United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
August 1987
EPA/530-SW-87-025
Solid Waste
National Dioxin Study

-------
             NATIONAL  DIOXIN STUDY


               REPORT TO CONGRESS
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Office of Solid  Waste and  Emergency Response
                  August, 1987
                             U.S. Environmental Protection Agency
                             Region V, Library
                             230 South Dearborn Street  ,-
                             Chicago, Illinois  60604

-------
                        Table of Contents



GLOSSARY

EXECUTIVE SUMMARY

                                                             Page

Chapter 1 - INTRODUCTION

1.1  Basis of Public and Congressional Concern	    1-1

1.2  The National Dioxin Strategy	    1-3

     1.2.1   Objectives	•	    1-3
     1.2.2   Management	    1-3
     1.2.3   Interagency/International Coordination.......    1-3

1.3  Background Information on 2,3,7,8-TCDD	    1-4

     1.3.1   Physicochemical Properties	    1-4
     1.3.2   Toxicity	    1-6
               Non-Human	    1-6
               Human	    1-7
     1.3.3   Fate and Transport	    1-8
     1.3.4   Toxicity Equivalence	    1-9
     1.3.5   Body Burden	   1-10
     1.3.6   Bioavailability	   1-11

1.4  Study Design and Implementation	   1-11

     1.4.1   Organization of the Study	   1-12
     1.4.2   Detection Limits/Analytical Support	   1-14

Chapter 2 - TIERS 1 AND 2

2.1  Approach	   II-l

2.2  Findings	   II-3

     2.2.1   Universe of Tiers 1 and 2	   II-3
     2.2.2   Other Dioxin-Contaminated Sites	   II-5
     2.2.3   Extent of Contamination	   II-6
               Fish Advisories.	   II-7
               Off-Site Contamination	   II-8

2.3  Response Actions	  11-14

-------
Chapter 3 - TIERS 3, 5, 6, 7

3.1  Tier 3 - Formulators	  III-2

     3.1.1   Objective	  III-2
     3.1.2   Study Design	  III-2
     3.1.3   Results	  III-3
     3.1.4   Findings	 III-ll
     3.1.5   Conclusions	 111-12

3.2  Tier 5 - Use Sites	 111-12

     3.2.1   Objective	 111-12
     3.2.2   Study Design	 111-15
     3.2.3   Results	 111-16
     3.2.4   Findings	 111-20
     3.2.5   Conclusions	 111-21

3.3  Tier 6 - 'Other' Chemical Manufacturers	 111-21

     3.3.1   Objective	 111-21
     3.3.2   Study Design	 111-23
     3.3.3   Results	 111-23
     3.3.4   Findings	 111-26
     3.3.5   Conclusion	 111-26

3.4  Tier 7 - Background Sites	 111-26

     3.4.1   Objectives	 111-26
     3.4.2   Study Design	 111-28
     3.4.3   Results	 111-29
     3.4.4   Findings	 111-31
     3.4.5   Conclusions	 111-32

3.5  Follow-on Investigations.....	 111-33

Chapter 4 - TIER 4 COMBUSTION SOURCES

4.1  Objectives	    IV-1

4.2  Background	    IV-1

4. 3  Study Des ign	    IV-2

     4.3.1   Sample Collection	    IV-4
             Stack Sampling	    IV-4
             Ash Sampling.	    IV-5
     4.3.2   Site Selection	    IV-5
     4.3.3   Sampling Procedure and Analyses	    IV-6

-------
4.4  Results	    IV-7

     4.4.1   Tier 4 Stack Test Results	    IV-7
               Quality Assurance	   IV-10
     4.4.2   Results Reported in the Literature	   IV-11

4.5  Discussion of Stack Test Results	   IV-11

4.6  Tier 4 Ash Sampling Results	   IV-19

4.7  Findings and Conclusions	   IV-23

4.8  Continuing Efforts	   IV-25

Chapter 5 - REGULATORY ACTIVITIES

5.1  RCRA Listing of Dioxin Containing Wastes	     V-l

5.2  PCB Transformer Fire Rule	     V-2

     5.2.1   Summary of the Rule	     V-2
     5.2.2   Background	     V-2

5.3  Cancellation of Registration of 2,4,5-T	     V-3

5.4  Ambient Water Quality Criteria Document	     V-4

5.5  Wood Preservation Pesticides.....	     V-4

5.6  TSCA §4/§8 Rulemaking	,	     V-5

5.7  Land Disposal Ban of Dioxin Containing Wastes	     V-7

Chapter 6 - RESEARCH

6.1  Introduction	    VI-1

6.2  Technology Assessment	    VI-2

6.3  Monitoring	    VI-4

6.4  Environmental Effects	    VI-5

6.5  Health Assessment	    VI-6

REFERENCES

-------
                             GLOSSARY

     In general, we have tried to use the more precise  term
2,3,7,8-TCDD (defined below) when discussing the particularly
toxic "dioxin" associated with Times Beach, Missouri, Love Canal,
and Agent Orange.  The terms CDD/CDF refer to the entire class of
chemicals of interest.  CDD/CDF, a term which is also
occasionally used in the text, is synonymous with
dioxins/furans.  When a specific isomer (individual chemical)
other than 2,3,7,8-TCDD is referred to, it will be identified by
means of the standard nomenclature outlined below.

The following defines, for purposes of this report, a few of the
more commonly used technical terms.

Chlorinated dibenzo-para-dioxin/Chlorinated dibenzofuran
(CDD/CDF)- any member ofthefamily of chlorodioxinsand
            related furans having one to eight chlorine
            substituents

Congener - any of the 75 CDDs or 135 CDFs

Homologue group - a group of chemicals that have the same degree
                  of halogenation
                  For example, the homologous class of  tetrachlo-
                  rodibenzo-jD-dioxins (TCDD) consists of those
                  PCDDs which have four chlorine atoms.

Isomer - a particular member of a homologous group
         E.g.,  2,3,7,8-TCDD is the tetra- isomer which
         has chlorine atoms at the 2-, 3-, 7- and 8-positions.

2,4,5-T - 2,4,5-Trichlorophenoxy acetic acid

2,4,5-TCP - 2,4,5-Trichlorophenol, a basic chemical used to make
            a number of herbicidal products including 2,4,5-T,
            Silvex,  Erbon, and Ronnel

RCRA - Resource Conservation and Recovery Act (as amended by the
       Hazardous and Solid Waste Amendments of 1984)

TSCA - Toxic Substances Control Act

FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act

CAA - Clean Air Act

CWA - Clean Water Act

CDC - Centers for Disease Control

FDA - Food and  Drug  Administration

NIOSH - National Institute of Occupational Safety and Health

-------
                        EXECUTIVE SUMMARY

Study Design
     EPA conducted a two-year nationwide study to investigate the
extent of dioxin (2,3,7,8-TCDD) contamination.  EPA also
developed and implemented a National Dioxin Strategy to provide a
coordinated management framework for investigative, remedial, and
regulatory activities.
     The nationwide investigation consisted of seven "tiers" with
roughly decreasing expectation of finding 2,3,7,8-TCDD
contamination:
     Tier 1  —  2,4,5-trichlorophenol (2,4,5-TCP) production
                 sites (and associated waste disposal sites)
     Tier 2  —  Sites where 2,4,5-TCP was used as a precursor to
                 make pesticidal products (and associated waste
                 disposal sites)
     Tier 3  —  Sites where 2,4,5-TCP and its derivatives were
                 formulated into pesticidal products
     Tier 4  —  Combustion sources
     Tier 5  —  Sites where pesticides derived from 2,4,5-TCP
                 were used
     Tier 6  —  Production sites for other chemicals where
                 2,3,7,8-TCDD formation may have occurred
     Tier 7  —  Background (urban/rural soil, fish samples)
     For combustion sources, EPA also tested for the presence of
other isomers of dioxins and furans, as previous testing had
shown significant levels of these other compounds.
Results
     In its investigatory and cleanup efforts at Tier 1 and 2
sites EPA identified twenty-one 2,4,5-TCP related production
facilities (tiers 1 and 2) and 79 associated waste disposal sites
(tiers la and 2a), considerably fewer than original projections
of as many as 50 production sites and 400-500 disposal sites.
     As expected, these sites had the highest levels and greatest
quantities of 2,3,7,8-TCDD.  Most of the sites are traditional
production and disposal facilities.  The widespread dispersal of

-------
dioxin-contaminated material that occurred in Missouri  (47 of  79
total disposal sites) was not identified elsewhere.
     In most cases the dioxin (2,3,7,8-TCDD) has not migrated
off-site.  However, in those cases where it has, extensive envi-
ronmental problems usually resulted, e.g., at Vertac, Love Canal,
and Hyde Park.  A mix of federal, state and responsible party
actions are underway to seek necessary corrective actions.
Emergency measures to protect public health have been success-
fully implemented wherever necessary.  Permanent remedies are
proceeding at a slower pace because of the complexities involved.
     With the exception of two large facilities that handled
2,4,5-TCP, 2,4,5-T and/or Silvex, soil at pesticide formulators
(tier 3) was not found to be extensively contaminated above the  1
ppb level.  2,3,7,8-TCDD was generally detected in only 1 or 2
samples at a given site.  Regional offices are following up at 17
large formulators that handle these materials, which were not
originally selected for sampling.
     2,3,7,8-TCDD was detected at greater than 1 ppb in soil
samples at 10 of the 64 pesticide formulator facilities sampled,
and at less than 1 ppb at 9 additional sites.  At 2 sites,
2,3,7,8-TCDD was detected at low ppt levels in fish or
sediment.  2,3,7,8-TCDD was not detected at 43 of the 64 sites.
     2,3,7,8-TCDD was found more frequently at 2,4,5-T and Silvex
use sites (tier 5) than at "background" sites (tier 7).  Soil  and
sediment contamination detected at 15 of the 26 use sites sampled
was generally in the low parts per trillion (ppt) range.  The
principal exception was a site where samples were taken at a
herbicide mixing/loading area.
     "Other1 chemical plants (tier 6) do not appear to be exten-
sively contaminated at levels of concern.  2,3,7,8-TCDD levels
greater than 1 ppb were detected at 3 of the 18 facilities
sampled.  Three had levels below 1 ppb and 12 were non-detected.
     2,3,7,8-TCDD was found infrequently in urban and rarely in
rural 'background' soils at the ppt level.
                                11

-------
     2,3,7,8-TCDD contamination in fish has previously been
reported by EPA and others.  Such contamination was generally
linked to chemical industry activity or waste disposal.  National
Dioxin Study activities have identified fish contamination
thought to be associated with chemical industry activities as
well as contamination possibly associated with the pulp and paper
industry.
     2,3,7,8-TCDD was detected in fish composite samples at 112
of the 395 sites sampled.  While levels were as high as 85 ppt in
whole fish and 41 ppt in filets, only four sites had levels above
25 ppt, one of which was in a filet.  2,3,7,8-TCDD was detected
in 23 of 29 Great Lakes fish samples.
     Fish advisories for 2,3,7,8-TCDD had been in effect prior to
the study for a number of areas such as the Tittabawassee River
in Michigan.  Advisories were in effect for the Great Lakes due
to contamination from mirex, PCBs and mercury.
     As a result of the study, advisories to limit fish consump-
tion have  been issued by the States of Maine for the Androscoggin
River at Lewiston; Minnesota for the Rainy River; and West
Virginia for the Kanawha River at Nitro, WV.
     Outside of the Great Lakes, fish contamination was primarily
found in major river systems, such as the Ohio and Mississippi
River, or in waterways with significant industrial activity.  The
initial focus of EPA followup is on pulp and paper and chemical
industry discharges.
     Earlier investigations of municipal waste combustors (MWCs)
had revealed that combustion sources emit dioxins and furans.
EPA stack tested 13 additional sources in various source
categories ranging from secondary copper smelters to wood
stoves.  The sources tested emit CCDs/CDFs, although generally at
very low levels.  Secondary copper smelters and sewage sludge
incinerators have the highest estimated ground level
concentrations of the sources tested under tier 4.  EPA has
                               111

-------
prepared a separate report to Congress on risks from emissions
and proper design and operation of MWCs.
Regulatory Activities
     EPA has initiated a number of regulatory activities to
control the generation, use and disposal of dioxin-contaminated
materials to prevent future contamination.  The Agency has:
     - Imposed stringent management and disposal requirements by
       listing certain dioxin-contaminated wastes as acutely
       hazardous under RCRA, and providing for eventual banning
       of such wastes from land disposal unless they are first
       treated.
     - Cancelled uses of the pesticide 2,4,5-T/ a principal
       ingredient in Agent Orange.
     - Placed additional restrictions on continued use of PCB
       transformers.  These requirements are intended to protect
       building occupants, emergency response personnel and
       others from exposure to CDDs/CDFs generated during PCB
       fires.
     - Under FIFRA, imposed additional use restrictions, handling
       requirements, and product contaminant level reduction
       requirements on wood preservative uses of pentachloro-
       phenol (PCP), inorganic arsenical compounds and
       creosote.  (It has been shown that PCP contain CDDs/CDFs.)
     EPA has also initiated rulemaking under TSCA to identify
additional products and industrial waste streams which may be
contaminated, and is evaluating waste streams from PCP wood
treatment operations for possible hazardous waste designation.
OAR is assessing whether to list CDD/CDF as a hazardous air
pollutant under Section 112 of the Clean Air Act.
Research
     EPA has successfully field tested its Mobile Incinerator
System in Missouri.  The unit demonstrated a 99.9999 percent
destruction and removal efficiency (ORE) for liquid waste and for
contaminated soil.  EPA has also used a chemical process,
polyethylene glycol (KPEG), to decontaminate a mixture of diesel
oil and PCP pumped from groundwater at a Superfund site  in
Montana.  EPA is  investigating other promising treatment
technologies as well as conducting research in the areas of
                                IV

-------
monitoring, analytic methods, environmental effects and health
assessment.
     EPA efforts are coordinated closely with FDA, CDC and NIOSH/
and with international entities through the NATO CCMS (Critical
Challenges Facing Modern Society) program.

-------
                           Chapter One
                           INTRODUCTION

     This report presents the results of EPA's investigation of
potential 2,3,7,8-TCDD  ("dioxin") contamination.  The study was a
two-year, nationwide, multimedia evaluation initiated at the
request of Congress in House Report 98-223 accompanying the bill
making appropriations for the Department of Housing and Urban
Development and for other independent agencies for FY'1984 (HR
3133).  EPA headquarters and regional staff, plus state personnel
from a variety of program offices, contributed significant time
and resources to the effort.  This report is a summary of
information contained in more detailed reports prepared by
individual program offices (EPA, 1987b, c, d).

1.1  Basis of Public and Congressional Concern
     Numerous incidents of contamination/exposure at home and
abroad coupled with the high toxicity and persistence of 2,3,7,8-
TCDD have resulted in a high level of public awareness and
concern.  This concern carries over into present efforts to
implement cleanup actions and conduct disposal operations.
     Among the best known incidents was the exposure of U.S.
servicemen to Agent Orange in Viet Nam (1966-1971).  A defoliant,
Agent Orange was contaminated with 2,3,7,8-TCDD.  A large class
action suit was filed on the basis of alleged health effects.
     In Seveso, Italy, a 1976 industrial accident involving
2,4,5-trichlorophenol (2,4,5-TCP) manufacturing resulted in
widespread, low-level 2,3,7,8-TCDD contamination.  This resulted
in evacuation of parts of the community, animal deaths, and
extensive cleanup efforts.  Approximately 175 cases of chloracne
and dermatitis, many of which were acute effects due to exposure
to chlorophenols and chlorobenzenes, were confirmed.
     Mild chloracne has been observed in humans in Nitro, West
Virginia for at least a decade after exposure to industrial
chemicals containing 2,3,7,8-TCDD.

-------
                               1-2
     In the early 1970's, waste oil contaminated with 2,3,7,8-
TCDD was used to control dust on roads in Times Beach,
Missouri.  The eventual result was the well-known government
'buy-out1 of the town.  Use of waste oil at several Missouri
horse arenas resulted in human health effects and the death of  65
horses.  Subsequent use of the excavated horse arena materials  as
fill at building sites resulted in a proliferation of cleanup
problems.
     2,3,7,8-TCDD and other chemical contamination of adjacent
land and water resulting from industrial waste disposal at Love
Canal and Hyde Park in New York posed health risks.  Efforts to
limit the spread of this contamination continue today.  2,3,7,8-
TCDD contamination resulting from 2,4,5-TCP manufacture and waste
disposal was also found to be extensive, both on- and off-site,
at the Vertac facility in Jacksonville, Arkansas.
     In 1979, investigations at a municipal incinerator in
Hempstead, New York, led to the discovery that CDDs/CDFs were
being emitted during the combustion process.  This information
supplemented European reports of CDD/CDF emissions from such
facilities, and a later Dow Chemical Company report of emissions
from numerous combustion sources.
     In 1980, a PCB transformer fire in the basement of a state
office building in Binghamton, New York, resulted in distribution
of soot containing dioxins and furans, including the 2,3,7,8-
isomer, throughout the building.  Cleanup costs to date have
exceeded the original construction cost of the building.
     In 1981, reports from Canada revealed the presence of
2,3,7,8-TCDD in Great Lakes fish.  These reports coincided with
reports of fish contamination in several U.S. rivers, notably the
Tittabawassee River in Michigan.
     In response to the public concern generated by these
incidents, Congress requested that EPA initiate an investigation.

-------
                               1-3
1.2  The National Dioxin Strategy
     At the time of the Congressional request for a study, EPA
was in the midst of responding to contamination in Missouri and
other locations.  The Agency also had rulemaking proceedings
underway in a number of offices.  To provide a coordinated
management framework for the numerous dioxin-related activities
throughout the Agency, EPA developed and implemented a National
Dioxin Strategy.  The Strategy describes the full range of
activities planned or underway to address various aspects of the
dioxin problem (EPA, 1983).
     1.2.1  Objectives
     EPA's National Dioxin Strategy had three objectives:
     1) study the extent of dioxin contamination and the
     associated risks to humans and the environment;
     2) implement or compel necessary cleanup action at
     contaminated sites; and
     3) further evaluate both disposal alternatives to alleviate
     current problems, and regulatory alternatives to prevent
     future contamination.
     1.2.2  Management
     The Assistant Administrator, Office of Solid Waste and
Emergency Response, was responsible for implementing the stra-
tegy.  The Deputy Director, Office of Solid Waste, was designated
Dioxin Management Coordinator.  Virtually every program in the
Agency has played a major role.  The Dioxin Management Coordina-
tor oversaw program office activities in conducting the study,
coordinated dioxin-related regulatory activities, and served as a
central point of contact for the numerous dioxin-related inquir-
ies.  Policy guidance was provided by the Dioxin Management Task
Force made up of Office Directors from affected programs.
     1.2.3  Interagency/International Coordination
     A number of federal agencies have been involved in various
aspects of the dioxin problem.  Many other countries have also
had to cope with dioxin incidents.
     EPA maintains contact with the Food and Drug Administration
(FDA) in interpreting results of fish contamination; with the

-------
                               1-4
National Institute of Occupational Safety and Health (NIOSH) for
assessments of worker exposure; and with the Centers for Disease
Control (CDC) in Atlanta for human health advisories.  EPA  is
also represented on the Agent Orange Work Group (AOWG), chaired
by the Department of Health and Human Services.  EPA is the lead
agency for U.S. participation in the NATO Committee on the  Chal-
lenges of Modern Society (CCMS) group established to coordinate
international dioxin information exchange activities.  EPA  is
also working closely with the Canadian government in its efforts
to investigate municipal waste combustor emissions.

1.3  Background Information on 2,3,1,8-Tetrachlorodibenzo-p-
     dioxin
     The primary purpose of this report is to present  the find-
ings of EPA's investigation of the extent of environmental  con-
tamination by 2,3,7,8-TCDD.  The following discussion  provides
general information on the physical, chemical, and toxicological
characteristics of 2,3,7,8-TCDD, the dioxin congener of principal
concern in the Strategy.  Related CDDs and CDFs are also
discussed briefly.  Additional information is available from a
number of sources.
     In 1980, EPA's Office of Research and Development published
an extensive compilation of information regarding dioxin (EPA,
1980).  This report includes information on the chemical
reactions which result in formation of 2,3,7,8-TCDD, and on
sources and pathways of human exposure.
     EPA's Office of Health and Environmental Assessment has
completed a Health Assessment Document (HAD) (EPA, 1985a),  that
compiles and evaluates existing health effects research on
2,3,7,8-TCDD, 1,2,3,7,8-PCDD, and a mixture of two isomers  of
hexachloro-dibenzo-_p_-dioxin (HxCDD).
     1.3.1  Physicochemical Properties
     2,3,7,8-Tetrachlorodibenzo-jD-dioxin ( 2 ,3 ,7 ,8-TCDD) is  one of
75 CDD congeners with various chlorine substituents.   There are
135 chlorinated dibenzofurans, all of which have the same basic

-------
                               1-5
chemical structure and many of which have qualitativity similar
toxicities.  The chemical structure of 2,3,7,8-TCDD can be
depicted as follows:
     The dioxin molecular framework consists of two benzene rings
connected by two oxygen bridges.  There are eight positions where
substitution of hydrogen atoms by other atoms or by organic or
inorganic radicals can occur.
     2,3,7,8-TCDD is an unwanted by-product of the manufacture of
several commercial chemicals, particularly the chlorinated
phenols.  CDDs/CDFs have also been shown to result from certain
combustion processes.  2,3,7,8-TCDD is a chemically stable,
extremely lipophilic (fat-soluble) molecule with limited
solubility in water.  In its pure form, 2,3;7,8-TCDD exists as a
colorless crystal.
     2,3,7,8-TCDF has a similar structure, but has one oxygen
bridge rather than two:

-------
                               1-6
2,3,7,8-TCDD
     Formula          C12H4C14°2
     Percent by Wt
            C                     44.7
            0                      9.95
            H                      1.25
            Cl                    44.1
     Molecular Wt                             322
     Melting Point (°C)                       305
     Decomposition Temp (°C)                 >700
     Solubility
       (in Water)                              19.3 ppt

     Since CDDs are usually formed only in low yields, the mini-
mum conditions leading to formation are poorly defined.  Heat,
pressure, photostimulation and catalytic action have been shown
to encourage the reactions from chlorinated precursors to diox-
ins.  Proper attention to temperature and pH control can minimize
formation; however, trace amounts are usually formed along with
other impurities (EPA, 1980).
     1.3.2  Toxicity
     1.3.2a  Non-Human
     2,3,7,8-TCDD is the most completely studied of the
CDDs/CDFs.  The compound has demonstrated a variety of toxicities
as a result of acute and chronic exposures in animal studies,
including death, careinogenicity, teratogenicity, and immuno-
toxicity.  For some of these effects  (e.g., death and reproduc-
tive effects) there is great variability among animal species,
including sub-human primates.  The material is nearly unique
in its ability to elicit these effects at very low doses
(1-100 ng/kg-day).
     2,3,7,8-TCDD has induced hepatocellular carcinomas in two
strains of female rats and in both sexes of one mouse strain,
thyroid tumors, subcutaneous fibrosarcomas and tumors of the
lung, nasal turbinates/hard palate in male rats, and tongue
tumors in female rats.  These effects occur at extremely low

-------
                               1-7
doses.  The evidence of carcinogenicity for 2,3,7,8-TCDD  in
animals is regarded as "sufficient" using the EPA weight-of-
evidence classification system for carcinogens  (EPA,  1985a).
     Other congeners of CDDs/CDFs have not been as well studied
as 2,3,7,8-TCDD; however, there is a growing body of  literature
which indicates that these compounds behave in  a qualitatively
similar manner, but have widely varying toxicities.   Some appear
to be nearly as toxic to animals as 2,3,7,8-TCDD while others are
much less toxic (see Section 1.3.3, Toxicity Equivalence).
     2,3,7,8-TCDD has been shown to be bioavailable to fish from
sediment and fly ash.  Preferential uptake of CDDs/CDFs
substituted in the 2-, 3-, 7- and 8- positions  has also been
demonstrated (Kuehl et al., 1986).  Fish/sediment contamination
ratios will vary depending on such factors as species, weight,
lipid content, and 2,3,7,8-TCDD sediment concentration.
     A significant amount of research has been  conducted on the
effects of 2,3,7,8-TCDD and other CDDs/CDFs on  aquatic
organisms.  Concentrations as low as 0.056 parts per  trillion
have been reported to affect coho salmon survival (Miller,
1973).  More recent work identified effects on  rainbow trout
survival at 0.038 ppt (Merhle, 1986).
     In lab experiments, concentrations as low  as 7.1 ppt
combined with exposures of 1-4 days produced significant
mortality to fathead minnows while continuous exposure to 1.7 ppt
produced 53 percent mortality in 28 days.  On the other hand,
2,3,7,8-TCDD had no effects on Daphnia magna at concentrations up
to 1,030 ppt during 48-hour exposure followed by 1 week of
observation (Adams et al., 1986).
     1.3.2b  Human
     There is much less information available on the  effects of
exposure of CDDs/CDFs in humans as compared to  animals.  A number
of accidents and/or the use of CDD/CDF-contaminated materials
have led investigators to believe that there are cases of signi-
ficant exposure to CDDs/CDFs.  A set of case control  studies from

-------
                               1-8
Sweden first raised concern about the possible association of
exposure to 2,3,7,8-TCDD and/or phenoxyacetic acid herbicides
with a relatively rare form of cancer, known as "soft  tissue
sarcoma" (STS) (3-5 fold increase) and non-Hodgkins Lymphoma
(5 fold increase).
     More recent studies in this country  (e.g., CDC birth defects
study and Ranch Hand morbidity/mortality  studies involving
Vietnam veterans) and overseas (e.g., New Zealand and  Australia)
have been unable to detect significant cancer or other adverse
health effects in exposed populations.  Unfortunately, the cancer
studies share the limitations of many epidemiological  studies,
e.g., low statistical power and limited time since exposure.  In
addition, examination of individuals clearly exposed as a result
of industrial accidents has not revealed consistent, persistent
deleterious health effects.
     As reported in EPA's Health Assessment Document (EPA,
1985a), the human evidence for the careinogenicity of  2,3,7,8-
TCDD alone is regarded as "inadequate" using the EPA
classification criteria, because of the difficulty of  attributing
the observed effects solely to the presence of 2,3,7,8-TCDD that
occurs as an impurity in the phenoxyacetic acids and
chlorophenols.
     The overall evidence for carcinogenicity, considering both
animal and human studies, would place 2,3,7,8-TCDD in  the B2
category of EPA's classification scheme.  Chemicals in category
B2 are regarded as being "probably" carcinogenic in humans.
     1.3.3  Fate and Transport
     Although significant uncertainties remain, a fair amount of
research has been conducted on the fate and transport  of 2,3,7,8-
TCDD in environmental media.
     Physicochemical properties suggest that 2,3,7,8-TCDD will
adsorb tightly to organic material in soil, resulting  in low
mobility.  Once in the soil, degradation processes (chemical,
biological, etc.) tend to be very slow, with half lives estimated

-------
                               1-9
to be 10 years or longer.  Freeman and Schroy  (1986) suggest  that
the rate of movement in soil by leaching is insignificant
compared to volatilization and erosion.
     Thus, except in cases of the presence of mobile, non-polar
co-contaminants or where channeling allows particulate transport,
large scale movement through the soil is thought to be
unlikely.  Unfortunately, disposal situations may involve  the
presence of such mobilizing agents.  This may help explain  the
fact that despite its strong sorptive properties, 2,3,7,8-TCDD
has been found distributed vertically through the uppermost soil
layers and horizontally beyond the boundaries of the initial
contaminated zone (DiDomenico, 1982).
     While photolysis (breakdown of contaminants by UV radiation)
has been shown to occur, the effect of this mechanism in
environmental settings has not been fully determined.  The
presence of CDDs/CDFs in isolated waterbodies thought to be
subject only to influence of airborne particulate transport
suggests that CDDs/CDFs are in fact transported in this manner
and that rapid photolysis does not occur.  Downstream transport
of 2,3,7,8-TCDD for considerable distances has also been found at
Superfund sites such as Vertac (Jacksonville, Ark.).
     Additional information on the fate and transport of 2,3,7,8-
TCDD may be found in the Tier 3,5, 6 and 7 Technical Support
Document.
     1.3.4  Toxicity Equivalence
     While the primary focus of this study was on contamination
associated with 2,3,7,8-TCDD, EPA is also concerned with human
exposure to other congeners of CDD/CDF.
     EPA and others have developed methods for comparing the
toxicities of various chlorinated dioxin and furan isomers  to
that of 2,3,7,8-TCDD.  Such Toxicity Equivalence Factor (TEF)
approaches express the toxicity of CDD/CDF mixtures in terms of
"2,3,7,8-TCDD equivalents".  This allows comparison of different

-------
                               1-10
toxicities of mixtures for purposes of risk assessment  and
remedial action planning.
     Under ideal conditions, toxicities of mixtures and/or  indi-
vidual constituents are based on long-term whole animal  toxicity
testing.  Unfortunately, complete toxicological information  is
lacking for most of the congeners of CDDs/CDFs.  With the
exception of 2,3,7,8-TCDD, the 2,3,7,8-HxCDDs, and 2,3,7,8-TCDF,
TEFs are based on estimates of the relative toxicity from in
vitro tests.
     EPA's Science Advisory Board has concluded that there  is a
plausible basis for the TEF approach of estimating risks associ-
ated with CDD/CDF exposures, and has recommended that the Agency
adopt this approach on an interim basis, as a matter of  science
policy.  The TEFs will be revised as additional scientific  infor-
mation is developed.  EPA's TEFs for the congeners of CDD/CDF
considered to be the most toxic are contained in Table  1-1.
     More detailed information and a comparison with similar
methods developed by the States of California and New York  and
the governments of Ontario and Switzerland may be found  in
Interim Procedures for Estimating Risks Associated with  Exposure
to Mixtures of Chlorinated Dibenzo-p-dioxins and Dibenzofurans
(EPA, 1987a).

