fire, Mitigated
Conservative (Large Fire)
On-Site Fire, Unmitigated Typical
(Small Fire)
Off-Site Fire, Unmitigated
Conservative (Large Fire)
Off-Site Fire, Unmitigated Typical
(Small Fire)
SpUl Area (m2)
180
180
75.7
735
37.9
Duration(s)
7030
600
170
430
170
Maximum One-hour Average
Concentration Factor
(Mg/m3 per g/s)
ISC-COMPDEP,
Conservative
Meteorological
Conditions'
63.4
NC'
NC
218.1
NC
CALPUFF,
Calm/Inversion
Meteorological
Conditions2
201.6
0.60
0.23
0.15
1.22
Notes:
1 Tables 16 and 17 of Appendix VIM.
2 CALPUFF Modeling of Accidental Fires During Calm Wind Scenarios, EARTH TECH.
3 NC = Not calculated:
-------
-5-
TABLE VII-12
Comparison of Downwind Distances1 to the IDLH and LOG Values Modeled
by the ISC-COMPDEP and CALPUFF Models for the Fire Scenarios
On-Site Fire, Unmitigated
Conservative (Large Fire)2
On-Site Fire, Mitigated
Conservative (Large Fire)2
On-Site Fire, Unmitigated
Typical (Small Fire)
Off-Site Fire, Unmitigated
Conservative (Large Fire)
Off-Site Fire, Unmitigated
Typical (Small Fire)
Distance to IDLH (m)
ISC-COMPDEP,
Conservative Meteorological
Conditions
3
...
—
100-125 (Phosgene)
100 - 275 (HC1)
—
CALPUFF, Calm/Inversion
Meteorological Conditions
25 - 45 (HCI)
(IDLH not exceeded for
phosgene)
—
—
—
—
Distance to LOC (m)
ISC-COMPDEP,
Conservative Meteorological
Conditions
675- 1125 (HCI)
(LOC not exceeded for
phosgene)
—
...
100- 1100 (Phosgene)
100 - 2100 (HCI)
—
CALPUFF, Calm/Inversion
Meteorological Conditions
25 - 1465 (Phosgene)
25 -24 10 (HCI)
—
—
—
—
Notes:
1 Modeling was performed for distances beyond 100 meters from the source.
2 Distances from the on-site fires are measured from the fenceline, which is approximately 75 meters from the center of the source.
3 Did not exceed the criteria for either phosgene or HC1.
-------
-6-
TABLE VII-13
Severity of Consequence for the Fire Scenarios
Under Calm/Inversion Meteorological Conditions
Scenario
Severity of Consequence
On-Site Fires
20,000 Gallons of Waste (Large Fire)
200 Gallons of Waste (Small Fire)
Moderate1
Minor2
Off-Site Fires
5,000 Gallons of Waste (Large Fire)
Minor3
100 Gallons of Waste (Small Fire)
Minor4
Notes:
On the basis of potential HCI and phosgene emissions, the 20,000-gallon on-site fire
under calm/inversion meteorological conditions is judged to have moderate
consequences. Given the potential heat effects, the event would be judged to have
minor consequences. In the event of a fireball, the severity of consequence would be
classified as major; however, the potential for a fireball is very low.
On the bases of potential HCI and phosgene emissions, heat effects and assumed fireball
formation, the 200-gallon on-site fire under calm/inversion meteorological conditions is
judged to have minor consequences.
On the basis of potential HCI and phosgene emissions, the 5,000-gallon off-site fire
under calm/inversion meteorological conditions is judged to have minor consequences.
Given the potential heat effects, the event would be judged to have moderate
consequences. In the event of a fireball, the severity of consequence would be
classified as major; however, the potential for a fireball is very low.
On the basis of potential HCI and phosgene emissions, the 100-gallon off-site fire under
calm/inversion meteorological conditions is judged to have minor consequences. Given
the potential heat effects of the fire, the event would be judged to have moderate
consequences. In the event of a fireball, the severity of consequence would be
classified as moderate; however, the potential for a fireball is very low.
01-3999C:WP\2479 2 WPD
-------
ATTACHMENT IV-1
Evaluation of the Use of ERPG-2 Values vs. LOC Values in the Accident Analysis for the
WTI Facility
Volume VIII
-------
EVALUATION OF THE USE OF ERPG-2 VALUES VS. LOG VALUES
WASTE TECHNOLOGIES INDUSTRIES
EPA ID NO. OHD980613541
Submitted to
Dr. Mario Mangino
Work Assignment Manager
U.S. Environmental Protection Agency
Region V
77 West Jackson Boulevard
Chicago, Illinois 60604
Submitted ty
A.T. Kearney, Inc.
222 West Adams Street
Chicago, Illinois 60606
and
ENVIRON International Corporation
4350 North Fairfax Drive
Arlington, Virginia 22203
Work Assignment No.
Contract No.
Kearney WAM
Telephone No.
EPA WAM
Telephone No.
R05002
68-W4-0006
Amv Anderson
312/223-6230
Mario Mangino
312/886-2589
June 26. 1996
-------
TECHNICAL MEMORANDUM
EVALUATION OF THE USE OF ERPG-2 VALUES VS. LOC VALUES
IN THE ACCIDENT ANALYSIS FOR THE WTI FACILITY
INTRODUCTION
The WTI Accident Analysis evaluates the potential for acute health effects that may result
from various accident types which could occur at the WTI facility. The severity of
consequences in the accident analysis was characterized using the Immediate Dangerous to
Life and Health (IDLH) and Level of Concern (LOC) values. In the Peer Review Panel
comments, it was suggested that the Emergency Response Planning Guideline, Tier 2
(ERPG-2) values developed by the American Industrial Hygiene Association (AIHA) may be
more appropriate toxicity criteria than IDLH or LOC values for evaluating irreversible health
effects. This technical memorandum is prepared to compare available ERPG-2 values to the
LOC values for chemicals modeled in the original Accident Analysis and the expanded fire
analysis.
THE ERPG-2 VALUES
According to AIHA, the ERPG values are intended to provide estimates of concentration
ranges above which one could reasonably anticipate observing adverse effects. Three tiers of
ERPG values are listed by AIHA based on the consequence of exposure to a specific substance
(AIHA 1994).
• The ERPG-1 value is the maximum airborne concentration below which it is believed
nearly all individuals could be exposed for up to 1 hour without experiencing other
than mild transient adverse health effects or perceiving a clearly defined objectionable
odor.
.1.
-------
• The ERPG-2 value is the maximum airborne concentration below which it is believed
nearly all individuals could be exposed for up to 1 hour without experiencing or
developing irreversible or other serious health effects or symptoms that could impair
their abilities to take protective action.
• The ERPG-3 value is the maximum airborne concentration below which it is believed
nearly all individuals could be exposed for up to 1 hour without experiencing or
developing life-threatening health effects.
The Peer Review Panel suggested that ERPG-2 values may be appropriate for evaluating the
off-site consequences of events considered in the WTI Accident Analysis.
COMPARISON OF THE ERPG-2 VALUES TO THE LOC AND IDLH VALUES
The ERPG values for 45 chemicals are currently available from AIHA. Table 1 compares the
available ERPG-2 values to the IDLH and LOC values for the chemicals addressed in the
original Accident Analysis and the expanded fire scenarios. Currently, only five chemicals of
these chemicals have ERPG-2 values. With the exception of methanol, the ERPG-2 values are
equal to or higher than (i.e., less stringent) the respective LOC values. Thus, the ERPG-2
values generally fall between the LOC and IDLH values, and the LOC values are generally
more stringent than the ERPG-2 values for public health protection.
THE IMPACT ZONES DEFINED BY THE ERPG-2 VALUES
Based on the comparison described above, the size of the off-site impact zones estimated to
exceed the ERPG-2 values would be generally smaller that those defined by the LOC values.
For the chemicals evaluated in the WTI Accident Analysis, a possible exception is methanol,
for which the ERPG-2 value is less than the LOC value. Tables 2 and 3 show the estimated
off-site methanol concentrations for the two fire scenarios involving methanol emissions. As
shown in Tables 2 and 3, the ERPG-2 value (1,000 ppm) for methanol will not be exceeded
during a fire accident due to methancl's low acute toxicity. Thus, use of the ERPG-2 value in
+*•
place of the LOC value would have no effect on the evaluation.
-------
REFERENCES
American Industrial Hygiene Association. 1994. Emergency response planning guidelines.
Prepared by the Emergency Response Planning Committee of the American Industrial
Hygiene Association.
United States Department of Health and Human Services, Public Health Service, National
Institute for Occupational Safety and Health (NIOSH). 1994. NIOSH pocket guide w
chemical hazards. DHHS (NIOSH). Publication No. 94-116.
United States Environmental Protection Agency (U.S. EPA). 1995. Supplemental
Information for Task 03. Letter from C. Bogard. Region 5 RCRA Permitting Branch, to
A. Anderson, A.C. Kearny, Inc. March 14, 1995.
-------
TABLE 1
Comoarison of ERPG-2 Values to the LOG and IDLH Values
fh^miral
Acetone
Cresols
Dimethyl sulfate
Dimethylhydrazine
Formaldehyde
Hydrazine
Hydrogen chloride
Hydrogen fluoride
Methanol
Methyl ethyl ketone
2-Nitropropane
Phosgene
Toluene
Toluene-diisocyanate*
ERPG-23
Ippm)
NA1
NA
NA
NA
10
NA
20
20
1000
NA
NA
0.2
NA
NA
LOG4
Innm)
1960
24.4
1
4.8
9.6
7.5
9.9
1.9
2450
294
226
0.2
1%
1
IDLH'
ippm*
2442
244
60
14.8
19.6
49.1
49.1
294
5890
2940
98.2
2
491
2.5
Notes:
1 NA = Not available.
2 As toluene-2,4-diisocyanate
3 AIHA 1994
4 USEPA 1995
5 NIOSH 1994. For chemicals without an IDLH value, but for which a level of concern (LOG) value has been
established, the IDLH value was provided by USEPA (1995) as 10 times the LOG.
-4-
-------
TABLE 2
Maximum Methanol Concentrations for the
Conservative Unmitigated On-Site Fire Scenario
Downwind
Distance
(m)
100
200
300
400
500
600
700
800
900
1000
1250
1500
1750
2000
1 ^
2500
3000
4000
5000
7500
10000
15000
20000
30000
40000
50000
Concentration1' (ppm)
Expanded Fire Scenario
DE3 = 99%
O.OOe-fOO
O.OOe+00
5.63e-04
1.57e-02
3.38e-02
3.82C-02
3.55e-02
7.94e-01
6.76e-0l
5.87e-01
4.30e-01
3.33e-01
2.72e-01
2.24e-01
1.85e-01
1.61e-01
l.lSe-01
7.80e-02
5.92e-02
3.54e-02
2.29e-02
1.36e-02
9.42e-03
5.61e-03
3.92e-03
2.97e-03
Notes:
1 ERPG-2 for methanol = 1000 ppm
2 All concentrations are less than the ERPG-2 value
3 DE: Destruction efficiency
Expanded Fire Scenario
DE = 90%
O.OOe-i-00
O.OOe-i-00
5.63e-03
1.57e-01
3.38e-01
3.82e-01
3.55e-01
7.94e-t-00
6.76e+00
5.87e+00
4.30C-I-00
3.33e-t-00
2.72e+00
2.24e+00
1.85e+00
1.61e+00
l.lSe+00
7.80e-01
5.92c-01
3.54e-01
2.29e-01
1.36e-01
9.42e-02
5.61e-02
3.92e-02
2.97e-02
-------
TABLE 3
Maximum Methanol Concentrations for the
Conservative Unmitigated Off-Site Fire Scenario
Downwind
Distance
-------
ATTACHMENT IV-2
Letter from the Hessisches Ministerium Fiir Umwelt, Energie, Jugend, Familie and
Gesundheit
Volume VIII
-------
HESSISCHES MINISTERIUM
FUR UMWELT, ENERGIE,
JUGEND, FAMILIE UND
GESUNDHEIT
Hess Mimstenum fur Umv ;!, Encrgie, Jugend, Familie und Gesundheit
Postftch 31 09 • D-65021 Wiesbaden
Mr Gary Victorine, Engineer
U. S. EPA Region 5 (DRP-8J)
77 West Jackson Boulevard
Chicago IL 60604-3590
USA
Aktenzeichen (Bine bei Antwort angeben)
Il5.1-53e411.17 2133/96
Bearbeiter/m
Durchwahl
Dir Zeichen
Dire Nachncht vom
Datum
Frau Schickel
815-1223
. Marz 1997
Incineration plants
Your letter from 15.11.1996; DRP-8J;
Waste incineration plant in Biebesheim of the Hessische Industriemull GmbH (HIM);
Myletterfrom 17.12.1996; Az.: 115.l-53e411.17 2133/97
Dear Mr Victorine,
in december I announced you to collect events which happened at the incineration plant in Biebesheim
in the last years.
Now we have made a tabel which contains all the events from 1985 to 1995. You will receive an english
version and a german version of the tabel. Sometimes it is difficult to find the specific technical
expression I was not able to find an english expression for example for ,,Drehrohr" or
,,NaBentschlacker". Maybe the original german tabel will be helpful
I hope you will find all the required information
So far as I can tell there were no injuries either on-site or off-site of the plant But often there were
some emissions, maybe they could be noticed by the neighbourhood.
Sincerely,
Im Auftrag
&
(Dr Rossner)
Bute Besuchc und Anrufe von Mo -.Do zwischen 8 30-12 00 und 13 30-15.30 Uhr. Fr von 8 30-12 00 Uhr oder nach Verembarung
Besuchem wird empfohlen, zur Anreise offenthche Verkehrsmittel zu benut/.en
Bereich Umwelt, Energie
Main/ci Slraftc 80 D-65189 Wiesbaden Telelbn (06 11) 8 1 5-0 Telefax (06 1 1) X 15 19 41 'lelex 4 1 X la 1 1 IIMUh 1)
-------
Breakdowns at the waste incineration plant in Biebesheim
Mr.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
V
18
19
20
21
22
Date
0901 1985
24041985
21 051985
12081985
21.091985
22.09.1985
05101985
15101985
1811.1985
2011 1985
05121985
1612.1985
10.041986
06.05.1986
11.08.1986
16.08.1986
02.05.1987
1711 1987
02.01 1988
0601.1988
08.01.1988
14.03.1988
Place of
breakdown
dosage
wet deslag
(Nafientschlacker)
bunker
bunker
bunker
bunker
bunker
bunker
wet deslag
bunker
bunker
bunker
scrubber
bunker
wet deslag
Bunker
railway carriage extinguish
Drehrohr
Saugzug (suction train)
source of current
Saugzug
Nachbrennkammer
Species of breakdown
fire in the funnel (street 1 )
the fire fighting device was frozen
explosion in the Nalientschlacker (street 2),
damage to property
fire in the bunker
fire in the bunker
fire in the bunker
fire in the bunker
little fire in the bunker
fire in the bunker
explosion im Nalientschlacker (street 1)
fire in the bunker
fire in the bunker
fire in the bunker
pump-defect in the SO2-scrubber; the incineration plant
was switched off
fire in the bunkerbrand and subsequent there was a fire
of cables
explosion in the Nalientschlacker; 17.20 Uhr
fire in the bunker
Tire in a railway-waggon which contained barrels with
dangerous waste from the collecting in households (like
little amounts of agricultural pesticide or spray bottles);
the cause for the fire is probably self-inflammation of
some poison
fire In the Drehrohr (street 2);
cause: short-circuit; destroying of measuring appliance
street 2. Saugzugausfall (disturbance of the
electronics), no emission
street 1 and 2, cause: error in the source of current
street 1 and 2, Saugzugausfall, error of the electronics;
no emission
Nachbrennkammer is plugged with slag; cause high
temperature during incineration-tests with waste
containing PCS
Period
ca. 1 hour
some minutes
10 minutes
5 minutes
3 hours 1 5 minutes
5 minutes
cause
beams wedged in the hopper which is used to
put in waste
probably barrels containing agricultural
pesticide
probably dangerous waste from the collecting in
households
probably dangerous waste from the collecting in
households
probably dangerous waste from the collecting in
households
probably self-ignition
probably dangerous waste from the collecting in
households
probably dangerous waste from the collecting in
households
cause. unknown
probably dangerous waste from the collecting in
households
probably dangerous waste from the collecting in
households
probably dangerous waste from the collecting in
households
pump-defect (SO2-scrubber)
probably waste containing a lot of solventl
cause: unkonown
Cause: unknown
self-ignition
there was no source of current
disturbance of the electronics
there was no source of current
disturbance of the elektronics
very high temperature in the Nachbrennkammer
and in the Drehrohr
-------
Nr.