-------
                               1-11
                            TABLE 1-1
              CDD/CDF  ISOMERS  OF  MOST TOXIC  CONCERN3
DIOXIN
Isomer TEF
2,3
1,2
1,2
1,2
1,2
1,2
a/
b/
,7,8-TCDD 1
,3,7,8-PeCDD 0.5
,3,4,7,8-HxCDD 0.04
,3,7,8,9-HxCDD 0.04
,3,6,7 ,8-HxCDD 0.04
,3,4,6,7,8-HpCDD 0.001
DIBENZOFURAN
Isomer TEFb
2,3,7,8-TCDF 0.1
1,2,3,7,8-PeCDF 0.1
2,3,4,7,8-PeCDF 0.1
1,2,3,4,7,8-HxCDF 0.01
1,2,3 ,7,8, 9-HxCDF 0.01
1,2,3,6,7,8-HxCDF 0.01
2,3,4,6,7,8-HxCDF 0.01
1,2,3,4,6,7 ,8-HpCDF 0.001
1,2,3,4,7,8,9-HpCDF 0.001
In each homologous group the relative toxic ity factor for
the isomers not listed is 1/100 of the value listed above.
TEF = toxic equivalence
factor = relative toxicity assigned.
     1.3.5  Body Burden
     Researchers in numerous countries report finding CDDs/CDFs
in human adipose tissue.  2,3,7,8-TCDD is often, but not always,
found in such investigations.  To date, no studies have
established a connection between adipose tissue levels and human
health effects; nor have researchers definitively established the
source(s) of the CDDs/CDFs.
     The Centers for Disease Control (CDC) conducted a study of
2,3,7,8-TCDD levels in the adipose tissue of exposed and control
persons in Missouri (Paterson et al., 1986).  While exposed
persons had considerably higher levels of TCDD on average
(approximately 80 ppt) than the controls (approximately 7 ppt),
all members of both exposed and control groups had detectable
levels.  Controls ranged from 1.4-20 ppt while exposed ranged
from 2.8-750 ppt.

-------
                               1-12
     1.3.6  Bioavaliability
     Researchers have compared the bioavailability (uptake by the
biological system) of 2,3,7,8-TCDD from two sites:  Times Beach,
Missouri and Newark, New Jersey.  The Times Beach soil was found
to be highly toxic to guinea pigs and produced typical TCDD
symptoms.  The Newark soil was much less toxic at comparable
levels of contamination.
     Possible explanations for these apparent differences in
bioavailability include differences in soil composition  (e.g.,
amount of organic matter); presence of other compounds that might
offset TCDD soil binding; and method of application of the TCDD
to the soil (Umbreit et al., 1986).

1.4  Study Design and Implementation
     EPA developed a tiered approach to address the first two
objectives of the strategy—to study the extent of contamination
and to ensure necessary cleanup action at contaminated sites.
Seven tiers were developed and ranked by anticipated likelihood
of contamination, with a general but not exclusive focus on
activities involving 2,4,5-trichlorophenol (2,4,5-TCP).
     EPA initially focused on facilities involved with 2,4,5-TCP
for a number of reasons.
     - 2,3,7,8-TCDD is a known by-product of the manufacture
       of 2,4,5-TCP.
     - 2,4,5-TCP was manufactured in large quantities.
     - 2,4,5-TCP is an intermediate in the manufacture of several
       widely used products including 2,4,5-trichlorophenoxy
       acetic acid (2,4,5-T) and related herbicides.
     - Most of the incidents to date involving high level of
       2,3,7,8-TCDD have been associated with 2,4,5-TCP
       manufacture.
     1.4.1  Organization of the Study
     EPA defined the following tiers based on decreasing
expectation of finding 2,3,7,8-TCDD contamination:
     Tier 1 -    2,4,5-Trichlorophenol (2,4,5-TCP) production
                 sites (and associated waste disposal sites)

-------
                               1-13
     Tier 2 -    Sites  (and associated waste disposal  sites)
                 where  2,4f5-TCP was used as a precursor  in  the
                 manufacture of pesticidal products

     Tier 3 -    Sites  (and associated waste disposal  sites)
                 where  2,4,5-TCP and its derivative pesticidal
                 products were formulated or packaged  into
                 commercial pesticides

     Tier 4 -    Combustion sources

     Tier 5 -    Sites  where pesticides derived  from 2,4,5-TCP
                 have been or are being used on  a commercial
                 bas is

     Tier 6 -    Certain organic chemical and pesticide manu-
                 facturing facilities where improper quality
                 control on certain production processes  could
                 have resulted in the inadvertent formation of
                 2,3,7,8-TCDD

     Tier 7 -    Networks of existing ambient stations where fish
                 and soil were sampled to determine whether
                 2,3,7,8-TCDD was widespread in  the environment
                 and, if so, at what levels

     The tier 1 and tier 2 facilities, and their associated waste

disposal sites, tiers "1A and 2A" respectively,  were the  sites

where EPA expected to find the most contamination.  They  were

investigated through the Superfund program because of  its

authority to address contaminated sites.  Remedial actions at the

sites in these tiers will continue in the future.

     Tiers 3, 5, 6 and  7 were managed by the Office of Water
Regulations and Standards (OWRS).  The tier 4 work was managed by
the Office of Air Quality Planning and Standards (OAQPS).

     Detailed project plans were prepared for tiers 3  through 7.

The project plans underwent extensive internal and external
review.   External reviewers included staff of the Centers for
Disease  Control and the Office of Technology Assessment,  several

members  of EPA's Science Advisory Board, and the American
Chemical Society.

     In  addition to conducting basic research, EPA's Office of

Research and Development (ORD) provided extensive technical and
analytical support to the project.

-------
                               1-14
     Regulatory activities were undertaken by  the specific
Offices in EPA with the appropriate  legislative authority and
media expertise.   (See Chapter 5.)
     1.4.2  Detection Limits/Analytical Support
     During the initial round of  investigations in Missouri, EPA
requested assistance from CDC in  interpreting  the significance of
2,3,7,8-TCDD contamination at a residential site.  CDC developed
a health advisory  level of 1 part per billion  (ppb) for residen-
tial soil (Kimbrough et al., 1984).  A major consideration  in
arriving at this level was the presence of small children,  who
typically play in  and ingest residential soil.  CDC suggested
that a somewhat higher level might be acceptable in non-
residential settings where continuous exposure of children  would
not occur, but cautioned that lower  levels might be of concern on
pastures and rangelands where there  is potential bioaccumulation
in the food chain.
     Although 1 ppb was intended  to  be site-specific, the charac-
teristics at residential sites tend  to be similar.  This guidance
provided important design parameters for the study.
     For tiers 1 and 2, EPA selected a detection limit of 1 part
per billion (1 ppb) based on the generally non-residential  nature
of the production  and disposal facilities.  Similar reasoning
resulted in the selection of a detection limit of 1 ppb for soil
sampling at sites  in tiers 3 and  6.
     The investigations in tiers  5 and 7 (fish and soil) were in
the nature of a "background" evaluation, thus  the objective was
to employ state-of-the-art detection capability to determine
whether 2,3,7,8-TCDD was present  in  the sample.  A nominal  detec-
tion limit of 1 part per trillion (ppt) was selected for fish and
soil samples, using high resolution  gas chromatography/high
resolution mass spectrometry.  This  technology allows a detection
limit in the parts per quadrillion (ppq) range in water samples
although the method is much more experimental when applied  to
these samples.

-------
                               1-15
     The 1 ppt detection limit and the number of samples to be
processed resulted in pressing the state-of-the-art in both
capability and capacity.  To meet this need and to provide
requisite consistency for a nationwide study of this nature, EPA
established a consortium of three in-house laboratories—the so-
called "Troika".
     Because of the low levels expected in combustion source
emissions, the Troika also performed ppt analyses for the tier 4
samples.  Analysis of tier 4 samples addressed additional CDD/CDF
congeners because 2,3,7,8-TCDD generally represents only a small
part of the total CDDs/CDFs generated by these facilities.
     As used in this report, the term "detection limit" is
synonymous with "analytical method quantitation limit," that is,
the contaminant concentration required to produce a signal with
peak height 2.5 times the background signal level.

-------
                            Chapter Two
                           TIERS 1 AND 2

      This chapter presents EPA's investigatory and cleanup
 efforts for sites in tiers 1 and 2.
      °    Tier 1 - 2,4,5-trichlorophenol (2,4,5-TCP) production
          sites and associated waste disposal sites
      0    Tier 2 - Sites where 2,4,5-TCP was used as a precursor
          to make pesticidal products, and associated disposal
          sitesjV
      The objective in these tiers was to identify contaminated
 sites and develop appropriate response measures.  EPA estimated
 that  most 2,3,7,8-TCDD  produced in this country would be
 associated with tier 1  and 2 sites.
      Activities at these sites were assigned to the Office of
 Solid Waste and Emergency Response (OSWER).  OSWER is also
 responsible for sites from the other five tiers where significant
 2,3,7,8-TCDD contamination is discovered.   Funding and authority
 for these investigations and response actions comes from the
 Superfund program.
      EPA had been addressing 2,3,7,8-TCDD sites prior to the
 National Dioxin Strategy.   This report does not generally distin-
 guish ongoing activities from those conducted after the Strategy
 was established.   Additional information on tiers 1 and 2 is
 contained in the  Technical Support Document (EPA, 1987c).

 2.1   Approach
      Investigation  and  cleanup at tier 1 and 2 sites are modeled
 after the approach  taken under the Comprehensive Environmental
 Response,  Compensation,  and Liability Act  (CERCLA)  program
 (Superfund).   The major  difference is that, for the first time,
 the Agency has  targeted  industry-specific  production and disposal
 facilities.
_V  Waste disposal sites  associated with Tiers  1  and  2  are
    referred  to  as Tiers  la  and  2a  sites,  respectively.

-------
                               II-2
     EPA conducted extensive data base research and used
enforceable information request letters to identify production
facilities and associated waste disposal sites.  As needed,
additional data were collected from site visits and employee
interviews.
     Field testing was conducted to determine actual 2,3,7,8-TCDD
contamination.  EPA employed a targeted approach, sampling  in
locations most likely to be contaminated (i.e., loading  areas,
storage areas, production areas).  If off-site migration was
suspected, samples were collected outside the facility boundary.
     Sampling plans were developed in consultation with  the
Centers for Disease Control (CDC) to ensure that if 2,3,7,8-TCDD
was detected, the data would be usable by CDC in developing
health recommendations.  Quality assurance/quality control
protocols that follow Superfund procedures were developed  to
ensure that all data generated would be of known quality.
     If 2,3,7,8-TCDD contamination was detected, a site-specific
decision on the need for an immediate or longer term response
action was made in consultation with CDC.  Where possible,
potentially responsible parties  (PRPs) were encouraged to  take
appropriate response action.jV   If necessary, response activities
were performed under Superfund.
     All activities have been coordinated with State and local
authorities as well as other Federal agencies such as  the  Centers
for Disease Control (CDC),  the National Institute for
Occupational  Safety and Health  (NIOSH), the Food and Drug
Administration (FDA) and the Federal Emergency Management  Agency
(FEMA).
    A potentially  responsible  party  is  any  person  who:
    1) owned, operated or otherwise  controlled  activities
    at any  facility  where hazardous  substances  were  disposed of;
    2) arranged  for  disposal or  treatment of  a  hazardous
    substance; or  3)  accepted  a  hazardous substance  for transport
    to disposal  or treatment facilities.

-------
                               II-3


2.2  Findings
     2.2.1  Universe of Tiers  1 and  2
     There are 100 sites  in tiers  1  and  2.   Table  2-1  shows  a
breakdown of sites by tier.

                            TABLE  2-1
                    OSWER DIOXIN SITES BY TIER

Tier              1           la           2_          2a
No. of Sites:    11           53          10           26

     It was originally thought that  there  were  about  450  tier  1
and 2 sites (50 production sites  and  about  400  associated
disposal sites).  The difference  in  the  actual  versus the
estimated number of tier  1 and 2  facilities  has two  bases.
First, many of the  facilities alleged  to  have produced  the
chemicals of concern, in  fact, did not.   For example, they  may
have been registered with EPA to  produce  2,4,5-TCP and  some of
its derivatives, but only formulated  selected derivatives  in
actuality.  This would make them  a tier  3  rather  than a tier 1 or
2 facility.  Second, those facilities  that  did  produce  2,4,5-TCP
or use it as a precursor had an average of  4 associated disposal
sites, instead of the originally  estimated  8 to 10.
     Tier 1 and 2 sites are located  in 8 of  the 10 EPA  Regions.
Figure 2-1 is a graphic representation of  dioxin  site locations.
     Many of the sites of concern are  in Missouri.  Twenty-nine
of the tier 1A sites in Missouri  were  unwitting recipients  of
2,3,7,8-TCDD waste.  Recycled oil contaminated  with  2,3,7,8-TCDD
was used as a dust control measure on  private roads, parking lots
and horse arenas.  Later, contaminated soils from a horse  arena
were used as fill dirt at several farms and  residences.
     Prior to the National Dioxin Strategy,  EPA had sampled the
majority of the 200 sites in Missouri  alleged to  have been
sprayed with contaminated waste oil.   No 2,3,7,8-TCDD was

-------
                                     II-4

                                   FIGURE 2-1

                             OSWER  DIOXIN SITES
                            REGIONAL  DISTRIBUTION
                                                                   N
                                TIER 16 2:    1
                                TIER1A&2A:  1
                                                        TIER It 2:   7
                                                        TIER1At2A:  g
                         TIER 1 & 2:    1
                         TIER1A&2A:  3
    TOTALS

TIER 1*2:   21
TIER 1A « 2A: 79
® EPA REGIONAL OFFICE

-------
                               II-5
detected at the 1 ppb detection limit at 110 of the sites.  EPA

determined that other sites had never been sprayed.

     It is of particular note when considering the extent of

environmental contamination, that no other situations such as in

Missouri have been discovered.  That is, the widespread

distribution of contaminated material at numerous locations

occurred only in Missouri.

     Twenty* dioxin sites are on or proposed for the Superfund

National Priorities List (NPL).  The NPL identifies the targets

for long-term action under Superfund.  Most of these NPL sites,

such as Love Canal in Niagara Falls, New York, are on the NPL for

chemical contamination problems beyond dioxin.  The 20 sites on

the NPL or proposed NPL are:

     Baird and McGuire              Holbrook, MA
     Bliss Property                 Ellisville, MO
     Conservation Chemical          Kansas City, MO (proposed)
     Diamond Alkali                 Newark, NJ
     Drake Chemical                 Lock Haven, PA
     Fike Chemicals                 Nitro, WV
     Hooker Chemical (Hyde Park)    Niagara Falls, NY
     Hooker Chemical (Love Canal)   Niagara Falls, NY
     Hooker Chemical (S-Area)       Niagara Falls, NY
     Hooker Chemical (102nd St.)    Niagara Falls, NY
     Minker/Stout/Romaine Creek     Imperial/ MO
     Moyers Landfill                Collegeville, PA
     NIES                           Furley, KS (proposed)
     Quail Run                      Gray Summit, MO (proposed)
     Rohm & Haas                    Bristol, PA (proposed)
     Shenandoah Stables             Moscow Mills, MO
     Syntex                         Verona, MO
     Times Beach                    Times Beach, MO
     Vertac                         Jacksonville, AR
     Western Processing             Kent, WA

     2.2.2  Other Dioxin-Contaminated Sites
     Under the Dioxin Strategy, sites found to be contaminated in

tiers 3 through 7 are referred to OSWER for possible CERCLA

action.  To date, 13 sites have been referred from tiers 3
   In one case, five residential areas in Missouri are listed
   as one NPL site (Minker/Stout/Romaine Creek/Sullins/Cashel).
   The .site is known as Minker/Stout/Romaine Creek.

-------
                               II-6
through 7.  These are described in greater detail in the next
chapter.
     Although 2,3,7,8-TCDD has generally not been found in
commercial grade pentachlorophenol (PCP), 2,3,7,8-TCDD has been
detected at a number of PCP wood treatment facilities.  At an
inactive facility in Butte, Montana, for example, 2,3,7,8-TCDD
was de'tected at a level of 28 parts per billion  (ppb) .  These
sites are being handled by EPA's Superfund program.
     EPA's Office of Solid Waste (OSW) is investigating wastes
from PCP wood treatment for possible designation as hazardous
under RCRA.  OSW is collecting information on 2,3,7,8-TCDD and
other environmental contamination associated with wood treatment
operations.
     EPA is also monitoring or responding to other sites, such as
sites where PCBs were burned.
     2.2.3  Extent of Contamination of Tier 1 and 2 Facilities
     EPA, States, or responsible parties have sampled all of the
21 production sites in tiers 1 and 2 and most of the 79 tier 1A
and 2A disposal sites for 2,3,7,8-TCDD.  EPA's definition of
disposal sites goes beyond traditional active or inactive
disposal facilities to include sites such as those in Missouri
where contaminated material was dumped or received unknowingly.
     Eleven tier 1 and 2 production and disposal sites are
classified as requiring "no further action" under the Strategy.
This classification is based on sampling results that indicate
very low  (i.e., 0.7 ppb) or undetectable levels  of 2,3,7,8-TCDD,
using analytical methodology capable of detecting levels of  1
ppb.  These sites are:
     Calgon Corporation             Pasadena, TX
     Drake Chemical                 Lock Haven,  PA
     Eastman Kodak                  Rochester, NY
     Georges Creek                  Poca, WV
     GROWS                          Morrisville, PA
     Millmaster Onyx                Berkeley Heights, NJ
     Moyers Landfill                Collegeville, PA
     Resource Recovery              Pasco, WA
     Rhone Poulenc                  Portland, OR

-------
                               II-7
      Sourth  Charleston  Landfill      South  Charleston,  WV
      Union Carbide                   South  Charleston,  WV
      Two of  these sites (Drake Chemical  and  Moyers  Landfill)  are
on  the  Superfund NPL  for  contamination problems  unrelated  to
dioxin.
      Where 2,3,7,8-TCDD was detected, levels were generally
highest in the vicinity of actual waste  handling operations
(processing,  loading, storage).  At  sites  where  concentrated
2,4,5-TCP production  wastes were stored  or disposed of,  2,3,7,8-
TCDD  concentrations were  as high as  2,000  parts  per million
(2,000  ppm).  At most sites, however, 2,3,7,8-TCDD  levels  in
soils were in the parts per billion  (ppb)  range.  In fish  samples
from  nearby  lakes and streams, 2,3,7,8-TCDD  was  measured in terms
of  parts per  trillion (ppt).  A summary  of sampling data from
each  site is  provided in  Table 2-2.
      The majority of  2,3,7,8-TCDD contamination  at  tier  1,  1A,  2
and 2A  sites  remained on-site.  However, fish contamination and
off-site soil migration were detected in a number of instances.
      2.2.3a   Fish Advisories
      Fish advisories have been issued by State health  agencies
for nine sites.  The Michigan Department of  Public Health  issued
a fish advisory for certain species  (catfish and carp) in  the
Tittabawassee River downstream from  Dow  Chemical in Midland,  due
to dioxin contamination.  The remaining  advisories generally
recommend consuming fish  from specified  areas no more  than  once
or twice per month.   Six  sites are located on or near  the Niagara
River:
     0   Hooker Chemical (Buffalo Ave.)
     0   Hooker Chemical (S-area)
     0   Hooker Chemical (Love Canal)
     0   Hooker Chemical (102nd St.)
     0   Hooker Chemical (Hyde Park).
     0   Olin Chemical Corp.
An advisory was issued by the New York Department of Environ-
mental Conservation concerning fish obtained from the entire
Niagara River during 1985 and 1986.  Similarly, an advisory was
issued by the State of Arkansas for fish from the Bayou Meto from

-------
                               II-8
Jacksonville, Arkansas (near Vertac), to the Arkansas River; this
advisory has been issued for an indefinite period.  Fish from  the
Spring River from Verona, Missouri (Syntex), to the Oklahoma line
should be consumed with caution until further notice as well.  An
advisory (not associated with a specific site) was issued by the
Governor of West Virginia for the Kanawha River between the Coal
River at St. Albans and the Ohio River.
     2.2.3b  Off-site Contamination
     Off-site 2,3,7,8-TCDD soil contamination at levels of
concern has been confirmed in seven cases:
     Diamond Shamrock               Newark, NJ
     Brady Metals                   Newark, NJ
     Dow Chemical _!/                Midland, MI
     Love Canal                     Niagara Falls, NY
     Hyde Park                      Niagara Falls, NY
     Vertac                         Jacksonville, AR
     Bliss Tank Property  (1A)       Frontenac, MO
     To illustrate the type of environmental problems  EPA can
face at tier 1 or 2 facilities, several of the facilities with
off-site contamination are briefly discussed below.
Diamond Alkali - Newark,  New Jersey
     This facility was a  former herbicide manufacturing site
involved in the production of Herbicide Orange.  2,4,5-TCP  was
manufactured at the plant from February 1946 through August
1969,  The facility is located along  the Passaic River in an
industrial/commercial section of  Newark which contains a  sizable
number of residential dwellings.  The  site  is on the Superfund
NPL.
     Sampling Data— On-site soil samples confirmed high  (60  to
1200 ppb) levels of 2,3,7,8-TCDD.  Later analyses  showed  one
sample to be greater  than 50 ppm.
     An extensive off-site testing program  in  the  neighborhood
covered a 4,000 ft radius and consisted of  four  phases:   areas  of
_!/  The  contaminated  off-site  area is now included within the
     plant  fence  line.

-------
                               II-9
human habitability (including an 800-family public housing unit,
a church and a school):  open spaces (parking lots, street
corners); transport routes (roads, rail line and storm sewers)
and the Passaic River (sediments and fish).  2,3,7,8-TCDD was
detected above 1 ppb in samples taken at the following locations;
     0   Passaic River (bottom sediments):  5 of 35 samples
         greater than 1 ppb (range 1.2 to 3.0 ppb)
     0   Public Contact Areas (soil/sweep):
           Hayes Park East—2 of 11 samples (1.0-3.1 ppb)
           Joseph Street  —3 of 5 samples (1.1-4.1 ppb)
     0   Habitability Sampling
           Esther Street  —1.1 ppb (vacuum bag)
           SCA            —1.2 ppb (air conditioner filters)
           Joseph Street  —5.8 ppb (soil)
     0   Transportation Routes (soil/sweep)
           Esther Street  —4  samples 1.0-5.9 ppb
           Lockwood Street—9  samples 1.5-7.3 ppb
           Euclid Street  —3  samples 1.8-4.2 ppb
           Railroad       —27 samples 1.1-520 ppb
     Activities Undertaken to Date — As partial site
stabilization, a tarp was installed over on-site areas of
contamination and a fence was installed in the back of the
property.  Adjacent residential areas have been vacuumed and
swept to remove 2,3,7,8-TCDD contamination.
     Diamond Shamrock is now performing a feasibility study that
will be used by EPA and the State of New Jersey to determine
appropriate cleanup actions.
Brady Metals - Newark, New Jersey
     Brady Metals is a scrap metal facility that allegedly
received contaminated reactor vessels from the Diamond Shamrock
facility.  The site is located in a residential/industrial area
known as the Iron-bound section of Newark, New Jersey.
Contamination resulted from disassembly of reactor vessels on-
site.  Dioxin contamination has also been detected off-site.  It
is believed to have been transported by wind, erosion and
vehicles.

-------
                              11-10
     Sampling Data — Dioxin concentrations above 5 ppb were
found over most portions of the site with many samples from the
western half of the site exceeding  100 ppb.  The highest
concentration was 3,500 ppb.
     Off-site data were summarized  above in the discussion of
Diamond Shamrock.
     Activities Undertaken to Date— An impermeable barrier,
filters, and fence screening were installed to prevent off-site
migration and to control dust.  Nearby streets were cleaned, soil
was excavated from the nearby road  and stored on-site.  New
Jersey provided security to prevent public exposure.  The
responsible party has assumed cleanup responsibility.  The State
is providing compliance monitoring  at the site.
Hooker Specialty Chemicals Division - Niagara Falls, New York
     The Hooker Niagara Falls facility was involved in the
manufacture of 2,4,5-TCP from 1949-1972.  The facility is located
along the Niagara River in a highly industrialized setting.
Soluble 2,4,5-TCP wastes were sewered and discharged into the
Niagara River.  The Province of Ontario, Canada is located across
the Niagara River, a distance of approximately 2 miles.  On-site
landfilling of 2,4,5-TCP residues took place at the S-Area
disposal location which lies 10 yards west of the City of Niagara
Falls Water Treatment Plant.  Existing data indicate that
contamination from the S-Area disposal site has infiltrated the
main intake tunnel of the water treatment plant.  The S-Area site
is on the Superfund National Priorities List (NPL).
     Sampling Data — Hot spots were found at the former 2,4,5-
TCP production area with one particularly high hit at what  is
thought to be the former TCP waste  staging area.  On-site
sediment samples collected from catch basins ranged from 4.6-524
ppb.  On-site subsurface soil samples ranged from ND to  18.6
parts per million.  Off-site sampling found 8.6 ppb in one  sewer
sediment sample and 1.1 ppb in a surface soil sample.

-------
                              11-11
     Activities Undertaken to Date — EPA and New York State  are
negotiating with Hooker to determine if the company will
undertake necessary feasibility studies and remedial
investigations at its production facility.
Love Canal - Niagara Falls/ New York
     More than 21,000 tons of chemicals were disposed of  in Love
Canal.  In 1954, 3,000 cubic yards of fly ash and BHC cake taken
from Love Canal were used as fill at the nearby 93rd Street
School.  The Love Canal site consists of a large former
residential area (the so-called Emergency Declaration Area (EDA))
surrounding the Love Canal area proper, some of whose residents
have chosen to remain in the area.  The site was used as  a
disposal site from approximately 1942-1952.
     Sampling Data— Several sampling programs for 2,3,7,8-TCDD
have been conducted, including the 1980 EPA monitoring at Love
Canal; 1983 Malcolm Pirnie sampling; 1984 NYSDOH sampling; and
1983 EC Jordan Borehole Investigation.  Results included:

Medium (soil,          Location (on-        High Concentration
water, etc.)           or off-site)         	(ppb)	
Sediments:
  Bergholtz Creek      Off-site (EDA area)          45.8
  Black Creek          Off-site (EDA area)           4.0
102nd St. Outfall      Off-site                      3.3
  Sewer                Off-site (EDA area)         650
Soil:
  93 St. School        Off-site (EDA area)           1.6
  (3+ ft. deep)
  Canal-surface        On-site (on Canal             6.7
                       proper)

     Actions Undertaken to Date — A cap, including a synthetic
liner, now covers the canal proper.  A leachate collection system
and leachate treatment plant are operating.  Sewers exiting the
canal were severed and plugged.  It is expected that contaminants
are no longer migrating from the canal due to these measures.

-------
                              11-12
     Significant additional cleanup and long-term monitoring
activity is anticipated at this site.
Dow Chemical Company - Midland, Michigan
     Dow Chemical Company U.S.A. - Michigan Division (Dow)  is a
chemical manufacturing plant which produced 2,4,5-TCP.  The
2,4,5-TCP and its derivatives were formulated into pesticide
products.  Dow historically landfilled its wastes on-site.  Dow
is also a combustion source because of its on-site incinerator.
     Dow began brine production operations in 1897.  Commercial
production of a variety of chlorinated phenols began in the mid-
1930 's and ended in the late 1970's.
     Dow is located within Midland, Michigan (population
approximately 37,250), and the manufacturing complex encompasses
a land area of approximately 1,500 acres.
     Sampling Data — Dow and the surrounding area have been
extensively sampled for dioxin by Dow and the U.S. EPA.  In
December 1983, initial sampling detected 2,3,7,8-TCDD at levels
up to 52 parts per billion (ppb) in soil on the plant site  and up
to 2 ppb at the plant perimeter (now on-site).  2,3,7,8-TCDD has
been detected in fish in the Tittabawasee River at levels from 12
to 530 parts per trillion (ppt).  2,3,7,8-TCDD soil samples in
residential areas were less than 1 ppb.  2,3,7,8-TCDD is also
being monitored in the ambient air and in the emissions from
Dow's incinerator.  In 1985, Dow performed follow-up soil
sampling and reported a cone of contaminated soil with
concentrations ranging from non-detectable outside the cone (Det.
Limit .005 ppb) up to 1500 ppb.  The contamination is from
historical releases from a tank farm associated with the
production of chlorophenol.  The highest concentration was
detected in the center of the cone at a depth of 10-12 feet.
     Activities Undertaken to Date — In 1984 and 1985, under the
terms of a U.S. EPA Administrative Order, Dow removed
contaminated demolition debris and capped contaminated areas to
prevent airborne migration and direct contact with

-------
                              11-13
contaminants.  The State of Michigan has issued a fishing
advisory for the Tittabawassee River downstream of the Dow
plant.  An NPDES limit of 10 ppq (parts per quadrillion) 2,3,7,8-
TCDD in Dow wastewater discharge into the Tittabawassee River was
also established as an interim effluent limitation.
     Pursuant to the Hazardous and Solid Waste Amendments (HSWA)
to RCRA of 1984, Dow is required to address corrective action for
all releases of hazardous waste or constituents from any solid
waste management unit.  This will encompass both on-site and off-
site releases of dioxin, including highly contaminated areas.
Dow's compliance plan for corrective action is currently under
review.  EPA is currently writing a Corrective Action Plan
(CAP).  Interim corrective measures are expected to be approved
before the end of September 1987.  Further investigations and
corrective measures will be incorporated into Dow's HSWA permit.
Vertac - Jacksonville, Arkansas
     The site is located adjacent to a residential area of
Jacksonville, Arkansas, just north of Little Rock.  In the mid-
fifties, Reasor-Hill Company began the manufacture of phenoxy
herbicides at the site, including the manufacture of 2,4,5-T.  In
1961, the plant was sold to Hercules, who operated until 1972 and
produced 2,4-D, 2,4,5-T, 2,4,5-TP and Herbicide Orange.  In  1971,
Vertac, Inc. began operation at the site.  From the time
production began during the Reasor-Hill era until March 1979, one
of the major products produced was 2,4,5-T.
     Solid and liquid waste from the Reasor-Hill period up to
1974 were buried on-site in a series of landfills.  All surface
flow from Vertac ends up in Rocky Branch Creek which runs along
the western edge of the plant.  Non-contact cooling water from
the Reasor-Hill operations was held in a dammed portion of Rocky
Branch.  Rocky Branch drains into Bayou Meto about 2 miles south
of the Vertac plant.

-------
                              11-14
     Sampling Data— 2,3,7,8-TCDD has been detected both on- and
off-site:
     Highest levels found were:
     0   Equalization basin on site         1,200 ppb
     0   Sewer collection line south of
           facility                            10.9 ppb
     0   Oxidation ponds from City
           of Jacksonville sewage
           treatment facility                   3.4 ppb
     0   Sewerline                            334 ppb
     0   Fish                                 798 ppt
     Activities Undertaken to Date — Pursuant to a consent
decree, Vertac/Hercules are containing wastes on-site with slurry
walls, French drains, and clay caps.  Some sediments and
contaminated soils are being contained in a clay vault on-site.
EPA did not feel this remedy provided sufficient protection to
human health and the environment; however, Vertac's remedy was
found to be judicially acceptable.  EPA will closely monitor this
site.
     An off-site Remedial Investigation/Feasibility Study  (RI/FS)
is in progress.  2,3,7,8-TCDD has been found in fish as far as
roughly 100 miles downstream from the plant.  The Arkansas
Department of Health has quarantined Rocky Branch from where it
flows through the Vertac property, to its confluence with  Bayou
Meto and has quarantined Bayou Meto from Jacksonville to the
Bayou's confluence with the Arkansas River.

2.3  Response Actions
     Initial Agency actions responding to verified contamination
have focused on mitigating the threat of public exposure.
Inhalation, soil ingestion, dermal contact, and fish consumption
are the major exposure routes of concern.  Cleanup actions,
emergency removals and associated health and fish consumption
advisories have focused on reducing potential exposure via these
routes.  EPA prioritizes its cleanup actions according to  the
risks associated with each site.

-------
                              11-15
     Cleanup action has been taken at 11 of the 21 production
sites in tiers 1 and 2.  Some of these sites have been the
recipients of multiple actions; many will receive additional
cleanup.
     Cleanup activities include:
     0   Removal Actions—designed to mitigate, in a relatively
         short time-frame, a threat or potential threat to humans
         and the environment; removals include such activities
         as:
            Relocation of threatened populations
            Restricting access by fence construction or sign
            posting
            Excavation of contaminated soils with on- or off-site
            storage
            Capping or paving measures to control migration
         -  Cleaning/vacuuming of contaminated surfaces
     0   Remedial Actions—to mitigate, in a longer time-frame
         and consistent with a permanent remedy, a threat or
         potential threat to human health and the environment;
         remedial actions may encompass the same type of
         activities as removals.
Figure 2-2 presents the cleanup actions and pre-cleanup
activities (sampling, analysis, engineering assessments) that EPA
has taken, or has compelled responsible parties to take, at tier
1 and 2 production facilities.  Planned or anticipated cleanup
actions are also given.
     Figure 2-3 presents similar information for disposal
facilities that received wastes directly from production
facilities.  Figure 2-4 presents sites that received contaminated
waste oil in Missouri.
     As shown in Figure 2-4, monitoring is planned for 16
Missouri sites.  Monitoring may involve observing the integrity
of a paved surface or a storage tank as well as periodic sampling
and analysis.  Sites now being monitored may undergo further
action.

-------
                                               11-16

                                         FIGURE 2-2

                                  PRODUCTION FACILITIES
                                         TIERS 1 AND 2
                                      ACTIONS TAKEN TO DATE
REMOVALS/REMEDIAL ACTIONS
AMCHEM. AMBLER, PA
BAIRD & MCGUIRE, HOLBROOK, MA
DIAMOND ALKALI, NEWARK, NJ
DOW CHEMICAU MIDLAND, M
DRAKE CHEMICALS. LOCK HAVEN. PA-
HOOKER CHEMICAL (BUFFALO AVE.),
  NIAQRA FALLS, NY
MONSANTO PLANT, NITRO, WV"
MONSANTO (QUEENY PLANT), ST. LOUIS. MO
ROHM & HAAS, BRISTOL. PA"
SYNTEX AGRIBUSINESS, VERONA, MO
THOMPSON-HAYWARD CHEM. CO.,
  KANSAS CITY, KS
VERTAC CHEMICALS, JACKSONVILLE, AR
              SAMPLED AND ANALYZED

              CHEMICAL INSECTICIDE, EDISON, NJ
              EASTMAN KODAK, ROCHESTER, NV
              FIKE (ARTEL) CHEMICALS. NfTRO. WV
              GIVAUDEN, CLIFTON, NJ
              MILLMASTER ONYX. BERKELEY HEIGHTS. NJ'
              OLIN CHEM. CORP., NIAGARA FALLS, NY
              RHONE-POULENC, PORTLAND, OR'
              SUPERIOR SOLVENTS, ST. LOUIS, MO
              UNION CARBIDE, SOUTH CHARLESTON, WV
                                 ACTIONS PLANNED OR ANTICIPATED
  NO FURTHER ACTION
  AT THIS TIME
  DUE TO SAMPLING RESULTS

  DRAKE CHEMICAU LOCK HAVEN. PA
  EASTMAN KODAK, ROCHESTER. NY
  MILLMASTER ONYX, BERKELEY HEIGHTS. NJ
  RHONE-POULENC. PORTLAND.OR
  UNION CARBIDE. SOUTH CHARLESTON, WV
  NO FURTHER ACTION
  AT THIS TIME
  DUE TO CORRECTIVE ACTIONS

  MONSANTO PLANT, NfTRO, WV
  ROHM & HAAS, BRISTOL, PA
FURTHER SAMPLING AND ANALYSIS
OLIN CHEM. CORP, NIAGARA FALLS. NY
         ENGINEERING ASSESSMENT

         CHEMICAL INSECTICIDE, EDISON, NJ
         GIVAUOEN, CLIFTON, NJ
         SUPERIOR SOLVENTS, ST. LOUIS, MO
      REMOVALS/REMEDIAL ACTIONS

      AMCHEM, AMBLER, PA
      BAIRD & MCGUIRE, HOLBROOK. MA
      DIAMOND ALKALI, NEWARK, NJ
      DOW CHEMICAL, MIDLAND, Ml
      FIKE (ARTEL) CHEMICALS, NITRO, WV
      HOOKER CHEMICAL (BUFFALO AVE.). NIAGARA FALLS, NY
      MONSANTO (OUEENY PLANT). ST. LOUIS. MO
      SYNTEX AGRIBUSINESS, VERONA, MO
      THOMPSON-HAYWARD CHEM. CO., KANSAS CITY, KS
      VEHTAC CHEMICALS, JACKSONVILLE. AH
    IF A SITE UNDERWENT (OR IS ANTICIPATED TO UNDERGO) MORE THAN ONE ACTIVITY,
    THE MOST ADVANCED ACTIVITY IS INDICATED.  SOME ACTIVITIES ARE ONGOING.

-------
                                                             11-17

                                                         FIGURE 2-3

                                     DISPOSAL SITES - TIERS 1A AND 2A
                                          WASTES RECEIVED DIRECTLY
                                           FROM PRODUCTION FACILITY
                                                    ACTIONS TAKEN TO DATE
         REMOVALS' REMEDIAL ACTIONS
         BALDWIN PARK. AURORA. MO
         BILL HAY FARM. BARRY CO., MO-
         BUSS TANK PROPERTY. FRONTENAC. MO
         BRADY METALS, NEWARK. NJ
         DENNY FARM SfTE, BARRY CO.. MO
         S. 8 ERWIN FARM, LAWRENCE CO, MO*
         HOOKER CHEM (LOVE CANAL), NIAGARA FALLS, NY
         HOOKER CHEM. (HYDE PARK), NIAGARA FALLS. NY
         HOOKER CHEM (S-AREA), NIAGARA FALLS. NY
         HOOKER CHEM (102nd SI). NIAGARA FALLS, NY
         MANILA CREEK, POCA. WV
         MONSANTO LANDFLL. NITRO, WV
         NEOSHO DIGESTER. NEOSHO. MO
         NEOSHOTANK SPILL AREA, NEOSHO. MO>
         NIES (1A), FURLEY. KS
         NIES (2A). FURLEY. KS
         NITRO DUMP. NTTRO, WV
         ROBERT  RUSHA FARM. BARRY CO.. MO-
         ROYAL TALLEY FARM, MCKINLEY.  MO*
         SYNTEX  LAGOON. SPRINGFIELD. MO
         WESTERN PROCESSING CO.. KENT. WA*
                                                                           PRELIMINARY INVESTIGATION
                                                                           BFI. LIVINGSTON, LA*
                                                                           BFI (1A). MISSOURI CITY. MO*
                                                                           BFI (2A). MISSOURI CITY. MO*
                                                                           BOYERTOWN SCRAP. BOYERTOWN. PA*
                                                                           CHEM CLEAR CHESTER PA*
                                                                           CHEM. WASTE MNGMT., INC., EMELLE, AL*
                                                                           CHEM. WASTE MNGMT., WC., PORT ARTHUR, TX*
                                                                           CHEMTROL/SCA SERVICES. MODEL CfTY. NY
                                                                           COLWEULANE.PA*
                                                                           TOSCANOTRUCMNG*
                                                                           WASHINGTON IRON 4 METAL, PHILADELPHIA, PA-
                                                                           WHEELING DISPOSAL. AMAZONIA, MO
                                                                          SAMPLED AND ANALYZED
                                                                          ALKAU LAKE, SOUTHEASTERN. OR
                                                                          CALGON CORP. PASADENA. TX*
                                                                          CHEM. SECURITY SYSTEMS. INC.. ARLINGTON. OR
                                                                          CONSERVATION CHEMICAL CO.. KANSAS CITY. MO
                                                                          ENVIRO. SERV OF IDAHO. INC.. GRANDVIEW, ID-
                                                                          GEORGES CREEK, POCA. WV
                                                                          GREEN VILLAGE DISPOSAL. GREEN VILLAGE. NJ*
                                                                          GROWS.. MORFISVILLE, PA*
                                                                          HEIZER CREEK, POCA, WV
                                                                          MOVERS LANDFILL. COLLEGEVILLE, PA*
                                                                          POCA LANDFILL, POCA, WV
                                                                          POSEYVILLE LANDFILL. POSEYVIUE. M
                                                                          RESOURCE RECOVERY, PASCO. WA*
                                                                          SOUTH CHARLESTON LANDFILL, S. CHARLESTON. WV
                                                                          SPRING RWER VERONA. MO
                                                                          ST. JOHNS LANDFILL. PORTLAND, OR
                                                                          SYNTEX AGRIBUSINESS, VERONA, MO
                                            ACTIONS PLANNED OR ANTICIPATED
     NO FURTHER ACTION
         AT THIS TIME
                                                          SAMPLING AND ANALYSIS
                                                          CHEMTROUSCA SERVICES. MODEL CITY. NY
                                                          WHEELING DISPOSAL. AMAZONIA. MO
DUE TO
SAMPLING
RESULTS
DUE TO
CORRECTIVE
ACTIONS
REFERRED TO
HCHA PROGRAM
UNABLE TO
TRACE WASTE

UNABLE TO
IDENTIFY
DISPOSAL
SITES
  CALGON CORP , PASADENA. TX
{  GEORGES CREEK.POCA. WV
  GREEN VILLAGE DISPOSAL. GREEN VILLAGE. NJ
  GROWS. MORRISVILLE. PA
  MOVERS LANDFILL. COLLEGEVILLE. PA
  RESOURCE RECOVERY.PASCO. WA
  SOUTH CHARLESTON LANDFILL, WV
   BILL RAY FARM, BARRY CO, MO
 -SB. ERWIN FARM, LAWRENCE CO.. MO
 I  MONSANTO LANDFILL. NITRO. WV
<  NEOSHO TANK SPILL AREA, NEOSHO. MO
 I  NTTRO DUMP. NITRO. WV
 V ROBERT RUSHA FARM. BARRY CO.. MO
   ROYAL T ALLEY FARM, LAWRENCE CO.. MO
   WESTERN PROCESSMO. KENT. WA
 _ an (1A\ MWSOUM cnv, MO
 I BR 
-------
                                             11-18

                                        FIGURE 2-4

                            DISPOSAL SITES -1A - MISSOURI
                         WASTES RECEIVED FROM SPRAYING
                             OF CONTAMINATED WASTE OIL
                                      ACTIONS TAKEN TO DATE
REMOVALS/REMEDIAL ACTIONS

BLISS PROPERTY. ELLISVLLE. MO
BUBBLING SPRINGS ARENA, FENTON. MO
CASHEL RESIDENCE, FENTON. MO
COMMUNITY CHRISTIAN CHURCH MANCHESTER, MO
EAST NORTH STREET, EUREKA. MO
JONES TRUCK LNES, ST. LOUIS. MO
LACY MANOR DRIVE CEDAR HILL, MO
M1NKER RESIDENCE. IMPERIAL. MO
OVERNITE TRANSPORTATION, ST. LOUIS. MO
PIAZZA ROAD. ROSATI. MO
OAJAIL RUN MOBILE PARK. GRAY SUMMIT, MO
ROMAINE CREEK. IMPERIAL, MO
RUSSELL BLISS FARM ROAD, ROSATI, MO
SADDLE AND SPUR RIDING CLUB, HIGH RIDGE. MO
SHENANDOAH STABLES. LINCOLN CO., MO
SONTAG ROAD. CASTLEWOOD. MO
STOUT RESIDENCE. IMPERIAL, MO
SULLINS RESIDENCE, IMPERIAL. MO
TIMBERLINE STABLES, GALLOWAY. MO
TIMES BEACH. MO
=(=

 SAMPLED AND ANALYZED

 ARKANSAS BEST FREIGHT. ST. LOUIS, MO
 BAXTER GARDEN CENTER CHESTERFIELD, MO
 BONFIELD BROTHERS TRUCKING,, ST. LOUIS, MO
 BULL MOOSE TUBE CO.. GERALD, MO
 EAST TEXAS MOTOR FREIGHT. ST. LOUIS. MO
 ERXLEBEN PROPERTY, ST. LOUIS, MO
 OLD ACCESS ROAD, HWY. 141. MO
 SOUTHERN CROSS LUMBER HAZELWOOD. MO
     ENGINEERING ASSESSMENT

     HAMILL TRANSFER CO., ST. LOUIS, MO
     MANCHESTER METHODIST CHURCH, ST. LOUIS, MO
                                ACTION PLANNED OR ANTICIPATED
MONITORING

ARKANSAS BEST FREIGHT, ST. LOUIS, MO
BAXTER GARDEN CENTER. CHESTERFELD, MO
BONIFIELD BROTHERS TRUCKING. ST. LOUIS. MO
BULL MOOSE TUBE CO.. GERALD, MO
CASHEL RESIDENCE. FENTON, MO
COMMUNITY CHRISTIAN CHURCH, MANCHESTER. MO
EAST NORTH STREET, EUREKA. MO
ERXLEBEN PROPERTY, ST. LOUIS CO., MO
HAMILL TRANSFER CO., ST. LOUIS. MO
JONES TRUCK LINES, ST. LOUIS. MO
LACY MANOR DRIVE. CEDAR HUL MO
MANCHESTER METHODIST CHURCH ST. LOUIS. MO
QUAIL RUN MOBILE PARK. GRAY SUMMfT, MO
OVERNITE TRANSPORTATION CO., ST. LOUIS, MO
SOUTHERN CROSS LUMBER HAZELWOOD. MO
SULLINS RESIDENCE. FENTON. MO
ENDANGERMENT ASSESSMENTS
PENDING LITIGATION

BUBBLING SPRINGS HORSE ARENA, JEFFERSON CO., MO
PIAZZA ROAD. ROSATI, MO
RUSSELL BLISS FARM ROAD, ROSATI. MO
SADDLE AND SPUR RIDING CLUB, HIGH RIDGE, MO
SHENANDOAH STABLES, LINCOLN CO., MO
TIMBERLINE STABLES, CALJLAWAYCO.. MO
      REMOVALS/REMEDIAL ACTIONS

      BLISS PROPERTY. ELLISVK.LE, MO
      EAST TEXAS MOTOR FREIGHT, ST. LOUIS, MO
      MINKER RESIDENCE, IMPERIAL, MO
      OLD ACCESS ROAD, HWY. 141, MO
      ROMAINE CREEK, IMPERIAL, MO
      SONTAG ROAD, CASTLEWOOD, MO
      STOUT RESIDENCE, IMPERIAL, MO
      TIMES BEACH, MO
     IF A SJTE UNDERWENT (OR IS ANTICIPATED TO UNDERGO) MORE THAN ONE ACTTVrTY.
     THE MOST ADVANCED ACTIVITY IS INDICATED. SOME ACTIVITIES ARE ONGOING.

-------
                              11-19
     Several of the Agency's actions are considered temporary
solutions.  These actions were taken to mitigate the immediate
threat of public exposure.  Temporary solutions normally contain
rather than reduce, destroy, or permanently dispose of
contaminated material.  Permanent solutions may be undertaken in
the future.
     The Agency's planned or anticipated activities focus on
permanent remedies.  As discussed in Chapter 6, EPA is currently
funding several demonstration projects aimed at developing
effective and affordable treatment technologies.  EPA's mobile
incinerator has successfully treated Missouri soils, achieving
99.9999 percent destruction and removal efficiency.  EPA has
issued regulations under RCRA (see Chapter 5) specifying
procedures for approving dioxin treatment and disposal
facilities; however, there are currently no approved commercial
treatment and disposal facilities for dioxin.
     Most of EPA's cleanup activities discussed above were based
on CDC or NIOSH health recommendations.  NIOSH and CDC have
issued recommendations concerning at least 37 residential,
recreational, and commercial sites.  These sites are listed in
Table 2-3.
     Health recommendations were issued for 16 residential and 7
public access area sites.  Each site had been contaminated by
dioxin-containing oil sprayed to control dust, or by oil-
contaminated fill dirt.  Of the 16 residential areas, residents
of 6 of the sites have been advised to avoid contact with soil
until cleanup or removal takes place.  Access to portions of six
additional sites is restricted until cleanup or removal.
Evacuation and prohibition of use have been advised at the
remaining four residential sites, the most notable being Times
Beach, Missouri.  An evacuation has been established, and many of
the residents are complying.
     For public access areas, access has been limited to a
portion of the area at one park pending further testing.  Two
churches have been permitted to continue operations (including

-------
                              11-20
day-care center operations), provided access is limited at a
remote area of each site.  Due to the potential of soil
disturbance and dust generation at riding stables, four stables
require remedy; their use is currently restricted.
     CDC and NIOSH issued health recommendations for 14
industrial sites, 11 of which are commercial facilities involved
in light industry.  Most of these sites were contaminated by
dioxin-containing oil used for dust control.  Seven of the 11
were found to present no hazard to the employees under current
operating conditions.  However, if activities which will disturb
the soil occur (such as excavation or underground pipeline
repair), safety precautions including protective clothing and
respirators should be used.  At an eighth commercial site which
required cleanup, operations were permitted to resume.  Access
has been prohibited at a waste-oil storage facility until
cleanup.  At the tenth site, EPA expects responsible parties to
mitigate all exposure routes.  At the eleventh site (Nalco-tier
3), public access is restricted until additional samples are
analyzed.
     Health recommendations were issued for three tier 1 and 2
production facilities.  One site has been found to pose no major
hazard under current operations.  The second site is not
currently used, and access has been limited until cleanup.  The
third site ceased operations in 1982.

-------
                                                             TABLE 2-2
                                                            SITE LISTING
                                                      NATIONAL DIOXIN STRATEGY
                                                                2/87
Name

Tier 1
    Location'
No. And Kind Of
Sample Analyzed
Concentration
Range (DDb)
                                                                               Response Actions
Baird & McGuire
    Hoi brook,  MA
Chemical Insecticide
                                Edison,  NJ
Diamond Alkali
                                Newark,  NJ
Givauden
u"oker Chemical  (Buff?1
   Clifton, NJ
.)  Niagara  r:'' ^
       REGION I

96 on-site soil
17 off-site soil
 2 on-site sediment
 5 off-site water
18 on-site soil
 5 on/off-site air
35 on/off-site fish
                                 REGION II

                            61 on-site soil
                            80 off-site soil
                            9 on-site soil
                          537 off-site soil
                           28 off-bite vacuum bogs
                           32 off-site sediment
                                                       37  on-site  soiT
                                                       28  off-site soil
                                                       17  en  ;-t:
                                                        1  off-site  soil
                                                        5  on-site
                                                        2  off-site  sediment
                                                                                      n.d. -48
                                                                                      n.d.
                                                                                      n.d.
                                                                                      n.d.
                                                                                      n.d.-11.3
                                                                                      n.d.
                                                                                      n.d.-.0045
                                                                                      0.09-17
                               60-51.000
                               n.d.-725
                               n.d.-5.8
                               n.d.-6.7
                                                         n.d.-9.7
                                                         n.d.
                                                         4.6 - 524
                                                          ?  - 8.6
                                                                               Prior to dioxin dis-
                                                                               covery, removal of
                                                                               1000 yd3 of soil,
                                                                               installed ground
                                                                               water recirculation
                                                                               system and clay cap.
                                                                               Fence erected by EPA
                                                                               after dioxin dis-
                                                                               covery.  New 12"
                                                                               water-main built to
                                                                               reroute water supply
                                                                               around site.
                     Fence installed. On-site
                     and off-site sampling
                     of air,  soil .  ground-
                     water, surface water
                     and other materials
                     pi anned .

                     Tarp placed over on-site
                     contamination  areas and
                     fence installed in back
                     of property.  Adjacent
                     residential areas vac-
                     uumed and swept.

                     None to  date;  consent
                     decree under negoti-
                     ation to  conduct
                     RO/RA.
                                                    covered,  some waste
                                                    containerized.  Results
                                                    of sampling transmitted
                                                    to EPA RCRA and State
                                                    for enforcement
                                                    activities.
                                                                                                                                                to

-------
                                                            SITE LISTING
                                                      NATIONAL DIOXIN STRATEGY
                                                                2/87
Name

01 in Chemical Corp.




Tier 2

Eastman Kodak


Millmaster Onyx
Location

Niagara Falls, NY
Rochester. NY
No. And Kind Of
Sample Analyzed

15 on-site soil
 2 off-site soil
23 soil
 2 sediment
Berkeley Heights,  NJ   25
Concentration
Range (oobl

n.d. - 8.7
n.d.
n.d.
n.d.

n.d - 0.7
Response Actions

Future action pending;
additional sampling
will be conducted.
(still negotiating)
No further action
planned.

No further action
planned.
Chemtrol/SCA Services
Hooker Chemical  (S-Area)
                                Newark, NJ
Model City, NY
Niagara Falls,  NY
Hooker Chemical  (Love Canal)     Niagara Falls.  NY
                       to on-site soil
                       30 off-site soil
                       14 on-site ver  ical  soil
                       14 on-site surface wipe
                        3 on-site sweeping
                               1.9-3500
                               1.7-1156
                               0.95-1900
                               12-56  ng
                               5.4-16

                               0.001
                        ?  on-site  soil                 7-6.7
                        ?  off-site sediment            7-45.8
                        ?  off-site soil  (subsurface)   7-1.6
                        ?  off-site sewer              7-650
                     Impermeable barriers,
                     filters,  and fence
                     installed; responsible
                     party performing clean-
                     up.

                     None to date; pre-
                     liminary dioxin
                     screening planned.

                     Area fenced; surveys
                     and  studies phase of
                     program begun.   Site
                     barrier wall, drain
                     collection system, cap
                     to be installed.  All
                     work governed by
                     Consent Decree;  no
                     dioxin sampling  per
                     this decree.

                     Cap  with  synthetic
                     liner installed.
                     Leachate  collection
                     system creeks to be
                     cleaned.   Parts  of
                     sewers cleaned;  rest to
                     be cleaned later.
                     Long-term monitoring
                     program being imple-
                     mented.   RI/FS being
                     conducted.
                                                                                                                                               to

-------
Name                            Location

Hooker Chemical (102nd Street)  Niagara Falls,  NY
Hooker Chemical (Hyde Park)
Town of Niagara,  NY
                                                            SITE  LISTING
                                                      NATIONAL  DIOXIN STRATEGY
                                                               2/87
                       No.  And Kind Of                Concentration
                       Sample Analyzed                Range (ppb)

                       10 on-site surface soil         0.59
                       14 on-site subsurface soil      173-630
 1  on-site non-aqueous phase
   liquid                      20,600
20  off-site soil               3-263
 1  off-site ground water       0.00018
Toscano Trucking
none to date
                     Response Actions

                     Area fenced; warning
                     signs posted; RI/FS
                     being conducted.

                     Site is capped, fenced,
                     and has a tile drain
                     system nearby; planned
                     collection of leachate
                     by purge and recircula-
                     tion wells.

                     None to date; no
                     specific site
                     identified yet; no
                     future activities
                     planned.
                                                                                                                                                H
                                                                                                                                                H
Green Village Disposal
Green Village,  NJ
n.d.
                                                    None to date.  Responsi-
                                                    ble party search and
                                                    dioxin screening
                                                    completed.  Dioxin was
                                                    undetected in all
                                                    samples.
                                                             REGION III
Drake Chemical
Lock Haven, PA
                                                                                      n.d.
Rohm & Haas
Union Carbide-SC
Bristol, PA
South Charleston,  WV
                                                       various (ca.  300)
                                                      7-3
                                                                                      n.d.
                     Site is fenced; drummed
                     materials and reactor
                     vessels removed and
                     disposed; no additional
                     dioxin response actions
                     necessary.

                     Buildings vacummed;
                     waste drummed and
                     removed for inciner-
                     ation; no further
                     actions necessary.

                     No further action
                     necessary.

-------
                                                              SITE LISTING
                                                        NATIONAL DIOXIN STRATEGY
                                                                  2/87
Name

Tier 2

Amchem




Artel Chemicals




Monsanto
                                   Location
Ambler. PA
Nitro, WV
Nitro, WV
                                                         No. And Kind Of
                                                         Sample Analyzed
                                               Concentration
                                               Ranoe (ppbl
 9 on-site soil                n.d.-118.0
 1 on-site pipe dust           609.9
11 off-site soil               n.d.
 1 on-site sump                1.3

189 on-site soil               n.d.-18.8
  6 on-site drummed waste      1.78-1.94
 30 off-site soil              n.d.
Ca. 400 on-site soil           n.d.-400
Ca.  50 off-site soil          n.d.-1.8
                                                   Response Actions
                                                   Buildings vacuumed;
                                                   waste being drummed
                                                   and removed for in-
                                                   cineration.

                                                   Planned coverage with
                                                   asphaltic concrete cap;
                                                   planned proper storage
                                                   of contaminated drums.