23
24
25
26
27
28
29
30
31
32
33
34
35
35
37
38
39
40
41
42
43
44
45
V
46
47
48
49
50
51
Date
1904.1908
16051988
17051988
3005.1988
30061988
22071988
26.091988
08121988
15.12.1988
02.02.1989
0611.1989
07.11.1989
0501.1990
03021990
1002.1990
1902.1990
26.03.1990
0305.1990
0605.1990
15.05.1990
2905.1990
1706.1990
20.06.1990
26.06.1990
26061990
01.08.1990
0208.1990
26.08.1990
28081990
Place of
breakdown
source of current
Saugzug
Saugzug
source of current
source of current
source of current
turbine
source of current
source of current
source of current
bunker
bunker
chimney
source of current
source of current
chimney
wide open space
source of current
source of current
source of current
source of current
chimney
bunker
source of current
chimney
source of current
steam boiler
source of current
source of current
Species of breakdown
street 1 and 2, problem with tension; no emission
street 1 , the Saugzug was out of action, cause.
unknown, no emission
street 1 , the Saugzug was out of action, no emission
there was no source of current, the incineration plant
was stopped automatically
there was no source of current
the generator is out of action because of a lightning; no
emission
the incineration plant is out of action because of
problems by electricity for the turbine;
there was no source of current
there was no source of current
there was no source of current
there had almost been a fire in the bunker because of
some special waste, some emission of solvent,
ca. 1 hour
self-ignition of some waste which belonged to the
incineration plant since 6.1 1 .1 989
red-coloured emission out of the chimney
Saugzugausfall because of problems by the tension
Saugzugausfall because of problems by the tension
pink-coloured emission out of the chimney
Tire by degradation of the old scrubber for flue gases
Saugzugausfall; the incineration plant was out of action
Saugzugausfall (lightning)
Saugzugausfall because of an error of the cooling
system
Saugzugausfall
brown-coloured emission
Tire in the bunker containing solid waste, probably self-
ignition
Saugzugausfall because of an error by the air-
conditioning system
jodine or bromemission, waste collected in households:
for example agricultural pesticide
Saugzugausfall because of an error by the cooling
system (Simovert Schrank)
blistered tube in the steam boiler, emission,
lightning, the incineration plant worked without solid
wastel (If there is a lightning the input of solid waste is
stopped ;no emission
Saugzugausfall (lightning)
Period
5 minutes
5 minutes
5 minutes
32 minutes
40 minutes
1 minute
5 minutes
1 0 minutes
3 minutes
2 minutes
1 hour
8 minutes
1 0 minutes
ca. 1 hour
40 minutes
cause
there was no source of current
error in the electronics
error in the elektronics
there was no source of current
there was no source of current
lightning --> there was no source of current
disturbance in the electronics of the turbine
there was no source of current
there was no source of current
Erdschluli
the composition of the waste is unknown
the composition of the waste is unknown
input
there was no source of current
there was not always source of current
barrels of laboratory chemicals
danger by welding -works
the incineration plant was out of action
lightning
error of the cooling system
cause: unknown
probably waste containing brom
probably self-ignition
error by the air-conditioning system
error am Referenzgerat fur Brombestimmung
bei Identitatsanalyse
error by the cooling system
materialfailure
there was no source of current
there was no source of current
-------
Nr.
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
>k
70
71
72
73
74
75
Date
0211 1990
0611.1990
1001 1992
0402.1992
19021992
1303.1992
18.03.1992
21.03.1992
23.03.1992
21 05.1992
2305.1992
02.07.1992
14.07.1992
20.081992
13.04.1993
02.061993
08.061993
20.10.1993
V
08.07.1994
28.11 1994
20.06.1995
2906.1995
0708.1995
07121995
Place of
breakdown
Spruhabsorber
source of current
source of current
emergency power
burner for fuel oil
Saugzug
Saugzug
Saugzug
electrostatic filter
bunker
Saugzug
Saugzug
bunker
source of current
source of current
Saugzug
Saugzug
Nafientschlacker
Faftabsaugung
burner for fuel oil;
emergency power
Kastenbeschicker
Kastenbeschicker
Kastenbeschicker
source of current
Species of breakdown
emission out of the Spruhabsorber by service works (in
the incineration plant there was no waste but fuel oil)
Saugzugausfall because of an error by the cooling
system (Simovert)
Saugzugausfall; the incineration plant was out of action
there was no source of current
carbon formation because of a badly adjusted burner;
emission (street I)
the Saugzug of street I was out of action, the
incineration plant was for short time out of action
the Saugzug of stree I was out of action
the Saugzug of stree was out of action, disturbance of
the Simovert
the electrostatic filter was automatically out of action
because of peaks of CO, both streets were stopped. If
there may happen an explosion the electrostatic filter will
go out of action. There was waste of unknown
composition
RUckzUndung out of the Orehrohr in the bunker
the Saugzug of street I was out of action for a short
time; disturbance of the Simovert by lightning
the Saugzug of street I and II were out of action, there
was no source of current because of lightning
fire in the bunker because of some special waste
there was no source of current because of lightning
there was no source of current
the Saugzug was out of action because of a vacuum-
turn
the Saugzug was out of action (street I and
ll);operating-error
explosion in the Na&entschlacker II; flue gases in the
area of the bunker.
development of nitrous gas out of som barrels (ph value
4 and ph value 1 4)
disturbance of the burner for fuel oil, then the vapour
pression of the turbine was low. Subsequent there was
no source of current by failure; no emissionen because
there was no waste-input
explosion
explosion
explosion
fire
Period
5 minutes
1 0 minutes
35 minutes
3 minutes
5 minutes
1 minute
ca. 3 hours
5 minutes
ca. 3 hours
3 minutes
3 minutes
5 minutes
13 minutes
ca 1 hour
cause
Zu schnelles Ziehen des Reaktoskonusses
(SprUhabsober)
error by the cooling system
the incineration plant was out of action
there was no source of current
error by the fuel oil burner
cause, unknown
error: source of current
disturbance of the Simovert
some barrels
cause: unknown
lightning
there was no source of current because of
lightnimg
waste containing solvents
there was no source of current
there was no source of current
regulation of the vacuum for the filter
regulation of the vacuum for the filter
steam
waste containing nitrite
an engine was defect and failure
probably waste containig solvente
probably waste containig solvente
probably waste containig solvente
probably the switch for capacity was defect
-------
ATTACHMENT IV-3
Evaluation of Emissions from Spills Under Extremely Low Wind Speeds.
Volume VIII
-------
EVALUATION OF EMISSIONS FROM
SPILLS UNDER EXTREMELY LOW WIND SPEEDS
USING ALTERNATIVE EVAPORATION MODELS
WASTE TECHNOLOGIES INDUSTRIES
EPA ID NO. OHD980613541
TASK 03E DELIVERABLE
Submitted to
Dr. Mario Mangino
Work Assignment Manager
U.S. Environmental Protection Agency
Region 5
77 West Jackson Boulevard
Chicago, Illinois 60604
Submitted by
A.T. Kearney, Inc.
222 West Adams Street
Chicago, Illinois 60606
and
ENVIRON International Corporation
4350 North Fairfax Drive
Arlington, Virginia 22203
Work Assignment No.
Contract No.
Kearney WAM
Telephone No.
EPA WAM
Telephone No.
R05002
68-W4-0006
Ann Anderson
312/223-6230
Mario Mangino
312/886-2589
April 16, 1996
-------
TECHNICAL MEMORANDUM
R05002 - TASK 03E
EVALUATION OF EMISSIONS
FROM SPILLS UNDER EXTREMELY LOW WIND SPEEDS
USING ALTERNATIVE EVAPORATION MODELS
WASTE TECHNOLOGIES INDUSTRIES
16 April 1996
Introduction
The WTI Accident Analysis included an evaluation of emissions from spill scenarios
under three meteorological conditions: 1) "typical"; 2) "conservative"; and 3) "calm/
inversion". A wind speed of 3.2 m/sec, which could result in higher emissions from spill
scenarios, was used in predicting emissions under both conservative and calm/inversion
conditions. In its comments on the Accident Analysis, the Peer Review Panel indicated that
evaporation models have been developed for predicting emissions under extremely low wind
speed conditions, and could be used as alternatives to the approach used in the Accident
Analysis for the inversion/calm condition. To address this comment, the Accident Analysis
scenarios that involve spills under extremely low wind speeds (i.e. the inversion/calm
condition) have been reevaluated using an alternative evaporation model provided to EPA by
the Peer Review Panel. The two spill scenarios to be evaluated are:
• Conservative (large) on-site spill of "worst-case" waste (resulting in formaldehyde
releases)
• Conservative (large) off-site spill of "worst-case" waste (resulting in formaldehyde
releases)
This technical memorandum reviews the evaporation models recommended by the Peer
Review Panel and presents the approach to be used in the reevaluatibn.
-i-
-------
Selection of Emission Model for Calm and Low Wind Conditions
Two evaporation models (Rife 1981; Gauss 1973) are selected and recommended by the
Peer Review Panel for estimating the evaporation rates under extremely low wind speeds.
The first model (Rife 1981) empirically relates the vapor evaporation rate to the air
diffusivity, the vapor pressure, and the molecular weight of a chemical by the following
equation:
Es = 0.38 D»(MW)P./P
where
Es = Vapor evaporation rate, g/min;
D,ir = Air diffusivity, cnWsec;
MW = Molecular weight, g/gmole;
P, = Partial vapor pressure of the chemical, mm Hg; and
P = Atmospheric pressure, mm Hg.
This model was developed based on laboratory evaporation experiments of six pure
chemicals placed in evaporation pans of diameters less than 8 cm (or 3.2 inches). The
model may not be applicable for estimating evaporation from larger areas (Rife 1981)
because larger surface areas could have a lower evaporation rate per unit area. In addition,
the model is only applicable to indoor environment with still air since it does not consider the
effect of wind speed on chemical evaporation (Rife 1981).
The second model (Gauss 1973) was developed semi-empirically using equations for
three dimensional diffusion and two dimensional vaporization into flowing air. This model is
applied by Rife (1981) to estimate chemical evaporation rates under low wind or calm
conditions. For evaporation from a square area, the model takes the following form:
Es = 169 (1 + 0.51 Re1/2Sc1/3) • P./P • (MW)/T • D* • /
where . '
Es = Emission rate, g/min;
Re = Reynold's number, Re = 0.03 p x It> x 104;
-2-
-------
0.03 = assumed wind speed for calm conditions (Gauss 1973). m/sec:
Sc = Schmidt number, Sc = n/pD^;
fi = Air viscosity, g/cm-sec;
p = air density, g/cm3;
/ = length of the square, m; and
Dtir, MW, P., and P are defined as before.
It is recommended by Rife (1981) that a wind speed of 3 cm/sec (0.03 m/sec) be used
for the calm condition. The model predicts a rather rapid decrease in the vapor evaporation
rate per unit area as the total area increases. This is because the experiments conducted to
develop the model used very small evaporation pans; the decrease in specific evaporation rate
observed may or may not occur as predicted for larger areas. To overcome this deficiency,
it is suggested by Rife (1981) that a 10 m2 area be used for areas greater than 10 m:.
However, users are cautioned to obtain data for larger areas to validate whether the model is
applicable.
The second model (the Gauss Model) will be used in this analysis for estimating the
evaporation rates of formaldehyde for the two spill scenarios. As recommended by Rife, the
wind speed will be assumed to be 0.03 m/sec to represent the calm condition (or extremely
low wind conditions) and the evaporation rate (in g/m2-sec) estimated for a 10 nr area will
be used to yield an estimate for areas greater than 10 m2. For low wind conditions other
than the calm condition, assumed wind speeds of up to 1 m/sec will be used in this analysis.
Estimation of Vapor Evaporation Rates
The Gauss Model will be used to estimate the evaporation rate of a formaldehyde/
methanol spill. Apparent chemical properties (except for the air diffusivity) of the mixture
will be used in the model to estimate the evaporation rate of the mixture. The air
diffusivities for different chemicals are not expected to form an apparent air diffusivity since
each chemical (formaldehyde and methanol) would move freely and independently in the air
once transferred from the liquid phase to the vapor phase. The air diffusivity of
formaldehyde will be used in the Gauss Model to yield a conservative'evaporation rate for
the mixture because the air diffusivity of formaldehyde is the greater of the two chemicals in
the mixture.
-3-
-------
The evaporation rate calculated by the Gauss Model for the fonnaJdehyde/methanol
mixture under the calm condition (assuming a wind speed of 0.03 m/sec) is calculated to be
12.8 g/min/nf (or 128 g/min per 10 nr area). Using the Gauss Model and assuming a wind
speed of 1.0 m/sec, the formaldehyde/methanol evaporation rate is calculated to be 73.9
g/min/nr . The evaporation rate under the calm condition (0.03 m/sec) is approximately 10-
fold less than the evaporation rate previously calculated in the Accident Analysis using a
"non-calm" evaporation model assuming a 3.2 m/sec wind speed (USEPA 1993, hereinafter
referred as the EPA Model). However, the evaporation rate at 1 m/sec (low wind speeds)
estimated using the Gauss Model is very similar (i.e. within 50 %) to the corresponding .
value estimated using the EPA Model. Thus the Gauss Model appears to provide results
which are consistent with those calculated using the EPA Model at wind speeds that both
models are applicable.
Off-site Air Impacts
Consistent with the Accident Analysis, the SLAB air dispersion model will be used to
estimate the downwind air concentrations resulting from the two spills defined in this
technical memorandum. The inversion/calm meteorology will be used in the analysis, along
with the evaporation rates estimated using the Gauss Model and a wind speed of 0.03 m/sec
for the calm hour. The hypothetical meteorology assumes that a temperature inversion with
conservative meteorology would occur after one hour of calm condition. The temperature
inversion is represented by a mixing height of 100 m and the conservative meteorology is
represented by the combination of low wind speed (1 m/sec) and stable atmosphere (Pasquill-
Gifford atmospheric stability F) in the SLAB model. Due to the high evaporation rate of
formaldehyde at the low wind condition (estimated using either the Gauss Model or the EPA
Model), adjustment for time-varying emissions (as performed in the WTI Accident Analysis)
is necessary to ensure that the total mass during a spill accident is conserved.
The emission rates, downwind air concentrations, and impact zones for the two worst-
case spill scenarios will be presented in the analysis and the results will be compared to the
results from the previous Accident Analysis.
-4-
-------
References
Gauss A. 1973. Fuel and hydrocarbon vaporization. BRL Report No. 1661. AD-769709.
Rife R.R. 1981. Calculation of evaporation rates for chemical agent spills. Environmental
& Safety Division. US Army Toxic and Hazardous Materials Agency. Report DRXTH-
ES-TM-81101.
United States Environmental Protection Agency (U.S. EPA), Office of Air Quality Planning
and Standards. 1993. Guidance on the application of refined dispersion models for
hazardous/toxic air releases. U.S. EPA-454/R-93-002. Research Triangle Park. NC.
-5-
-------
ATTACHMENT VI-1
Literature References and Technical Reports on
Health Effects of Hazardous Waste Incineration
SECTION 1: List of Literature References and Technical Reports on Health Effects of
Hazardous Waste Incineration
PART A: References from U.S. EPA Search
PART B: References from State of Florida Search
SECTION 2: State of Florida Report: Review and Critique of Health Effects Studies of
Hazardous Waste Incineration
-------
SECTION 1: List of Literature References and Technical Reports on Health
Effects of Hazardous Waste Incineration
PART A: References from U.S. EPA Search
Agency for Toxic Substances and Disease Registry. 1993. FINAL REPORT: Study of symptom
and disease prevalence, Caldwell Systems, Inc. Hazardous waste incinerator; Caldwell County,
North Carolina. Division of Health Studies; Atlanta, GA; NTIS No. PB93-231041.
Bresnitz, E.A, J. Roseman, D. Becker, et al. 1992. Morbidity among municipal incinerator
workers. Amer. Jour. Indust. Med. 22(3): 363-378.
Driver, J.H., H.W. Rogers, and L.D. Claxton. 1990. Mutagenicity of combustion emissions from
a biomedical waste incinerator. Waste Management 10(3): 177-184.
Elliot, P., M. Hills, J. Beresford, et al. 1992. Incidence of cancers of the larynx and lung near
incinerators of waste solvents and oils in Great Britain. Lancet (United Kingdom), 339: 854-858.
Gulyas, H., M. Labedzka, N. Schmidt, et al. 1988. Effects of quartz airborne particulates and fly
ash fractions from a waste incinerator on elastase release by activated and nonactivated rabbit
alveolar macrophages. Arch. Environ. Health 43(1): 28-33.
Hattemer-Frey, HA. and C. Travis. 1991. Health effects of municipal waste incineration. CRC
Press; Boca Raton, FL.
Hsieh, D.P.H., J.N. Sieber, and G.L. Fisher. 1985. Potential health hazards associated with
paniculate matter released from rice straw burning. California State Air Resources Board;
Sacramento, CA; ARB-R-85/244.
Ma, X.F., J.G. Babish, J.M. Scarlett, et al. 1992. Mutagens in urine sampled repetitively from
municipal refuse incinerator workers and water treatment workers. Jour. Toxicol. Environ.
Health 37(4): 483-494.
National Institute for Occupational Safety and Health. 1988. Health Hazard Evaluation Report:
ENSCO; El Dorado, AR; BETA 86-519-1874; Atlanta, GA.
National Institute for Occupational Safety and Health. 1990. Health Hazard Evaluation Report:
National Electric (APTUS), Inc.; Coffeyville, KS; BETA 86-510-2032; Atlanta, GA.
National Institute for Occupational Safety and Health. 1991. Health Hazard Evaluation Report:
Grosse Pointers - Clinton Refuse Disposal Authority; Mount Clemens, MI; HETA 90-348-2135;
Atlanta, GA. >•
-------
National Institute for Occupational Safety and Health. 1992. Health Hazard Evaluation Report:
Northwest Incinerator; Philadelphia, PA; BETA 88-207-2195; Atlanta, GA.
National Institute for Occupational Safety and Health. 1992. Health Hazard Evaluation Report:
The Caldwell Group; Lenoir, NC; HETA 90-240-2259; Atlanta, GA.
Pani, B., U. Laureni, N. Babudri, et al. 1983. Mutagenicity test of extracts of airborne dust from
the municipal incinerator of Trieste (Italy). Environ. Mutagens 5(1): 23-32.
Scarlett, J.M., J.G. Babish, J.T. Blue, et al. 1990. Urinary mutagens in municipal refuse
incinerator workers and water treatment workers. Jour. Toxicol Environ. Health 31(1): 11-27.
Shane, B.S., C.B. Henry, J.H. Hotchkiss, et al. 1990. Organic toxicants and mutagens in ashes
from eighteen municipal refuse incinerators. Archiv. Environ. Contam. Toxicol. 19: 665-673.
Shy, C.M., D. Degnan, D.L. Fox, et al. 1995. Do waste incinerators induce adverse respiratory
effects? An air quality and epidemiology study of six communities. Environ. Health Perspectives
103(7-8): 714-724.
Suter-Hofrnann M., and C. Schlatter. 1986. Toxicity of paniculate emissions from a municipal
incinerator: critique of the concept of TCDD-equivalents. Chemosphere 15(9-12): 1733-1744.
Travis, C.C., E.L. Etnier, G. A. Holton, et al. 1986. Inhalation pathway risk assessment of
hazardous waste incineration facilities. Oak Ridge National Laboratory; Oak Ridge, TN;
ORNL/TM-9096.
U.S. Environmental Protection Agency. 1988. Assessing potential effects of incinerating
organic wastes at sea: development and field-testing of the marine incineration biological
assessment sampler. Office of Research and Development; Research Triangle Park, NC;
EPA/600/J-88/358.