                                                   Area covered with
                                                   asphalt, clay or gravel;
                                                   building vacuumed, and
                                                   waste drummed and re-
                                                   moved for incineration;
                                                   no further action
                                                   necessary.
                                                                                                                                                H

                                                                                                                                                N>
Boyerton Scrap
Boyerton, PA
Chem Clear






Colwell Lane




Georges Creek


GROWS


Heizer Creek

Manila Creek
Chester. PA
Poca. WV


Morrisville.  PA


Poca. WV

Poca. WV
Not tested
19 on-site soil

19 on-site soil
                               n.d.


                               n.d.


                               n.d.-1.10

                               n.d.-57.2
All potentially
contaminated waste
was bagged on receipt
and land-filled;
dioxin project
terminated.

No method available to
trace wastes;
contamination not
found •in waste at
Tier 2 site.

Drums buried on site; no
further action necessary
unless drums removed from
site.

No further actions
necessary.

No further actions
necessary.

RI/FS underway.

Remedial order planned.

-------
                                                            SITE LISTING
                                                      NATIONAL OIOXIN STRATEGY
                                                                2/87
Name

Monsanto Landfill


Moyers Landfill


Nitro Dump


Poca Landfill


South Charleston Landfill


Washington Iron & Metal
Location

Nitro. WV


Collegeville, PA


Nitro. WV


Poca, WV


South Charleston,  WV


Philadelphia, PA
                                                       No.  And Kind Of
                                                       Sample Analyzed

                                                       See  Monsanto (Tier 2)
                                                        6 on-site soil
                                                        9 on-site soil
                                                       Not  tested
                                                                                      Concentration
                                                                                      Range  (ppb)
                                                                                      n.d-1.8


                                                                                      n.d.-17.8
Response Actions

No further actions
necessary.

No further actions
necessary.

Capping completed.
Negotiation underway
for RI/FS.

No further actions
necessary.

Metal melted down; no
way to trace
potentially
contaminated metal.
Tier 2a

Chemical Waste Management       Emelle,  AL
Tier 1

Dow Chemical  Co.                 Midland,  MI
                                                             REGION IV
                                                       None to date for TCDD except
                                                       for PCB storage tanks
                                                              REGION V
                                                       43 on-site soil  (1984 study)
                                                       11 off-site soil
                                                       45 fish
                                                      0.041-52.0
                                                      0.0006-0.45
                                                      0.012-0.53
                                                       106 on-site soil  (1985 study)   n.d.-1500
                                                       42 off-site soil                0.003 - 2.03
                                                                           Facility referred to
                                                                           RCRA program for
                                                                           permitting action.
                                                                                                           Contaminated debris
                                                                                                           removed and site
                                                                                                           capped; responsible
                                                                                                           party RCRA compliance
                                                                                                           plan under review.
                                                                                                           Corrective action
                                                                                                           investigations for
                                                                                                           three point source
                                                                                                           areas are under
                                                                                                           discussion.

-------
                                                             SITE  LISTING
                                                        NATIONAL DIOXIN  STRATEGY
                                                                 2/87
Name

Tier la

Poseyville Landfill
                                   Location
Midland, MI
                                                              No. And Kind Of
                                                              Sample Analyzed
                                                        Concentration
                                                        Range (ppbl
                                   Jacksonville,  AR
BFI (CECOS Int'l)





Chemical Waste Management, Inc.
Livingston, LA
Port Arthur, TX
Tier 2a

Calgon Corporation
Pasadena, TX
                                                               REGION VI
                          320 off-site various
                           45 on-site soil/sediment
                           26 fish
                            5 on-site water
                            ? on-site wastes from
                             2.4,5 T production
                                                             none  to  date
none to date
                                
-------
                                                              SITE  LISTING
                                                        NATIONAL  DIOXIN  STRATEGY
                                                                 2/87
Name
                                   Location
                           No.  And Kind Of
                           Sample Analyzed

                            REGION VII
                                                                                           Concentration
                                                                                           Range (DDb)
                                                     Response Actions
Syntex Agribusiness



Tier la

Arkansas Best Freight


Baldwin Park
Baxter Garden Center
Russell Bliss Farm Road
(=Piaz2a Road)

Bliss Property
Bliss Tank Property
Bonifield Brothers Trucking
Verona, MO





St. Louis, MO


Aurora, MO





Chesterfield, MO


Rosati, MO


Ellisville, MO
Frontenac,  MO
St. L-ouis, MO
Browning-Ferris Industries (BFI)   Missouri City, MO
Bubbling Springs Arena
Bull Moose Tube Company
Fenton, MO
Gerald, MO
74 on-site soil
14 on-site water
 3 off-site water
25 on-site soil
 1 off-site soil

67 on-site soil

 5 on-onsite sweep



19 on-site soil


 7 on-site soil
74 on-site soil
 2 off-site
50 on/off-site soil
16 on/off-site sediment
13 off-site dust

 5 on-site soil
                          Quarterly groundwater
                          monitoring
11 on-site soil
 7 on-site sediment
106 on-site soil
  6 on-site sediment
  6 on-site dust
n.d.-979
n.d.-41
n.d--5.8
n.d.

n.d.-743

n.d.



n.d.-82


n.d.-382
n.d.-120
n.d.
n.d.-430
n.d.-14.4
n.d.

12.9-55.8
                                                                                             n.d.
n.d.-95
1-22
n.d.-29.0
n.d.
n.d.
Responsible party
planning removal
action.
City to continue
observation of site.
Access roads
barricaded
and area posted.
clean-up under
negotiation.
                                                                                                                                    Site
State to continue
observation of site.

RI/FS under develop-
ment.

Creek bank stabiliza-
tion and stream
reroute on-going.
RI/FS report
completed; RD/RA
underway.

Contaminated soil
paved; area is posted.
City to continue ob-
servation of site.

Site transferred to
RCRA program for
further action.

Contaminated soil
excavated; RI/FS
under development.

State to continue ob-
servation of site.
                                                                                                                                                  H
                                                                                                                                                  H
                                                                                                                                                  I
                                                                                                                                                  to

-------
                                                               SITE LISTING
                                                         NATIONAL DIOXIN STRATEGY
                                                                   2/87
Name

Cashel Residence
Community Christian Church
Denney Farm
Eai,t North Street
East Texas Motor Freight
S.B. Erwin Farm
Erxleben Property
Location

Fenton. MO
Manchester. MO
                                   Aurora, MO
Eureka. MO
St. Louis. MO
Verona. MO
                                   Glencoe. MO
Hamill Transfer Company
Jones Truck Lines
St. Louis, MO
St. Louis, MO
 No. And Kind Of
 Sample Analyzed

82 on-site soil
 3 off-site dust
134 on-site soil
  2 on-site soil
 ? on-site oil
 ? on-site soil, solids,
   solvents

107 on-site soil
 1 off-site soil
 1 on-site dust
 71 on-site soil
  4 on-site dust
 SO off-site sediment
                                                             20 on-site soil
                          129 on-site soil
                            1 on-site dust
145 on-site soil
  1 on-site sediment
  4 on-site dust

  5 on-site soil
Concentration
Range (pool

  n.d.-250
  n.d
  n.d.-230
  n.d.
                                                          up to 2,000,000
                                                          up to 2,000
  n.d.-6
  n.d.
  n.d.
  n.d.-51.8
  n.d.-1.5
  n.d.-   20
                                                          n.d.-3.3
                                n.d.-280
                                n.d.
  n.d.-155
  n.d.
  n.d.

  7.9-22.0
Response Actions

Contaminated soil
bagged and removed;
site restored.  Final
management of soil
pending.

Area paved; State to
continue observation
of site.

Site is current
location of EPA
mobile incinerator

Road was regraded
and repaved with
asphalt; State to
continue observation
of site.

Responsible parties to
implement response
action.  Sampling to
determine extent of
contamination.

Area fenced; soil ex-
cavated and removed
for incineration; site
restored.

Site posted; State to
continue observation.
Additional sampling to
define extent of
contamination to be
conducted.

None to date; city to
continue observation.
Area paved and building
decontaminated.
                                                                                                                                                H
                                                                                                                                                to
                                                                                                                                                CO

-------
                                                               SITE  tISTING
                                                         NATIONAL  DIOXIN STRATEGY
                                                                   2/87
Name

Lacy Manor Development
Manchester United Methodist
  Church

Minker Residence
Location

Cedar Hill, MO




Manchester, MO


Imperial,  MO
National Industrial Environmental  Furley,  KS
  Services (NIES)
Neosho Digester
Neosho, MO
Neosho Tank Water and              Neosho,  MO
  Wastewater Technical School
Overnite Transportation Company    St.  Louis,  MO
Piazza Road
Rosati,  MO
                           No.  And Kind Of
                           Sample Analyzed

                          102 on-site soil
                            5 on-site dust
10 on-site soil
                          41  on-site soil
                          180 on-site soil
                              Concentration
                              Range (oob)

                                n.d.-48.0
                          121  on-site soil                 n.d.-5.4
                            3  on-site dust                 n.d.

                          289  on-site soil                 n.d.-340
                           16  on-site dust                 n.d.-1.90
                           21  on-site sediment            n.d.-210
                          12 on-site monitoring well      n.d.-1.8
                             waste                        n.d.
                          39 on-site other
                                n.d.-33.0
                                n.d.-17
360
105
71
19
5
2
2
5
3
1
on-site
on-site
on-stie
on-site
on-site
on-site
on-site
on-site
on-site
on-site
soil
discrete soil
sieved
sediment
dust
pond water
pond sediment
drainage
bark
rec. vehicle
n
n
n
n
n
<
n
n
n
1
.d.-l
.d.-l
.d.-
.d.-
.d.-
1 .0
.d.-
.d.-
.d.-
.9
,800
.020
611
165
18

29
21
1.









.4

Response Actions

Portion of area
excavated, portion
paved; residence de-
contaminated.

State to continue
observation of site.

Permanent relocation
of residents; drain-
age diversion;
excavation of
contaminated soil.
Final management of
soil pending.

Landfill capped; moni-
toring wells sampled
monthly; extraction
wells installed.
Evaporation ponds fluid
treated; disposal cell
being build for
evaporation ponds
sludges.

Area fenced and posted;
ground-water monitoring
system to be installed.
Soils incinerated.

Soils excavated and
drummed; drums were
placed in bunker
on-site and were then
Incinerated off-site.

Site paved; periodic
observation.

Area barricaded and
pasted; road excavated
and paved; relocation
offered; anticipate
incineration of drummed
soil off-site.
                                                                                                                                                 H
                                                                                                                                                 H
                                                                                                                                                 I
                                                                                                                                                 to

-------
                                                               SITE LISTING
                                                         NATIONAL DIOXIN STRATEGY
                                                                   2/87
 Name

 Quail Run Mobile Home Park
Location

Gray Summit, MO
Bill Ray Farm
Roma me Creek
Verona. MO
                                   Imperial, MO
  No.  And  Kind  Of
  Sample Analyzed

 341 on-site  soil
  42 on-site  dust
 various on-site
                          251  on site sediment
                            8  on-site soil
                            2  on-site water
Concentration
Range (ppb)

  n.d.-1.650
  n.d.-ll
                                                                                             <20-160.0
                                n.d.-272
                                n.d.-50
                                n.d.
 Response Actions

 Mobile homes being
 decontaminated,  and
 contaminated soil  being
 excavated.   Site
 restoration nearing
 completion.

 Drums removed;  no
 further action
 necessary.

 Drainage diversion
 constructed at
 Minker.   Anticipate
 excavation  and  storage
 of  contaminated  soils.
Robert Rusha Farm
Saddle and Spur Riding Club
Shenandoah Stables
Sontag Road
                                   Barry County. MO
High Ridge. MO
                                   Moscow Mills.  MO
Ballwin,  MO
Southern Cross Lumber
Spring River
Hazelwood,  MO


Verona.  MO
                           8 on-site soil
91 on-site soil
19 on-site soil
 3 on-site dust
 1 on-site water
 3 on-site sediment
 2 off-site water

756 on-site soil
 53 on-site dust
  2 on-site water
  2 on-site insulation
 10 on-site sediment
                                                             11  on-3ite  soil
60 fish
13 sediment
                                                          n.d.-4.5
                                                                                             n.d.-31
  n.d.-1.750
  n.d.-110
  n.d.
  n.d.
  n.d.

  n.d.-588
  n.d.-36
  n.d
  1.0
  n.d.  -  1.4
                                n.d.-27.3
 n.d.-55 ppt.
 n.d.-12 ppt.
 Soil  to  be  excavated
 and  removed for  in-
 cineration.

 Area  covered with
 sand;  site  fenced.
 posted,  and inspected
 week 1y.

 Site  fenced  and  posted;
 RI/FS  under
 development.
Immediate removal
action approved for
excavation and
containment of
contaminated soil.  All
material will be stored
on-site.

State to continue
monitoring.

Continued fish and
sediment monitoring.

-------
                                                               SITE LISTING
                                                         NATIONAL DIOXIN STRATEGY
                                                                   2/87
Name

Stout Residence
Sullins Residence
Syntex Agribusiness

Syntex Facility
Location

Imperial, MO
                                   Fenton, MO
Verona, MO

Springfield, MO
Royal Talley Farm
Timber!ine Stables
Times Beach
Marionville,  MO
New Bloomfield,  MO
                                   Times Beach,  MO
 No. And Kind Of
 Sample Analyzed

374 on-site soil
  7 on-site dust
                          57 on-site soil
                           3 on-site water
                           2 on-site dust
                           3 on-site sediment
See Tier 1

 4 on-site sludge

 1 on-site supernatant
 1 on-site sludge
 (pretreatment)
 3 on-jite chamber water
 (pretreatment)
 1 on-site lift pump
(pretreatment)
 5 on-site pilot plant
15 on-site lagoon wells
 5 on-site monitoring wells

15 on-site soil
 24 on-site soil
  3 on-site dust
  2 on-site sediment

451 on-site soil
 90 on-site sediment
 13 on-site dust
 84 on-site water
  2 on-site storm  water
 10 on-site surface debris
 96 on-site test pit-soil
Concentration
Range (oob)

  n.d.-241
  n.d.
                                                                                             n.d.-820
                                                                                             n.d.
                                                                                             n.d.
                                                                                             n.d.
1-8


1.5






n.d - 5.9




n.d. - 16.2




n.d.-42
n.d.-53
n.d.

n.d.-1,200


n.d.-1.8


n.d -404.0
                     Response Actions

                     Restricted access,
                     area posted; reloca-
                     tion offered; soil
                     excavation under
                     evaluation.

                     Access restricted;
                     soil excavated; site
                     restored.  Final
                     management of soil
                     pending.
                                                                                                                  Sludge removal
                                                                                                                  completed.
                                                                                                                  Sludge stored in
                                                                                                                  concrete storage tank.
                                                                                                                  Sludges schedule for
                                                                                                                  incineration.
                                                                                                             M
                       Soil  excavated and
                       transported for in-
                       cineration.

                       Site  fenced and posted;
                       RI/FS under develop-
                       ment.

                       Residents relocated;
                       levee constructed;
                       town  barricaded and
                       guarded.
Monsanto Company Queeny Plant
St. Louis,  MO
 3 on-site soil
21 on-site dust
  n.d.
  n.d.-4.8
                     Buildings being decon-
                     taminated.  Final
                     clean-up anticipated
                     soon.

-------
                                                               SITE LISTING
                                                         NATIONAL DIOXIN STRATEGY
                                                                   2/87
Name.
                                   location
Superior Solvents and Chemicals    St. Louis, MO
  Company
Thompson-Hayward Chemical
  Company
Kansas City.  KS
Tier__2a.

Browning Ferris Industries (BFI)   Missouri City, MO
National Industrial Environmental  Furley, KS
  Services (NIES)

Conservation Chemical Company      Kansas City, MO
WhCL-1 ing Dlbpot>al
Amazonia, MO
                                                                      •;Vyzed
43 or, -s'te soil
 2 off-site soil
 1 on-site sediment

16 on-site soil
 1 off-site soil
 5 on-site dust
 3 on-site wipe
 1 on-site sludge
10 on-site water
 1 off-site water
                          See Tier la
                          61  on-site soil
                                                             none Lo dale
                                                                  REGION X
                                                                                                 -46
n.d.
n.d.
n.d.-3.6C
n.d
n.d.
n.d.
n.d.
                                                          n.d.
                                n.d.-29
                                                                               Response
                                                                               RI/F2 to be negotiated.
Some areas paved; dust
suppressants applied;
area fenced and posted;
processing building to
be sealed, remaining
areas to be paved,
groundwater to be
sampled.
                                                     Site tranferred to
                                                     RCRA program for
                                                     further action.
                     Site fenced; cap.
                     slurry wall. with-
                     drawal well system,
                     well water  treatment
                     system to be'installed.

                     Groundwater monitoring
                     planned.
                                                                                                                                                LO
                                                                                                                                                KJ
Tier 2

Rhone Poulunc
Portland, OR
several soil, sediment, and     n.d.
ground water
                     No further EPA action
                     necessary.  State
                     pumping treating
                     contaminated ground
                     water; continues to
                     monitor the site.

-------
                                                                SITE  LISTING
                                                          NATIONAL  DIOXIN  STRATEGY
                                                                   2/87
Name

Tier 2a

St. Johns Landfill
Alkali Lake
Resource Recovery
Western Processing Co.
                                   Location
Portland,  OR
Southeastern,  OR


Pasco,  WA





Kent, WA
Envirosafe Services of Idaho, Inc. Grandview, ID
Chemical Security Systems, Inc.    Arlington, OR
                                                              No.  And  Kind  Of
                                                              Sample Analyzed
34 samples (including
groundwater, soil/refuse,
leachate, gas)
40 on-site soil
11 on-site ground water

14 ground water and 20 soil
samples
                                                        Concentration
                                                        Range (ppbl
                                                          n.a.
                                                             various
                          various
.007-.063
n.d.

n.a.
35 on-site tank                 n.d.-7.7
several on- and off-site soil   n.d.
                                                                                             n.a.
                                                                                             n.a.
                                                     Response Actions
State responsible for
monitoring site.
Samples not tested for
TCOO due to low levels
of pesticide indicators
(silvex. 2.4D).

State owned property.
No further on-site
action necessary.
State monitors the
site.  EPA sampling
off-site drinking wells.

Contaminated materials
drummed and secured
on-site.  Liquid dioxin
dechlorinated.
Dioxin-free material
incinerated and
disposed off-site.

Ground-water sampling
conducted.

Ground-water sampling
conducted.

-------
            TABLE 2-3
01OX IN SITES ISSUED HEALTH RECOMMENDATIONS
REGION
I
II
V
VII
VII
VII
VII
VII
VII
VII
VII
VII
VII
VII
VII
VII
VII
VII
VII
VII
SITE NAME
Baird & McGuire Site
Diamond Shamrock
Nalco Chemical Co.
Arkansas Best Freight
Baldwin Park
Baxter Garden Center
Russell Bliss Farm Road
Bl iss Property
Bliss Tank Property
Bonified Brothers Trucking
Bull Moose Tube Co.
Cashel Residence
Community Christian Church
East North Street
EdSt Texas Motor Freight
S.B. Erwin Farm
Erxleben Property
Haim 11 Transfer Co.
Jones Truck Lines
Lacy Manor Development
LOCATION
Hoi brook. MA
Newark , NJ
Bedford Park, IL
St. Louis, MO
Aurora, MO
Chesterfield. MO
Rosati. MO
Ellisville. MO
Frontenac, MO
St. Louis. MO
Gerald. MO
Fenton, MO
Manchester, MO
Eureka, MO
St. Louis, MO
Lawrence County, MO
St. Louis, MO
St. Louis, MO
St. Louis, MO
Cedar Hill , MO
AGENCY
CDC
CDC
CDC
NIOSH
CDC
NIOSH
CDC
CDC
CDC
CDC
NIOSH
CDC
CDC
CDC
NIOSH
CDC
CDC
NIOSH
NIOSH
CDC
                                                          ADVISORY
                                                    Recommendations  issued  after  sampling
                                                    is finished.
                                                    Limited access until  cleanup.
                                                    Public access  restricted  until
                                                   additional
                                                    samples are analyzed.
                                                    No modifications  necessary.
                                                    Continued  monitoring,  limited access.
                                                    Normal activities may continue;
                                                    excavation requires  protective gear.
                                                    Avoid contact  with soil.
                                                    Mid America arena is  too  contaminated
                                                    for use.
                                                    Prohibited access.
                                                    Site should remain unused.
                                                    Normal activities may continue;
                                                    excavation requires  protective
                                                    gear.
                                                    Soil should not be disturbed.
                                                    Limited access to portion of
                                                    property.
                                                    Limited access.
                                                    Avoid  contact  with soil.
                                                    Incinerate dioxin wastes  above 50 ppm,
                                                    remove soil to 50 ppt.
                                                    Evacuation and prohibition of
                                                    use.
                                                    No dioxin  hazard.
                                                    No hazard  after clean-up.
                                                    Contact with soil  should  be
                                                    avoided.
i
U)

-------
                                                   OIOXIN SITES ISSUED HEALTH RECOMMENDATIONS
REGION
VII

VII

VII
VII

VII
VII
VII
VII
VII
VII
VII
VII
VII
VII

VII

VII
VII
SITE NAME
Manchester United Methodist
 Church
Minker Residence
Overnite Transportation Co.
Piazza Road

Quail Run Mobile Home Park
Romaine Creek
Robert Rusha Farm
Saddle and Spur Riding Club
Shenandoah Stables
Sontag Road
Southern Cross Lumber
Stout Residence
Sullins Residence
Royal Talley Farm

Timberline Stables

Times Beach
Superior Solvents
LOCATION
St. Louis, MO
Imperial, MO
St. Louis, MO
Rosati. MO
Gray Summit, MO
Imperial . MO
Barry County, MO
High Ridge, MO
Lincoln County, MO
Castlewood, Mo
Hazelwood, MO
Imperial, MO
Fenton, MO
McKinley, MO
Call away Co. , MO
Times Beach, MO
St. Louis, MO
AGENCY
CDC
CDC
NIOSH
CDC
CDC
CDC
CDC
CDC
CDC
CDC
CDC
CDC
CDC
CDC
CDC
CDC
NIOSH
      ADVISORY
Limited access to portion of
property.
Residents are at health risk;
relocation offered by EPA.
No dioxin hazard.
Contact with soil should be
avoided; 3 families at risk.
Contact with soil should be avoided.
Access to fill area prohibited.
Incinerate dioxin wastes above 50 ppm.
Prohibited use.
Facility should not be used.
Avoid contact with soil.
Normal activities may continue.
Residents are at health risk.
Limited access to proper;  .
Site should not be used for'
cattle grazing.
Those in contact with soil are at
health risk.
Relocation of residents.
Normal activities may continue.
H

Ul

-------
                          Chapter Three
                         TIERS 3,  5,  6,  1

     The Office of Water coordinated the collection of over  4,000
samples from 862 sites nationwide.  Regional, State and
contractor personnel collected the samples.  Sampled media
included soil, sediment, fish, water, and various plants and
animals.
     The objective was to learn more about the extent of 2,3,7,8-
TCDD contamination in the general environment.  While tiers  1 and
2 sites were investigated with an expectation, based on
experience, of finding contamination, tiers 3, 5, 6, and 7 were
investigated with no such advance expectation.  EPA defined  these
four tiers as follows:
     Tier 3 -    Formulators, blenders, and packagers of 2,4,5-
                 trichlorophenol (2,4,5-TCP)-based pesticides;
     Tier 5 -    Sites where suspected contaminated pesticides
                 were commercially applied;
     Tier 6 -    Other chemical producers with a lower potential
                 for contamination; and
     Tier 7 -    Background sites.
     As previously mentioned, the initial focus of tiers 3,  5, 6,
and 7 was on 2,3,7,8-TCDD.  The Strategy provided for testing for
other congeners where appropriate; however, at the time the study
was developed, there was a severe shortage of analytical methods,
reference materials, and laboratories capable of testing for
other congeners.   Samples and/or extracts were saved to allow
future analysis for other congeners.  Follow-on work will take
advantage of improvements in analytical capability.
     Information for this chapter was derived from the more
extensive report prepared by the Office of Water Regulations and
Standards (EPA, 1987b).

-------
                              III-2
3.1  Tier 3—Formulators
     3.1.1  Objective
     Tier 3 consisted of facilities  (and associated waste
disposal sites) where 2,4,5-TCP and  its derivatives were
formulated into pesticidal products.  Generally, these products
are herbicides, insecticides, fungicides and germicides:
             Products                         Uses
     2,4,5-Trichlorophenol           fungicide; bactericide
         (2,4,5-TCP)
     2,4,5-Trichlorophenoxyacetic    plant hormone; herbicide;
         acid  (2,4,5-T)                 defoliant
     Silvex                          herbicide; plant growth
                                        regulator
     Erbon                           herbicide
     Ronnel                          insecticide
     Hexachlorophene                 topical antiinfective
                                        (restricted); germicidal
                                        soaps; veterinary medicine
     Isobac 20                       topical antiinfective
                                      (restricted);
                                     germicidal soaps;
                                     veterinary medicine
The objective of the tier 3 sampling program was to determine the
percentage of facilities that have concentrations  of 2,3,7,8-TCDD
above 1 ppb in soil, or at any detectable level in other
environmental media  (e.g., fish in nearby streams).  The
detection limits for other media, and therefore the levels that
determine whether contamination is present, vary slightly from
site to site.
     3.1.2  Study Design
     EPA statistically selected 61 formulator sites from the
_FIFRA and T^SCA _E_nforcement System (FATES) data base.  FATES
contains the names of companies which have registered with EPA to
engage in commercial activities with designated classes of
chemicals.  Regional Offices and States selected 23 additional
sites for sampling.
     Regional Offices sent information  request letters to these
facilities to verify existing EPA records on chemicals and their

-------
                               III-3
volumes,  and  to  obtain  additional  information  on  the  types  and
quantities  of waste  generated, waste  disposal  methods,  and  the
location  of disposal  sites.   In  addition,  regional  personnel
visited the selected  sites prior to sampling to identify
potential sampling locations.  In  some  cases the  information
gathered  through these  efforts resulted in a decision not to
sample a  particular  facility, either  because the  facility did  not
actually  formulate the  compounds of interest  (13  ineligible
sites) or because site  reconnaissance revealed that the site was
not suitable  for sampling, e.g., extensive paving (7  eligible,
missing sites).   These  7 sites are considered  missing for
purposes  of statistical analysis and  are  included in  the
statistical evaluation.  Sampling was actually conducted at 41 of
the statistically selected sites, and at  all 23 of  the  regionally
selected  sites.
     At each  facility,  targeted  sampling was conducted  in areas
where contamination was considered most probable,  including
loading/unloading areas, storage areas, disposal  areas,  and storm
water drainage areas.  A random  sampling scheme was developed  for
sites or  portions of  sites where there  was  not enough information
to identify areas most  likely to be contaminated.
     3.1.3  Results
     Results of  the tier 3 investigation are portrayed  in Figure
3-1.  Soil contamination levels  greater than 1  ppb were  found  at
five of the statistically selected sites.   Five additional  sites
had soil  concentrations below 1 ppb.
     2,3,7,8-TCDD was found in soil at  a level  greater  than 1  ppb
at five regionally selected sites.   Four regional sites  had soil
levels below 1 ppb.
     When found, contamination was usually  limited, within a site
area.   At three of the five statistically selected contaminated
sites  and four of the six contaminated regionally selected  sites,
only one or two samples had soil  levels above  1 ppb.

-------
                              III-4
     2,3,7,8-TCDD was found in fish at 3 ppt at one statistically
selected site, and at levels from 1-25 ppt in fish and sediment
in a river adjacent to a regionally selected site.  Soil samples
were "non-detected" for these sites.
     The one widely contaminated statistically selected site  (13
of 14 soil samples with 2,3,7,8-TCDD at levels greater than or
equal -to 1.0 ppb) handled large quantities of 2.,4,5-T, silvex and
2,4,5-TCP.  The total amount handled was greater than 100,000
pounds.  This site was already under investigation through the
Superfund program when it was selected for this study.  The one
widely contaminated regionally selected site (16 of 26 soil and
sediment samples at levels greater than or equal to 1 ppb) also
handled 2,4,5-T and silvex, with the total amount handled greater
than 100,000 pounds.
     Based on the results of sampling at the statistically
selected sites and using the assumption that the seven missing
eligible sites are contaminated with similar frequency as the
sites that were actually sampled, it is estimated that 12±8
percent of the 312 facilities in the FATES data base may be
contaminated.  It is  important to note that this estimate is
derived simply from whether any samples at a facility had levels
greater than one part per billion.  As discussed below, the
number of positive samples at most sites was very limited.
     These estimates  do not necessarily apply to the 325
potential formulators identified from other sources.  Fewer of
these facilities are  likely to have actually engaged in
formulation activities  (e.g., registered to handle the pesticide
but  never actually did  so because of the 2,4,5-T cancellation
proceedings).
     EPA has  identified 29 facilities in the FATES data base
which handled more than 100,000 pounds of  2,4,5-T, silvex,  and/or
2,4,5-TCP.  EPA  investigated  12 of  these as part of  this  study,
and  is gathering information  on the remaining  17 to  determine if
future sampling  is needed.

-------
                               III-5
Discussion of Contaminated Sites
     During review of the sampling  results,  the  appropriateness
of EPA's soil sampling methodology  was questioned.   The  specific
issue was whether taking 4-inch core samples might  have  diluted
the  2,3,7,8-TCDD levels to such an  extent  that low  levels  in  the
surface layer might not be detected.
     EPA's work plans for soil sampling  in tiers  3-7 were
extensively peer-reviewed prior to  implementation.   Four-inch
core samples were selected because  a number  of studies had  shown
that highest levels were most likely to  be found  in subsurface
layers.
     The Seveso, Italy accident involved airborne dispersal and
deposition of contaminants.  Subsequent  investigation of the
vertical distribution of 2,3,7,8-TCDD found  that  the highest
levels were not found in the uppermost (0.5  cm)  layer, but  rather
most often in the second (0.5-1.0 cm) or third (1.0-1.5  cm)
layers (DiDomenico, et al., 1980).
     Investigation of soil concentrations  of 2,3,7,8-TCDD at
Eglin AFB after aerial application  of Herbicide Orange found  the
highest levels in the 2-4 inch layer (EPA, 1980).
     Researchers have suggested that photolysis and  other
degradative processes, volatilization, and downward  diffusion
play varying roles in the vertical  distribution of material.
     During the investigation of DOW Midland and associated
comparison sites, EPA collected a limited  number of  samples which
were surficial in nature.   The data from this effort are
presented below.  With the exception of the areas subject to  the
influence of the DOW plant, the results were comparable to those
from tiers 3-7.

-------
                                 III-6
            Surficial* Soil Sampling Conducted for the Midland,
                      Michigan Study (2,3,7,8-TCDD)
 Location
Number of
Samples
Number of
Detects
Range of
Detects
(ppt)
Range of
Detection
Limits for
Non-detects
(ppt)
 Midland—Dow Plant               15
       —Plant Perimeter           9
       —Open Areas               22
       —Downspouts               13

 Upwind of Midland—Open Areas       3
                —Downspouts       2

 Middletown, Ohio                 22

 Henry, Illinois                  13

 Minnesota Natural Areas            4
15
9
21
13
0
2
10-36,000
10-2,030
3-110
13-270
__
6-9
             6

             1

             0
             3-5

             2
             2-4


             1-3

             1-3

             1-3
 *A11 samples taken to a depth of 0.5-1 inch.
      Figures  3-1 and 3-2 and  Table 3-1 summarize site results.

 Following  is  a narrative description of contaminated sites  and

 sampling results.  2,3,7,8-TCDD was not detected at 43 of the  64
 sites which were sampled.   A  summary of sampling activities  at

 these sites is provided in  the Tiers 3,5,6,7  Report (EPA, 1987b).

 Region  II  * Farmingdale Garden Lab—Farmingdale, New York
      This  facility, located on 0.5 acres,  blended and repackaged
"silvex  from 1965 to 1978 and  erbon in 1969.   Over 90 percent of
 the site  is covered by a building and pavement.

      Twenty-five random soil  samples were  collected from a  10  by
 75 ft gravel  area at the rear of the processing  building.   One  of
 these samples contained 2,3,7,8-TCDD at 17.6  ppb.

      This  site has been referred to Superfund and will be
 resampled  under that program.
 * Statistically selected  site.

-------
                              III-7
Region II * Rockland Chemical Co., Inc. - West Caldwell, NJ
     This facility, located on approximately 1.8 acres,
formulated products containing silvex from 1961 to  1979 and
products containing 2,4,5-T until 1976.  There are  currently five
underground storage tanks on-site which are used for storing
solvents.  A septic tank was used for disposal of process waste
and sanitary wastewater before the plant connected  to a treatment
facility.

     Ten soil samples were collected along the perimeter of
former and current loading docks where runoff from  on-site
loading and storage areas would collect.  The one sample
containing 2,3,7,8-TCDD (1.32 ppb) was collected down-gradient
from the current loading dock area.

     Additional sampling at the site indicated levels of 2,3,7,8-
TCDD below 1 ppb at several storage and loading areas.  The New
Jersey Department of Environmental Protection is discussing
possible remedial actions with the facility.

Region III  R.H. Bogle Company—Alexandria, Virginia
     This facility, located on five acres, distributed 2,4,5-T
and silvex from 1954 to 1979.  These herbicides were stored on-
site and loaded into railroad sprayer cars for application to
railroad rights-of-way.  In 1978, most of the site  was clay-
capped to contain arsenic contamination.  Residential townhouses,
office buildings, and asphalt parking lots now cover the site.

     As the site has been changed substantially in  recent years,
40 soil samples were collected at 17 locations that had received
runoff from the site prior to capping.  No 2,3,7,8-TCDD was
detected in any of these samples.  However, five of the nine
sediment samples taken from the Oronoco Bay and the Potomac
Estuary, which border the site, contained 2,3,7,8-TCDD at levels
of 5.5-23 ppt.  Seven of the eight fish collected from the
Potomac Estuary within 2 miles north of the site contained
2,3,7,8-TCDD at levels of 1.6-6.3 ppt.  Since the samples
containing 2,3,7,8-TCDD were collected off the site, there is no
conclusive evidence that the contamination came from the Bogle
facility.

     The Centers for Disease Control concluded that no further
sediment and fish sampling for 2,3,7,8-TCDD is required.  EPA
Region III is evaluating the impact that dredging may have on the
bioavailability of 2,3,7,8-TCDD in the Potomac Estuary.

Region III * Holder Chemical Company—Ona, West Virginia
     This facility, located on 2.5 acres, used a number of
insecticides and herbicides, including 2,4,5-T, in  formulating
products.  The years when 2,4,5-T was used in formulation are
unknown.  Based on a 1982 site evaluation, approximately 280 tons
of contaminated topsoil containing malathion, chlordane, sevin,
DDT,  dieldrin, heptachlor, lindane, kepone, and 2,4-D were
removed from the site (no dioxin analyses were performed).

-------
                              III-8
     Thirty-six soil samples were collected:  31 from locations
surrounding the main building, and 5 from the wooded area
bordering the site.  No 2,3,7,8-TCDD was detected in any of these
samples or in the five sediment samples and a clam sample
collected from the nearby Mud River.  However, all three fish
samples collected from this river 0.5 miles downstream from the
site contained 2,3,7,8-TCDD at levels between 0.5 and 2.9 ppt.
There is no conclusive evidence that the contamination came from
the Holder facility.

     No followup action is planned for this site.

Region III  Smith Douglas (Borden)—Norfolk, Virginia
     This facility, located on 35 acres, formulated products
using silvex.  The formulation activity took place in two
buildings.

     Fifty-three soil samples were collected:  15 from around the
storage building, 14 around the formulation building, 5 from
ditches at the perimeter of the property, and 19 at various other
locations around the site.  Ten dust samples were also collected
from the storage building and from the formulation building.  A
sample of trash from the formulation area was also analyzed.  The
one soil sample containing 2,3,7,8-TCDD (10.1 ppb) was collected
along a driveway leading to the building where silvex was
formulated.  No 2,3,7,8-TCDD was detected in the dust or trash
samples.

     Intensive followup sampling under the Superfund program was
conducted around the formulation building.  The location of
2,3,7,8-TCDD contamination was confirmed, with no additional
contaminated locations being identified.  The company has agreed
to excavate the contaminated soil and dispose of it along with
the formulation equipment in a manner acceptable to EPA.

Region IV - Chem Spray—Belle Glade, Florida
     This facility, located on two acres, formulated products
using large amounts (more than 100,000 pounds) of 2,4,5-T from
1967 to 1977.  A residue pile is adjacent to a formulation
building.  In addition, canals border two sides of the site.
     Nineteen soil samples were collected:  2 from the residue
pile, 4 from outside the formulation building, 2 from between the
formulation building and a second building, and 3 from around
this second building.  Eight random samples were also taken
between the two buildings.  The two soil samples containing
2,3,7,8-TCDD (0.2 and 3.0 ppb) were both collected outside the
second building.  Seven sediment samples were also collected from
canals.  All contained 2,3,7,8-TCDD at levels between 20.9 and
515 ppt.

     Additional sampling and analysis confirmed the isolated
nature of the 2,3,7,8-TCDD contamination.  The facility has
secured the contaminated area.  EPA is currently pursuing
alternatives for disposal.

-------
                              III-9
Region IV  * Security Chem (Woolfolk Chem)—Fort Valley, Georgia
     This facility, located on 22 acres, repackaged and stored
silvex from 1978 to 1979, in a general warehouse which housed a
loading dock.
     Seventeen soil samples were collected:  three from around
and underneath the warehouse (the building is on raised blocks),
three along the street where silvex was transported, five around
another site building, five from various other site locations,
and one from a drainage ditch.  The soil sample containing
2,3,7,8-TCDD (23 ppb) was collected from underneath the warehouse
where 55 gallon drums were stored.  A field duplicate for the
same sample contained 40 ppb.  It appears that the contamination
was due to spillage.  The drainage ditch sample also contained
2,3,7,8-TCDD at 36.7 ppt.
     Security Chemical, as the responsible party, and the Georgia
Environmental Protection Division conducted a comprehensive
sampling survey of the entire facility, confirming the isolated
nature of the contamination.  Appropriate measures have been
taken to secure these areas.  EPA is currently pursuing
alternatives for disposal.

Region V * ETM Enterprises (Parsons Chemical Works, Inc.)
           Grand Ledge, Michigan
     The facility, located on approximately five acres,
formulated products using 2,4,5-T and ronnel for an unknown
number of years, although the mixing, manufacturing, and
packaging of agricultural chemicals at the site generally
occurred from 1945-1979.  Several areas of this site had
previously been found contaminated with other pollutants, and
some excavation of contaminated soil has taken place.

     Twenty-one soil samples were collected:  7 from a storm-
water drainage ditch, 2 from an area where a septic system had
been removed as a result of previous sampling, 2 at the storm
drain pipe (1 at the inlet and 1 at the open catch basin), 4 off
the southwest corner of the building where previous sampling had
indicated other pollutant contamination (no previous 2,3,7,8-TCDD
analyses), 1 from just outside the parking lot, 4 along the south
side of the building near the loading dock in a low area  (under
downspouts), and 1 near the mid-north side of the building along
the roof drain line.  The two samples containing 2,3,7,8-TCDD
(0.56 and 1.13 ppb) were collected at two depths at the location
where storm water from the storm drain pipe discharges into the
drainage ditch.
     Additional samples, collected and analyzed at lower  levels
of detection, contained 2,3,7,8-TCDD in sediments from a  nearby
stream and the Grand River, at levels of 9 and 15 ppt; soils on-
site had levels between 0.005 and 0.246 ppb.
  r" denotes a statistically selected site.

-------
                              111-10
     The State of Michigan has fenced, covered and paved the
drain outlet.  A septic tank and surrounding soils have been
removed.  Plant floor drains have been closed.  Additional
remedial measures are being discussed by the company and the
State.

Region V  Nalco Chemical Company—Bedford Park, Illinois
     This facility, located on approximately 21 acres, used large
amounts of sodium 2,4,5-trichlorophenate (approximately 100,000
pounds) and 2,4,5-TCP (approximately 8,500,000 pounds).  The
2,4,5-TCP was reported by one of Nalco's suppliers to contain a
maximum of 0.098 ppm 2,3,7,8-TCDD.  Formulation wastes were
disposed of off-site with other soil waste from the plant, or
with plant waste water which went to the sanitary sewers after
treatment (removal of oils and solids).  The sludge was
temporarily stored on-site and then disposed of off-site in a
landfill.  Products not meeting specifications were stored on-
site in 55-gallon drums and then disposed of off-site in a
landfill.

     This site is extensively paved.  Ten soil samples were
initially collected:  7 from loading docks, and 1 sample each
from outside a warehouse, a processing building, and a storage
building.  These three samples were in areas of expected roof
drainage.  The two samples containing 2,3,7,8-TCDD (1.9 and 2.2
ppb) were collected at two of the loading docks, one at the drum
rinsing operation location and the other at a processing
location.  Significant levels of other dioxin isomers were also
found in one of those samples.
     Additional sampling in areas adjacent to previously
identified contamination and areas of expected drainage indicated
the presence of 2,3,7,8-TCDD ranging from 0.24 to 5.2 ppb in all
samples; significant levels of other dioxin and furan homologues
were also found.  Contaminated areas have been covered with
plastic and gravel.
     EPA issued a unilateral 106 Order under CERCLA to Nalco to
investigate the extent of contamination and to take appropriate
steps to prevent migration.

Region V  * Riverdale Chemical Company—Chicago Heights, Illinois
     This site formulated products using silvex, 2,4,5-T and
2,4,5-TCP, and had already been scheduled for investigation under
the Superfund program prior to its statistical selection for this
study.  The sampling approach used at the site by the Superfund
program was slightly different than those used at the other tier
3 sites.

     Fifteen soil samples were initially collected by gridding
and sampling all the open areas.  Areas covered by gravel or
pallets were not sampled.  Widespread 2,3,7,8-TCDD contamination
was found on-site; 13 of the 14 soil samples collected contained
2,3,7,8-TCDD at concentrations ranging from 1.1 to 364 ppb.

-------
                              III-ll
     Two Consent Orders are being implemented by the Riverdale
Chemical Company.  The first involved covering the area where
2,3,7,8-TCDD was detected with tarp or gravel.  The second
requires Riverdale to conduct a remedial investigation/feasibility
study of the site and its surrounding areas to determine the
extent of contamination.  This information will be used to
develop further appropriate remedial action.

Region VII  Union Carbide Agricultural Products Company Inc.
            (formerly Amchem Product Co.)—Saint Joseph, Missouri
     This facility was owned by Amchem Product Co. when it
formulated products containing 2,4,5-T and silvex.  More than
100,000 pounds of these compounds were used in formulation from
about 1957 until about 1978.  Union Carbide purchased the
facility from Amchem Products in 1978.  This site is about seven
acres, with about five acres of open fields.

     Twenty-six soil samples were collected at this site:  4 from
the railroad loading area, 4 from around a storage tank of
2,4,5-T, 8 from a bare spot where a spill may have occurred, and
10 from a drainage ditch that receives runoff from on-site
loading and unloading areas.  Valid analytical results were
obtained for 25 of the 26 samples (questionable results were
obtained from one of the drainage ditch samples).  Of the 25
samples, detectable levels of 2,3,7,8-TCDD of 0.13-39.1 ppb were
found in 23; values greater than 1 ppb were detected in 16.  The
highest concentrations were observed in soils taken from the bare
spot.
     After being notified of the results from the sampling, Union
Carbide voluntarily installed a fence around the entire site in
order to limit unauthorized access.  The Superfund program
requested Union Carbide to evaluate pollution abatement
options.  Additional samples were collected by EPA to determine
the extent of pollution more accurately.  Further cleanup
negotiations are on hold pending review of analytical results
from the additional sampling.

Region IX  Magna Corp.—Sante Fe Springs, California
     This facility, located on two acres, blended large amounts
of 2,4,5-TCP (greater than 100,000 pounds) into products from
1961 to 1978.
     Ten soil samples were collected along the perimeter of this
facility where drainage would collect.  The one sample containing
2,3,7,8-TCDD (2.0 ppb) was collected downgradient from the 2,4,5-
TCP mixing area.
     EPA issued an immediate removal order under Superfund.  The
company drummed all contaminated soil, sediment, and debris and
conducted additional sampling in an off-site drainage ditch.

     3.1.4  Findings
     o   Assuming that the 7 unsampled sites have the same

         frequency of contamination as sampled sites, EPA

-------
                              111-12


         estimates that approximately 12 percent of the tier 3
         facilities identified in the FATES data base would be
         found contaminated.
     o   At contaminated sites, the extent of contamination was
         usually limited to one or two soil samples with
         concentrations of 2,3,7,8-TCDD above 1 ppb.  Only two
         tier 3 sites were extensively contaminated.
     o   All 12 contaminated sites were at or near facilities
         that handled 2,4,5-TCP, 2,4,5-T, and/or silvex.
     o   The two extensively contaminated facilities were both
         large handlers of 2,4,5-T, 2,4,5-TCP and/or silvex.
     3.1.5  Conclusions
     o  Based on the limited number of sites found to be
        contaminated, the small number of positive samples at
        most of these sites,  and the generally low levels of
        2,3,7,8-TCDD detected, immediate national investigation
        of all of the remaining Tier 3 formulator facilities does
        not appear to be warranted.
     o  In addition to the facilities referred to Superfund for
        more immediate followup, the names of the remaining
        facilities have been transmitted to the Regional Offices
        with the request that they be added to CERCLIS, the
        Superfund facility list, for future Superfund attention.
     o  Since the two extensively contaminated facilities were
        both large handlers of 2,4,5-T, silvex, and/or 2,4,5-TCP,
        further evaluation of other large handlers of these three
        compounds is warranted.  EPA sampled 12 of the 29 large
        handlers of these compounds as part of the study, and is
        collecting information on the remaining 17 facilities.

3.2  Tier 5—Use Sites
     3.2.1  Objective
     Tier 5 sites are areas where 2,4,5-TCP and pesticide
derivatives (including 2,4,5-T and silvex) were used on a

-------
H
H
H

H
OJ

-------
                                111-14
    50 --
    40 -J
o
f-
    Tr>
    30 —
    20 -
    10 -
                            Figure 3-2
                         TIER 3 RESULTS
         45
ND   <1   10
    d.e.f.g.h.i
                              20
30
 ft
40
                                                  *-+#
50 200 400
                                             b.j
                  Levels of Soil Contamination (ppb)
                      (Maximum Value at Site)
                       * POSITIVE/* SAMPLES
       Randomly Selected I     I      Regional Selection Yf'*\
a)
b)
c)
d)
e)
—Ml,, — y •
1/25 (
2/16 (
13/14 <
2/20 <
1/10 i
P 17.6
? 23-40
? 1.1-364
£ .56-1.13
£ 1.3
f)
g>
h)
i)
j)
1/53
2/19
1/10
2/10
23/26
——————— MH
9 10. 1
e 1.9-3.2
e 2.0
e 1.9-2.2
e. 13-39.1

-------
                              111-15
commercial basis.  A statistical sampling of this tier was not
possible due to the variety of uses and conditions.  The
objective was to determine whether 2,3,7,,8-TCDD is present at
detectable levels (approximately 1 ppt) in areas where major uses
of these pesticides had occurred.
     Tier 5 sampling was generally limited to those areas where
the use of 2,4,5-T or silvex has been documented, since
information from the Office of Pesticide Programs indicated that
these two compounds have been more heavily used in specific areas
and thus have a greater potential for causing significant human
exposure to dioxin.  The other compounds were of lesser interest
due to:  (1) low levels of active ingredient pesticide in the
end-products; (2) use on very small areas; or (3) a wide
diversity of uses at low levels of application.  Lack of
documentation of usage also made it impractical to focus on these
other compounds.
     3.2.2  Study Design
     To identify applicable sites, the Office of Pesticide
Programs compiled general information on areas of use for the
pesticides of interest.  EPA Regional Offices, in conjunction
with state or local agencies, then identified the specific sites
to be sampled.
     A total of 26 tier 5 sites were sampled, including six
forest sites, seven rice fields, three surgarcane fields, three
rights-of-way, three rangeland areas, and four aquatic sites
(used for recreation, fisheries, or multiple uses).
     A random sampling approach was generally used to select the
sampling locations at tier 5 sites.  This approach assumed that
"hot spots" could not be identified within a pesticide use site,
and that the 2,3,7,8-TCDD is either uniformly or randomly
distributed within the site.  In a few cases, locations such as
equipment loading areas or drainage ditches were targeted for
sampling, since 2,3,7,8-TCDD contamination, if present, was
expected to be higher in these areas.

-------
                              111-16
     The environmental media to be sampled were determined by the
Regional Offices on a site-by-site basis.  These included soils,
stream sediments, fish tissue, vegetation, and animal tissue.
All analyses were done at detection levels of approximately 1
ppt, because soil concentrations below 1 ppb can be of concern in
certain types of areas, such as grazing lands.
     3.2.3  Results
     2,3,7,8-TCDD has been detected at 15 of the 26 sites
including 2 rights-of-way, 1 aquatic use site, 2 sugarcane
fields, canals adjacent to 1 sugarcane field, 4 rice fields, 3
forest areas, 1 rangeland area, and 1 multiple use area.  More
than 40 percent of the soil and sediment samples taken at
contaminated sites had 2,3,7,8-TCDD present above the detection
limit of approximately one ppt.  Two sites had detectable levels
in fish.  At one of these, all fish samples were contaminated at
levels up to 23 ppt in filets.  2,3,7,8-TCDD levels in soils at
contaminated sites were between 0.6 and 6623 ppt with 67 percent
below 5 ppt; levels in sediments were between 0.7 and 200 ppt
with 61 percent below 5 ppt; and levels in fish filets were
between 8 and 23 ppt.  No 2,3,7,8-TCDD was detected in animal
tissue or vegetation samples collected from land used for grazing
or raising crops? however, only a limited number of these samples
were collected.
     CDC has indicated that 2,3,7,8-TCDD soil levels as low as
6.2 ppt may be of concern where dairy cattle graze.  Levels of
potential concern for soil where beef cattle graze range from 20
to 79 ppt.  With the exception of the Tonto National Forest
discussed below, grazing did not occur and/or levels detected
were below the values suggested by CDC.
Discussion of Contaminated Sites
     Figure 3-3 and Tables 3-2 and 3-3 summarize tier  5 site
results.  Following is a narrative description of the  15
contaminated sites.  A summary of sampling results for the  11
sites where 2,3,7,8-TCDD was not detected may be found in the
Tiers 3,5,6,7 Report.

-------
                              111-17
Region I  Grindstone, Maine
     In 1977, approximately 1,000 acres of railroad yards and
railroad rights-of-way were sprayed with a herbicide containing
2,4,5-T.  A 16-foot area, 8 feet to each side of the centerline
of the tracks, received the herbicide directly; an estimated 2
feet beyond this area on each side received the herbicide from
aerial drift.  An 1,800-foot long section of this right-of-way
was sampled.
     Twenty-two soil samples were collected approximately 2 feet
from the ends of the rail ties.  Eighteen of the 22 samples
contained 2,3,7,8-TCDD at levels ranging from 8 to 35 ppt.

     No additional action is planned at this time.  The low ppt
level contamination found is in the ballast or subgrade areas of
an active railroad, and thus presents minimal risk.

Region II  Long Island Railroad, New York
     This railroad right-of-way was treated with 2,4,5-TCP based
herbicides during the 1970's.
     A 480-foot long section along the tracks was sampled.
Twenty-six samples were collected 13 feet from each end of the
tracks.  One sample contained 2,3,7,8-TCDD at a level of 9 ppt.

     No additional action is planned.

Region IV  Cleveland, Mississippi
     This ricefield was treated with 2,4,5-T in 1978, 1981, and
1984.
     Twenty random soil samples were collected from a recently
harvested field (60-100 acres).  Sixteen samples contained levels
of 2,3,7,8-TCDD at levels ranging from 0.8 to 1.7 ppt.

     No additional action is planned.

Region IV  Scot, Mississippi
     This ricefield was treated with 2,4,5-T in 1984.
     Twenty random soil samples were collected from a recently
harvested field (60-100 acres).  Two samples contained  2,3,7,8-
TCDD at levels of 0.6 and 0.7 ppt.  No 2,3,7,8-TCDD was detected
in the one rice sample.
     No additional action is planned.

Region IV  West Palm Beach, Florida
     These sugarcane fields were treated with silvex for weed
control around the perimeter of the fields.
     Sampling was not permitted directly on the sugarcane fields
so sediment samples were collected from canals adjacent to the
fields.  Twenty-seven of 36 collected sediment samples  contained
2,3,7,8-TCDD at levels ranging from 0.7 to 26.5 ppt.
     EPA has notified the Florida Pesticide Enforcement Division
of Inspection, Department of Agriculture and Commerce Services of
the results.

-------
                              111-18
Region V  Petenwell Flowage, Wisconsin
     This 23,000-acre reservoir on the Wisconsin River supported
a major commercial carp fishery until 1983 when 2,3,7,8-TCDD was
detected in carp at levels above 50 ppt.  Chlorophenol-based
slimicides, reportedly containing 2,3,7,8-TCDD as a contaminant,
had previously been used by several pulp and paper mills along
the river.  Use of these slimicides had been voluntarily stopped
by the mills by 1980.

     Whole fish and filets from several species, fatty tissue
from raccoons, aquatic bird tissue and eggs, aquatic sediments,
and sludges from the paper mills were sampled.  An information
request was directed to each of the facilities in order to
acquire more detail regarding past slimicide usage and sludge
disposal practices.
     All sampled fish contained 2,3,7,8-TCDD, with levels of 9-47
ppt in the whole fish and 3-23 ppt in the filets.  Aquatic
sediments at both ends of the reservoir contained 2,3,7,8-TCDD at
levels from 35-200 ppt.  Two of the paper mills are still
producing sludges with 2,3,7,8-TCDD levels over 100 ppt, even
though chlorophenol-based slimicides are no longer used.  The
chlorine-bleaching process has been identified as a potential
source of 2,3,7,8-TCDD.

     As a result of these findings additional work is being
conducted at this site, with particular interest in determining
the cause of 2,3,7,8-TCDD sludge contamination and environmental
conditions at and near the sludge disposal sites.  The industry
has begun followup studies under State direction.

Region VI  Assumption, Louisiana
     This 2,500 acre site, used for growing sugarcane, was
treated with silvex in 1983.  Twenty-four soil samples were
randomly collected from eight acres.  Fourteen samples contained
2,3,7,8-TCDD at levels between 0.3 and 1.1 ppt.

     No additional action is planned.

Region VI  Desha County, Arkansas
     This experimental agricultural station specializes in rice
reproduction, with soybeans grown in rotation.  Two 20-acre
fields at this site were aerially sprayed with 2,4,5-T.  One
field was treated with 2,4,5-T in 1972, 1974, and 1975; the other
was treated in 1975 only.

     Forty-six soil samples were randomly collected from the 2
fields and associated drainage ditches.  One sample from the
field that had been treated three times contained 2,3,7,8-TCDD at
3 ppt.  No 2,3,7,8-TCDD was detected in the five plant tissue
samples or the three drainage ditch samples.

     No additional action is planned.

Region VI  Richland Parish, Louisiana
     Approximately 70 acres of this ricefield were treated with
2,4,5-T, with one application in 1982 and two applications in

-------
                              111-19
1983.  Thirty-five samples and 1 sediment sample were randomly
collected; 2,3,7,8-TCDD was detected in 9 soil samples at levels
between 0.3 and 0.4 ppt.  No 2,3,7,8-TCDD was detected in the
sediment sample.
     No additional action is planned.

Region VI  Pointe Coupee Parish, Louisiana
     This site, used for growing sugarcane prior to 1985 and
soybeans in 1985, was treated with silvex in 1983.

     Twenty-five soil samples were randomly collected from two
fields, 2.6 acres and 2.7 acres in area.  Twenty samples
contained 2,3,7,8-TCDD at levels ranging from 1.0 to 2.5 ppt.

     No additional action is planned.

Region VI  Rio Grande Plain Experimental Ranch, Kinney Co.,
           Texas
     This site is an experimental ranch used for research on
brush control and livestock production.  In 1981, parts of three
experimental pastures (five acres each) were aerially sprayed
with 2,4,5-T.  Parts of each were left untreated as controls.

     Thirty-eight soil samples were randomly collected from the
three pastures among the treated and untreated areas.  Twelve
samples contained 2,3,7,8-TCDD—5 samples from treated areas and
7 samples from untreated areas—at levels between 0.2 and 3 ppt.
No 2,3,7,8-TCDD was detected in a rattlesnake or in six
vegetation samples collected from the sprayed pastures.

     No additional action is planned.

Region VII  Mark Twain National Forest, Missouri
     The herbicide 2,4,5-T was applied in 1977 to 3 sites
totaling approximately 95 acres within the forest, to facilitate
the relief of shortleaf pines from competing hardwoods.  A
tractor drawn, high-volume ground spray tanker unit was used to
apply the herbicide.
     A total of 50 soil samples were collected from 2 sub-areas
at one of the 3 treated sites.  These areas were located at the
bottom of slopes, where herbicide runoff would tend to
accumulate.  Twenty-one of 50 soil samples contained 2,3,7,8-TCDD
at levels between 0.3 and 120 ppt.
     No additional action is planned at this time.  The
contamination is within a forest area, not used for grazing.

Region IX  Tonto National Forest, Arizona
     Between 1965 and 1969, 2,4,5-T, 2,4-D, and silvex were
sprayed over more than 2,500 acres in the Globe Ranger
District.  This spraying project was designed to improve
rangeland and to increase water runoff, resulting in increased
water yields for downstream users.

     Soil samples were collected from three helicopter landing
areas used as herbicide mixing-loading areas and from five other

-------
                              111-20
locations within the sprayed area.  Whole animals and animal
tissues were also collected within the sprayed areas.  Twenty-
four of 77 soil samples had 2,3,7,8-TCDD at levels of 2 to 564
ppt.  Soil contamination was found at two of the three mixing-
loading areas.  (The mixing-loading area where no 2,3,7,8-TCDD
was found was later determined not to have been used for that
purpose.)  2,3,7,8-TCDD was detected a short distance beyond the
boundaries of the actual mixing/loading locations, but no
2,3,7,8-TCDD was detected at the other five locations.  No
2,3,7,8-TCDD was detected in any of the animal samples.