Watts, R.R., P.M. Limieux, R.A. Grote, et al. 1992. Development of source testing, analytical,
and mutagenicity bioassay procedures for evaluating emissions from municipal and hospital waste
combustors. Environ. Health Perspectives 98: 227-234.
Williams, F.L., A.B. Lawson, and O.L. Lloyd. 1992. Low sex ratios of births in areas at risk
from air pollution from incinerators, as shown by geographical analysis and 3-dimensional
mapping. Int. Jour. Epidemiology 21(2): 311-319.
-------
PART B: References from State of Florida Search
I Acharya, P. et al. 1 99 1 . Factors that can Influence and Control the Emissions of Dioxins and
Fuxans from Hazardous Waste Incinerators. Joum. Air Waste Manage. Assoc. 41 : 1605-1615.
J Agency for Toxic Substances and Disease Registry (ATSDR). 1989-1993. Toxicological
Profiles for Chemicals of Concern. U.S. Department of Health & Human Services, Atlanta, GA.
| Series of reports regarding individual chemicals from 1989 to 1993.
Agency for Toxic Substances and Disease Registry (ATSDR). 1992. Public Health Overview of
I Incineration as a Means to Destroy Hazardous Wastes: Guidance to ATSDR Health Assessors.
U.S. Department of Health & Human Services, Atlanta, GA. February, 1992.
I Agency for Toxic Substances and Disease Registry (ATSDR). 1993. Study Of Symptom And
Disease Prevalence At The Caldwell Systems Inc. Hazardous Waste Incinerator, Caldwell
County, N. Carolina. U.S. Department of Health & Human Services, Atlanta, GA. January,
] 1993.
_ Agency for Toxic Substances and Disease Registry (ATSDR). 1994. Proceedings of the Expert
I Panel to Evaluate the Public Health Implications of the Treatment and Disposal of
Polychlorinated Biphenyls-contaminated Waste (Public Comment Draft). U.S. Department of
Health & Human Services, Atlanta, GA. September, 1994.
1
American Society for Mechanical Engineers (ASME). 1988. Hazardous Waste Incibneration: A
(Resource Document. Report sponsored by ASME, U.S. EPA, APCA and AIChE. Published by
ASME, New York, NY.
i Anddman, J.B. and D.W.Underhill. 1987. Health Effects from Hazardous Waste Sites. Lewis
J Publishers, Inc.
| Baker, R.D. et al. 1992. Management of Hazardous Waste in the United States. Haz Waste &
1 Haz Materials 9(1): 37-59.
I Becker, R- A. 1994. Personal communication; memorandum from Air Board of the California
Environmental Protection Agency.
I Behmanesh, N. et al. 1992. Flow Rates and Compositions of Incinerated Waste Streams in the
United States. Joum. Air Waste Manage. Assoc. 42: 437-442.
J Bresnitz, E.A. et al. 1992. Morbidity Among Municipal Waste Incinerator Workers. Am.
Joum. Industrial Med. 22: 363-378.
I
i*1
A-103
g
I
-------
British Medical Association. 1991. Hazardous Waste and Human Health. Oxford University
Press, Oxford, New York.
Brunner, C.R. 1993. Hazardous Waste Incineration. Second Ed., McGraw-Hill, Inc.
Buffler, P. A. et al. 1985. Possibilities of Detecting Health Effects by Studies of Populations
Exposed to Chemicals from Waste Disposal Sites. Environ. Health Perspectives 62: 423-456.
Buonicore, A.J. 1989. Experience with Air Pollution Control Equipment and Continuous
Monitoring Instrumentation on Hazardous Waste Incinerators. Joum. Haz Materials 22:
233-242.
Bundesarztekammer (German Federal Union of Physicians). 1993. Potentielle
Gesundheitsgefahren Durch Emissionen Aus Mullverbrennungsanlagen (Potential Health Effects
From Emissions From Incineration Facilities). Deutsche Arzteblatt 90 (1/2):A2 51-59. January
ll.CitedinPleusetal. 1993.
Callender TJ et al, 1993. Neurotoxic effects of chemical mixtures in a hazardous waste
incinerator. (Abstract) Presented at: The International Congress on Health Effects of Hazardous
Waste, Atlanta, Georgia May 3-6,1993.
Canadian Council of Ministers of the Environment (CCME. 1992. National Guidelines for
Hazardous Waste Incineration Facilities. March, 1992.
Castaldini, C. et al. 1986. Nonsteady-state Testing of Industrial Boilers Burning Hazardous
Wastes. In: Land Disposal, Remedial Action, Incineration and Treatment of Hazardous Waste:
Proceedings of the Twelfth Annual Research Symposium at Cincinnati, Ohio. EPA
600/9-86/022.
Clement International Corporation. 1992. Scientific Peer Review of Greenpeace's Position on
Hazardous Waste Incineration Impacts in Its "Report on the Hazardous Waste Incineration
Crisis" and "Playing With Fire".
Connett, P. and T.Webster. 1987. An Estimation of the Relative Human Exposure to
2,3,7,8-TCDD Emissions Via Inhalation and Ingestion of Cow's Milk. Chemoshpere 16(8-9):
2079-2084.
Cooper, C.D. and C.A. Clausen. No date. Enhancement of the Kinetics on Incineration of Dilute
Hazardous Organic Vapors. Abstract, no full citation available from paper copy acquired.
Cox, E.A. and E.E.Finnecy. 1986. Dioxins and Waste Disposal: The UK Experience.
Chemosphere 15(9-12): 1543-1548.
A-104
-------
I
*
Cranmer, M.F. et al. 1993. Biologic Indicators of Exposure for Residents of Jacksonville,
(Arkansas, to Contaminants from Vertac/Hercules Superfund Site. Presented at: 1993
International Congress on the Health Effects of Hazardous Waste, Atlanta, Georgia, May 3-6,
1993.
^ Cundy, V.A. et al. 1989. Rotary Kiln Incineration - Combustion Chamber Dynamics. Journ.
Haz. Materials 22: 195-219.
Decker, W.A. et al. 1983. Worker Exposure to Organic Vapors at a Liquid Chemical Waste
Incinerator. Amer. Ind. Hyg. Assoc. Joum. 44(4): 296-300.
Deister, U. and R.Pommer. 1991. Distribution of PCDD/F in the Vicinity of the Hazardous
g Waste Incinerator at Schwabach. Chemosphere 23(11-12): 1643-1651.
Demirgian, J. C. and M.D.Erickson. 1989. The Potential of Continuous Emission Monitoring of
I Hazardous Waste Incinerators Using Fourier Transform Infrared Spectroscopy. Proceedings of
J the 1989 Incineration Conference on Incineration of Hazardous, Infectious, Radioactive and
Mixed Wastes. DE89-013172.
I Dempsey, C.R. and E.T.Oppelt. 1993. Incineration of Hazardous Waste: A Critical Review
Update. Air & Waste 43: 25-73.
• DiCristofaro, D.C. et al. 1994. Assessing Health Risk Uncertainty at a PCB Thermal
Incinerator. Presented at the 87th Annual Meeting & Exhibition of the Air & Waste Mgmt.
| Assoc., June, 1994.
Diggle, P.J. et al. 1990. Modelling the Prevalence of Cancer of the Larynx in Part of
1 Lancashire: A New Methodology for Spatial Epidemiology. In: Spatial Epidemiology, (ed.
R.W.Thomas), Pion Limited, pp. 34-47.
| Dockery, D.W. et al. 1993. An Association Between Air Pollution and Mortality in Six U.S.
Cities. The New England Joum. of Med. 329(24): 1754-1759.
9
J Favata, E.A. and M.Gochfeld. 1989. Medical Surveillance of Hazardous Waste Workers:
Ability of Laboratory Tests to Discriminate Exposure. Amer. Journ. Ind. Med. 15: 255-265.
j Feigley CE et al, 1993. Community Study Of Health Effects Of Hazardous Waste Incineration:
Preliminary Results Abstract presented at the International Congress on Health Effects of
I Hazardous Waste, Atlanta, Georgia May 3-6,1993, Cited in Orloff, ATSDR, 1994.
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* Name of the principal author was illegible on available copy. +•
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SECTION 2: State of Florida Report: Review and Critique of Health Effects Studies of
Hazardous Waste Incineration
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GROUP 1 STUDIES: HAZARDOUS WASTE INCINERATORS
Case Study #1
REFERENCE: National Institute for Occupational Safety and Health (NIOSH). 1992. Health
Hazard Evaluation Report: The Caldwell Group, North Carolina. HETA 90-240-2259, NTIS
PB93-214237. Agency Report.
OBJECTIVES: To determine whether former Caldwell employees might have undetected or
unreported neurologic disorders.
DESIGN: Screening medical examinations by NIOSH investigators.
SETTING: A hazardous waste incinerator which operated between March 1977 and May
1988 In a semi-rural area in North Carolina. CSI burned varnish, paint, glues, lacquer, toluene,
xylene and other halogenated and non haiogenated solvents as well as solid and liquid wastes
resulting from the remediation by EPA of other hazardous waste sites. Company records show
that waste torpedo fluid (propellant) from the US Navy constituted almost 8% of the material
burned by weight. This so called Otto Fluid II contains propylene glycol dinitrate (76%) and the
stabilizers 2-nitrodiphenylamine (1.5%) and dibutyl sebucate (22.5% as well as cyanide gas (10
to 1000 ppm). According to the permit granted by North Carolina in 1977, CSI was permitted to
burn more than twice as much waste per hour as the specified design rate of 1800 pounds per
hour.
PART 1: September 1990 Evaluations
SUBJECTS: Fourteen former Caldwell employees reported by the local physician to have
neurologic problems related to occupational chemical exposures.
MAIN OUTCOME MEASURES: Standardized medical evaluations focused on the
neurological system and psychiatric status. This consisted of the administration of 2
questionnaires, a general physical examination by an internist, examinations by 2 neurologists
and an interview with a psychiatrist. A movement disorder specialist was asked to view selected
portions of the videotaped examinations. None of the examiners was given work or exposure
histories.
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RESULTS: Fourteen of the 15 invited former employees completed all parts of the evaluation;
one agreed only to a brief interview with the psychiatrist and a brief neurologic examination. His
findings have been excluded from this report. All participants reported daily or weekly
headaches, positional lightheadedness, dizziness and problems with memory. Two individuals
without a previous history of hypertension were found to have elevated blood pressure. Four
individuals had epigastric tenderness, of whom 3 had histories of peptic ulcer disease. Five of the
14 participants accounted for most of the abnormal neurologic signs. Two had abnormal station
and gait as well as myoclonus, resting tremor and postural tremor. A video of these abnormalities
was examined by a third expert who noted the presence of Parkinsonian-like movements. A third
individual had abnormal station but none of the other movement disorders. A fourth had postural
tremor only. Two clients had reduced ankle reflexes and diminished peripheral touch sensation,
consistent with mild sensory peripheral neuropathy. Eleven participants reported symptoms
including headaches, lightheadedness, numbness and palpitations following brief induced
episodes of hyperventilation. The most frequent psychiatric symptoms were irritability, sleep
disturbances, aggressive outbursts, depressed mood and problems with memory. Twelve
individuals were noted to have diminished concentration as indicated by a subnormal digit span
on the mental status examination. Except for alcohol abuse or dependence, no more than 2
individuals were found to have the same psychiatric diagnosis.
CONCLUSION: The authors concluded that the majority of symptoms and signs were either
non-specific and common in the general population or probably related to known causes other
than work-related toxic exposures. In view of the fact that they were unable to demonstrate a
high prevalence of any objectively quantifiable finding, they concluded that a valid
epidemiologic study to address the reported health effects was not feasible.
CRITIQUE: The authors attempted to evaluate all other possible causes of these symptoms
and signs. In particular they noted that ten of the participants reported taking medications with
potential neurologic side effects, in particular the two clients with abnormal gait and movement
disorders. Seven individuals also reported histories of exposure to potentially neurotic chemicals
in jobs with other employers. A common causal factor for the two cases of abnormal movement
gait and movement disorders could not be established, but the possibility of Wilson's disease (a
rare genetic disorder of copper metabolism) was suggested. The persistence of symptoms even
after exposure had ended raises the possibility of chronic organic solvent toxicity, but as the
authors state, the psychiatric symptoms were complicated by the legal and socio-political aspects
of this investigation. Moreover, in the absence of objective data concerning the participant's
behavior before beginning work at the Caldwell facilities, it is impossible to assess whether
changes in behavior are attributable to employment at this incinerator facility.
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PART 2: November 1991 Evaluations
SUBJECTS: All current and former employees who were not examined by NIOSH
investigators in September 1990 were eligible to participate, of which only 54 (i.e., 21%) of the
328 eligible participants responded, despite multiple attempts to contact them.
MAIN OUTCOME MEASURES: Standardized medical evaluations focused on the
neurological system, consisting of the administration of a brief questionnaire (including the Short
Michigan Alcohol Screening Test), a general physical examination by an internist, and if a
neurologic abnormality was identified by the initial examiner, examination by a neurologist
followed.
J RESULTS: Thirty six of the 54 participants (67%) had no neurologic abnormalities. Most of
the 18 clients seen by the neurologist complained of multiple symptoms including vertigo,
clumsiness, poor coordination, unsteady gait or loss of balance, tremor, muscle twitching and
I parenthesis, as did the 14 participants of the September 1990 evaluations. The most frequent
neurologic finding was a mild postural tremor in 8 patients.
f CONCLUSION: Because of the limiting factors (some of which are outlined below)
encountered during this investigation, the authors concluded that the question of whether or not
, the symptoms or movement disorders are related to hazardous waste exposures at the Caldwell
I facilities remains unanswered. They recommended that studies of other groups of workers may
be warranted but as in the present study, the potential limitations of such an exercise should be
i recognized and addressed before such efforts are undertaken.
CRITIQUE: The authors clearly state that there are other possible non-occupational causes
for the documented findings. Postural tremor (but not intention tremor) may represent a normal
variant in the absence of associated findings which would support a specific diagnosis, e.g.,
hyperthyroidism. The major limitation of this portion of the evaluation of the health status of
former Caldwell employees is the unexpectedly low participation rate. This raises the possibility
of selection bias which diminishes the likelihood that these observations are representative of the
entire Caldwell workforce. As stated by the authors, there is a notable lack of information
concerning types of exposures (including quantity, complexity and routes), quantitative
environmental data and most importantly no information concerning baseline health status of
these former employees. Moreover the pre-investigation publicity undoubtedly influenced the
results in some unspecified way. It should also be noted that the absence of a clear medical
explanation for a symptom often increases anxiety which in turn may exacerbate symptoms. The
extent to which factors influenced the observations noted in this report is uncertain.
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Case Study #2
REFERENCE: Agency for Toxic Substances and Disease Registry (ATSDR). 1993. Study
Of Symptom And Disease Prevalence At The Caldwell Systems Inc. Hazardous Waste
Incinerator, Caldwell County, N. Carolina. U.S. Department of Health & Human Services,
Atlanta, GA. January, 1993. Agency Report.
OBJECTIVES: To determine whether the prevalence of specific symptoms or diseases in
persons living within a 1.5 mile radius of the former Caldwell Systems Incinerator (CSI) site,
i.e., the target population, were different from those of selected but similar persons not living
near the site (the comparison population).
DESIGN: Screening interview to determine eligibility followed by cross sectional symptom
and disease questionnaire developed by ATSDR.
SETTING: A hazardous waste incinerator which operated between March 1977 and May
1988 in a semi-rural area in North Carolina. CSI burned varnish, paint, glues, lacquer, toluene,
xylene and other halogenated and non halogenated solvents as well as solid and liquid wastes
resulting from the remediation by EPA of other hazardous waste sites. Company records show
that waste torpedo fluid from the US Navy constituted almost 8% of the material burned by
weight. This so called Otto fluid contains propylene glycol dinitrate (76%) and the stabilizers
2-nitrodiphenylamine (1.5%) and dibutyl sebucate (22.5% as well as cyanide gas (10 to 1000
ppm). According to the permit granted by North Carolina in 1977, CSI was permitted to burn
more than twice as much waste per hour as the specified design rate of 1800 pounds per hour.
SUBJECTS: 713 residents living within 1.5 miles of the CSI site and 588 residents of a
comparison area.
MAIN OUTCOME MEASURES: Self reported symptoms and diagnosis of disease not
verified by reviewing medical records.
RESULTS: Increased prevalence of self reported respiratory symptoms but not respiratory or
other diseases in the target population over the comparison group when adjusted for age, gender
and cigarette smoking. Target area residents were nine times more likely than those of the
comparison area to report symptoms consisting of recurrent wheezing or cough following a
respiratory insult when adjusted for cigarette smoking, asthma and environmental concern (Odds
ratio = 9.0; 95% confidence interval = 2.8-29.1). Residents living within 0.9 miles of the site
were almost twice as likely as those living between 0.9 and 1.5 miles of the site to report
recurrent wheezing or cough following a respiratory insult when adjusted for cigarette smoking,
asthma and environmental concern (Odds ratio = 1.8; 95% confidence interval = 1.1-2.9).
Residents of the target area were approximately one and a half times as likely to report
neurological symptoms as residents of the comparison area (Odds ratio**1 1.4; 95% confidence
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interval = 1.0-2.1) and almost two and a half times as likely to report the diagnosis of selected
neurological diseases (Odds ratio = 2.4; 95% confidence interval = 1.0-5.9) when controlled for
smoking, gender, diabetes, alcohol ingestion and environmental concern.
Statistically significant odds ratios were found within the target area for dizziness and
poor coordination as well as irritative symptoms (any one of the following: watery, burning or
irritated eyes, irritation or burning of the nose or nasal passages or skin rashes) both north and
south of the incinerator compared with east and west. Chest pain, poor coordination, dizziness
and irritative symptoms were more prevalent among persons living less than 0.9 miles or the
incinerator compared with those living further away.
There was no difference in the prevalence of either physician diagnosed diseases nor
hospital admissions for these diseases between the target and comparison groups. There was no
difference in the self reported prevalence of cancer or adverse reproductive outcomes between
the two groups.
CONCLUSION: The authors conclude that the statistically significantly increased prevalence
of respiratory, neurologic and irritative symptoms suggests that further examination of
respiratory, immune and neurologic function of the residents living near the incinerator is
warranted.
CRITIQUE: As clearly stated by the authors, this study was not designed to determine
whether the association between environmental exposure and health outcomes is causal. This
study suffers from the usual limitations of such symptom and disease prevalence studies, i.e., the
lack of specificity of the exposure and health outcome variables. Conclusions that can be drawn
from prevalence studies are limited because a condition may have developed before an exposure
began and some affected residents may have moved or died and thus may have been missed.
Since no good marker for the exposure variable was available, the investigators used distance and
direction as surrogate measures of exposure.
The authors took great care to attempt to eliminate all possible sources of bias in this
retrospective study including selection, information, and recall bias. The latter is of particular
concern since this study was performed 2 years after the facility closed and 14 years after
operations had started at the plant. With these caveats in mind, it is noteworthy that the study
authors noted that persons who responded affirmatively to the question "Do you have any current
health problems you think were caused by chemicals in or near your home?" were more than 20
times as likely to report respiratory symptoms than those who answered no to this question, even
when adjusted for area of residence, age and cigarette smoking.
Perhaps the most important point to be made in this critique is that this incinerator is not
representative of incinerators which burn waste efficiently and within their design limitations.
Therefore caution should be exercised in extrapolating from this case to the case of a properly
operated facility. *
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Case Study #3
REFERENCE: Callender TJ et al, 1993. Neurotoxic effects of chemical mixtures in a
hazardous waste incinerator. (Abstract) Presented at: The International Congress on Health
Effects of Hazardous Waste, Atlanta, Georgia May 3-6, 1993. Conference Paper.
OBJECTIVES: To correlate brain SPECT scan results with the clinical and
neuropsychological impairment in workers who had chronic encephalopathy after hazardous
waste exposure to a mixture of chemicals.
DESIGN: Descriptive study.
SUBJECTS: Five workers (ages 23-43) employed at a HWI over a period of 1.5 to 4 years
who developed chronic encephalopathy.
MAIN OUTCOME MEASURES: History and physical exams, neuropsychological tests and
SPECT scan of the brain.
RESULTS: Type 2A/B chronic encephalopathy with personality and mood changes,
diminished impulse control, diminished concentration, memory and learning capacity. Abnormal
brain SPECT scans with decreased regional blood flow areas in the brain.
CONCLUSION: The brain SPECT scan is a sensitive and accurate tool to globally define the
extent of CNS dysfunction as well as to serve as a biomarker of neurotoxicity in cases of
chemical exposures.
CRITIQUE: This descriptive study is interesting from the point of view of documenting the
extent and location of the brain lesions in these 5 workers, but the authors make no attempt to
confirm the extent of exposure in these individuals, beyond stating that they "suffered from
heavy exposure to mixtures of chemicals". There is no information concerning the incinerator
facility at which these exposures occurred, but the involvement of a physician from the Caldwell
Family Physicians group, would suggest the Caldwell facility might have been the site.
Additional information may be available in the full paper to be published in the Proceedings of
this meeting.
Case Study #4
REFERENCE: Cranmer, M.F. etal. 1993. Biologic Indicators of Exposure for Residents of
Jacksonville, Arkansas, to Contaminants from Vertac/Hercules Superfund Site. Presented at:
1993 International Congress on the Health Effects of Hazardous Waste, Atlanta, Georgia, May
3-6, 1993. Conference Paper.
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OBJECTIVES: To determine whether persons living for more than 15 years within 1300
yards of the Vertac site before the on-site incineration of 28,500 barrels of 2,4,5-T and 2,4-D
waste at the Vertac Superfund site begins, have higher background concentrations of the tested
chemicals than do persons who live in a comparison area.
DESIGN: Blood and urine samples from 108 persons in the target area and 72 persons in the
comparison group tested for pre-incineration levels of 2,3,7,8-TCDD and 2,4-D and 41 other
environmental pollutants.
SETTING: The incinerator was built in 1990, tested in 1990-1991 and approved for operation
in 1992.
SUBJECTS: Three groups of residents were identified: Group 1 (n = 72) consists of a random
sample of target area residents with the greatest likelihood of past exposure to toxicants from the
Vertac site by virtue of having lived within 1300 yards of the Vertac/Hercules Superfund site for
more than 15 years; Group 2 (n = 36) consists of those with minimal likelihood of exposure
because of residence for less than 5 years; Group 3 (n = 72) consists of residents from Mabelvale,
Arkansas, a control group not expected to have had any exposure to the same site.
I MAIN OUTCOME MEASURES: Serum and urine levels of 2,3,7,8-TCDD and 2,4-D
2,3,7,8-TCDD and 2,4-D and 41 other environmental pollutants including 2,3,7,8-substituted
dibenzodioxins and furans, polychlorinated biphenyls, chlorinated hydrocarbon insecticides,
• chlorophenols and chlorophenoxyacetic acids between March 16 and 24, 1991.
RESULTS: After correcting for age, sex and race, the only statistically significantly increased
levels of analytes at the p < 0.05 level in the long term Jacksonville residents (Group 1) over the
control community (Group 3) were serum levels of 2,3,7,8-TCDD and 2,4-D and urine levels of
2,4-D.
CONCLUSION: Excess exposure to the compounds 2,4-dichlorophenoxyacetic acid,
2,4-dichlorophenol and 2,3,7,8-TCDD, the major contaminants on the Vertac/Hercules
Superfund site, occurred even before the incineration program began.
CRITIQUE: The authors clearly state that the results of this study should be extrapolated with
great caution to the general population because their study excluded those over the age of 65 and
under the age of 18. Moreover, although the most sensitive and reliable analytic procedures were
used, the lowest limit of detectability and quantification were not sufficiently sensitive to detect
many of the analytes in several of the serum and urine samples, thus weakening the power of
statistical comparisons. A follow up study is in progress to determine whether concentrations of
the test chemicals in persons who live within 1300 yards of the site incinerator will increase
during the period of operation of the incinerator, i.e., between 1992 and 1995. The results of this
follow up study will be of particular relevance in the context of the potential adverse health
effects of incineration of hazardous waste. •«•
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Case Study #5
REFERENCE: Orloff KG, 1993. Health consultation for ThermalKEM Incinerator, Rock Hill,
South Carolina ATSDR. Obtained from Morris F. Cranmer, Arkansas Department of Health,
Little Rock, Arkansas. Agency Report.
OBJECTIVES: To evaluate the results of ambient air monitoring of semi-volatile organic
chemicals (SVOC), hydrogen chloride, non-methane organic compounds (NMOC) and
particulates, in the vicinity of the ThermalKEM facility. The analysis was prompted by concerns
from area residents regarding odors emanating from the site and over potential adverse health
effects from air emissions from the incinerator.
DESIGN: Descriptive study.
SETTING: The ThermalKEM facility began operations in 1965 as Industrial Chemical Co,
Inc., changing its name to ThermalKEM in 1987. Hazardous materials have been incinerated at
the site since 1982. As part of the RCRA Part B permit for the facility, ThermalKEM conducted
daily ambient air monitoring at the periphery of their property, ending in February 1993.
SUBJECTS: None.
MAIN OUTCOME MEASURES: Air levels of semi-volatile organic chemicals (SVOC),
hydrogen chloride, non-methane organic compounds (NMOC) and particulates, in the vicinity of
the ThermalKEM facility. The two monitoring stations are located 230 yards northeast of the
incinerator scrubber stack and 260 yards southwest of the stack, which lie in the predominant
downwind and upwind directions from the incinerator stack. This analysis was based on data
collected between September 1990 and December 1991.
RESULTS: Monthly average air concentrations of NMOCs ranged from 0.01 to 0.17 ppm (as
propane), the maximum daily and hourly concentrations being 0.26 and 0.39 ppm respectively.
Yearly average air paniculate concentrations were 53 to 58 ug/m3 and daily maximum paniculate
concentrations were as high as 228 ug/m3, most likely influenced by dust from gravel roads near
the monitoring stations. The maximum detected air concentrations of metals were as follows:
arsenic 0.087 ug/m3, barium 0.039 ug/m3, cadmium 0.012 ug/m3, chromium 0.64 ug/m3, lead
0.048 ug/m3 and thallium 0.044 ug/m3. The only pesticide related contaminants detected were
naphthalene (maximum concentration 0.036 ug/m3) and chlorobenzene (maximum concentration
0.09 ug/m3). Air monitoring data for hydrogen chloride were invalidated by technical problems.
CONCLUSION: Air paniculate levels exceeded the daily (150 ug/m3) and annual (50 ug/m3)
standards established by the National Ambient Air Quality Standards. The authors report that
maximum reported air concentrations of arsenic, chromium, thallium and barium exceeded levels
that are typically found in urban air in the US, which, in their view, may pose a significant cancer
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risk (> 1 x 10'5). The lack of ambient air data for hydrogen chloride is unfortunate in view of the
_ common complaints of eye, nose and throat irritation reported by area residents.
CRITIQUE: Unfortunately, no ambient air monitoring data are available for residential areas
3 surrounding the facility, and hence ATSDR were unable to determine whether residents are being
exposed to air contaminants at levels of health concern. In addition to emissions from the
incinerator stack, spills and fugitive emissions from the routine transport, handling and storage of
J wastes at the facility could contribute to ambient air pollution. It should be noted that in addition
to ThermalKEM, a chemical plant that produces pharmaceutical intermediates and a facility that
produces treated lumber are located in the area, and hence there may be other potential sources of
1 chemical emissions.
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Case Study #6
REFERENCE: Feigley CE et al, 1993. Community Study Of Health Effects Of Hazardous
Waste Incineration: Preliminary Results (Abstract) Presented at: The International Congress on
Health Effects of Hazardous Waste, Atlanta, Georgia May 3-6, 1993. Conference Paper.
I OBJECTIVES: To determine the self reported prevalence of respiratory symptoms in residents
living near the ThermalKEM hazardous waste incinerator and storage facility in Rock Hill, South
Carolina.
DESIGN: Cross sectional symptom and disease questionnaire.
SETTING: The ThermalKEM facility began operations in 1965 as Industrial Chemical Co,
Inc., changing its name to ThermalKEM in 1987. Hazardous materials have been incinerated at
the site since 1982.
SUBJECTS: 900 persons in total divided into 2 communities in South Carolina: one exposed
to the plume of HWI and a comparable control community.
MAIN OUTCOME MEASURES: Self reported symptoms and diagnosis of disease not
• verified by reviewing medical records.
RESULTS: Significantly higher prevalence of self reported respiratory symptoms particularly
morning cough and phlegm/mucus in residents living near the facility as compared to a control
area. No significant differences in the prevalence of reported physician diagnoses of respiratory
conditions including bronchial asthma, emphysema, pneumonia, sinus trouble and hay fever.
Residents in the exposed community were more than ten times more likely to report concern over
health problems caused by chemicals in or near their home.
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CONCLUSION: Statistically significantly increased prevalence of self reported respiratory
complaints but not of physician diagnoses.
CRITIQUE: Unfortunately we were only able to obtain a copy of the abstract but not the
complete paper relating to this report; hence the missing detailed data in this summary. The
authors state that they performed multivariate analysis controlling for smoking and other health
behaviors in order to account for differences in symptom prevalence. These details are
unavailable for review. Overall, the significance of this type of retrospective inquiry is tempered
by the fact that the study community were obviously more motivated to report symptoms relating
to potential chemical exposure.
Case Study #7
REFERENCE: Hornung AC et al, 1993. Reliability of proxy measures of the health effects of
exposure to hazardous waste incineration (Abstract) Presented at: The International Congress on
Health Effects of Hazardous Waste, Atlanta, Georgia May 3-6, 1993. Conference Paper.
OBJECTIVES: To compare the validity of proxy and self report responses to symptom
questionnaire in residents living near the ThermalKEM hazardous waste incinerator and storage
facility in Rock Hill, South Carolina.
DESIGN: Cross sectional symptom and disease questionnaire.
SETTING: The ThermalKEM facility began operations in 1965 as Industrial Chemical Co,
Inc., changing its name to ThermalKEM in 1987. Hazardous materials have been incinerated at
the site since 1982.
SUBJECTS: 900 persons in total divided into 2 communities in South Carolina: one exposed
to the plume of HWI and a comparable control community. These respondents also provided
proxy data for more than 1200 individuals living in their households, of whom a random sample
of 60 were contacted and interviewed.
MAIN OUTCOME MEASURES: Self reported symptoms and diagnosis of disease not
verified by reviewing medical records.
RESULTS: Comparison of proxy and self report responses showed generally poor reliability of
the proxy data. The sensitivity of questions designed to identify hypersensitive individuals
ranged from approximately 0.33 for having "wheezing" to 0.71 for "awakening with a feeling of
tightness in the chest". Positive predictive values for these same symptoms were 0.31 and 0.62
respectively, while negative predictive values were 0.74 to 0.96 respectively. Proxy responses
also had low sensitivity but high specificity and negative predictive values for physician
diagnosed respiratory diseases. *'
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CONCLUSION: Unreliability of proxy measures of the health effects of exposure to HWI
related to gender, education, community location and beliefs about local environmental health
hazards of the initial interviewee.
CRITIQUE: Unfortunately we were only able to obtain a copy of the abstract but not the
complete paper relating to this report; hence the missing detailed data in this summary.
Nevertheless, its conclusion, that we take into consideration exactly who is providing
information about alleged health effects relating to exposure to HWI, is an important one.
Case Study #8
REFERENCE: Rothenbacher D et al, 1993. Respiratory symptom prevalence in 3 North
Carolina Incinerator Communities (Abstract) Presented at: The International Congress on Health
Effects of Hazardous Waste, Atlanta, Georgia May 3-6, 1993. Conference Paper.
OBJECTIVES: To investigate possible respiratory effects in people living near waste
incinerators.
DESIGN: Cross sectional symptom questionnaire.
SETTING: Three N. Carolina communities surrounding a biomedical, municipal or hazardous
waste incinerator.
SUBJECTS: 400-500 households in each of these three communities matched with three
non-incinerator communities.
MAIN OUTCOME MEASURES: Self reported symptoms assessed with an expanded
questionnaire of the American Thoracic Society not verified by reviewing medical records.
RESULTS: The prevalence of possible risk factors for respiratory conditions (that may have
skewed the analysis) such as the prevalence of smoking, occupational exposure to chemicals,
mold problems in the home, "were higher in the comparison groups" (sic).
CONCLUSION: None stated.
CRITIQUE: Our critique of this paper is limited by the fact that we had access only to the
abstract where the authors stated: "Prevalence of lower respiratory diseases, lower and upper
respiratory symptoms, asthma and other respiratory hypersensitive conditions in target versus
control communities will be shown, after controlling for various factors affecting respiratory
health". Clearly, the information is simply not available in this report. Publication of the full
paper in the Proceedings of the meeting is awaited.
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Case Study #9
REFERENCE: Sinclair SM et al, 1993. Diurnal variations in peak expiratory flow rate in a
study of three North Carolina Incinerator communities. (Abstract) Presented at: The
International Congress on Health Effects of Hazardous Waste, Atlanta, Georgia May 3-6, 1993.
Conference Paper.
OBJECTIVES: To investigate the acute effects of air quality on persons with respiratory
hypersensitivity.
SETTING: Two communities located in adjacent counties in urban and rural N. Carolina.
SUBJECTS: 480 participants from six communities for 35 consecutive days. None were
smokers or regularly exposed to environmental tobacco smoke.
MAIN OUTCOME MEASURES: Morning and evening measurements of peak expiratory
flow rate (PEFR), data concerning respiratory symptoms, medication use, indoor exposures and
time spent outdoors and 12 hour integrated samples of air quality in each community for
particulate matter and gases.
RESULTS: Awaited.
CONCLUSION: "Daily variations hi morning and evening PEFR, diurnal variations in PEFR
and the amplitude of the diurnal difference in PEFR are being assessed in relation to daily air
quality".
CRITIQUE: Our critique of this paper is limited by the fact that we had access only to the
abstract where the authors did not state what their results were, i.e., there is no record in this
abstract of the effects of air quality on persons with respiratory sensitivity. Publication of the full
paper in the Proceedings of the meeting is awaited.
Case Study #10
REFERENCE: Kelly, K.E. 1984. Methodologies for Assessing the Health Risks of
Hazardous Waste Incinerator Stack Emissions to Surrounding Populations. Haz. Waste 1(4):
507-531. Peer-reviewed Journal.
OBJECTIVES: To estimate the health risks of incinerator stack emissions on surrounding
populations.
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DESIGN: Use of stack emissions data from an incineration facility in West Germany (now
Germany) to estimate what the effects of such emissions would be on a hypothetically exposed
population in the US.
SETTING: A hazardous waste incineration facility located in Biebesheim in the state of
Hessen, Germany which began operation in 1982. The facility was designed to accept 50,000
metric tons per year of solid, semi-solid, liquid and drummed hazardous waste. Monitoring of
incinerator effluents and influents for a variety of substances revealed that the only facility
permit limit that was exceeded was that of lead with an average value of 3 mg/m3 instead of < 1
mg/m3. By modifying the scrubber system it was possible to reduce average lead emission values
in subsequent measuring periods.
SUBJECTS: None, because hypothetical analysis.
MAIN OUTCOME MEASURES: Cancer risk expressed as the cumulative risk over a 70
year lifetime of continuous exposure, using both conservative and more realistic assumptions for
comparison. The calculations were as follows: Risk = Potency x Inhalation exposure; Inhalation
exposure = Total Dose/Body weight x lifetime; Total dose = contaminant cone, x Inhalation rate
x exposure duration x absorption fraction. The data used included: volume flow rate = 51,000
m3/h; population exposed to max cone. = 373; average human lifetime = 74 years; average
human body weight 70 kg; daily volume inhaled = 23m3/person-day; exposure duration (life of
facility) = 20 years; cancer potency for one carcinogen (cadmium) = 7.8 (mg/kg/day)'1, lung
absorption of cadmium = 1 (conservative), modeled stack emission rate = 1 g/s; max exposure
cone, at 1 g/s = 0.364 ug/m3, cadmium emission rate = 0.00096 g/sec.