     Forty-five additional samples, which included soil and fish,
were collected from 3 additional and 1 previously sampled
mixing/loading area.  Twenty-one soil samples contained 2,3,7,8-
TCDD at levels from 0.4 to 6623 ppt.  Four samples had levels
greater than 1,000 ppt.  No 2,3,7,8-TCDD was detected in the fish
collected.

     The U.S. Forest Service has restricted access to the
contaminated heli-pads.  EPA Region IX is reviewing alternative
treatment technologies, focusing on in situ treatment.  The
Forest Service has indicated willingness to sponsor a pilot
project.

Region IX  Santa Ana River, California
     The Santa Ana River Basin includes agricultural, industrial,
and residential areas.

     Twenty-eight sediment samples were collected from stations
along the Santa Ana River and a few of its tributaries.  These
locations have been routinely monitored for conventional and
priority pollutants.  Fish samples were collected at eight of the
sediment stations where water flow was sufficient to support
fish.  One sediment sample had 2,3,7,8-TCDD at 0.6 ppt; one of
the seven whole fish had 2,3,7,8-TCDD at 4.6 ppt.

Region X  Santiam Forest, Gates, Oregon
     A 75-acre area of this forest site was aerially sprayed with
a herbicide containing 2,4-D and 2,4,5-T in 1976 and 1977.

     Twelve sediment samples were collected from a stream that
runs through the sprayed area, from an area where this stream
empties into the North Santiam River, and from an area of the
North Santiam River near the confluence with the stream.  Thirty-
five soil samples were collected from a wetlands area south of
the sprayed area, a heliport used by helicopters that sprayed the
area, and the heliport drainage area.  One fish sample was
collected from the North Santiam River sampling area.  2,3,7,8-
TCDD was detected in 3 of 12 sediment samples at levels of 0.2
and 0.4 ppt.  No 2,3,7,8-TCDD was detected in the 35 soil samples
analyzed or the 1 fish sample.

     3.2.4  Findings

     o  Contamination was found at a variety of the pesticide use

        sites where 2,4,5-T, silvex, and 2,4,5-TCP based pesti-

-------
                             111-21


        cides were used and in  various media (soil, sediment, and
        fish); however, the levels found were generally very low.
     o  The highest levels for  each media were generally found
        where sampling was targeted for specific areas most
        likely to be contaminated (areas used for equipment
        loading, areas where contaminants would tend to
        accumulate).
     o  Levels were much lower, in most cases not detected, for
        samples in areas where  the pesticides were uniformly
        applied (spray areas).
     o  2,3,7,8-TCDD was more frequently detected and was
        occasionally at higher  levels at tier 5 sites than at
        background sites (tier  7).
     o  Two of the seven sites  where fish were collected had
        detectable levels of 2,3,7,8-TCDD; whole fish were
        contaminated with levels up to 47 ppt (Petenwell
        Flowage).
     3.2.5  Conclusions
     o  With the exception of helicopter loading areas in the
        Tonto National Forest,  the levels found of tier 5 sites
        where spraying of pesticides occurred were generally low
        and of no concern.  Further national investigation of
        tier 5 spray areas does not appear to be warranted.
     o  The source of 2,3,7,8-TCDD at the one significantly
        contaminated tier 5 site  (Petenwell Flowage) may not be
        related to pesticide use.  As described in greater detail
        under the tier 7 discussion, further investigations of
        certain types of pulp and paper mills using the chlorine
        bleaching process are being conducted.

3.3  Tier 6 - 'Other' Chemical  Manufacturers
     3.3.1  Objective
     Tier 6 consists of organic chemical and pesticide
manufacturing facilities where  improper quality control on

-------
111-22
                                                       CO
                                                       UJ


                                                       55

                                                       m

                                                       c
                                                       UJ
                                                      Q
                                                      UJ
                                                       CO
                                                       o

                                                       CO

                                                       O


                                                       O
                                                       o
                                                       UJ
                                                       QC


                                                       O

-------
                              111-23
production processes could have caused products or waste streams
to become contaminated with 2,3,7,8-TCDD.  Facilities producing
any of sixty compounds were identified.  The objective of the
sampling for this tier was to determine the percentage of
facilities with concentrations of 2,3,7,8-TCDD above 1 ppb in
soil or at detectable levels in other environmental media (e.g.,
fish in nearby streams).
     3.3.2  Study Design
     EPA identified 67 facilities which manufacture 1 or more of
the 60 compounds of interest.  Information to identify these
facilities was obtained from the SRI Directory of Chemical
Producers (1977-1983), FATES data base, Dioxins (EPA, 1980), and
EPA Regional Office staff suggestions.
     Twenty-five sites were statistically selected for
sampling.  EPA Regional Offices identified three additional
facilities of particular interest, based on either known
activities or previous contamination incidents at these
facilities.
     The approach to sampling tier 6 sites was identical to that
described for tier  3.  Of the 25 statistically selected sites,  10
were considered ineligible because further information revealed
that no tier 6 compounds which could cause 2,3,7,8-TCDD to be
formed were actually produced at these  sites.
     3.3.3  Results
     Contamination  (soil concentration greater  than or equal  to  1
ppb or detectable levels in other media) was found at 2 of  the 15
statistically selected sampled sites and at 1 of  the 3 regionally
selected sites.
     At all three contaminated sites, soil contamination was
limited to one or two samples.  At the regionally selected
contaminated site,  groundwater contamination was  also found at
the 0.07 to 0.10 ppt level in three samples.  The groundwater at
this site is not used as a drinking water source.

-------
                              111-24



     Soil concentrations below  1 ppb were detected at  two

additional statistically selected sites and  at one additional
regionally selected site.

Discussion of Contaminated Sites

     Figure 3-4 and Table 3-4 summarize tier  6 results.

Following is a narrative description of contaminated sites and

sampling results.  2,3,7,8-TCDD was not detected at 12 of the 18

sites which were sampled.  A summary of sampling at these sites

is provided in the Tiers 3,5,6,7 Report.

Region II  * W.A. Cleary - Somerset, New Jersey
     This facility, located on  137 acres, produced mecoprop and
2,4-D salts from 1977 to 1983.  During this time an estimated
10,000 gallons per year of liquid waste were  discharged to an on-
site lagoon.

     Thirty-one soil samples were collected:  21 at the areas
around the production buildings and the lagoon and 10  random
samples from the remainder of the property which includes a
densely wooded area and the company's golf course.  One soil
sample collected near a production building  (below a loading
dock) contained 2,3,7,8-TCDD at 34.7 ppb.  2,3,7,8-TCDD was not
detected in a sediment sample collected from  the lagoon.

     This site has been referred to the Superfund program for
further sampling.

Region VI  * Chemall, Inc. (formerly Riverside Chemical Company)
               —Port Neches, Texas
     This facility is located on 14.19 acres  with the
manufacturing facility situated on 11.9 fenced acres within the
tract.  A former operator of the facility produced penta-
chlorophenol (PCP) at this site prior to the  facility's purchase
by Chemall, Inc. in 1978.  In addition, a number of organic
chemicals, including 2,4,5-T (a tier 3 chemical) and 2,4-D and
parathion (both tier 6 chemicals), have been  stored at this
site.  As a result of a 1976 Texas Water Quality Board Enforcement
Order, the former owner removed soils contaminated with PCP and
toxaphene and covered areas around the processing facilities,
warehouse, office and railroad spur with approximately one to two
feet of crushed limestone.

     Thirty-two soil samples were collected from drainage ditches,
including those from the former PCP process and storage area, and
from areas near unloading and storage areas.  Many of these
samples were taken from beneath pools of standing water; about
  Denotes statistically selected site.

-------
                              ni-25
half were taken outside the fenced area.  2,3,7,8-TCDD was
detected in nine samples, with two samples containing greater  than
1 ppb  (1.1 ppb & 1.4 ppb).  These two samples were collected from
the tank car unloading area and the drainage ditches from behind
the central warehouse, where 2,4,5-T, 2,4-D, parathion and other
chemicals were stored.  The runoff area from the former PCP
process and storage area contained 2,3,7,8-TCDD at levels below 1
ppb.

     The Texas Water Commission (TWC) currently has Chemall under
an enforcement action to undertake remedial action relating to
contamination found on-site and in adjacent ditches.  All areas
where  2,3,7,8-TCDD was detected will be addressed in the TWC's
enforcement action.  The TWC will coordinate with EPA Region VI to
assure compliance with EPA's dioxin regulations.

Region IX  BMI Complex - Henderson, Nevada
     This industrial complex covers more than 350 acres and
includes the Stauffer Chemical Company and the Montrose Chemical
Corporation.

     The Stauffer facility produced lindane from 1948 to 1956,
ethyl  and methyl parathion intermittently since 1958, and
carbophenothion.  Alpha and beta BHC were produced as waste
products from the production of lindane.  The waste BHC was
disposed of in a surface pile, which was capped with a 1-foot
layer  of clay in 1978-1979.  Prior to 1974, aqueous wastes from
the production of carbophenothion were disposed of in on-site
leach  beds, and drums containing still bottoms from the
carbophenothion process were buried on-site.  Both areas have  been
capped with a 1-foot clay layer.  After 1974, carbophenothion
wastes were disposed of in on-site lined ponds or in an off-site
landfill.

     Montrose Chemical produced chlorobenzenes at this site from
1947 to 1983.  From 1947 to 1976, polychlorinated benzene wastes
(still bottoms) were disposed of in the on-site BMI dump.  From
1976 to 1983, the polychlorinated benzene wastes were disposed of
in a lined pond.  In 1980, the still bottoms from this pond were
transferred to a storage tank.

     Thirty-seven soil samples were collected from chemical
production, storage and loading areas, associated drainage areas,
and from areas adjacent to former waste disposal locations.
2,3,7,8-TCDD was detected at 1 ppb in one soil sample, taken down-
gradient from the chlorobenzene still bottom disposal area.  Seven
ground water samples were also collected from Stauffer's ground-
water  intercept and treatment system.  2,3,7,8-TCDD was detected
in four of these samples, at levels ranging from 0.07 to 0.11
ppt.  Other dioxin isomers were also detected but not quantified.

     Montrose Chemical's use of caustic soda in its former produc-
tion of chlorobenzene may account for the levels of 2,3,7,8-TCDD.
(Chlorobenzenes were not included as tier 6 compounds because  it
was not suspected that 2,3,7,8-TCDD could be formed during their
manufacture.)  The 2,3,7,8-TCDD detected in groundwater may have

-------
                              111-26
been brought into solution by benzene and chlorobenzenes disposed
of on-site.
     Additional soil, water, and waste samples have been
collected.  Analysis of these samples has been delayed until the
resolution of analytical difficulties (complex mixtures of
chlorinated products).
     3.3.4  Findings
     o  EPA estimates that 9 percent of the 67 facilities
        originally identified as tier 6 sites would be found to be
        contaminated.
     o  None of the three contaminated sites were extensively
        contaminated with 2,3,7,8-TCDD.
     3.3.5  Conclusion
     o  Further national investigation of tier 6 sites for
        2,3,7,8-TCDD does not appear to be warranted.

3.4  Tier 7 - Background Sites
     3.4.1  Objectives
     Tier 7 consists of sites that did not have previously known
sources of 2,3,7,8-TCDD contamination.  The tier 7 investigation
was intended to establish the prevalence of 2,3,7,8-TCDD in the
environment and to provide a basis for comparison with results
from the other tiers.  The specific objectives of the sampling
were to:
        Determine the percentage of sites in the EPA Urban and
        Rural Soil Networks that have detectable levels of
        2,3,7,8-TCDD in soil at a detection limit of approximately
        1 ppt.
     -  Determine the percentage of sites in the combined U.S.
        Geological Survey's (USGS) National Stream Quality
        Accounting Network (NASQAN) and Benchmark Network that
        have detectable levels of 2,3,7,8-TCDD in fish tissue at a
        detection limit of approximately 1 ppt.
     EPA Regional Offices also selected a large number of
additional fish samples in areas of general interest, including
areas near population centers, recreational or commercial fishing
areas or historical sampling areas.

-------
                                                                  H
FIGURE  3-4. LOCATIONS OF SAMPLED TIER 6 SITES

-------
                              111-28
     3.4.2  Study Design
     Soil
     Soil sampling locations (both urban and rural) were chosen
from the Rural and Urban Soils Networks of the National Soils
Monitoring Program, which was established to monitor pesticide
residues in rural and urban soils.  The Rural Soils Network con-
sists of 13,280 rural sites identified in the 1967 Conservation
Needs Inventory of rural land areas within the contiguous United
States.  Two-hundred sites were randomly selected from this net-
work.  A similar approach was used to select 300 urban soil sites
from the Urban Soils Network, which is comprised of 1,761 sites in
20 'Standard Metropolitan Statistical Areas.  One soil sample was
taken per site.
     Fish
     One-hundred fish sampling sites were statistically selected
from the combined U.S. Geological Survey NASQAN and Benchmark
Networks.  An additional 305 sites suggested by EPA's Office of
Water Regulations and Standards (OWRS) or EPA Regional Offices
were also chosen for sampling based on proximity to population
centers, commercial or recreational fishing activity, or
availability of water quality information.  Fish sampling was
generally conducted by State personnel.
     Protocols were defined to limit fish sample collection
variables among sites.  Certain species were targeted in order to
minimize interspecies variations.  Fish of similar age were
sampled whenever possible, and the time of sampling was limited to
reduce seasonal variations.
     Four composite samples per site were collected:  1) a whole
bottom-feeding fish, 2) a bottom-feeding fish filet, 3) a whole
predator or game fish, and 4) a predator or game fish filet.
Whole fish composites of bottom-feeders were analyzed first
because data indicate that 2,3,7,8-TCDD concentrations are likely
to be highest in these samples.  If 2,3,7,8-TCDD was detected in a
whole fish bottom-feeder sample, then the other three samples from
that site were analyzed.  Because of differences in species, age,

-------
                              111-29
or fat content of the fish being composited for each separate
analysis, it is possible that the highest level found at a site
could be in a sample other than the whole bottom-feeding fish.
     3.4.3  Results
     Of the statistically selected soil sites, 141 of 200 rural
and 221 of 300 urban sites were sampled.  The remaining 59 rural
sites and 79 urban sites could not be sampled because of diffi-
culty in locating the site (131 sites) or because permission to
collect a sample was denied (7 sites).  Of the 100 statistically
selected fish sites, 90 were sampled.  The remaining 10 sites
could not be sampled because of lack of water, fish, or success in
catching the latter.
     Soil
     Seventeen of the 221 urban soil sites and one of the 138
rural sites had detectable levels of 2,3,7,8-TCDD; the levels were
very low—between 0.2 and 11.2 ppt.  (The Linn County Oregon rural
soil sample had 0.5 ppt).  Samples for three sites were not
analyzed because they were either lost or broken during shipment.
     Fish
     Fish from 17 of the 90 statistically selected sites had
detectable levels up to 19 ppt in the whole fish composite sample.
     Whole fish composite samples from 95 of the 305 regionally
selected sites (includes rivers, Great Lakes, and estuarine and
coastal sites) (31 percent) had detectable levels up to 85 ppt.
This frequency is greater than that found for the statistically
selected sites; however, many of the regionally selected sites
were near urban or industrialized areas.
     Only 4 of the 57 estuarine or coastal sites had detectable
levels in fish or shellfish, with concentrations ranging from 1.08
to 3.5 ppt.  Three of the four sites with detectable levels were
in heavily industrialized areas, while the fourth contaminated
sample was collected from weathered, chemically-treated wood
pilings.  Additional analyses of shellfish attached to recent,

-------
                              111-30
chemically-treated wood pilings and artificial substrate at this
site showed no detectable 2,3,7,8-TCDD.
     At 74 sites (67 percent) where 2,3,7,8-TCDD was detected, the
maximum value was below 5 ppt, while at 4 sites levels were above
25 ppt.  As a result of these findings, two advisories to limit
fish consumption have been issued by the States of Maine (for the
Androscoggin River at Lewiston) and Minnesota (for the Rainy River
at International Falls).  An advisory was already in effect for
fish caught in Lake Ontario due to contamination from mirex, PCBs,
and mercury.  Additional sampling will be conducted at the fourth
site (Flint River at Elms Road) to verify levels and identify
potential sources of 2,3,7,8-TCDD.
     Twenty-three of the 29 sampled sites in the Great Lakes were
found to have detectable levels of 2,3,7,8-TCDD, which is a much
higher proportion than in the statistically selected or other
regionally selected sites.  Possible explanations for this finding
include:  1) the sites were selected based on potential
contamination from prior evaluation of toxic pollutants; 2) the
long water retention of the lakes causes elevated pollutant levels
in the system; and 3) there are many sources of pollutants
entering the lakes.  Areas in the lakes with higher levels are
subjects of State fish advisories, based on other chemicals.
Further investigation is being conducted cooperatively by Regional
Offices, States, and the Great Lakes National Program Office.
     Outside of the Great Lakes, detectable levels in fish appear
to be most frequently found in major river systems such as the
Ohio and Mississippi Rivers, or in waterways with significant
industrial activity.
     Levels found in filet samples (between 0.4-41 ppt) were
generally lower than levels in the whole fish samples.  In 46
percent of the cases where 2,3,7,8-TCDD was detected in whole
fish, it was not detected in the filet sample.  Even though only
one filet sample was greater than the FDA advisory level of 25
ppt, the levels found in fish filets may be a cause for concern
under particular conditions at specific locations.  For example,

-------
                              111-31
using the EPA cancer model and the consumption  estimates  from
EPA's water quality criteria document,  fish  contaminated  at  the
detection level of approximately  1 ppt  could cause  an  increased
lifetime cancer risk of  1 in 100,000.   The results  from tier 7
should be carefully evaluated by  local, State,  and  Federal
agencies in light of local exposure conditions  in determining
appropriate levels of concern.  Site-specific factors  include
consumption patterns (type of fish and  amount consumed),  length  of
exposure, level of contamination, and percent of fish
contaminated.
     EPA used two approaches in an effort to determine possible
associations between 2,3,7,8-TCDD presence in fish  and various
sources:  1) preparing stream profiles  identifying  types  of
industrial dischargers in the vicinity  of the fish  sampling  sites,
and 2) conducting additional sampling at selected sites.
     The two sites with  the highest 2,3,7,8-TCDD levels in whole
fish (the Androscoggin River—maximum 29 ppt, and the Rainy
River—maximum 85 ppt) have upstream pulp and paper mill
discharges.  Elevated levels in fish were also  found below paper
mills in the Petenwell Flowage.   Further investigations at those
sites have included sampling of waste treatment sludges from the
mills.  Levels of up to  414 ppt have been found in  these  sludge
samples.  Additional investigations, including  those previously
described for the Petenwell Flowage (tier 5) site, are underway by
EPA, States, and the paper industry to determine the sources  of
2,3,7,8-TCDD within several mills that produce bleached pulp  using
chlorine-based chemicals.
     3.4.4  Findings
     Figures 3-5 and 3-6 and Tables 3-5 through 3-9 provide  a
summary of tier 7 results.
     Soil
     o  2,3,7,8-TCDD was detected infrequently and at very low
        levels in background soil samples.  Seventeen of 221 urban
        sites and 1 of 138 rural sites had detectable levels, with

-------
                         111-32
   the highest level found being 11.2 ppt in an urban soil
   sample.
Fish
o  EPA estimates that 21 percent of the U.S. Geological
   Survey national monitoring network sites would have
   detectable levels above 1 ppt in fish.  The frequency of
   detection is greater (31 percent) at sites selected by
   EPA's Regional Offices, many of which are near industrial
   and urban areas.
o  An even higher proportion (23 of 29) of Great Lakes fish
   sampling sites had detectable levels.  This is of concern
   as it suggests multiple sources to the Great Lakes, which,
   because of their long water retention times, have
   increased bioaccumulation potential.
3.4.5  Conclusions
o  2,3,7,8-TCDD levels in filet samples can be a cause for
   concern at specific locations under certain consumption
   patterns; local exposure conditions must be evaluated to
   determine levels of concern for those areas.
o  Fish and shellfish from estuarine and coastal waters were
   rarely contaminated; three of the four sites where
   2,3,7,8-TCDD was detected are in areas heavily influenced
   by industrial discharges.
o  A previously unsuspected possible source of contamination
   in some areas appears to be certain types of pulp and
   paper mill discharges.  Mills using a chlorine bleaching
   process are being investigated by EPA, States and the
   paper industry to determine the source of 2,3,7,8-TCDD
   within the mills.
o  Fish contamination is a current and continuing phenomenon
   since recent EPA studies indicate that 2,3,7,8-TCDD has a
   half-life of slightly less than 1 year in fish.

-------
                              111-33


     o  Based on the very small number of positive soil samples
        and the low levels detected, soil contamination does not
        appear to be a problem in either rural or urban background
        settings.
     o  2,3,7,8-TCDD contamination in fish may be a cause for
        concern in specific locations.  Site-specific factors
        including levels of contamination, types of fish, length
        of exposure, and levels of consumption must be evaluated
        to determine the appropriate level of concern and
        response.

3.5  Follow-on Investigations
     Pulp and Paper Mills
     As previously discussed, results from the study indicate that
2,3,7,8-TCDD is present in fish and river sediments downstream
from a number of pulp and paper mills located in various parts of
the country.  In addition, current wastewater treatment plant
sludges from some Maine, Minnesota, and Wisconsin mills are
contaminated with 2,3,7,8-TCDD and other CDDs and CDFs.
     Given current knowledge and concerns about protection of
fisheries, EPA and the paper industry have initiated a cooperative
sampling program.  Data will be used to assess conditions at
sampled mills using chlorine bleaching processes, to draw prelim-
inary conclusions about the presence of dioxin in pulp and paper
processes in general, and to help focus further regulatory work in
this area.
     Sludges, process materials, and water and waste waters will
be analyzed for 2,3,7,8-TCDD, 2,3,7,8-TCDF, and other CDDS and
CDFs as homologues.  Isomer-specific analyses for 2,3,7,8-
substituted congeners and certain other selected congeners will be
conducted on selected samples.  Detection levels in the low parts
per trillion (ppt) range are required for sludges and process
materials and in the low parts per quadrillion (ppq) range for
water and wastewaters.  Analyses for a number of other related
compounds potentially associated with paper making operations will

-------
111-34
                                                     CO
                                                     UJ

                                                     <75
                                                     o
                                                     en
                                                     oc
                                                     UJ
                                                     o
                                                     UJ

                                                     0.

                                                     <
                                                     o
                                                     o
                                                     LP>
                                                     I
                                                     M^

                                                     UJ
                                                     OC
                                                     3

                                                     O

-------
35
                        i  «
                           U   if  •
                           lii'le
                                         0)
                                         UJ


                                         55
                                         UJ

                                         (0
                                         cc
                                         UJ
                                         O
                                         UI

                                         0.
                                         
-------
                              111-36


also be performed on selected samples.  Detection limits in the
range of 1 to 10 ppb will be required.
Bioaccumulative Pollutant Study
     The bioaccumulation study is a national sampling survey to
determine the extent to which selected contaminants bioaccumulate
in fish.  The study is in part a followup to the National Dioxin
Study, and reflects EPA and public concern that there may be other
pollutants similar to 2,3,7,8-TCDD which are persistent,
bioaccumulative, significantly toxic, and potentially widespread
in the environment.
     EPA currently has over 400 frozen fish samples collected from
the National Dioxin Study.  The funding for the bioaccumulation
study allows for analysis of a subset of these samples, plus
additional sampling and specific chemical analysis for a limited
number of contaminants at approximately 250 new sites over 2
years.
     The objective and potential outcomes of the study include:
     (1)  identification of toxic pollutants that need further
          study (toxicity testing, monitoring, source assessment,
          analytical methods development);
     (2)  establishment of a baseline for levels of selected toxic
          pollutants in fish;
     (3)  initiation of regulatory decisions on an industry- or
          pollutant-specific basis; and
     (4)  initiation of site-specific action (stricter discharge
          permits, local health advisories, cleanup action).

-------
               TABLE 3-1.  ANALYTICAL RESULTS FOR CONTAMINATED TIER 3 SITES—STATISTICALLY SELECTED SITES
REGION LOCATION DESCRIPTION:

CONTAMINATED SITES:

  2   NY  FARMINGDALE


      NJ  W. CALDWELL

  3   WV  ONA
  4   GA  FORT VALLEY
FARMINGDALE GARDEN
LABS, INC.
                    SOIL
ROCKLAND CHEM.  CO.  SOIL
                            HOLDER CORP.
                            SECURITY CHEM.  CO.
                            (WOOLFOLK CHEM.)
  5   IL  CHICAGO HEIGHTS   RIVERDALE CHEM.  CO.
                                                                                            RANGE
                                                                                         (PPB UNLESS
                                                                                        DET LIMIT
                                                                                       (PPB UNLESS
                    MATRIX TYPE     # SAMPLED  # DETECTED  OTHERWISE NOTED)  # CONT  OTHERWISE NOTED)
25
10
17.6
 1.3
                                         1    0.1-0.94
                                                                                 1   0.03 - 1.1
      MI GRAND LEDGE
                            ETM ENTERPRISES
SOIL
SEDIMENT
FISH
CLAM

SOIL
SOIL
SOIL
SOIL
36
5
3
1

16
1
14
21
0
0
3
0

2
1
14
2
ND
ND
0.5 - 2.9 (PPT)
ND

23 - 40
36.7 (PPT)
1.1 - 364
0.56 - 1.13
0
0
3
0

2
0
13
1
0.012 - 0
0.72-8
0.05 - 0.
2.2 (PPT)

.84
(PPT)
3 (PPT)

H
H
H
0.13-21 5*>
NA
NA
0.05 - 0


.76
  Contamination defined as concentration greater than or equal to 1  ppb in soil or above detectable levels in other media.

-------
                                     ANALYTICAL RESULTS FOR CONTAMINATED TIER 3 SITES—REGIONALLY SELECTED SITES
REGION LOCATION DESCRIPTION:

CONTAMINATEDaSITES:

  3   VA  ALEXANDRIA
      VA NORFOLK
  4   FL  BELLE GLADE
  5   IL  BEDFORD PARK
  7   MD  SAINT JOSEPH
R.H. BOGLE CO.
SMITH DOUGLAS CO.
(BORDEN)
CHEM. SPRAY, INC.
                            NALCO CHEM. CO.
                            UNION CARBIDE
                                                                                            RANGE
                                                                                         (PPB UNLESS
                                                                                       DET LIMIT
                                                                                      (PPB UNLESS
                                                MATRIX TYPE     # SAMPLED  # DETECTED  OTHERWISE NOTED)  # CONT OTHERWISE NOTED)
  9   CA  SANTE FE SPRINGS  MAGNA CORP.
SOIL
FISH-WHOLE
FISH-FILET
SEDIMENT
SOIL
DUST
OTHER
SOIL
SEDIMENT
SOIL
SOIL
SOIL
40
4
4
9
53
10
1
19
7
10
26
10
0
4
3
5
1
0
0
2
7
2
23
1

1.6
1.9
5.5



0.2
20.9
1.9
0.1
2
ND
- 6.3 (PPT)
- 5.0 (PPT)
- 23 (PPT)
10.1
ND
ND
- 3.0
- 515 (PPT)
- 2.2
3 - 39.1
.0
0
4
3
5
1
0
0
1
7
2
16
1
0
0
0
1
0
0

0

0
0
0.
.07 -
.3 - 1
.4 - 1
.2-9
.01 -
.08 -
0.12
.01 -
NA
.76 -
.11 -
07-0
0.89
.3 (I
.3 (1
.7 (I
0.83
0.83

60

0.65
1.04
.7

?P'
?P'
?P'


H
}_(
H
U>
oo





-------
                                    TABLE 3-2.  ANALYTICAL RESULTS FOR CONTAMINATED TIER 5 SITES
REGION LOCATION DESCRIPTION:


CONTAMINATED3 SITES:


  1   ME B&A - R-O-W - GRINDSTONE



  2   NY LONG ISLAND RAILROAD - STEWART MANOR



  4   FL WEST PALM BEACH - FLORIDA CANALS



  4   MS CLEVELAND CO.



  4   MS SCOT CO.





  5   WI PETENWELL FLOWAGE - WISCONSIN RIVER
MATRIX TYPE     # SAMPLED  # DETECTED       RANGE  (PPT)    DET LIMIT  (PPT)
  6   AR DESHA CO.
  6   LA ASSUMPTION PARISH
SOIL
SOIL
SEDIMENT
SOIL
RICE
SOIL
BOTTOM FEEDER-FILET
BOTTOM FEEDER-WHOLE
GREAT BLUE HERON
GREEN HERON
KING FISHER
RACCOON FAT
PREDATOR-FILET
PREDATOR-WHOLE
PLANT TISSUE
SEDIMENT
SOIL
22
26
36
20
1
20
3
4
3
1
2
3
2
2
5
3
46
18
1
27
16
0
2
3
4
1
1
2
1
2
2
0
0
1
8-35 1
9 1
0.7 - 26.5 0.
0.8 - 1.7 0.
ND
0.6 - 0.7 0.
20 - 23 0.
25 - 47 0.
1.2 0.
0.76
7.8 - 12 0.
1.9 0.
3-8 0.
9-37 0.
ND 1
ND 1
3 1
- 68
- 44
12 -
42 -
0.6
22 -
5 -
7 -
12 -
0.4
4 -
13 -
8 -
5 -
- 10
- 2
- 8


1.35
1.21

1.45
1.6
1.2
0.2

0.7
0.4
0.9
0.7



                                                                          H
                                                                          H
                                                                                                                          OJ
                                                                                                                          10
                                                SOIL
                      24
14
0.3 - 1.1
0.28 - 0.82
aContamination defined as detectable levels

-------
                                                        TABLE 3-2.   (CONT.)
REGION LOCATION DESCRIPTION:
MATRIX TYPE
# SAMPLED  # DETECTED
RANGE (PPT)   DET LIMIT (PPT)
CONTAMINATED SITES:
  6   LA POINT COUPEE PARISH
  6   LA RICHLAND PARISH
  6   TX RIO GRANDE PLAIN EXP. RANCH
          KINNEY COUNTY
  7   MO MARK TWAIN NATIONAL FOREST
          FREDERICTOWN

  9   AZ TONTO NATIONAL FOREST
                                                SOIL
SOIL
                                                SOIL
                                                COYOTE FAT
                                                COYOTE KIDNEY
                                                COYOTE LIVER
                                                DEER FAT
                                                DEER KIDNEY
                                                DEER LIVER
                                                FROGS WHOLE (20)
                                                JAVELINA FAT
                                                JAVELINA KIDNEY
                                                JAVELINA LIVER
                                                QUAIL WHOLE
                                                SUNFISH WHOLE
                                                SNAKE WHOLE
                                                TOAD WHOLE
                     25
              20
                      50
              21
1   - 2.5
0.3  - 124
                                                           0.26  - 1.15
SEDIMENT 1 0
SOIL 35 9
SOIL 38 12
RATTLESNAKE 1 0
VEGETATION 6 0




ND
0.3 - 0.4
0.2 - 3
ND
ND




0.46
0.19 - 0.39
0.09 - 0.75
0.1
0.5 - 1.1








H
H
H
1
*>.
0.17  - 0.7   °
121
1
1
1
2
1
3
1
3
2
3
1
1
3
1
45
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1.1 - 6623
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.