RESULTS: The total increased risk of cancer mortality due to inhalation exposure to
concentrations of arsenic, beryllium, cadmium, chromium, nickel and PCBs in stack emissions
over the life of the facility results in a 1.59 x 10"6 increased risk of cancer to the individual
exposed to the highest concentrations of carcinogens in the stack emissions. This can be
expressed as an increased chance of at most 1 cancer mortality in 628,930 individuals due to
exposures to carcinogens in facility stack emissions, in addition to the more than 150,000 (i.e.
25% of 628,930 persons) who are already statistically expected to die of cancer
CONCLUSION: The author concludes that an increased cancer risk of 1.59 in a million from
hazardous waste incineration should be compared with other risks which increase the chance of
cancer mortality to virtually the same extent (one in a million), e.g., smoking 1.4 cigarettes,
eating 40 tablespoons of peanut butter or 100 charcoal broiled steaks, drinking Miami water for 1
year or 30 12 oz cans of saccharine containing diet soda, living with a cigarette smoker for 2
months, or having one chest X ray taken in a good hospital.
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CRITIQUE: Some of the assumptions used in this health risk assessment are as follows: No
— population growth or decline, facility in operation for 70 years (human lifetime), constant and
™ continuous emission rates, atmospheric transport as the sole route ofcexposure, with 100% of the
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exposed concentration inhaled and absorbed, pollutant effects are additive (no synergistic or
antagonistic effects), gaussian plume dispersion. 1 here was no information available concerning:
possible onsite occupational exposures, that of residents in excess of 100 meters of the facility or
of workers that do not live within 50 km of the facility but commute to work, the risks of
transporting waste to the facility and disposing of incinerator residues as well as uncertainty in
the use of models, estimated data, census data, sampling data, potency values etc. These
assumptions and limitations constitute major sources of uncertainty in the methodologies used in
this study.
Case Study #11
REFERENCE: Travis, C.C. et al. 1987. Potential Health Risk of Hazardous Waste
Incineration. Journ. Haz. Materials 14: 309-320. Peer-reviewed Journal.
OBJECTIVES: To survey recent estimates of human inhalation exposure and health risk
resulting from POHCs emitted during incineration of hazardous wastes.
DESIGN: Theoretical risk assessment based on one generic waste stream containing
carcinogenic organic chemicals (pesticides: chloroform, ethylene dichloride,
hexachlorobutadiene and 1,1,2,2 tetrachloroethane) and one containing toxic but not carcinogenic
chemicals (phenol, toluene, pyridine, phthalic anhydride, methyl styrene).
SETTING: Three hypothetical incinerators (1 x 106, 10 x 106, 150 x 106 Btu/h) burning 1.84 x
108, 1.84 x 109 and 2.76 x 1010 g per year of pesticide related waste and 3.53 x 10s 3.53 x 109 and
5.29 x 10'° g per year of phenol/acetone distillation waste, assuming 99.99% DRE at each site.
SUBJECTS: Population exposures at three hypothetical waste incinerator sites in the Midwest
were estimated based on population distributions reported in the 1980 census. Representative
cumulative population distributions include 448,187 people living within 100km of site 1,
8,202,805 around site 2 and 7,389,283 around site 3.
MAIN OUTCOME MEASURES: Carcinogenic toxicity was estimated in terms of lifetime
excess cancer risk while non carcinogenic toxicity was estimated by acceptable daily intake and
threshold limit values. Toxicity data were taken from EPA Health Assessment for TCE, 1985
and EPA Draft Superfund Health Assessment Manual, 1985.
RESULTS: At the proposed EPA standard of 99.99% DRE, the expected number of excess
cancers over 70 years from incineration of pesticide related waste at a liquid injection incinerator
for a population of 0.45 x 106 is less than 1.6 x 10° for all incinerator sizes studied. The average
daily intake from phenol/acetone distillation wastes released by HWI is always 11% or less of
the ADI, and no adverse health effects would be expected provided there are no other significant
sources of exposure to these chemicals. ,.
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CONCLUSION: The authors concluded that both carcinogenic and non carcinogenic risk
from POHCs emitted during incineration of two representative hazardous waste streams are very
small.
CRITIQUE: The major limitation of this otherwise well designed risk assessment is that the
authors did not address the potential adverse health effects of products of incomplete combustion
or emission of metals during the process of hazardous waste incineration. Moreover, the
assumptions and limitations made in this risk assessment provide major sources of uncertainty in
the methodologies used in this study.
Case Study #12
REFERENCE: Kelly, K.E. and C.C. Beahier. 1992. Burning Hazardous Waste in Cement
Kims: A study of Emissions, Offsite Concentrations and Health Effects in Midlothian, Texas
(Draft). Environmental Toxicology International, Inc., Seattle, WA. Independent Report (not
peer-reviewed)
OBJECTIVES: To survey analytic test results reported through July 1992 from all sources
I relating to offsite exposure concentrations (ambient air, asphalt, soil, water, hay and other media)
to approximately 145 different chemical compounds in the Midlothian area. The study was
launched by the Texas Air Control Board in 1990.
DESIGN: Descriptive study.
SETTING & SUBJECTS: Midlothian is the site of three cement plants (Box Crow, North
Texas, TXI) burning hazardous waste located within a 3 mile radius of each other. Two are
currently permitted to bum hazardous waste fuels, a total of 108,000 tons being used in each of
1990 and 1991. A third plant has applied for permission.
MAIN OUTCOME MEASURES: Measured offsite concentrations, made available by both
the Texas Air Control Board and the cement industry, and including organics, inorganics and
metals such as lead, cadmium, chromium and mercury were compared to applicable federal and
state criteria.
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RESULTS: Over 99% of the analytic results were found to be below conservative federal or
I state screening levels. There were no exceedances in 365 soil analyses, 128 water analyses, 22
' cement kiln dust analyses, 12 concrete foundation analyses and 30 fuel oil analyses. Only one of
the 5281 results reported for ambient air exceeded the Effects Screening Level (ESL), that of
i carbon disulfide (0.0162ppm versus a short term ESL of O.Olppm) taken upwind of all three
facilities. The antimony Environmental Media Evaluation Guideline (EMEG) was exceeded in
one of 12 air conditioner filter analyses (130ppm versus EMEG of 20 ppm). Total chromium
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levels exceeded EMEG in 21 of 174 gravel, asphalt and rock analyses. The amount of hexavalent
chromium in a sample containing 3,200 ppm of total chromium was 0.5-1.6 ppm.
CONCLUSION: The Texas Air Control Board concluded that almost all of the measured
amounts are below the guideline levels and that although hydrogen sulfide was found at
concentrations high enough to be odorous, levels were still below the Texas state standard. They
stated that exposure to the measured contaminants are unlikely to cause adverse health effects in
the general public.
CRITIQUE: As clearly stated by the Texas Air Control Board, we should emphasize that this
study was not designed to document the incidence of health effects in the community. It is
noteworthy that other sources of emissions in Midlothian include a steel mill (the tenth largest
producer of steel in the US), and that Midlothian acts as a staging area for tens of thousands of
automobiles each year.
Case Study #13
REFERENCE: Favata, E.A. and M. Gochfeld. 1989. Medical Surveillance of Hazardous
Waste Workers: Ability of Laboratory Tests to Discriminate Exposure. Amer. Journ. Ind. Med.
15: 255-265. Peer-reviewed Journal.
OBJECTIVES: To evaluate the effectiveness of the traditional laboratory tests utilized in the
surveillance of workers employed at hazardous waste sites.
DESIGN: Retrospective analysis of results of medical surveillance examinations and correlation
with exposure classification based on the physician's review of the occupational history.
SETTING & SUBJECTS: 477 private and public sector workers whose duties were to inspect,
evaluate or clean-up toxic waste sites in New Jersey were stratified into a group with a high
potential for exposure ("exposed", n=286) and one with a low potential for exposure
("unexposed", n=191).
MAIN OUTCOME MEASURES: 55 different laboratory values (clinical chemistry,
hematology, urinalysis) controlled for gender, age, past exposure history.
RESULTS: The only consistently significant difference was a low mean corpuscular volume in
the "exposed" group.
CONCLUSION: The lack of other significant findings suggests that either the true exposure
status of individuals was not reflected in the classification of the authors, or that the traditional
tests were inappropriate or insensitive. The authors conclude that it is essential to carefully
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evaluate surveillance results and develop protocols that are appropriate to the actual exposures
encountered in work with hazardous waste.
CRITIQUE: There are a number of methodological problems with studies of this nature which
attempt to classify exposure based on a physician's analysis of the worker's occupational history.
The subjective nature of this process means that the results may be biased towards either
over-exposure or under-exposure. Moreover there is no recognized biological mechanism which
would explain why smaller red cells should be found in the exposed group. Bone marrow
toxicity is an unlikely cause of this effect, as only the red cell line was affected, and in any case,
interference with DNA synthesis of marrow red cell precursors (such as occurs after benzene
exposure) would result in larger, not smaller red cells.
Another limiting factor in this study is that although the study workers were employed at
many different sites under differing conditions, they were not generally involved in clean up, but
rather in feasibility studies and they were wearing protective equipment. One last possibility was
not addressed by the cross sectional nature of this study, i.e., that, the cumulative adverse health
effects of long term low level exposure have not as yet become manifest. This would clearly
require longitudinal study.
Case Study #14
REFERENCE: Hodgson, M.J. et al. 1989. Liver Injury Tests in Hazardous Waste Workers:
The Role of Obesity. Journ. Occupational Med. 31(3): 238-242. Peer-reviewed Journal.
OBJECTIVES: To examine risk factors for the presence of abnormal liver injury tests in two
groups of hazardous waste workers.
DESIGN: Retrospective review of case records.
SETTING: Case records obtained from Surveillance examinations at the Occupational and
Environmental Medicine Clinic at the University of Pittsburgh from the last available year
including all terminated employees.
SUBJECTS: Three hundred and twenty-five employees in "hazardous waste jobs" who had no
routine exposure to hepatotoxins, were compared with 13 workers who had potential intermittent
work to hepatotoxins in the routine performance of their duties, as well as 6 who had hobby
exposures. All 13 with potential work exposures wore adequate protective equipment when
continuing monitoring devices showed readings of VOCs above background levels. Examples of
exposures to hepatotoxins included a one day exposure to PCBs with undetectable blood levels at
the time of examination and exposures to trucking accidents with spillage of toluene and other
solvents. Hobby exposures included items such as methylene chloride in paint stripping,
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turpentine and petroleum products in painting. A further B of the 325 workers had incomplete
documentation of solvent exposures at work or at home.
MAIN OUTCOME MEASURES: Hepatotoxic exposures were based on direct information
from the workers and not on actual monitoring results. Body mass index (BMI) was calculated as
weight in Kg/height in meters. Duration of employment, alcohol use, solvent exposures at work
or home and current hobbies were recorded by self administered questionnaire. Laboratory
values for Aspartate aminotransferase (AST), Alanine aminotransferase (ALT) and Alkaline
phosphatase (AP) were obtained from the case records.
RESULTS: Workers in the higher tertiles of body mass index had the highest ALT and AP
mean values. Five workers had both abnormal ALT and AST levels (and these had significantly
higher BMIs than the workers with normal levels), one had elevated AST and AP and two had
elevated ALT and AP levels. There was no relationship between the proportion of abnormal
AST, ALT and AP levels, hepatotoxin exposures at work or at home, categories of alcohol
consumption or BMI. Morbidly obese workers (BMI > 30) were statistically significantly more
likely to have abnormal AST and ALT but not AP levels.
CONCLUSION: Workers with morbid obesity were substantially more likely to have
abnormal liver injury tests. BMI and gender were important determinants of the levels of AST
and ALT whereas minor exposures to hepatotoxins and alcohol were not.
CRITIQUE: The fact that in this study, liver injury tests were lower in those workers with the
longest duration of employment is likely to be related to the healthy worker effect, i.e., those
workers with liver injury due to alcohol or other causes may have left employment, leaving a
healthier population behind. The actual numbers of workers with known hepatotoxin exposures
in this study were too small to allow any kind of meaningful analysis. Moreover, hepatotoxic
exposures were based on direct information from the workers and not on actual monitoring
results. The author's conclusion that obesity be considered in the interpretation of abnormal liver
function tests in hazardous waste workers is reasonable in light of the known relationship
between obesity and liver injury.
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C. GROUP 2 STUDIES: INDUSTRIAL INCINERATORS
Case Study #15
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REFERENCE: Gatrell, A.C. and A.A. Lovett. 1992. Burning Questions: Incineration of
a Wastes and Implications for Human Health. In: Waste Location: Spatial Aspects of Waste
4 Management. Hazards and Disposal (ed. M.Clark, D.Smith and A.Blowers), Routledge,
pp. 142-157. Book Chapter.
• OBJECTIVES: To investigate a possible link between geographic distribution of a specific
cancer and proximity to an unnamed industrial incinerator in Coppull, Lancashire, England.
1 DESIGN: Descriptive mapping of the distribution of cases of laryngeal cancer reported to the
' Lancashire Health Authority in the vicinity of the plant.
I SETTING: The district around an industrial waste incinerator operating near Coppull in
Lancashire, England between 1972 and 1980 used primarily for the disposal of liquid wastes,
mostly solvents and oils. This incinerator was reportedly used to destroy industrial wastes
* generated on site.
I SUBJECTS: 6,200 cancer cases diagnosed between 1974 and 1983 in residents around the
I incinerator in Lancashire, England.
MAIN OUTCOME MEASURES: The numbers and types of cancers registered in Lancashire
I for the period 1974 to 1983 made available by the health authority.
RESULTS: Uneven distribution of episodes of cancer of the larynx. Four of 5 8 cases of this
cancer during this 10 year period came from within 2 kilometers of the incinerator.
CONCLUSION: Statistically significant association between the distribution of laryngeal
cancer in Lancashire and proximity to the incinerator, which the authors suggested was worthy of
further investigation.
CRITIQUE: Since the authors have not reported on the residential histories of the cases, or
details of where they worked, smoking histories (a known risk factor for laryngeal cancer),
I alcohol consumption and other risk factors including other sources of pollution, it is not possible
to conclude from this study that the association between proximity to the incinerator site and
J incidence of this type of cancer is causal. Moreover there is no reported information on the level
of air pollution at the time the incinerator was operating. The authors have not reported on other
demographic data that may influence their conclusions such as the age and gender distribution of
J their study population. Neither have they reported on prevailing wind patterns to allow an
assessment of whether the cases of laryngeal cancer resided upwind or downwind of the
incinerator. Although the results of this preliminary study suggest a link between living close to
| the incinerator site and the prevalence of laryngeal cancer, there is insufficient data to suggest
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that this is causal. Indeed, the authors made no attempt to determine whether the number of
observed cases of laryngeal cancer are greater or lesser than would be expected in such a
population. A subsequent report by Elliot et al (Lancet 339 (8797): 854-5, 1992) provided
additional statistical analysis of the incidence of cancer cases documented by Gatrell and Lovett.
In this report the authors found that "the incidence of lung and laryngeal cancer in individuals
living near the incinerator was not significantly greater than that expected in the population". The
Small Area Health Statistics Unit is currently investigating whether the incidence of cancer of the
larynx is raised in people living near incinerators in other parts of the United Kingdom.
Case Study #16
REFERENCE: Diggle, P. J. et al. 1990. Modelling the Prevalence of Cancer of the Larynx
hi Part of Lancashire: A New Methodology for Spatial Epidemiology. In: Spatial
Epidemiology, (ed. R.W.Thomas), Pion Limited, pp. 34-47. Book Chapter.
OBJECTIVES: To investigate the possible link between geographic distribution of a specific
cancer and proximity to an industrial incinerator in Lancashire, England.
DESIGN: Retrospective analysis of the number of cases of laryngeal cancer reported to the
Lancashire Health Authority in the vicinity of the plant. The novel statistical methodology used
in this study allows the authors to examine whether the location of the now closed incinerator
site is the only site within the district that has an influence on the spatial distribution of laryngeal
cancer.
SETTING: The district around an industrial waste incinerator operating near Coppull in
Lancashire, England between 1972 and 1980 used primarily for the disposal of liquid wastes,
mostly solvents and oils.
SUBJECTS: Residents around the incinerator in Lancashire, England.
MAIN OUTCOME MEASURES: The numbers and types of cancers registered in Lancashire
for the period 1974 to 1983 made available by the district health authority.
RESULTS: Uneven distribution of episodes of cancer of the larynx. Four of 58 cases of this
cancer during this 10 year period came from within 2 kilometers of the incinerator. Regardless of
where the location of the putative source was moved to hi this study, the only location to which
laryngeal cancer intensity was linked was the actual incinerator site.
CONCLUSION: Statistically significant association between the prevalence of laryngeal
cancer in Lancashire and proximity to the incinerator.
CRITIQUE: As hi the study of Gatrell and Lovett (1991), which essentially used the same
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data, there was no information on the residential histories of the cases, or details of where they
M worked, smoking histories (a known risk factor for laryngeal cancer), alcohol consumption and
• other risk factors. Neither was there any reported information on the level of air pollution at the
time the incinerator was operating. We should also caution that the authors were dealing with
M very small numbers of cancers and by repeating the analysis with one less cancer, their results
1J just failed to reach significance. Hence, it would be premature to conclude from this study that
the association between proximity to the incinerator site and incidence of this type of cancer is
causal.
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D. GROUP 3 STUDIES: CHEMICAL WASTE INCINERATORS
Case Study #17
REFERENCE: Decker, W.A. et al. 1983. Worker Exposure to Organic Vapors at a Liquid
Chemical Waste Incinerator. Arner. Ind. Hyg. Assoc. Journ. 44(4): 296-300. Peer-reviewed
\ Journal.
OBJECTIVES: To determine the extent of smployee exposure to organic vapors during the
I operation of a liquid chemical waste incinerator facility.
DESIGN: Comparison of employee exposure based on general area and personal breathing
1 zone samples analyzed for benzene, methyl ethyl ketone (MEK), toluene and xylene with
NIOSH, OSHA and ACGIH recommended criteria.
1
SETTING: A liquid/fluid chemical waste incinerator located in Cincinnati, Ohio employing a
rotary kiln and a cyclone furnace (liquid injection) with a common combustion chamber and
pollution control equipment. During the study, the incinerator destroyed 20,000 gallons of liquid
chemical waste per day (50% capacity). A wide variety of liquid industrial chemical wastes are
accepted but not Group LA and IIA elements, isocyanates, peroxides, PCBs, pesticides,
insecticides, explosives or radioactive wastes.