5

0.

3
0.
0.


0.

06 - 33
5.1
0.6
0.8
- 6.9
0.2
3 - 0.6
0.3
- 11
2 - 0.4
4-0.8
0.3
0.44
3-1.7
0.5

-------
                                                        TABLE 3-2.   (CONT.)
REGION LOCATION DESCRIPTION:
                                                MATRIX TYPE
# SAMPLED  # DETECTED
                                                                                            RANGE (PPT)    DET LIMIT (PPT)
CONTAMINATED SITES:
  9   CA SANTA ANA RIVER
                                                BOTTOM FEEDER-WHOLE    7
                                                PREDATOR-WHOLE         2
                                                SEDIMENT              28
               1
               0
               1
                 4.6
                 ND
                 0.6
               0.24 - 0.68
               0.05 - 0.67
               0.14 - 0.85
  10  OR SANTIAM FOREST - GATES
                                                SEDIMENT
                                                SOIL
                                                WHOLE SCULPIN
      12
      35
       1
3
0
0
0.2 - 0.4
    ND
    ND
0.1   - 0.43
0.13 - 1.05
    0.3
H
H
1
   Contamination defined as detectable levels.

-------
                                                                            TABLE  3-3
                                                                  TIER 5 SITE CHARACTERIZATION
II
III
IV

Name of Site
Lake Abenaki , VT


Lake Clara, VT


Grindstone, ME



Yarmouth, ME


Long Island Ral 1-
road, NY

King & Queen
Co., VA
Matthews Co.,
VA
Cleveland,
MS
Boyle,
MS
Pesticide
Site Use Applied
Aquatic recreation and Si 1 vex
private water supply

Aquatic recreation SI 1 vex


Rai 1 road right-of-way 2,4,5-T3



Power 1 1 ne right-of-way 2,4,5-T


Right-of-way 2,4,5-TCP
herbicides

Forest 2,4,5-T

Forest 2,4,5-T with
2,4-D
Rlcefleld 2,4,5-T

Ricefield No Information
aval table
Date(s)
Treated
1975


1971-73
(once each
year)

7 - 1977



1978


1970's


7-1978

7-1978

1978, 1981,
1984
Unknown

Vo 1 ume
App 1 i ed
5 gal . Si Ivex


5 gal. (1973)


537.5 Ibs.



Unknown


Unknown


300 !bs/yr
(calculated)
40 Ibs/yr
(calculated)
Unknown

Unknown

Area Rate of
Applied Appl ication(AI)
15 acres 1/3 gal /acre
(southern (calculated)
third)
18 acres Unknown
(1972)2;
spot treat-
ment (1973)
1075 acres 0.5 Ibs/acre
(along ral 1-
road)

Within 75 ft Unknown
of tower
center 1 1 ne
Area unknown Unknown
(along ral 1-
road)
150 acres 2 Ibs/acre

20 acres 2 1 bs/acre

Unknown 1 qt/acre

Unknown Unknown

Type of
Appl i cat I on
Spraying
from boat

Spraying
from boat


Spray
H
1
NJ
Sprayed at
base of
selected plant
Spray


Unknown;
probably spray
Unknown;
probably spray
Unknown

Unknown


-------
                                                                   TABLE 3-3
                                                          TIER 5 SITE CHARACTERIZATION
iglon
IV
(cont.)

V
VI



Name of Site
Scot, MS
West Palm Beach,
FL
Escambla Exp.
Brewton, AL
Petenwel 1 Flowage,
Wl
Assumption Parish,
LA
Polnte Coupee Parish,
LA
U. of Arkansas
Experimental Station
Desha County, AR
New Mexico State
Univ. Expt. Ranch
Site Use
Rlcefleld
Sugarcane Field
Forest
Carp Fishery; closed
since 1983
Sugarcane
Sugarcane field
(soybeans In 1985)
Rlcefleld (soybean in
rotation)
Rangeland
Pesticide
Appl led
2,4,5-T
Si Ivex
2,4,5-T
Tr I ch 1 ore—
phenate
Si Ivex
SI Ivex
2,4,5-T
2,4,5-T
Si Ivex
Oate(s)
Treated
1984
Unknown
1957
? - 1980
1982
1983
1972, 1974
1975
1968
1984
Volume
Appl led
Unknown
Unknown
Unknown
9,000 Ibs
Unknown
Unknown
15 1 bs each
field
(calculated)
400 Ibs
Unknown
Area Rate of
App 1 1 ed Appl lcatlon(AI)
Unknown
Unknown
Unknown
Pulp and Paper
ml 1 Is upstream
8. 1 acres
2 fields,
2.6 acres and
2.7 acres
2 fields,
20 acres
each
800 acres
4000 acres
Unknown
Unknown
Unknown
Unknown
2 Ibs/acre
2 Ibs/acre
0.75 Ibs/
acre
0.5 Ibs/acre
Unknown
Type of
Appl 1 cat I on
Unknown
Unknown
Aer i a 1 spray
Paper ml 1 1
bioclde
Spray from
' H
ground rig H
Spray from oj
ground rig
Aerial spray
Aerial spray
Aerial spray
Dona Ana Cty, NM
Madison Parish, LA
                       Rlcefleld
Rio Grande Plain       Rangeland
Experimental Ranch,
Kinney Co, TX
2,4,5-T
2,4,5-T
1982,  1983
                                                                   1981
25 gal  (1982);   200 acres
17.5 gal  (1983)  (1982)
(calculated)     140 acres
                 (1983)
                                                                                 2.5 Ibs
                               Experimental
                               applicatlon-3
                               plots approx.
                               5 acres
1/8 gal/acre
                                                                                                                  0.5 Ib/acre
                                                                                                                                       AerI a I  spray
                                                                                     Aerial spray

-------
                                                                              TABLE 3-3
                                                                     TIER  5  SITE  CHARACTERIZATION
Region    Name of Site
                                 Site Use
vl        Oklahoma Range I and     Range I and
(cont.)   Site 1, THIman Co.,
          OK
                                                         Pesticide
                                                         Applied

                                                          2,4,5-T
                                                                            Date(s)
                                                                            Treated
                              Volume
                              App11ed
                 1980, 1984    93  Ibs
                                               Area
                                               App I led

                                                93 acres
     Rate of
Appllcatlon(AI)

    1 Ib/acre
  Type of
ApplI cat Ion

    Aerial spray
          Rich I and Parish, LA    Rlcefleld
                                                          2,4,5-T
                 1982 (once);  22 gal. total    40 acres
                 1983 (twice)  (calculated)     (1982);
                                                65 and 72
                                                acres (1983)
                                                                 1/8 gal/acre
                         Aerial spray
VII     Mark Twain National
        Forest, MO
                                 Forest
2,4,5-T
                                                                             1977
                               190 Ibs (est.)   3 sites,
                                                                                                                             2  Ibs acid
                                                                                                            95 acres total   equiv/acre
                         Ground
                         spray
  IX
        Tonto National
        Forest, AZ
                                 Forest
2,4,5-T; 2,4-D   1965-1966;    5400 Ibs 2,4-D   Greater than    2  Ibs acid
Silvex           1968-1969     and 2,4,5-T;     2560 acres      equlv./acre
                               7260 Ibs si I vex
                                                                                                                                                 Aer I a I
                                                                                                                                                 spray
                                                                                                H
                                                                                                H
          North California Rice  Rlcefleld
          Growing Areas
                                                          2,4,5-T and
                                                          Si I vex
                 Before 1971   Unknown
                 thru 1982
                                                Unknown
                                                                Unknown
                                                                                      Spray
          Santa Ana River, CA    Multiple uses
                                                          No information
                                                          aval table
                 Unknown
                               Unknown
                                                Unknown
                                                                Unknown
                                                                                      Unknown
          Santlam State Forest,  Forest
          Gates, OR
                                                          2,4,5-T and
                                                          2,4-D
                 1976-1977
                               Unknown
                                                75 acres
                                                                2  Ibs acid
                                                                equlv./acre
                                                                                      Spray
   Max. depth of lake:  7 ft.
   Lake was partially drained In 1982; now about 1/3 the size of original  lake:   4-5 ft deep.
   Area was sprayed with several pesticides (Including 2,4,5-T In 1977)  from 1975 to 1983.
   Sampled areas include portion of the site where 2,4,5-T was sprayed and where surface runoff from the sprayed sites would drain.
   Initial spraying In 1965 and 1966; maintenance spraying in 1968 and 1969.
   Conflicting data exist; Info, from pesticide use permits probably Includes rangeland; sampled area represents points where runoff from rlceflelds
   could Impact river water quality.

-------
                          TABLE 3-4.   ANALYTICAL  RESULTS  FOR CONTAMINATED TIER 6 SITES—STATISTICALLY SELECTED SITES
REGION LOCATION DESCRIPTION:
                                                                                            RANGE
                                                                                         (PPB UNLESS
                                                                                       DET LIMIT
                                                                                      (PPB UNLESS
                    MATRIX TYPE    # SAMPLED  #  DETECTED  OTHERWISE NOTED)    # CONT  OTHERWISE NOTED)
CONTAMINATED SITES:
  2   NJ  SOMERSET
  6   TX  PORT NECHES
W.A. CLEARY
                                                SOIL
                                                SEDIMENT
CHEM ALL, INC.
(RIVERSIDE CHEMICALS)
                    SOIL
                                       31
                                        1
                                                                   32
1
0
        34. 7b
         ND
              0.1 - 1.4
1   0.02 - 0.17
0      0.08
                                                                                                              2   0.028 - 0.37
                                                                   - REGIONALLY SELECTED SITES
REGION LOCATION DESCRIPTION:
                                                MATRIX TYPE
                                                                RANGE
                                                             (PPB UNLESS
                                   # SAMPLED  # DETECTED  OTHERWISE NOTED)
                                                                                                                    DET LIMIT
                                                                                                               a  (PPB UNLESS
                                                                                                         # CONT OTHERWISE NOTED)
CONTAMINATED SITES:
  9   NV  HENDERSON
STAUFFER CHEM.
                                                SOIL
                                                WATER

                                                AQUEOUS LIQUID
                                       37
                                        7
1
4
      1
0.07 - 0.11 (PPT)

      ND
1   0.05 - 0.29
4   0.005 -
    0.02 (PPT)
0   0.002 - 0.005
a  Contamination defined  as concentration greater than 1 ppb in soil or detectable levels in other media

b  Concentration level uncertain - may be high by 20%

-------
                                  TABLE 3-5.   RESULTS OF ANALYSES OF TIER 7 URBAN SOILS
REGION
LOCATION DESCRIPTION :    NO. SAMPLES    DETECTION LIMIT  (PPT)
LEVELS DETECTED (PPT)
CONTAMINATED  LOCATIONS  :
    3                     DC, WASHINGTON
                          PA, PITTSBURGH


                          IN, EVANSVILLE

                          IN, GARY
    9

   10
LA, LAKE CHARLES

CA, SAN FRANCISCO

WA, TACOMA
NOT DETECTED LOCATIONS:

    1
                                 TOTAL
                          CT, HARTFORD
                          MA, FITCHBURG
                          MA, PITTSFIELD

                          PA, PITTSBURGH
                          PA, READING
                          VA, NEWPORT NEWS
                          DC, WASHINGTON
3


2

1
2

1

1
7






17
8
6
9
22
7
11
16
0.40 - 2.0


1.0 - 4.0

NOT AVAILABLE
NOT AVAILABLE

NOT AVAILABLE

1.0
NOT AVAILABLE






1.0 - 10.0
1.0 - 10.0
1.0 - 4.0
1.0 - 9.0
1.0 - 4.0
1.0 - 4.0
0.4 - 17.0
3.0
2.0
4.0
5.0
2.0
1.3
0.5
4.1
0.2 3
H
i
2.0 £
0.4
0.5
0.6
0.8
1.9
8.7
11.2
ND
ND
ND
ND
ND
ND
ND

-------
                                 TABLE  3-5.  RESULTS  OF  ANALYSES OF TIER  7  URBAN  SOILS
REGION

NOT DETECTED LOCATIONS
    4
    7

    9

   10
LOCATION DESCRIPTION


AL, GADSDEN
GA, MACON
NC, DURHAM
SC, GREENVILLE

IL, SPRINGFIELD
IN, EVANSVILLE
IN, GARY

AR, PINE BLUFF
LA, LAKE CHARLES

IA, DBS MOINES

CA, SAN FRANCISCO

WA, TACOMA
NO. SAMPLES
DETECTION LIMIT (PPT)
LEVELS DETECTED (PPT)
8
7
12
7
11
2
12
10
8
14

27
7
1.0 -
1.0 -
0.5 -
0.7 -
1.0 -
0.2 -
0.27 -
0.2 -
0.07 -
0.5 -

1.0 -
0.33 -
3.0
2.0
5.5
1.8
9.0
0.34
1.13
3.0
0.53
3.0

8.0
0.98
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND









H
H
H
i

                                                        204
   Sampling was conducted in the SMSAS for these cities.
   Contamination defined as detectable levels.

-------
                      TABLE 3-6.   ANALYTICAL RESULTS  FOR CONTAMINATED TIER  7  FISH SITES  -  STATISTICALLY SELECTED  SITES
REGION   LOCATION DESCRIPTION:







CONTAMINATED SITES




  1     ME ANDROSCOGGIN RIVER - BRUNSWICK










  3     MD SUSQUEHANNA RIVER - CONOWINGO










  3     PA SCHUYLKILL RIVER - PHILADELPHIA
TYPE OF FISH
CUT OF SAMPLE     # DETECTED     VALUE (PPT)   DET LIMIT (PPT)
  4     MS YAZOO RIVER - REDWOOD
  5     IN WABASH RIVER - NEW HARMONY
  5     MI MUSKEGON RIVER - BRIDGETON
  5     MN RAINY RIVER - LONG SAULT
BOTTOM FEEDER
BOTTOM FEEDER
BOTTOM FEEDER
BOTTOM FEEDER
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
PREDATOR
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
BOTTOM FEEDER
PREDATOR
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
WHOLE
FILET
WHOLE
FILET
WHOLE
WHOLE
FISH

FISH

FISH

FISH

FISH

FISH

FISH
FISH

FISH

FISH
FISH
1
1
1
1
2
0
1
0
2
0
1
0
0
1
0
1
0
1
1
19
11
1.2
0..5
1.2
ND
1.9
ND
3*2
ND
2
ND
ND
2.8
ND
4.3
ND
19
12
1
0.6
0.8
0.1
0.1
0.7
0.2
0.5
•1.1
1.2
0.3
0.9
0.9
0.1
0.6
0.1
0.4
1.2
2
                                                                                                                            H

-------
                                                  TABLE  3-6.   (CONT.)
REGION   LOCATION DESCRIPTION:


CONTAMINATEDasITES

  5     OH GREAT MIAMI RIVER - NEW BALTIMORE



  5     OH LITTLE MIAMI RIVER - MILFORD


  5     WI NEMADJI RIVER - SOUTH SUPERIOR




  6     AR MISSISSIPPI RIVER - ARKANSAS CITY



  6     AR RED RIVER - INDEX



  6     LA BEOUF RIVER - FT.- NECESSITY
TYPE OF FISH
BOTTOM FEEDER
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
BOTTOM FEEDER
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
CUT OF SAMPLE     # DETECTED     VALUE (PPT)   DET LIMIT (PPT)
WHOLE
WHOLE
WHOLE
WHOLE
FILET
WHOLE
WHOLE
WHOLE
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
FISH
FISH
FISH
FISH
FISH
FISH
FISH
FISH
FISH
FISH
0
1
1
1
1
1
t
1
1
1
1
0
1
0
ND
1.2
1.2
4
0.9
1.5
3.7
2.4
6
1.9
7
ND
1.1
ND
4.6
0.08
0.18
H
0.2 H
0.4 j,
0.6 *>
0.4
0.96
0.8
0.3
0.2
0.3
0.4
0.6

-------
                                                  TABLE  3-6.   (CONT.)
REGION   LOCATION DESCRIPTION:
                                              TYPE OF PISH
CUT OF SAMPLE
# DETECTED     VALUE (PPT)   DET LIMIT (PPT)
  6     OK WASHITA RIVER - DURWOOD
  7     NE PLATTE RIVER - LOUISVILLE
  9     CA OWENS RIVER - BIG PINE
  10    OR WILLAMETTE RIVER - PORTLAND
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
WHOLE FISH
FISH
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
WHOLE FISH
FILET
1
0
0
0
1
0
1
0
0
2
1
1.3
ND
ND
ND
2
ND
1.2
ND
ND
4.5
1.5
0.32
0.39
0.38
0.34
0.4
1.4
0.8
1.3
0.7
1.1
0.73






H
H
H
Ul
O



a  Contamination defined as detectable levels.

-------
                       TABLE 3-7.  ANALYTICAL RESULTS FOR CONTAMINATED TIER 7 FISH SITES - REGIONALLY SELECTED SITES
REGION   LOCATION DESCRIPTION:


CONTAMINATED a SITES

  1     CT QUINIPIAC RIVER - NORTH HAVEN



  1     MA BLACKSTONE RIVER - MILLVILLE
  1     MA MERRIMACK RIVER - TYNGS ISLAND
  1     MA NASHUA RIVER - PEPPERELL
  1     ME ANDROSCOGGIN RIVER - LEWISTON
  1     ME KENNEBEC RIVER - SIDNEY
TYPE OF FISH
BOTTOM FEEDER
BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
CUT OF SAMPLE
# DETECTED
VALUE (PPT)   DET LIMIT (PPT)
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FISH

FISH

FISH

FISH
FISH

FISH

FISH

FISH

FISH

FISH
1
0
1
1
1
0
1
1
0
1
0
1
1
1
1
1
1
1
0.9
ND
1.1
0.4
2.4
ND
1.2
3.3
ND
3.5
ND
29
4.6
24
4.5
11.4
1.2
20.3
0.3
0.66
0.05
0.13
0.1
0.76
0.24
0.5
0.7
0.3
1.1
0.32
0.43
0.5
0.47
0.02
0.4
0.4
                                                                                                                           H
                                                                                                                           H

-------
                                                            TABLE 3-7.  (CONT.)
REGION   LOCATION DESCRIPTION:




CONTAMINATED a SITES





  1     ME PENOBSCOT RIVER - EDDINGTON
        VT CONNECTICUT RIVER - NEWBURY
TYPE OF FISH
CUT OF SAMPLE
# DETECTED
VALUE (PPT)   DET LIMIT (PPT)
        NJ PASSAIC RIVER - PATERSON
        NY HUDSON RIVER - PEEKSKILL
        NY HUDSON RIVER @ GREEN ISLAND - TROY
        DC POTOMAC RIVER - EAST POTOMAC PARK
        MD POTOMAC RIVER - SHEPHERDSTOWN
        PA ALLEGHENY RIVER - NEW KENSINGTON
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
PREDATOR
PREDATOR
PREDATOR
PREDATOR
BOTTOM FEEDER
PREDATOR
WHOLE FISH
FILET
WHOLE FISH
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
WHOLE FISH
1
1
1
1
0
0
0
1
1
1
1
0
1
0
1
0
2
2
2
1
1
0
7.6
2.6
4.6
1.6
ND
ND
ND
1.7
0.9
2.7
1.3
ND
1.9
ND
1.2
ND
4.9
5
4.8
2.9
1.7
ND
0.2
0.45
0.5
0.11
0.6
1.4
0.4
3.8
0.6
0.1
0.21
0.2
0.58
0.7
0.75
0.26
0.8
0.9
0.5
0.3
0.44
1







H
H
H
1
Ul
M













-------
                                                            TABLE 3-7.  (CONT.)
REGION   LOCATION DESCRIPTION:

CONTAMINATED a SITES

  3     PA JUNIATA RIVER - NEWPORT
        VA JAMES RIVER - GLASGOW
        VA SHENANDOAH RIVER - ROCKLAND
TYPE OF FISH
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                  CUT OF SAMPLE
# DETECTED
VALUE (PPT)   DET LIMIT (PPT)
        WV OHIO RIVER @ PIKE ISLAND - WHEELING
        AL ALABAMA RIVER - CLAIBORNE
        AL COOSA RIVER - CHILDERSBURG
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FISH
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
1
0
0
0
1
0
1
0
1
0
0
1
0
1
0
1
1
1
1
1
1
1
1
0.7
ND
ND
ND
4.5
ND
1.4
ND
0.1
1
1.1
0.4
0.8
1.6
0.3
1
1
ND
ND
1.2
ND
1.2
ND
23
2.4
17
12
15
3.2
13
6.7
1.3
0.4
0.2
0.1
1
0.2
0.6
0.65
0.08
0.09
0.15
0.1
1.2
1.4
0.3
H
H
H
1
in
OJ













-------
                                                            TABLE  3-7.   (CONT.)
REGION   LOCATION DESCRIPTION:

CONTAMINATED a SITES

  4     AL TENNESSEE RIVER - WATERLOO
TYPE OF FISH
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                  CUT OF SAMPLE
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
# DETECTED
   1
   1
   0
   0
VALUE (PPT)   DET LIMIT (PPT)
  3.5
  2
   ND
   ND
0.75
0.23
1.5
0.22
        GA FLINT RIVER, LAKE BLACKSHEAR
                        - CORDELLE
        GA SAVANNAH RIVER  - AUGUSTA
  4     KY KENTUCKY RIVER  - GEST
  4     KY OHIO RIVER  - CANNELTON DAM
   4     KY OHIO  RIVER - MARKLAND DAM
   4      KY OHIO RIVER - UNIONTOWN
                                              BOTTOM FEEDER
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                               BOTTOM FEEDER
                                               BOTTOM FEEDER
                                               PREDATOR
                                               PREDATOR
                                               BOTTOM  FEEDER
                                               BOTTOM  FEEDER
                                               PREDATOR
                                               PREDATOR
                                               BOTTOM FEEDER
                                               BOTTOM FEEDER
                                               PREDATOR
                                               PREDATOR
                                               BOTTOM FEEDER
                                               PREDATOR
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE  FISH
                  WHOLE  FISH
   1
   0
   0
   0
   1
   0
   1
   0
   1
   1
   1
   0
   1
   0
1.3
1.1
3
8.1
5.1
0.8
ND
ND
ND
3.9
ND
4.1
ND
13
6.4
4.2
ND
3.4
ND
0.1
0.08
0.3
1.6
0.1
0.23
0.45
0.31
0.62
0.24
1.2
0.13
2.6
1.1
0.06
0.06
0.53
1.6
0.9
                                                                                                                             Ul

-------
                                                            TABLE 3-7.  (CONT.)
REGION   LOCATION DESCRIPTION:




CONTAMINATED a SITES





  4     KY OHIO RIVER - WESTPOINT







  4     MS BIG BLACK RIVER - BOVINA
TYPE OF FISH
CUT OF SAMPLE
# DETECTED
VALUE (PPT)   DET LIMIT (PPT)
        MS HOMOCHITTO RIVER - ROSETTA
        MS PASCAGOULA RIVER - BENNDALE
        NC CATAWBA RIVER - LAKE HICKORY
        SC LAKE MURRAY - PROSPERITY
        SC PEE DEE RIVER - PEE DEE
BOTTOM FEEDER
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
PREDATOR
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
WHOLE
WHOLE
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
FISH
FISH
FISH

FISH

FISH

FISH

FISH

FISH

FISH

FISH

FISH

FISH

FISH

1
1
1
0
0
0
2
1
1
0
1
0
1
0
0
0
1
1
0
0
1
1
0
0
5.2
2.1
2.2
ND
ND
ND
1.8
2.6
5.2
ND
2.7
ND
1.5
ND
ND
ND
3.7
1
ND
ND
2.3
3.9
ND
ND
0.3
0.4
0.1
0.64
0.4
0.9
0.5
0.3
0.7
2.9
0.2
0.67
0.21
0.7
0.4
0.6
0.1
0.74
1.4
1.3
0.6
0.1
0.7
0.8








H
H
H
1

-------
                                                            TABLE 3-7.   (CONT.)
REGION   LOCATION DESCRIPTION:

CONTAMINATED a SITES

  5     IL DBS PLAINES RIVER - LOCKPORT



  5     IL ILLINOIS RIVER - FLORENCE
  5     IL ILLINOIS RIVER - MARSEILLES
  5     IL KASKASKIA RIVER - VANDALIA
  5     IL MISSISSIPPI RIVER - THEBES
  5     IN GRAND CALUMET RIVER - HAMMOND
  5     IN MISSISSNEWA RIVER - MATTHEWS
  5     IN WABASH RIVER - BLACKROCK.
TYPE OF FISH
BOTTOM FEEDER
BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
CUT OF SAMPLE     # DETECTED     VALUE  (PPT)   DET LIMIT  (PPT)
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
WHOLE
FILET
WHOLE
WHOLE
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
FISH

FISH

FISH

FISH

FISH

FISH
FISH

FISH
FISH
FISH

FISH

FISH

1
1
1
0
0
0
1
1
1
0
0
1
0
0
1
1
0
1
0
1
0
12
8.9
2.7
ND
ND
ND
15
7
1.2
ND
ND
5.4
ND
ND
8
1
ND
2
ND
1.4
ND
0.6
0.1
0.5
0.92
0.69
0.36
0.7
0.3
1
0. 7
3
0.3
1.6
1.6
0.1
0.1
1.1
0.1
0.8
0.2
0.4

-------
                                                            TABLE 3-7.  (CONT.)
REGION   LOCATION DESCRIPTION:

CONTAMINATED a SITES

  5     MI CLINTON RIVER - MT. CLEMENS


  5     MI FLINT RIVER, ELMS ROAD - FLINT
TYPE OF FISH      CUT OF SAMPLE     # DETECTED     VALUE (PPT)   DET LIMIT (PPT)
  5     MI KALAMAZOO RIVER - LAKE ALLEGAN

  5     MI MUSKEGON LAKE - MUSKEGON
        MI PINE RIVER - ALMA
        MI ST. GLAIR RIVER - ALGONAC
        MN RAINY RIVER - INTERNATIONAL FALLS
        OH GREAT MIAMI RIVER - FRANKLIN
        OH GREAT MIAMI RIVER - HAMILTON
BOTTOM FEEDER     WHOLE FISH
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR

BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              BOTTOM FEEDER
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                                      2.6
0.3
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
WHOLE FISH
F (skinless)
WHOLE FISH
F (skinless)
WHOLE FISH
WHOLE FISH
WHOLE FISH
FILET
WHOLE FISH
WHOLE FISH
WHOLE FISH
WHOLE FISH
FILET
1
1
1
0
1
0
1
1
0
1
1
1
1
1
1
1
2
0
28
5.1
1.6
ND
3
ND
5.2
3.9
ND
8.6
4.9
23
5.9
85
4.8
1.8
3.7
ND
0.02
0.23
0.23
0.12
0.7
1.4
2
1.6
2.4
0.4
0.3
0.52
0.1
0.11
1
0.13
0.3
0.6