SUBJECTS: 13 workers over the 24-hour period.
MAIN OUTCOME MEASURES: Air sampling and 8 hour time weighted average exposures
to benzene, methyl ethyl ketone, toluene and xylene selected as screening compounds on the
basis of the fact that they were the most common compounds to the variety of wastes received,
their health hazard potential, feasibility of sampling and analysis and reliability of the sampling
and analytical methods. The data obtained during sampling were analyzed with respect to job
classification, operation performed, compounds sampled and waste type.
RESULTS: General area samples collected both upwind and downwind from the incinerator
facility revealed average air concentration of each of the four indicator'organic compounds to be
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less than 0.05 ppm. The workers operating the incinerator unit were exposed to no detectable
levels of benzene and MEK and less than 0.2 ppm of toluene and xylene. The laboratory
technician and other workers in charge of receiving the wastes received slightly higher
exposures, up to 0.8 ppm benzene exposure for the laboratory technician who conducted benzene
distillations during his entire work shift. The worker in charge of sampling the receiving wastes
received no detectable amounts of benzene or MEK and approximately Ippm each of toluene and
xylene.
Approximately twice a year, the waste storage tank is entered by one worker wearing self
contained breathing apparatus (SCBA) for maintenance or repair and a second worker, without
respiratory protection stands immediately outside. Breathing zone samples collected on the
outside worker and on the outside of the SCBA contained no benzene or MEK. Toluene vapor
levels averaged 15 ppm outside the tank and 104 ppm inside; xylene vapor levels averaged 31
ppm outside the tank and 194 ppm inside.
CONCLUSION: Routine operation of the facility resulted in worker exposure considerably
less than the action level for all compounds tested except benzene when compared with the
NIOSH but not with the OSHA or ACGIH criteria. The incinerator facility itself did not cause
any increased organic vapor levels 50 meters downwind from the site. ITie non routine operation
of storage tank entry resulted in the highest potential exposure of any operation. The significance
of this observation is tempered by the very short duration of this exposure.
CRITIQUE: Perhaps the most important criticism of this otherwise well designed study, is the
choice of indicator chemicals. Since the authors do not specify exactly what liquid chemical
wastes are being incinerated at the plant, it is not possible to ascertain whether their choice of
benzene, methyl ethyl ketone, toluene and xylene is a reasonable one. The generally low worker
exposure noted in this study is not unexpected in view of the fact that most of the incinerator
facility is a system of closed pipelines operated from within a control building
E. GROUP 4 STUDIES: MUNICIPAL WASTE PLUS INCINERATORS
Case Study #18
REFERENCE: Lloyd, O.L. et al. 1988. Twinning in Human Populations and in Cattle
Exposed to Air Pollution from Incinerators. British Joum. of Industrial Med. 45: 556-560.
Peer-reviewed Journal.
OBJECTIVES: To follow up anecdotal reports of increased number of twins in humans and
cattle at risk from plumes from two incinerators near the town of Bonnybridge in Central
Scotland.
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DESIGN: Retrospective analysis of the numbers and geographic clustering of single and twin
births in all hospitals in central Scotland during 1975-1983.
SETTING: Primary risk areas around two incinerators near Bonnybridge: 1) a municipal
waste incinerator that had operated for several years and 2) a nearby chemical incinerator which
began operating in 1974 and did not burn any polychlorinated biphenyls (PCBs) between 1977
and 1979 but restarted PCB incineration from 1980. The incinerator closed in 1984.
SUBJECTS: Humans and cattle living within the primary risk area, based on postcode
districts located west of the incinerator, due to the prevailing easterly winds. Exposure was
confirmed by the detection of high concentrations of polychlorinated hydrocarbons in surface
soils in the primary risk area as well as traces of polychlorinated hydrocarbons in tissue samples
from local cows reported in previous studies (Smith and Lloyd, Chemistry in Britain 2: 139-141,
1986).
MAIN OUTCOME MEASURES: Twinning rate in humans (controlled for maternal age
over the age of 35) and cattle on two local farms.
RESULTS: Increase in the rate of twinning for the period 1975 to 1983, particularly in those
| areas with the most direct exposure to incinerator air pollution. The background twinning rate
' ranged from 3 to 13 per 1000 in 1976-1979, increasing to 16-20 per 1000 during 1980 to 1983. A
dramatic increase in the rate of cattle twinning was also recorded, increasing from 0 to 2% for the
• years 1972-79 (equivalent to the average twinning rate for cattle) up to 22% of all calvings at two
farms in the primary risk area near Bonnybridge.
I CONCLUSION: The authors concluded there was an increased frequency of human and
cattle twinning in areas most at risk from air pollution from the incinerators, but they cautioned
^ against attributing causality to this association based on this data alone.
CRITIQUE: Although the results of this preliminary study are consistent with the hypothesis
that environmental air pollution may have affected obstetric parameters of the local human and
animal population, there are a number of additional points that need to be considered. First,
although the mean age of the twins' mothers in the primary risk area did not differ the mean age
t in the area as a whole, other social factors known to affect human twinning could act as
confounding variables and were not controlled for in this study. Second, the genetic component
of the twinning phenomenon in these populations remains to be investigated, although the
authors report that the calf twinning occurred despite the use of several bulls for artificial
insemination. Third, although polychlorinated hydrocarbons (PCHs) and PCBs had been
incinerated at Bonnybridge, there is unclear information concerning the timing of these activities
which detracts from the strength of the association. In particular it should be noted that the
reported increased twinning rate in cattle occurred during periods in which the Rechem
incinerator was not handling PCHs.
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The major limitation of this study is the notable absence of any actual measurements of
chemicals in either the air, the cattle feed, soil or animal tissue samples. Hence, exposure cannot
be proven, let alone quantified. In a subsequent report by Jones in the same journal (46(3): 215,
1989), the results of the Lloyds study are criticized on the basis that published concentrations of
PCHs are indistinguishable from concentrations normally found in the soils in the UK and that
these background levels have remained unchanged since the Rechem chemical waste incinerator
was closed in 1984. By far the likeliest alternative source of these compounds in the environment
are coal combustion and auto emissions while cigarette smoke is a major source of PCH
exposure to individual. The original paper by Lloyd et al. unfortunately fails to report on the
smoking habits of the study group.
Jones (1989) re-examined the rates of human twinning published by Lloyd et al and failed
to demonstrate any consistent trend over time, suggesting rather that the Lloyd data shows a
"random occurrence of marginally raised rates". Indeed, the report of Lloyd et al. demonstrates
that the clustering of human twinning occurred in one specific geographic area during 1980 only.
We should also mention that other independent investigations, both at the university and
government levels have failed to demonstrate the association between health problems in cattle
and environmental pollution in the Bonnybridge area (Lenihan J, Scottish Home and Health
Department Report: Bonnybridge/Denny Morbidity Review, 1985, cited in British Medical
Association, "Hazardous Waste and Human Health", Oxford University Press, 1991); Petts J,
"Incineration risk perceptions and public concern: experience in the UK, Waste Management and
Research (UK) 10: 169-182, 1992 (cited in Pleus et al. Health effects of hazardous waste
incineration facilities: Five case studies, Report by Environmental Toxicology International, Inc.,
1993), although unfortunately we were unable to obtain a copy of either of these for review.
Case Study #19
REFERENCE: National Institute for Occupational Safety and Health (NIOSH). 1982. Health
Hazard Evaluation Report (HETA 82-056-1186), Monroe County Incinerator, Key Largo,
Florida, US NIOSH, PB84-152966, NTIS. Agency Report.
OBJECTIVES: To determine the extent of possible biohazards from the handling of municipal
and hospital waste at the Monroe County Incinerator, Key Largo, Florida.
DESIGN: Walk through survey of the facility prompted by a report from NIOSH on
November 24, 1981.
SETTING: A mixed municipal (132,000 Ibs/day) and hospital (4200 Ibs/day) waste
incinerator.
SUBJECTS: 12 workers operating 3 shifts per day, 6 days per week.
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MAIN OUTCOME MEASURES: Interviews with incinerator operators and general
laborers. Organic content of grate ash samples.
RESULTS: Interviews indicated blood had been observed leaking from bags onto the
incinerator floor, but there were no incidents of seeing human body parts spilling from bags.
There was no evidence of unburned infectious waste in the grate ash. Samples of grate ash were
analyzed for organic content and found to contain 0.08 to 0.12% volatile material (consistent
with municipal waste incineration). There were no complaints of adverse health effects from the
employees at the facility.
CONCLUSION: No immediate biohazard was identified at the incinerator during the survey,
although worker exposure to infectious waste was deemed possible due to breakage of the bags
because of mishandling.
CRITIQUE: Apart from sampling grate ash for organic content, which was within acceptable
limits, this study considered (but did not mear.ure) potential exposure of the employees to
excessive dust concentrations when cleaning out the ash hoppers. This procedure requires about
30 minutes to complete and the worker observed during this particular site visit wore
monogoggles but no dust respirator. The report also mentioned the potential for contaminated
cistern water to enter the municipal drinking water system. Again, this hypothesis was not tested
and no water samples were analyzed.
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F. GROUP 5 STUDIES: MUNICIPAL WASTE INCINERATORS
Case Study #20
REFERENCE: Gustavsson, P. Mortality Among Workers at a Municipal Waste
Incinerator. 1989. Amer. Journ. Industrial Med. 15: 245-253. Peer-reviewed Journal.
OBJECTIVES: To investigate health effects from exposure to combustion products of
organic materials by examining mortality among male workers at a municipal waste incinerator.
DESIGN: Retrospective cohort study based on review of company records. Work practice
and smoking habit information was obtained by interviewing a small group of retired workers
and the plant director. Computerized registers were used to trace and follow up the 91 remaining
workers alive as of 1985. Information on cause of death from the death certificate for 79 of the
85 deaths. Actual deaths were compared with expected numbers of deaths from 1951 to 1985,
calculated from national and local death rates, standardized fcr age and calendar year.
SETTING: An incinerator plant located 15km west of Stockholm, burning household and
industrial wastes until 1955, but only household waste since then; 110,000 metric tons were
incinerated between 1938-1956, rising to 220,000 in 1965 and gradually reducing thereafter until
the plant was closed down in 1986.
SUBJECTS: 176 male workers employed for at least 1 year between 1920 and 1985 (4412
person years) at a municipal waste incinerator.
MAIN OUTCOME MEASURES: Observed and expected (both local and national) mortality
and cause of death; duration of employment and tobacco use.
RESULTS: Total mortality was slightly increased compared with national rates but equal to
local rates. There was a 3.5 fold excess risk for lung cancer compared to national rates and 2 fold
compared to local mortality rates. There was also a tendency toward increased mortality from
ischemic heart disease (SMR 138) and liver cirrhosis (SMR 454). The higher excess risk for
those with ischemic heart disease was in the group of workers with the longest duration of
exposure (> 40 years). 55% of the incinerator workers were reportedly smokers (as determined
by retrospective interview of retired workers) which is comparable to the general Swedish male
population (based on 2 surveys of tobacco use among Swedish males in 1965 and 1983).
CONCLUSION: The risk of death from lung cancer and ischemic heart disease was higher in
the group of municipal waste incinerator workers employed for more than 30 years than the
national rates. The author felt that smoking did not appear to account for the observed pattern of
excess mortality because longitudinal smoking data for the workers did not differ from that of the
general population.
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CRITIQUE: The primary criticism of this otherwise excellent study is that exposure data is
notably lacking. Moreover, due to the low number of employees in the mortality subgroups, it is
reasonable to conclude that the latency and exposure time documented in this study are
compatible with, but do not prove an occupational relationship. We should also emphasize that
the findings do not apply to workers employed for less than 30 years.
The major problem with extrapolation of this data to current hazardous waste incinerator
plants is the fact that (as pointed out by the author himself), this particular plant undoubtedly
operated under highly dusty conditions. Occupational exposures may have been higher in this
plant as 1) it was one of the oldest in Sweden and had been operating for a long time with
leakage of fumes into the incinerator hall; 2) some work practices at the plant were very dusty
including the handling of slag and high dust levels were reported in sampling done in 1973; 3) no
respirators were used in earlier years; 4) electrostatic filters introduced in 1973 probably
increased maintenance worker exposure; 5) the incinerators were manually cleaned of soot every
1 to 3 weeks by workers entering the incinerator. We would therefore question the relevance of
this data to currently operating hazardous waste incinerators.
Case Study #21
REFERENCE: Nessel, C.S. et al. 1991. Evaluation of the Relative Contribution of Exposure
Routes in a Health Risk Assessment of Dioxin Emissions from a Municipal Waste Incinerator.
Journ. of Exposure Analysis and Environ. Epidemiology 1(3): 283-307. Peer-reviewed Journal.
OBJECTIVES: To perform a cancer risk assessment of polychlorinated dioxin (PCDD) and
furan (PCDF) emissions from a municipal waste incinerator to evaluate the relative contributions
of various exposure routes.
DESIGN: Use of stack emissions data from an incineration facility to estimate what the effects
of such emissions would be on a hypothetically exposed population in the US. Three scenarios
4 were examined, i.e., common-case, highly exposed case and worst case, all of which predicted
ingestion offish to be a significant source of exposure, at 26%, 37% and 48% of total exposure
respectively for the three scenarios examined. In the common case which represented the general
population consuming mainly foods from commercial sources, inhalation was predicted to be the
source of greatest exposure. In addition to fish, milk and beef ingestion contributed significantly
to total exposure under the highly exposed and worst case scenarios.
SETTING: A municipal waste incineration facility with a 400 ton per day capacity and air
pollution control equipment consisting of dry scrubbers for acid gas control and baghouse filters
J for paniculate collection. The average of 3 emission samples collected within a one week period
for one of the stacks were analyzed for trichlorinated through octachlorinated PCDD and PCDF
isomers to assess chronic exposure.
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SUBJECTS: None, because hypothetical analysis.
MAIN OUTCOME MEASURES: Lifetime cancer risk from the emitted PCDD/PCDFs
expressed as the cumulative risk over a 70 year lifetime of continuous exposure and assessed for
each of the three scenarios. The data used included- TCDD equivalent emission rate of 2.14 x
10'8 kg/hr, total TCDD equivalent cone, of 0.3958 ng/dry standard m3; estimated max. annual
average ambient concentration TCDD equivalents = 2.83 x 10'3 pg/m3; overall deposition
velocity 0.112 cm/sec; deposition rate in TCDD toxic equivalents = 99.94 pg/m^yr; average
TCDD equivalent concentration in soil = 0.0826 pg/g, in leafy vegetables = 0.414 pg/kg, in
garden fruit = 0.250 pg/kg, in legumes = 0.342 pg/kg, in corn = 1.784 pg/kg, in fish = 0.0921
pg/g, in milk 1.48 pg/1, in table beef 4.78 x 10° pg/g; total average daily intake of TCDD
equivalents via all routes of exposure = 1.14 x 10'3 pg/kg/day (common case), 1.60 x 10*2 (highly
exposed) and 4.32 x 10'2 pg/kg/day (worst case); EPA potency factor for TCDD = 1.56 x 10"4
(pg/kg/day)-1-
RESULTS: The lifetime cancer risk from the emitted PCDD/PCDFs was estimated as 1.8 x
10'7 (common case), 2.5 x 10"6 (highly exposed) and 6.7 x 10"6 (worst case). This can be
expressed as an increased chance of at most 1 cancer mortality in 5,555,555 individuals due to
exposures to carcinogens in facility stack emissions in the common case assumption, in addition
to the more than 1,388,888 (i.e. 25% of 5,555,555 persons) who are already statistically expected
to die of cancer. The worst case scenario can be expressed as an increased chance of 1 cancer
mortality in 149,253 people, in addition to the 37,313 persons who are already statistically
expected to die of cancer.
CONCLUSION: Based on the conservative assumptions used in this cancer risk assessment,
the predicted excess cancer risk in the population exposed to PCDD/PCDF emissions from this
incinerator is relatively low and should not be considered a significant public health concern.
CRITIQUE: Some of the conservative assumptions used in this cancer risk assessment which
may have led to an overestimation of risk are as follows: disregard for photodegradation or
reactivity during dispersion modeling which may reduce the ambient PCDD/PCDF
concentration, deposition to environmental media and transport to biota based on the maximum
ambient concentration, no degradation of compounds on plant surfaces with the exception of
particulate weathering, continuous PCDD/PCDF exposure of the population for 70 years,
residence of the receptor population in the area of max. ambient concentration, overestimation of
the fraction of PCDD-contaminated foodstuffs consumed by the populations, 100% TCDD
inhalation bioavailability. These assumptions and limitations constitute major sources of
uncertainty in the methodologies used in this study.
Case Study #22
REFERENCE: Bresnitz, E.A. et al. 1992. Morbidity Among Municipal Waste Incinerator
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Workers. Am. Joum. Industrial Med. 22: 363-378. Peer-reviewed Journal.
OBJECTIVES: To examine the incidence of adverse health effects in active incinerator
workers.
DESIGN: Cross sectional analysis of medical and exposure monitoring data.
SETTING: A Philadelphia incinerator (Northwest) built in 1959 burning 750 tons of trash
per day at 1650 to 1900°F.
| SUBJECTS: Eighty six of 105 actively employed male incinerator employees identified
following an ATSDR site survey and NIOSH health hazard evaluation. Job exposure and
classification were based on job descriptions obtained by questionnaire and classified as high,
(slagging the furnace, hosing the cooling tower, shoveling ash and cleaning the dust work),
middle (bridge crane operators, firemen) or low (mechanics, tractor trailer operators, clerks, plant
superintendent). All the employees in the high exposure group had worked for at least 7 months
(median 15.9 years) at that high exposure job. Medical histories, physical examinations and
laboratory tests were obtained as part of their medical monitoring program.
MAIN OUTCOME MEASURES: 1) Monitoring of environmental, personal and area
samples for PCDDs and PCDFs expressed as TCDD equivalents, total dust, respirable dust,
crystalline silica and metals including those workers with high potential dust exposures; 2)
laboratory data and 3) pulmonary function test results. Samples were taken when only one of the
two incinerators were operating.
| RESULTS: Four of the breathing zone samples were above OSHA or ACGIH standards: one
each for lead and phosphorous and two for total particulates. Eight of the 471 tests (<2%) for
^ heavy metal exposure in the 86 workers were above the normal range (blood lead, zinc
§ protoporphyrin and blood mercury) but this was not related to the worker's exposure categories.
The authors were not able to correlate biological with personal breathing zone samples because
I of NIOSH's policy on confidentiality. There were no statistically significant differences in
pulmonary function between the high and low exposure groups, even after adjustment for
smoking status (50% prevalence of current smokers in the sample).
fFive workers, all in the low exposure group, had X ray findings suggestive of pleural
plaques/thickening. Three of these 5 were included in a group of 8 workers who had pulmonary
interstitial opacification; five of the 8 were in the high exposure group and three in the low. All 8
i were either current (5), ex-smokers (1) or obese (6). 34% of the workers were diagnosed as
* hypertensive: 16 in the low exposure and 13 in the high exposure group. The prevalence of
hypertension was elevated for both white and African-American workers aged 45-64 compared
J to the US population even after adjustment for the higher proportions of African-Americans in
the study sample.
CONCLUSION: This study did not consistently demonstrate significant environmental
•A-91
-------
elevations in ash and airborne contaminants and only a few biological tests for heavy metals
were elevated, with no apparent relationship between the highly exposed plant workers and those
less exposed.
CRITIQUE: For the following reasons it is possible that the sampling results may
inadequately reflect true exposures experienced by workers who normally performed the task: 1)
During the sampling by NIOSH only one of the 2 furnaces was operating; 2) personal and
environmental monitoring and sampling over brief periods of time may not be representative of
conditions normally encountered in the plant; 3) particularly at weekends, the pool of workers
available for personal sampling was reduced and while all tasks were sampled, the workers
performing them at the weekends, were not always the ones who normally did that particular job;
4) basic health and safety protections for the workers had been practically non-existent (no
protective clothing or respirators until 1988). In spite of these largely unprotected conditions, the
authors were unable to show substantial morbidity due to high exposure. However, 16 workers
employed at the time of the evaluation chose not to participate in the study (hence the potential
for referral bias) and no information was obtained about individuals v/ho no longer worked at the
plant (potential bias by healthy worker effect).
G. GROUP 6 STUDIES: UNSPECIFIED INCINERATORS
Case Study #23
REFERENCE: Gateshead Metropolitan Borough Council. 1988. Incidence Of Acute
Lymphoblastic Leukemia In Gateshead. Cited in "Hazardous Waste and Human Health", British
Medical Association, Oxford University Press, 1991. Independent Report (not peer-reviewed).
OBJECTIVES: To investigate a reported cluster of cases of acute lymphoblastic leukemia
(ALL) hi Gateshead, England between 1968 and 1977 in the proximity of the Wrekenton
incinerator, followed by a dramatic fall in the following years while the incinerator was still in
operation. In a number of cases, pairs of children living very close to each other reportedly
developed ALL within a very short period of time.
DESIGN: Retrospective analysis of the number of cases of ALL in Gateshead from 1968 to
1985.
SETTING: The district around the Wrekenton incinerator in Gateshead which operated
between 1972 and 1980. No information was available about type and size of this incinerator,
although levels of heavy metals emissions were reportedly well within control limits. By
contrast, the incinerator failed to meet the standards set by the Department of the Environment on
grit and dust emissions.
SUBJECTS: Residents around the Wrekenton incinerator in Gateshead, England.
A-92
-------
1
I
3
I
I
I
I
f
I
I
I
MAIN OUTCOME MEASURES: Cases of ALL reported to the Gateshead Metropolitan
Borough Council between 1974 and 1983
RESULTS: The number of cases of ALL reported in Gateshead was no higher than expected.
CONCLUSION: No objective evidence of an increase in the frequency of ALL in residents
near the Wrekenton incinerator in Gateshead.
CRITIQUE: Although there is a biological mechanism to explain the association between
exposure to heavy metals and benzene emitted from incinerators and leukemia, levels of heavy
metals emissions from this incinerator were reportedly well within control limits. Unfortunately
we were unable to obtain a copy of this report, such that it is difficult to evaluate its scientific
quality. Further information about the size and type of incinerator, background incidence of ALL
in this area and further details of the mechanisms by which the cases of leukemia were collected,
would help in evaluating the reliability of this study.
Case Study #24
REFERENCE: Welsh Office. 1985. The Incidence Of Congenital Malformation In Wales
With Special Reference To The District Of Torfaen, Gwent. Welsh Office, Cardiff. Cited in:
"Hazardous Waste and Human Health", British Medical Association, Oxford University Press,
1 99 1 . Independent Report (not peer-reviewed).
1 OBJECTIVES: To evaluate possible health effects associated with residence near the
Pontypool incinerator plant because of anecdotal reports of raised levels of congenital eye
malformations in children in the area.
DESIGN: Retrospective analysis of the number and types of malformations from 1974 to 1983.
SETTING: The district around the Pontypool incinerator in Wales which operated between
1972 and 1980. No information was available aoout type and size of this incinerator.
SUBJECTS: Children of residents around the Pontypool incinerator in Wales.
MAIN OUTCOME MEASURES: All eye malformations reported to the Welsh Office
between 1974 and 1983
RESULTS: No cases at all of eye malformations within this 10 year period within this district.
CONCLUSION: No objective evidence of an increase in the frequency of human eye
a malformations in children residing near the Pontypool incinerator in Wales.
A-93
-------
CRITIQUE: The main deficiency in this report (which unfortunately we were unable to obtain
a copy of) lies in the mechanisms for reporting and collecting data on such malformations in the
UK. The national system for notifying congenital defects was set up in 1964 in the UK and relies
entirely on physicians entering information on a voluntary basis, a system which often leads to
under reporting. Moreover malformations must be reported to the Central office within seven
days of birth; hence defects diagnosed after this point in time are not recorded. This alone may
explain the discrepancy between public anecdotes and the published data on the incidence of
congenital defects in this area in Wales. The results of a prospective study on the incidence of
eye malformations is in progress.
Case Study #25
REFERENCE: Zmirou D, Parent B, Poleton JL Epidemiological study of the health effects of
air pollution produced by the incineration of industrial and household wastes Rev. Epidem. et
Sante Publ. 1984, 32: 391-397. Peer-reviewed Journal.
OBJECTIVES: To relate consumption of medication for respiratory ailments to living
distance from an industrial and municipal waste incinerator.
DESIGN: Retrospective analysis.
SETTING & SUBJECTS: Residents of an unnamed village in L'Isere, France (population
3800) who were studied over a 2 month period in 1981.
MAIN OUTCOME MEASURES: Consumption of medication for respiratory problems over
a 2 year period in 3 matched groups of residents: zone 1 < 200 m south west (prevailing winds
from the north east) from the incinerator (n=89), zone II 1 km south of the incinerator (n=98),
zone III 2 km away (n=105). Information concerning use of medication was obtained by
analyzing social security forms filed by the residents after each purchase. Seven residents
(equally divided among the 3 groups) declined to participate in the study. Medication groups
included antibiotics and sulfonamides, anti-septics (?), bronchodilators, expectorants and
antitussive agents, anti-inflammatory agents, anti-histamines and immunotherapy. If a combined
preparation was prescribed, it was counted once under each category, whereas if a product was
considered to have more than one medicinal property, it was classified only under the major
functional category. Emissions analyzed in July 1980 (prior to the start of the study) included
sodium, potassium, calcium, magnesium, iron, copper, cadmium, zinc and lead (no actual
numerical data provided).
RESULTS: There were no demographic or socio-professional differences between the 3
groups. Statistically significantly more drugs in each category were purchased by zone 1
residents than either zone 2 or 3 residents (mean zone 1= 7, mean zone 2 = 4, mean zone 3 =
2.9). Numerically, the greatest differences occurred in the bronchodilator, anti-inflammatory and
A-94
-------
I
i
I
1
I
I
I
I
anti-histamine groups (although there was an interesting effect whereby zone 3 residents
purchased more than zone 2 but less than zone 1).
CONCLUSION: The authors concluded that the group most directly exposed to pollution
(zone 1 residents) were the most affected by the respiratory effects of polluted air as indicated by
the numbers of respiratory medications they purchased.
CRITIQUE: The major criticisms that could be leveled at this otherwise interesting study, are,
first, that the number of residents studied is somewhat small in comparison to the total village
population (approximately 7%), thus raising the possibility of exclusion bias. Second, it was not
possible to determine why these medications were purchased, i.e., there is no documented
evidence of an increase in respiratory ailments. The authors do not distinguish between
prescribed and over-the-counter medications, nor do they attempt to verify whether the
medications purchased were in fact used by the study residents. This is probably because the
study was performed very quickly: the authors state that they were under intense pressure from
the Health Authority to determine whether or not emissions from this incinerator were harmful to
local residents, such that a rapid decision could be reached about the future of the incinerator.
The lack of a true dose-response relationship between number of purchased medications in the
various categories and distance from the incinerator, further diminishes the strength of the
authors' conclusion. Finally, the original French version of this paper provides very little
information concerning the incinerator in question, specifically concerning emissions data.
I
A-95
-------
ATTACHMENT VI-2
Toxic Release Inventory Data for Facilities
Located in the Vicinity of WTI
-------
TABLE VI-2-1. Toxic Release Inventory Data for Facilities within 15-Mile Radius of WTI*
COUNTY: Beaver; STATE: Pennnsylvania
TYPE OF EMISSION: Stack Air Release (Pounds of Chemical)
CHEMICAL8
Acrylamide
Benzene
Butadiene- 1,3
Butyl acrylate
Chlorodifluoromethane
Cyclohexane
Ethylbenzene
Ethylene glycol
"Mycol ethers
ivlaleic anhydride
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Styrene
Thiourea
Toluene
Trichloroethylene
Trimethylbenzene
Xylene (total)
Ammonia
Chlorine
Hydrochloric acid
.ydrogen fluoride
Facility
#1
50
270
49,000
480
4,400
Facility
#2
1
75
200
350
6
Facility
#3
Facility
#4
Facility
#5
Facility
#6
250
-------
TABLE VI-2-1 (CONTINUED):
CHEMICAL8
Nitric Acid
Phosphoric acid
Sulfuric acid
Antimony
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Facility
#1
Facility
#2
Facility
#3
250
250
Facility
#4
Facility
#5
250
250
Facility
#6
5
250
'
A A list of all facility names and adresses can be found after the final data table in this attachment.
B All chemicals reported as releases for these facilities; other chemicals generated or used are not included.
NOTE: Empty spaces in Table denote that chemical was not present at the required threshold level at this facilty,
or chemical was not reported as a release for this facility.
-------
TABLE VI-2-2. Toxic Release Inventory Data for Facilities within 15-Mile Radius of WTIA
COUNTY: Beaver; STATE: Pennnsylvania
TYPE OF EMISSION: Stack Air Release (Pounds of Chemical)
CHEMICAL8
Acrylamide
Benzene
Butadiene- 1,3
Butyl acrylate
Chlorodifluoromethane
Cyclohexane
Ethylbenzene
Ethylene glycol
'ycol ethers
Maleic anhydride
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Styrene
Thiourea
Toluene
Trichloroethylene
Trimethylbenzene
Xylene (total)
Ammonia
Chlorine
Facility
#7
Facility
#8
Facility
#9
Facility
#10
Facility
#11
Facility
#12
-------
TABLE VI-2-2 (CONTINUED):
CHEMICAL8
Hydrochloric acid
Hydrogen fluoride
Nitric Acid
Phosphoric acid
Sulfuric acid
Antimony
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Facility
#7
90
27,000
480
10
180
770
630
2,700
Facility
#8
20
131
23
Facility
#9
1.800
36,000
250
Facility
#10
Facility
#11
250
750
250
Facility
#12
5
''
A A list of all facility names and adresses can be found after the final data table in this attachment.
BAII chemicals reported as releases for these facilities; other chemicals generated or used are not included.
NOTE: Empty spaces in Table denote that chemical was not present at the required threshold level at this facilty,
or chemical was not reported as a release for this facility.
-------
TABLE VI-2-3. Toxic Release Inventory Data for Facilities within 15-Mile Radius of WTIA
COUNTY: Beaver; STATE: Pennnsylvania
TYPE OF EMISSION: Stack Air Release (Pounds of Chemical)
CHEMICAL8
Acrylamide
Benzene
Butadiene- 1,3
Butyl acrylate
Chlorodifluoromethane
Cyclohexane
Ethylbenzene
Ethylene glycol
X|ycol ethers
Maleic anhydride
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Styrene
Thiourea
Toluene
Trichloroethylene
Trimethylbenzene
Xylene (total)
Ammonia
Chlorine
Hydrochloric acid
,-iydrogen fluoride
Facility
#13
Facility
#14
Facility
#15
Facility
#16
Facility
#17
-------
TABLE VI-2-3 (CONTINUED):
CHEMICAL8
Nitric Acid
Phosphoric acid
Sulfuric acid
Antimony
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Facility
#13
Facility
#14
6,800
Facility
#15
6
19
4
Facility
#16
Facility
#17
700
200
8,000
90
600
421,000
A A list of all facility names and adresses can be found after the final data table in this attachment.
B All chemicals reported as releases for these facilities; other chemicals generated or used are not
included.
NOTE: Empty spaces in Table denote that chemical was not present at the required threshold level
at this facilty, or chemical was not reported as a release for this facility.
-------
TABLE VI-2-4. Toxic Release Inventory Data for Facilities withinl 5-Mile Radius of WTIA
COUNTY: Hancock; STATE: West Virginia
TYPE OF EMISSION: Stack Air Release (Pounds of Chemical)
CHEMICAL8
Acrylamide
Benzene
Butadiene-1 ,3
Butyl acrylate
Chlorodifluoromethane
Cyclohexane
Ethylbenzene
Ethylene glycol
"'ycol ethers
Maleic anhydride
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Styrene
Thiourea
Toluene
Trichloroethylene
Trimethylbenzene
Xylene (total)
Ammonia
Chlorine
Hydrochloric acid
. .ydrogen fluoride
Facility
#1
Facility
#2
Facility
#3
250
10
10
83,000
100,000
5
70
Facility
#4
38,594
-------
TABLE VI-2-4 (CONTINUED):
CHEMICAL8
Nitric Acid
Phosphoric acid
Sulfuric acid
Antimony
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Facility
#1
Facility
#2
3,000
9,200
Facility
#3
Facility
#4
52
100
1,130
7,000
54
500
A A list of all facility names and adresses can be found after the final data table in this attachment.
B All chemicals reported as releases for these facilities; other chemicals generated or used are not included.
NOTE: Empty spaces in Table denote that chemical was not present at the required threshold level at this facilty,
or chemical was not reported as a release for this facility.
-------
TABLE VI-2-5. Toxic Release Inventory Data for Facilities within 15-Mile Radius of WTI*
COUNTIES: Columbiana and Jefferson; STATE: Ohio
TYPE OF EMISSION: Stack Air Release (Pounds of Chemical)
CHEMICAL8
Acrylamide
Benzene
Butadiene-1,3
Butyl acrylate
Chlorodifluoromethane
Cyclohexane
Ethylbenzene
Ethylene glycol
~lycol ethers
Maleic anhydride
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Styrene
Thiourea
Toluene
Trichloroethylene
Trimethylbenzene
Xylene (total)
Ammonia
Chlorine
Hydrochloric acid
.ydrogen fluoride
Columbiana:
Facility
#1
Columbiana:
Facility
#2
Columbiana:
Facility
#3
Columbiana:
Facility
#4
3,100
4,100
6,300
8.000
6,100
Jefferson:
Facility
#1
Jefferson:
Facility
#2
250
-------
TABLE VI-2-5 (CONTINUED):
CHEMICAL8
Nitric Acid
Phosphoric acid
Sulfuric acid
Antimony
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Columbiana:
Facility
#1
Columbiana:
Facility
#2
Columbiana:
Facility
#3
4,900
Columbiana:
Facility
#4
Jefferson:
Facility
#1
Jefferson:
Facility
#2
250
»f
A A list of all facility names and adresses can be found after the final data table in this attachment.
8 All chemicals reported as releases for these facilities; other chemicals generated or used are not included.
NOTE: Empty spaces in Table denote that chemical was not present at the required threshold level at this facilty,
or chemical was not reported as a release for this facility.
-------
TABLE VI-2-6. Toxic Release Inventory Data for Facilities within 15-Mile Radius of WTIA
COUNTY: Beaver; STATE: Pennnsylvania
TYPE OF EMISSION: Fugitive Air Release (Pounds of Chemical)
CHEMICAL8
Acrylamide
Benzene
Butadiene-1,3
Butyl acrylate
Chlorodifluoromethane
Cyclohexane
Ethylbenzene
Ethylene glycol
^lycol ethers
i\/laleic anhydride
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Styrene
Thiourea
Toluene
Trichloroethylene
Trimethylbenzene
Xylene (total)
Ammonia
Chlorine
Hydrochloric acid
/drogen fluoride
Facility
#1
9
53,000
1,500
Facility
#2
Facility
#3
Facility
#4
Facility
#5
Facility
#6
250
-------
TABLE VI-2-6 (CONTINUED):
CHEMICAL8
Nitric Acid
Phosphoric acid
Sulfuric acid
Antimony
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Facility
#1
Facility
#2
Facility
#3
1,385
1.345
Facility
#4
4.300
Facility
#5
5
5
Facility
#6
750
250
,-*"
\
A A list of all facility names and adresses can be found after the final data table in this attachment.
8 All chemicals reported as releases for these facilities; other chemicals generated or used are not included.
NOTE: Empty spaces in Table denote that chemical was not present at the required threshold level at this facilty,
or chemical was not reported as a release for this facility.
-------
TABLE VI-2-9. Toxic Release Inventory Data for Facilities within 15-Mile Radius of WTI*
COUNTY: Hancock; STATE: West Virginia
TYPE OF EMISSION: Fugitive Air Release (Pounds of Chemical)
CHEMICAL8
Acrylamide
Benzene
Butadiene- 1,3
Butyl acrylate
Chlorodifluoromethane
Cyclohexane
Ethylbenzene
Ethylene glycol
Glycol ethers
Maleic anhydride
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Styrene
Thiourea
Toluene
Trichloroethylene
Trimethylbenzene
Xylene (total)
Ammonia
Chlorine
Hydrochloric acid
lydrogen fluoride
Facility
#1
19,875
Facility
#2
Facility
#3
50
30
30
69,000
76,000
80
220
Facility
#4
15,883
250
500
-------
TABLE VI-2-9 (CONTINUED):
CHEMICAL8
Nitric Acid
Phosphoric acid
Sulfuric acid
Antimony
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Facility
#1
Facility
#2
1
1
Facility
#3
Facility
#4
500
502
250
100
1,502
26
100
A A list of all facility names and adresses can be found after the final data table in this attachment.
8 All chemicals reported as releases for these facilities; other chemicals generated or used are not included.
NOTE: Empty spaces in Table denote that chemical was not present at the required threshold level at this facilty,
or chemical was not reported as a release for this facility.
-------
TABLE VI-2-7. Toxic Release Inventory Data for Facilities within! 5-Mile Radius of WTIA
COUNTY: Beaver; STATE: Pennnsylvania
TYPE OF EMISSION: Fugitive Air Release (Pounds of Chemical)
CHEMICAL8
Acrylamide
Benzene
Butadiene- 1,3
Butyl acrylate
Chlorodifluoromethane
Cyclohexane
Ethylbenzene
Ethylene glycol
"lycol ethers
Maleic anhydride
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Styrene
Thiourea
Toluene
Trichloroethylene
Trimethylbenzene
Xylene (total)
Ammonia
Chlorine
Hydrochloric acid
. lydrogen fluoride
Facility
#7
Facility
#8
Facility
#9
Facility
#10
/•
Facility
#11
250
Facility
#12
-------
TABLE VI-2-7 (CONTINUED):
CHEMICAL8
Nitric Acid
Phosphoric acid
Sulfuric acid
Antimony
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Facility
#7
150
10
1,000
190
100
1,200
Facility
#8
14
85
11
Facility
#9
Facility
#10
6,700
Facility
#11
750
250
Facility
#12
250
/"°~
-
A A list of all facility names and adresses can be found after the final data table in this attachment.
8 All chemicals reported as releases for these facilities; other chemicals generated or used are not included.
NOTE: Empty spaces in Table denote that chemical was not present at the required threshold level at this facilty,
or chemical was not reported as a release for this facility.
-------
TABLE VI-2-8. Toxic Release Inventory Data for Facilities withinl 5-Mile Radius of WTI*
COUNTY: Beaver; STATE: Pennnsylvania
TYPE OF EMISSION: Fugitive Air Release (Pounds of Chemical)
CHEMICAL8
Acrylamide
Benzene
Butadiene- 1,3
Butyl acrylate
Chlorodifluoromethane
Cyclohexane
Ethylbenzene
Ethylene glycol
~lycol ethers
Maleic anhydride
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Styrene
Thiourea
Toluene
Trichloroethylene
Trimethylbenzene
Xylene (total)
Ammonia
Chlorine
Hydrochloric acid
.ydrogen fluoride
Facility
#13
5
Facility
#14
Facility
#15
Facility
#16
250
Facility
#17
-------
TABLE VI-2-8 (CONTINUED):
CHEMICAL8
Nitric Acid
Phosphoric acid
Sulfuric acid
Antimony
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Facility
#13
Facility
#14
2,250
Facility
#15
46,000
Facility
#16
250
750
Facility
#17
300
4,000
155,000
A A list of all facility names and adresses can be found after the final data table in this attachment.
8 All chemicals reported as releases for these facilities; other chemicals generated or used are not
included.
NOTE: Empty spaces in Table denote that chemical was not present at the required threshold level
at this facilty, or chemical was not reported as a release for this facility.
-------
TABLE VI-2-10. Toxic Release Inventory Data for Facilities within 15-Mile Radius of WTIA
COUNTIES: Columbiana and Jefferson; STATE: Ohio
TYPE OF EMISSION: Fugitive Air Release (Pounds of Chemical)
CHEMICAL8
Acrylamide
Benzene
Butadiene- 1,3
Butyl acrylate
Chlorodifluoromethane
Cyclohexane
Ethylbenzene
Ethylene glycol
"ilycol ethers
Maleic anhydride
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Styrene
Thiourea
Toluene
Trichloroethylene
Trimethylbenzene
Xylene (total)
Ammonia
Chlorine
Hydrochloric acid
hydrogen fluoride
Columbiana:
Facility
#1
Columbiana:
Facility
#2
Columbiana:
Facility
#3
Columbiana:
Facility
#4
1,400
1,700
2,700
3,000
2,600
i '
Jefferson:
Facility
#1
168,700
Jefferson:
Facility
#2
250
-------
TABLE VI-2-10 (CONTINUED):
CHEMICAL8
Nitric Acid
Phosphoric acid
Sulfuric acid
Antimony
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Columbiana:
Facility
#1
4,000
500
Columbiana:
Facility
#2
250
250
Columbiana:
Facility
#3
Columbiana:
Facility
#4
Jefferson:
Facility
#1
Jefferson:
Facility
#2
250
A A list of all facility names and adresses can be found after the final data table in this attachment.
8 All chemicals reported as releases for these facilities; other chemicals generated or used are not included.
NOTE: Empty spaces in Table denote that chemical was not present at the required threshold level at this facilty,
or chemical was not reported as a release for this facility.
-------
TABLE VI-2-11. Releases from WTI of Chemicals Reported in Toxic Release Inventory Data
for Facilities in Vicinity of WTIA
TYPE OF EMISSION: Stack Air Release and Fugitive Air Release (Pounds of Chemical)8
CHEMICAL0
Acrylamide
Benzene
Butadiene- 1,3
Butyl acrylate
Chlorodifluoromethane
Cyclohexane
Ethytbenzene
Ethylene glycol
Glycol ethers
Maleic anhydride
,
-------
TABLE VI-2-11 (CONTINUED):
CHEMICAL
WTI Stack Air Releases
WTI Fugitive Air Releases
Nitric Acid
Phosphoric acid
Sulfuric acid
Antimony
0.3
Barium
10.4
0.05F
Cadmium
1.1
Chromium
0.05
Copper
6.5
Lead
2.9
1F
Manganese
Mercury
97.1
Nickel
0.35
0.02F
Zinc
8.3
A A list of all facility names and adresses can be found after the final data table in this
Attachment.
BData on releases from WTI were obtained from Volume III: Characterization of the Nature and
Magnitude of Emissions.
c All chemicals reported in the Toxic Release Inventory data for facilities within a 15 mile radius
of WTI (See Table VI-2-1 through Table VI-2-10).
D For comparison to other facilities, WTI stack emission rates were converted to pounds per
year using the assumption that the incinerator operates continuously (8760 hours per year).
E Fugitive emission from waste storage tanks.
F Fugitive emission from fly ash.
NOTE: Empty spaces in this Table denote that it was not possible to assign an emission rate
for this chemical (See Volume III: Characterization of the Nature and Magnitude of
Emissions).
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LIST OF FACILITIES REPORTING TOXIC RELEASE INVENTORY DATA IN VICINITY OF WTI
County: Beaver; State: Pennsylvania
Facility #1: ARCO Chemical; 400 Frankfort Rd.; Monaca, PA 15061
Facility #2: BASF Corp. - Dispersions Facility; 370 Frankfort Rd.; Monaca, PA 15061
Facility #3: Beaver Valley Alloy Foundry; 1899 Brodhead Rd.; Monaca, PA 15061
Facility #4: Beaver Valley Heat Treating; 1585 Beaver Ave.; Monaca, PA 15061
Facility #5: Brighton Electric Steel Casting Co.; 510 45th St.; Beaver Falls, PA 15010
Facility #6: Cutler Hammer; #1 Tuscarawas Rd.; Beaver, PA 15009
Facility #7: J & L Specialty Steel, Inc.; 12th St. & Midland Ave.; Midland, PA 15059
Facility #8: J & L Structural, Inc.; 111 Station St.; Aliquippa, PA 15001
Facility #9: LTV Steel Co. - Aliquippa Works; Franklin Ave.; Aliquippa, PA 15001
Facility #10: Moltrup Steel Products Co., Inc.; 14th St. & 2nd Ave.; Beaver Falls, PA 15010
Facility #11: Pittsburgh Tool Steel, Inc.; 1535 Beaver Ave.; Monaca, PA 15061
Facility #12: Pittsburgh Tube Co. - Monaca Div.; 1817 Pennsylvania Ave.; Monaca, PA 15061
Facility #13: Pittsburgh Tube Co. - Darlington Div.; 305 Cannelton Rd.; Darlington, PA 16115
Facility #14: Precision Kidd Steel Co.; 2nd & Erie St.; West Aliquippa, PA 15001
Facility #15: Republic Engineering Steels Inc.; 220 7th Ave.; Beaver Falls, PA 15010
Facility #16: West Homestead Engineering. & Machine Co.; #1 12th St.; Beaver, PA 15059
Facility #17: Zinc Corp. of America; 300 Frankfort Rd.; Monaca, PA 15061
County: Hancock; State: West Virginia
Facility #1: Air Products & Chemicals, Inc.; 4th and St. Johns Rd.; Weirton, WV 26062
Facility #2: Homer Laughlin China; 6th and Harrison Sts.; Newell, WV 26050
Facility #3: Quaker State Corp.; St. Route 2, PO Box 336; Newell, WV 26050
Facility #4: Weirton Steel Corp.; 400 Three Springs Dr.; Weirton, WV 26062
County: Columbiana; State: Ohio
Facility #1: ALBCO Foundry & Machine Co.; 230 W. Maple St.; Lisbon, OH 44432
Facility #2: Columbiana Foundry Co.; 501 Lisbon Rd.; Columbiana, OH 44408
Facility #3: National Refractories & Minerals; 41738 Esterly Dr.; Columbiana, OH 44408
Facility #4: U.S. Can Balonoff; W. Park Ave.; Columbiana, OH 44408
County: Jefferson; State: Ohio
Facility #1: Hancock Manufacturing Co.; Cleveland and 5th Sts.; Toronto, OH 43964
Facility #2: TIMET; 100 Titanium Way; Toronto, OH 43964
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ATTACHMENT VH-1
Risk Characterization for Metals Emitted at the Permit Limits
Volume VIII
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RISK CHARACTERIZATION FOR METALS
EMITTED AT THE PERMIT LIMITS
WASTE TECHNOLOGIES INDUSTRIES
EPA ID NO. OHD980613541
TASK 08, Subtask 1
Submitted to:
Dr. Mario Mangino
Work Assignment Manager
U.S. Environmental Protection Agency
Region V
77 West Jackson Boulevard
Chicago, Illinois 60604
Submitted by:
A.T. Kearney, Inc.
222 West Adams Street
Chicago, Illinois 60606
and
ENVIRON International Corporation
4350 North Fairfax Drive
Arlington, Virginia 22203
Work Assignment No.
Contract No.
Kearney WAM
Telephone No.
EPA WAM
Telephone No.
R05002
68-W4-0006
Ann Anderson
312/223-6230
Mario Mangino
312/886-2589
January 29, 1996
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Technical Memorandum
R05002 - Task 08
Risk Characterization for Metals Emitted at the Permit Limits
29 January 1996
As pan of the HHRA, cancer risks and hazard index (HI) values associated with
human exposure to 14 metals1 emitted from the incinerator stack of the WTI facility were
calculated based on estimated emission rates. U.S. EPA (1994) developed preliminary
permit limit metal emission rates for 11 of these metals2, based on inhalation exposure to
metals at the location of maximum predicted air concentration (based on air
dispersion/deposition modeling). Indirect exposure to metals at this location, however, was
not considered by U.S. EPA in developing the preliminary metal emission limits. Therefore,
human health cancer risks and HI values associated with exposure (direct and indirect
combined) to metals emitted from the facility stack at the preliminary permit limits were
estimated for the point of maximum predicted concentration. In addition, because indirect
exposure may be a more significant route of exposure than direct inhalation exposure, cancer
risks and HI values were estimated at the location of maximum predicted deposition (based
on air dispersion/deposition modeling) for the metals with preliminary permit limits. Human
health risks associated with exposure to incinerator stack emissions vary linearly in relation
to emission rate; consequently, the preliminary permit limit emission rates may be adjusted,
if necessary, to account for risks associated with indirect exposure.
Table 1 presents the estimated and permit limit emission rates for each metal.
Table 2 provides a comparison of the total cancer risk and HI values associated with
estimated emission rates for each metal at the point of maximum concentration, and the
corresponding cancer risk and HI values associated with permitted emission rates at the point
of maximum concentration and the point of maximum deposition. Risks to a subsistence
1 Potential health effects associated with exposure to lead were evaluated using U.S. EPA's
uptake/biokinetic modeling approach. Cancer risks and the potential for noncancer health effects
associated with lead are not evaluated as part of this analysis.
2 U.S. EPA did not develop specified permit limit emission rates for aluminum, copper, and
zinc; therefore, these metals are not included in this analysis.
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farmer child, who represents the most highly exposed population for metals, are shown in
Table 2.
Insignificant cancer risks were estimated for four carcinogenic metals—arsenic.
beryllium, cadmium, and chromium—emitted at the preliminary permit limit. For nickel, the
total lifetime cancer risk emitted at its preliminary permit limit was estimated to be 2 x 10 '
and 3 x 10'5 at the location of maximum concentration and maximum deposition.
respectively. For metals with noncancer effects, HI values greater than 1.0 were estimated
for six metals—barium, mercury, nickel, selenium, silver, and thallium—as shown in Table
2.
For four of the metals with noncancer effects—nickel, selenium, silver, thallium—HI
values are estimated to be higher at the location of maximum deposition than at the location
of maximum concentration by a factor of between three and seven. For the metals with
carcinogenic effects, estimated cancer risks are higher at the location of maximum
concentration.
Risks to a subsistence fisherman were estimated to evaluate the potential
bioaccumulation of metals (primarily mercury) in fish. Table 3 summarizes the estimated
cancer risks and HI values for a subsistence fisherman located at Tomlinson Run Lake3.
Estimated cancer risks and HI values for exposure to metals by a subsistence fisherman are
not predicted to be significant at either the estimated emission rate or the preliminary permit
limit emission rate, as shown in Table 3.
3 Of the local water bodies evaluated in the HHRA, this lake is predicted to receive the
greatest impact from metal emissions from the WTI facility.
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TABLE 1
Comparison of Estimated Metal Emission Rates and
Preliminary Permit Limit Emission Rates
Metal
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Mercury
Nickel
Selenium
Silver
Thallium
Estimated
Emission Rate
(g/sec)
4.2 x ID'6
3.7 x 1(T5
1.5 x 1(T4
3.3 x 10-8
1.6x 10~5
7.1 x 10-7
1.4x 1(T3
5.0 x ID"6
4.7 x 10-4
1.5 x 1(T5
3.4 x 1(TS
Permit Limit
Emission Rate
(g/sec)
1.6x 10~4
1.1 x 1(T4
55
3.6 x 1(T6
1.9 x 10~4
1.5x 10-4
8.8 x 10-2
22
4.4
3.3
5.5 x ID'1
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TABLE 2
Comparison of Metal Cancer Risks and Hazard Indices
Based on Estimated and Permit Limit Emission Rates
Point of Maximum Concentration and Point of Maximum Deposition, Subarea El
Subsistence Farmer Child
Metal
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Mercury
Nickel
Selenium
Silver
Thallium
Estimated Emission Rates
Point of Maximum
Concentration
Total
Cancer Risk
NA
1.5 x i
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TABLE 3
Comparison of Metal Cancer Risks and Hazard Indices
Based on Estimated and Permit Limit Emission Rates Tomlinson Run Lake
Subsistence Fisherman
Metal
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Mercury
Mercury (MeHg)
Nickel
Seleniurh
Silver
Thallium
Estimated
Emission
Rate
(g/sec)
4.2 x 10-6
3.7 x 1(T5
1.5 x 10-4
3.3 x 10-"
1.6 x 10-5
7.1 x 1(T7
1.4 x 1(T3
1.4 x 1(T3
5.0 x 10-6
4.7 x 10-4
1.5 x 1(TS
3.4 x 1(TJ
Total Cancer
Risk
NA
9.6 x 10-'2
NA
1.2 x 10-14
NA
NA
NA
NA
NA
NA
NA
NA
Total
Hazard Index
1.2 x 10~'°
1.4x 10-7
1.2 x 10-'°
4.2 x 10~12
2.3 x 10-7
7.3 x 10-"
4.9 x lO'4
2.8 x lO0
3.6 x 10-'°
2.1 x 10-7
1.7 x 10-"
1.8x 10-6
Permit Limit
Emission
Rate
(g/sec)
1.6x 10-4
1.1 x HT4
5.5 x 10+1
3.6 x 10-«
1.9x 10-4
1.5 x 10-4
8.8 x 10-2
8.8 x 1Q-2
2.2 x 10*'
4.4 x 10°
3.3 x 10°
5.5 x 10'1
Total
Cancer Risk
NA
2.9 x 10-"
NA
1.3 x 1Q-'2
NA
NA
NA
NA
NA
NA
NA
NA
Total
Hazard Index
4.5 x 10 '
4.2 x 10 7
4.4 x 10 s
4.6 x 10 "'
2.7 x 10 fi
1.5 x 10"
3.1 x 10 2
1.8 x 10 '
1.6 x 10 '
2. Ox 10 '
3.7 x 10 6
2.9.x 10 2
NA - U.S. EPA toxicity values are not available for this metal.
MeHg - Methyl mercury; 25 percent of mercury in aquatic environments was assumed to be methyl mercury.
Potential human health effects associated with exposure to lead are evaluated by U.S. EPA using a uptake/biokinetic modeling approach; U S KI'A derived
toxicity values (e.g., RfD, slope factor) are not available for this metal.
-6-
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REFERENCES
U.S. Environmental Protection Agency (U.S. EPA). 1994. Maximum metals emissions from
Waste Technologies Industries. Memorandum from G. Victorine to Administrative
Record, WTI Risk Assessment Phase 2. December 21.
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