-------
                                                            TABLE 3-7.  (CONT.)
REGION   LOCATION DESCRIPTION:

CONTAMINATED a SITES

  5     OH OHIO RIVER - EAST LIVERPOOL



  5     OH OHIO RIVER - GALLIPOLIS


  5     OH OHIO RIVER - MARIETTA



  5     OH OHIO RIVER - PORTSMOUTH



  5     OH SCIOTO RIVER - CIRCLEVILLE



  5     WI BLACK RIVER - BLACK RIVER FALLS
        WI ST. CROIX RIVER - ST. CROIX FALLS
        LA BAYOU LAFOURCHE - MATHEWS
TYPE OF FISH
BOTTOM FEEDER
PREDATOR
PREDATOR
BOTTOM FEEDER
PREDATOR
BOTTOM FEEDER
PREDATOR
BOTTOM FEEDER
PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                  CUT OF SAMPLE
# DETECTED
VALUE (PPT)   DET LIMIT (PPT)
WHOLE FISH
WHOLE FISH
WHOLE FISH
WHOLE FISH
WHOLE FISH
WHOLE FISH
WHOLE FISH

WHOLE FISH
WHOLE FISH
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
1
1
1
1
1
1
1

1
1
1
0
0
0
1
0
0
0
1
0
1
0
0.9
1.08
4
3.6
0.97
2
3.1

3.2
2.7
4.7
ND
ND
ND
1.8
ND
ND
ND
1.9
ND
1.9
ND
0.16
0.03
0.6
0.03
0.23
0.36
0.3 H
H
H
Ul
0.19 °°
0.4
0.2
1.4
0.9
0.9
0.7
1.1
0.3
0.5
0.2
0.72
0.1
0.67

-------
                                                            TABLE 3-7.   (CONT.)
REGION   LOCATION DESCRIPTION:

CONTAMINATED a SITES
TYPE OF FISH
CUT OF SAMPLE
# DETECTED
VALUE (PPT)   DET LIMIT (PPT)
        LA MISSISSIPPI RIVER - ST. FRANCISVILLE
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
        TX SAN JACINTO RIVER - LAKE HOUSTON
        IA BIG SIOUX RIVER - AKRON
        KS ARKANSAS RIVER - DERBY
        KS NEOSHO RIVER - CHETOPA
        KS TUTTLE CREEK RESERVOIR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
        MO LITTLE RIVER DITCHES - HORNERSVILLE
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                     1
                     0
                     1
                     1
                     1
                     0
                     0
                     0
                     1
                     0
                     1
                     0
                     1
                     0
                     0
                     0
                     1
                     0
                     0
                     0
                     1
                     1
                     1
                     0
5.3
ND
0.7
0.8
2.8
ND
ND
ND
1.3
ND
0.8
ND
2.4
ND
ND
ND
4.7
ND
ND
ND
1.9
0.4
1.3
ND
0.9
1
0.2
0.2
0.1
0.4
1.7
1.2
0.1
0.4
0.5
0.2
1.2
0.5
0.7
0.7
0.3
1.1
0.7
0.8
0.5
0.2
0.2
0.6








H
H
H
1
I/I















-------
                                                            TABLE 3-7.  (CONT. )
REGION   LOCATION DESCRIPTION:

CONTAMINATED a SITES

  7     MO MISSOURI RIVER - LEXINGTON
        MO ST. FRANCIS RIVER - CARDWELL
        ND RED RIVER - PEMBINA
TYPE OF FISH
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
CUT OF SAMPLE
# DETECTED
VALUE (PPT)   DET LIMIT (PPT)
   Contamination defined as detectable levels.
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
WHOLE FISH
FILET
WHOLE FISH


1
0
0
0
1
1
0
0


1.8
ND
ND
ND
3.4
1.8
ND
ND


0.2
0.6
0.6
0.1
0.21
0.72
0.8
0.72










H
H
H
Cfl
o

-------
                            TABLE 3-8.  ANALYTICAL RESULTS  FOR CONTAMINATED TIER  7 FISH SITES  - GREAT LAKES AREA
REGION   LOCATION DESCRIPTION:




CONTAMINATEDa SITES


  2     NY LAKE ONTARIO—BUFFALO RIVER





        NY LAKE ONTARIO—EIGHTEEN MILE CREEK
TYPE OF FISH      CUT OF SAMPLE    NO. DETECTED    VALUE (PPT)   DET LIMIT (PPT)
        NY LAKE ONTARIO—NIAGARA RIVER
        NY LAKE ONTARIO—OLCOTT
        NY LAKE ONTARIO—ROCHESTER
        NY LAKE ONTARIO—WILSON
BOTTOM FEEDER
BOTTOM FEEDER
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
PREDATOR
PREDATOR
PREDATOR
PREDATOR
PREDATOR
PREDATOR
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
1
1.9
0.76
6.3
ND
20
3.6
11
8.4
5.8
2.3
18
13
13
12
23
9
0.6
0.4
0.5
0.65
0.2
0.5
0.4
0.1
0.1
0.1
1.4
0.7
0.6
0.3
0.3
0.9
                                                                                                                            I
                                                                                                                            ff!
a Contamination defined as detectable levels.

-------
                                                                  TABLE 3-8.   (CONT.)
REGION   LOCATION DESCRIPTION:


CONTAMINATED3 SITES


  5     MI LAKE ERIE—TRENTON CHANNEL
TYPE OF FISH
                  CUT OF SAMPLE
                                   NO. DETECTED
VALUE (PPT)   DET LIMIT (PPT)
        MI LAKE ERIE—RIVER ROUGE
        MI LAKE ERIE—DETROIT RIVER
        MI LAKE MICHIGAN—ROCKPORT
        MI LAKE MICHIGAN—SANGATUCK
        MI LAKE MICHIGAN—WHITE LAKE
        MI LAKE ST. GLAIR—ANCHOR BAY
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
PREDATOR
PREDATOR
PREDATOR
PREDATOR
BOTTOM FEEDER
BOTTOM FEEDER
PREDATOR
PREDATOR
PREDATOR
PREDATOR
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
1
1
0
0
1
1
1
0
1
1
2
0
1
1
1
1
2
0
1
0
1
1
14
2.7
ND
ND
24.1
4.4
3.4
ND
9.1
8
3.8
ND
5.0
9.8
4.0
6.5
1.8
ND
1.1
ND
5.8
2.3
0.8
0.1
1.6
0.4
1.8
0.26
1.01
0.68
0.1
0.1
0.1
0.58
1.1
0.2
1.4
0.25
0.45
0.21
0.1
0.43
0.95
0.3
                                                                                                                           H
                                                                                                                           H

-------
                                                                  TABLE 3-8.  (CONT.)
REGION   LOCATION DESCRIPTION:

CONTAMINATED3 SITES

        MI LAKE HURON—SAGINAW BAY—CASEVILLE
TYPE OF FISH
        NY LAKE ONTARIO—OSWEGO
        OH LAKE ERIE—BLACK RIVER
        OH LAKE ERIE—CUYAHOGA RIVER
        WI LAKE MICHIGAN—FOX RIVER
        WI LAKE MICHIGAN—-MENOMINEE RIVER
        WI LAKE MICHIGAN—OCONTO RIVER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
CUT OF SAMPLE
                  WHOLE FISH
                  FILET
                  WHOLE FISH
                  FILET
                  FILET
                  WHOLE FISH
                  WHOLE FISH
NO. DETECTED
VALUE (PPT)   DET LIMIT (PPT)
                                   18
                                   13.2
                                    6.8
                                    0.7
                                                     41
                                    2.4
                                    3.1
                                0.5
                                0.4
                                0.1
                                0.2
                                                 1.1
                                0.19
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FILET
WHOLE FISH
FISH
WHOLE FISH
FILET
1
1
1
0
1
1
1
1
1
1
0
0
5.3
1.2
6
ND
7.3
8
1.4
1.8
3.6
1.2
ND
ND
0.3
0.3
1.5
0.48
0.7
0.1
0.1
0.2
0.5
0.2
1.5
0.2

-------
                                                                  TABLE 3-8.   (CONT.)
REGION   LOCATION DESCRIPTION:

CONTAMINATEDa SITES

        WI LAKE MICHIGAN—PESTIGO RIVER
        WI LAKE SUPERIOR—ASHLAND
        WI LAKE SUPERIOR—SUPERIOR
TYPE OF FISH
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              BOTTOM FEEDER
                                              PREDATOR
                                              PREDATOR
CUT OF SAMPLE    NO. DETECTED    VALUE (PPT)   DET LIMIT (PPT)
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
WHOLE
FILET
FISH

FISH

FISH

FISH

FISH

1
1
1
0
1
0
1
1
1
0
8.5
3.5
1.5
ND
4.8
ND
15
5.2
5.2
ND
0.6
0.29
0.38
0.22
0.4
1.3
0.2
0.71
0.46
1.2

-------
                                     TABLE  3-9.  RESULTS  OF ANALYSES  OF TIER 7 FISH - ESTUARINE AREAS
REGION   LOCATION DESCRIPTION:



CONTAMINATEDa SITES


  1     RI NARRAGANSETT BAY--NARRAGANSETT



  2     NJ SANDY HOOK BAY—LEONARD



  6     LA GARDEN ISLAND BAY—VENICE





        TX TRINITY BAY






a Contamination defined as detectable levels
MATRIX TYPE    NO. SAMPLED      NO. DETECTED     VALUE  (PPT)   DET LIMIT  (PPT)
 MUSSELS
 MUSSELS
 FISH-FILET
 FISH-WHOLE
 OYSTERS
0
1
                                                      3.5
                                                       1.08
 ND
3.3
                                                       2.2
                            1.7
                            0.03
1.8
0.1
                            0.3
                                                                               H
                                                                               H
                                                                               H

                                                                               CT>
                                                                               (Jl

-------
                           Chapter Four
                        COMBUSTION SOURCES

4.1  Objectives
     Tier 4 was designed as a screening study to determine  which
combustion source categories emit CDDs and at what concentra-
tions.  The main focus was on releases to the' ambient  air;
however, other samples, such as ash and scrubber water, were also
obtained to determine if these compounds  are released  to other
media.  Because some combustion sources were known to  emit  a wide
range of CDD and CDF compounds, tier 4 samples were analyzed for
specific homologues of CDDs and CDFs as well as for 2,3,7,8-TCDD,
the compound of most specific concern.

4.2  Background
     There are millions of combustion sources in the United
States.  Residential heating units burn oil, gas, coal, and wood
for heat.  Larger commercial, institutional, and utility boilers
burn fossil fuels to generate heat and electricity.  Many
industrial processes burn fuels and other raw or waste materials
to produce heat and/or to recover products of marketable value.
Other processes, such as incineration, use combustion  to reduce
the volume of unwanted waste products and to recover heat and
other resources from the waste products.  Open fires,  both
accidental (e.g., structural and forest fires) and intentional,
(i.e., those set for forest management and agricultural burning)
are other examples of combustion sources.
     Assessment of CDD and CDF emissions  from combustion sources
has been limited.  Previous work included studies of emissions
from hazardous waste incinerators, utility boilers and municipal
waste combustion.  Even for those source categories that have
been tested,  there is considerable variation in both the extent
and quality of testing and the test methods employed.

-------
                               IV-2
4.3  Study Design
     It was impractical to test all of the combustion source
categories under tier 4.  A study plan was developed that
identified those source categories which were believed to have
the greatest potential for CDD emissions.  Selection and
prioritization of source categories for testing were based upon a
review of CDD-related studies reported in the literature, and on
engineering judgment (EPA, 1984c).  Information from this review
suggested that the following conditions were most important for
CDD formation:
     1.  Presence of CDD in the materials being burned;
     2»  Presence of CDD precursors in the materials being burned
         (e.g., chlorinated phenols, chlorinated benzenes); and
     3.  Presence of chlorine, fuel and combustion conditions
         conducive to CDD formation, including:
         (a)  Relatively low combustion temperature (500-800°C);
         (b)  Short residence time of fuel in the combustion zone
              (
-------
                                IV-3
 TABLE 4-1.   COMBUSTION SOURCE CATEGORIES WHERE ASH AND STACK
             SAMPLES WERE COLLECTED
   Source Categories Sampled
                                                     Sample Type
Ash
Stack
   Sewage Sludge Incinerator

   Kraft Paper Recovery Boiler

   Industrial Waste Incinerator

   Wire  Reclamation Incinerator

   Secondary Copper Smelter

   Carbon Regeneration  Furnace

   Drum  and  Barrel  Furnace

   Wood  Stove

   Wood-fired Boiler

   Charcoal  Manufacturing Oven

   Mobile Source

   Utility Boiler

   Small  Spreader-Stoker Coal-fired  Boiler

   Commercial Boiler

   Kiln Burning Hazardous Waste

   Open Burning/Accidental  Fire

   Sulfite Liquor Boiler

   Apartment  House  Incinerator

   Hazardous  Waste  Incinerator

  Hospital Incinerator

   Municipal  Waste  Combustor

  Charcoal Grill
 X

 X

 X

 X

 X

 X

 X

 X

 X

 X



 X

 X

 X

 X

 X

 X

 X

 X

 X

 X

 X
X  (3)a

X  (3)

X  (1)

X  (1)

X  (1)

X  (1)

X  (1)

X  (1)

X  (1)




X  (2)
aNumber in parentheses indicates how many sources in the specified
 source category were stack tested under tier 4.

-------
                               IV-4
lists the source categories identified by the prioritization
effort.  A more complete explanation of the selection and
prioritization process is contained in the tier 4 Project Plan.
     The Project Plan was widely circulated for comment prior to
implementation.  Some of the source categories in Table 4-1 were
included primarily on the basis of reviewers' recommendations.
A few source categories (wood stoves and mobile sources) were
included because these sources were being tested for other
purposes, and the add-on cost of CDD/CDF testing was small.
Adjustments were made to the initial list as the study
progressed.
     Tier 4 sampling efforts focused on source categories that
had not been widely tested.  Although some municipal waste
combustors (MWCs) were known to emit CDDs, no additional stack
testing of this source category was performed directly under
tier 4.*  Compared to most other source categories, a relatively
large data base already existed.  In addition, other air
pollution control agencies, e.g., the New York Department of
Environmental Conservation and Environment Canada, were either
conducting or planning data collection studies for MWCs.
Selected MWC emission data and ash sampling results are
summarized later in this report.
     4.3.1  Sample Collection
     Two types of testing were considered for each of the source
categories listed in Table 4-1:
     Stack Sampling
     Stack sampling provides the best quantitative measurement of
emissions; however, it is expensive (e.g., $50,000-100,000 per
source, not including analytical costs).  Where possible, stack
gas samples were collected both before (inlet) and after (outlet)
   Subsequent to this decision, Congress directed EPA to
   provide a report specifically on municipal incinerator
   emissions of CDDs under the requirements of Section  102 of
   the Hazardous and Solid Waste Act of 1984.

-------
                               IV-5
any pollution control device.  Ash, feed, and soil samples were
also collected at sites that were stack tested.
     Because of the high costs, only 13 sources could be stack
tested.  Three kraft paper recovery boilers and three sewage
sludge incinerators were tested because they appeared to have
conditions particularly conducive to CDD formation.  Only one
source in each of the other selected source categories was
tested.  The focus of the testing program was primarily on
sources believed to be indicative of average to worst case
emission situations.
     Ash Sampling
     Ash samples were collected from air pollution control
devices (fly ash) or from residues of combustion  Cbottom ash) to
provide an indication of the presence of CDDs.  A secondary
objective of the tier 4 study was to examine possible
relationships between ash and stack test results.  If such a
relationship could be determined, inexpensive ash samples could
be used in lieu of expensive stack testing to identify source
categories with high CDD/CDF emission rates.  Use of ash data is
currently limited because observed correlations between levels of
CDDs in fly ash and CDD stack emissions are not sufficient for
quantitative use.  Ash samples were generally collected from
three sources in each of the source categories listed in Table
4-1.
     4.3.2  Site Selection
     Selection of test sites for stack and ash sampling was based
on a number of factors.  EPA Regional Offices recommended sources
based on the criteria outlined in the Project Plan (EPA, 1985b).
A technical analysis was conducted to determine the operational
parameters for a particular source category that would likely
result in a "representative" to "worst-case" emission situa-
tion.  Candidate sources were contacted, and pre-test survey
visits conducted, to identify plants with operations most closely
resembling the hypothesized conditions, which had acceptable
stack sampling locations.

-------
                               IV-6
     Once a site was selected' for stack testing, a detailed pre-
test plan was prepared which described the physical layout of  the
source, the location, number, and types of samples to be
collected, and associated quality assurance activities.  After
the test was completed, a separate report for each site was
prepared that described the actual testing performed and the test
results.
     Ash sampling sites were generally selected based upon
recommendations from Regional, State and local environmental
agencies.  Ease of sampling and level of participation by the
agencies were considered in those cases where several facilities
appeared to be of equal interest.  Ash samples were collected  by
State and local agencies and EPA contractors during the surveys
of candidate sources for the stack sampling program, as part of
actual stack sampling, and from selected additional facilities.
     4.3.3  Sampling Procedure and Analyses
     Consistent sample collection procedures were used at all
sites.  Sampling methodologies and procedures are described in
three tier 4 protocol documents.  One document describes the ash
sampling procedures, a second the stack sampling procedures, and
a third the quality assurance measures and procedures (EPA,
1985c, 1984d, 1985d).  The stack testing method used at tier 4
sampling sites is the state-of-the-art method proposed for use by
a joint American Society of Mechanical Engineers (ASME) and EPA
Work Group for municipal incinerators, with minor
modifications.  This procedure, which uses a modified EPA Method
5 sampling train, is described in detail in the stack test
protocol document.
     EPA1 s "Troika" of three in-house laboratories was
responsible for the analyses, as well as for the preparation of
the CDD and CDF analytical protocols and laboratory quality
control procedures to be used with tier 4 samples.  Analytical
methods are described in an addendum to a Troika procedures
document (EPA, 1986e).

-------
                               IV-7
     While the Troika was responsible for all CDD and CDF
analyses, an EPA contractor (Radian Corporation) provided support
for the analyses of other compounds.  For example, samples of the
fuels and other feed materials at each site were analyzed to
determine the presence of possible precursors (e.g., chlorinated
benzenes, biphenyls, and phenols).  In addition, continuous
emissions data were collected for various stack gases (e.g., CO,
CO2/ 02) during each stack test.  Analytical procedures used for
these analyses are described in a separate report (EPA, 1986f).
     A second EPA contractor (Research Triangle Institute)
conducted the quality assurance program, which  included auditing
three stack tests and introducing audit samples into the
laboratories to evaluate their performance.  The independent
quality assurance program, is described in a separate report
(EPA, 1985d).

4.4  Results
     Approximately 350 samples were collected, 20-25 percent of
which were for internal quality assurance purposes.  Thirteen
sources were stack tested and 72 sites were tested under  the ash
sampling program.  Collected samples were sent to the appropriate
analytical laboratory in accordance with established procedures.
     4.4.1  Tier 4 Stack Test Results
     Table 4-2 contains the CDD results for  the  13  sites  tested,
while Table 4-3 presents the CDF results.  Data  presented in
these tables represent concentrations of emissions  measured  in
the stack gases.  CDD/CDF stack concentrations have been
normalized to a 3 percent oxygen concentration.  This  removes  the
effect of dilution, and is a more appropriate means of  comparing
combustion processes.
     There is considerable variation  in the  concentrations  among
the sources tested under tier 4.  Each of the sources  with  valid
data had detectable levels of CDDs and CDFs, although  not all  had

-------
                                       TABLE  4-2.   TIER 4 CDD STACK TESTING RESULTS

                                                    (ng/dscm @ 3% 09)a
Source
Drum and Barrel Furnace
Industrial Carbon Regenerator
Industrial Waste Incinerator
Kraft Paper Recovery Boilers
Plant A
Plant B
Plant C
Secondary Copper Smelter
Sewage Sludge Incinerators
Plant A
Plant B
Plant C
Wire Reclamation Incinerator
Wood-fired Boiler
(Salt Laden Wood)
Wood Stoves
2,3,7,8-TCDD
0.05
NDC
4.5

ND
ND
ND
170

0.05
ND
0.14
0.07
0.28
NRe
Chlorinated Dibenzo-p-dioxin Homologues
Other
Tetra-
1.2
0.57
77

ND
ND
0.13
1400

11
0.40
8.1
1.2
47
MR
Penta-
0.72
0.44
100

ND
ND
0.15
2300

0.18
ND
1.1
2.2
48
NR
Hexa-
0.79
0.98
150

0.06
0.10
0.39
2200

0.51
ND
7.0
14
49
NR
Hepta-
1.3
0.90
230

0.18
0.26
0.88
5900

2.5
0.22
21
130
39
NR
Octa-
0.92
0.81
61

0.49
0.83
1.4
3700

5.3
0.98
15
290
11
NR
Totalb
Tetra-Octa
5.0
3.7
630

0.73
1.2
2.9
16,000

20
1.6
53
440
200
NR
                                                                                                                  H
                                                                                                                  00
 ng/dscm @ 3% 02 = nanograms per standard cubic meter of flue gas, normalized  to  3 percent  oxygen.
 Numbers across may not add up to totals due to rounding.
CND = Not detected, generally at less than 0.1 ng/dscm @ 3% 02«
 Estimated values.  Stack sampling results for this site do not meet analytical quality  assurance
 objectives, but represent lower level estimates.
eNR = Not reported due to organic interference.

-------
                                     TABLE  4-3.   TIER  4 CDF STACK TESTING RESULTS

                                                   (ng/dscm @ 3% 0?)a
Source
Drum and Barrel Furnace
Industrial Carbon Regenerator
Industrial Waste Incinerator
Kraft Paper Mill Recovery
Boilers
Plant A
Plant B
Plant C
Secondary Copper Smelter
Sewage Sludge Incinerators
Plant A
Plant B
Plant C
Wire Reclamation Incinerator
Wood-fired Boiler
(Salt Laden Wood)
Wood Stoves
2,3,7,8-TCDF
0.90
NDC
21

0.02
0.01
0.01
5100

NRe
2.1
54
0.40
1.8
NR
Chlorinated Dibenzofuran Homologues
Other
Tetra-
14
1.2
570

0.16
0.13
0.46
18,000

33
19
150
29
37
NR
Penta-
6.2
0.37
610

0.06
ND
0.46
1 9, 000

10
4.8
110
22
23
NR
Hexa-
3.0
0.59
650

0.07
0.34
0.59
6000

0.10
1.6
32
65
13
NR
Hepta-
2.0
0.61
470

0.16
0.17
0.50
1 1 , 000

0.5
ND
60
230
6.5
NR
Octa-
0.55
0.54
66

0.13
0.07
0.09
7200

0.10
0.07
45
230
0.92
NR
Totalb
Tetra-Octa
27
3.3
2400

0.59
0.71
2.1
65,000

44
28
450
580
83
NR
ang/dscm @ 3% 02 = nanograms per standard cubic meter of flue gas, normalized to 3 percent oxygen.
 Numbers across may not add up to totals due to rounding.
CND = Not detected, generally at less than 0.1 ng/dscm @ 3% O^-
^Estimated values.  Stack sampling results for this site do not meet analytical quality assurance
 objectives, but represent lower level estimates.
eNR = Not reported due to organic interference.

-------
                              IV-10
detectable levels of 2,3,1,8-TCDD.  The reported 2,3,7,8-TCDD,
CDD and CDF concentrations from the secondary copper smelter are
one or more order of magnitude larger than any other source
tested under tier 4, and as many as two to four orders of
magnitude greater than concentrations from some of the sources.
     A number of sources have considerably lower concentrations
than the secondary copper smelter, but considerably greater con-
centrations than a number of other sources.  On the other hand,
some sources (e.g., kraft paper recovery boilers) have very low
concentrations of 2,3,7,8-TCDD, CDDs and CDFs.  For most sources
the CDF concentrations appear to be closely related to those of
CDDs, i.e., sources which emit higher concentrations of CDDs also
emit greater amounts of CDFs.
     4.4.la  Quality Assurance
     The sampling and analysis in this study required the use of
state-of-the-art methods.  The stack sampling method is currently
undergoing validation testing.  Preliminary results indicate that
recovery efficiencies from the sampling train may be low and
variable.  Analytical methods were not always able to cope with
high levels of interfering contamination; thus, for some samples,
the desired validity and precision of results was not achieved.
     The stack gas samples collected at the secondary copper
smelter contained such high levels of CDDs and CDFs that the
sensitivity of the analytical procedures and equipment was
reduced.  Therefore, the results for this source represent
minimum levels, and actual values could have been considerably
higher.*
     At the wire reclamation incinerator, the levels of
concentration from other organic compounds in the sample were so
high, even after rigorous laboratory extraction and sample
*Subsequent to the tier 4 test, the secondary  copper  smelter  was
retested by the source in conjunction with  the State  agency.
This retest found CDD emissions to be one third of  the  tier 4
results while CDF emissions were  70 percent of the  tier 4  values,

-------
                              IV-11
cleanup procedures, that only estimates of CDDs and CDFs are
available.  At the wood stove site, it could not be determined if
CDDs/CDFs were present in any of the three stack test samples due
to similar organic contamination.  No results were obtained from
the mobile source exhaust samples because internal reference
standards were not added to the samples prior to the extraction
step in the analytical procedure.  At a few other sites,
relatively minor problems occurred with limited number of
samples, but these did not affect the analysis or the overall
integrity of the data.
     4.4.2  Results Reported in the Literature
     The scientific literature was reviewed to identify
combustion source studies that were similar in scope and
measurement methodology to tier 4.  CDD and CDF data for 17
sources in the U.S. and Canada are presented in Tables 4-4 and
4-5.  These results have also been normalized to a 3 percent
oxygen concentration.
     Table 4-6 has been prepared to facilitate a comparison of
these data with those obtained under the tier 4 program.  The
sources in Table 4-6 are listed in descending order of
2,3,7,8-TCDD concentrations.
     Eight source tests (seven coal-fired boilers and one co-
fired boiler firing fuel and refuse) reported in the literature
had "non-detectable" stack gas concentrations of CDDs and CDFs.
Pre-1986 data for municipal waste combustors (MWCs) are also
provided.

4.5  Discussion of Stack Test Results
     The determination of the ground level concentration includes
the impact on dispersion of stack height, stack gas temperature,
stack gas flow rate (i.e., the size of the source) and local
meteorological conditions, in addition to CDD and CDF stack

-------
                            TABLE 4-4.  CDD  EMISSIONS  DATA FROM STUDIES  SIMILAR TO TIER 4

                                                 (ng/dscm @ 3% 0?)a
Source
Hazardous Waste Incinerator
Hospital Incinerator
Municipal Carbon Regenerator
Municipal Waste Combustors
Plant A
Plant B
Plant C
Plant D
Plant E
Plant F
Co-fired Boiler
80% Coal/20% Refuse
Coal -fired Utility Boilers
Seven Plants
2,3,7,8-TCDD
1.4
NDC
ND

0.7
26
NR
0.8
16
NR
ND
NR

Other
Tetra-
64
ND
0.01

10
700
2.1
30
640
7
ND
ND
Chlorinated Dibenzo-p-dioxin Homologues
Penta-
8.3
74
0.13

NRd
1600
1.7
250
1700
18
ND
ND
Hexa-
1.3
65
0.37

26
1700
3.4
210
1200
36
ND
ND
Kept a -
1.1
79
0.47

12
1600
25
200
520
58
ND
ND
Octa-
2.4
110
1.6

4.1
860
14
15
210
90
ND
ND
Totalb
Tetra-Octa
77
330
3.3

53
6400
46
710
4300
2'10
ND
ND
                                                                                                                H

                                                                                                                f
                                                                                                                H
                                                                                                                10
ang/dscm @ 3% 02 = nanograms per standard cubic meter of flue gas, normalized to 3 percent oxygen.
Cumbers across may not add up to totals due to rounding.
CND = Not detected, generally at less than   1  ng/dscm @ 3% 02.
 Not reported.

-------
                           TABLE 4-5.  CDF EMISSIONS  DATA FROM STUDIES  SIMILAR TO TIER 4

                                                                 \a
                                                 (ng/dscm @ 3% 02)c
Source
Hazardous Waste Incinerator
Hospital Incinerator
Municipal Carbon Regenerator
Municipal Waste Combustors
Plant A
Plant B
Plant C
Plant D
Plant E
Plant F
Co-fired Boiler
80% Coal/20% Refuse
Coal-fired Utility Boilers
Seven Plants
2,3,7,8-TCDD
2.1
NRC
0.02

NR
31 Od
NR
4
57
NR
ND
NR
Chlorinated Dibenzofuran Homologues
Other
Tetra-
170
130
1.4

150
3300
14
65
1400
38
ND
ND
Penta-
12
220
1.1

NR
4200
9.4
60
2100
63
ND
ND
Hexa-
4.8
200
0.76

100
2200
15
13
1400
78
ND
ND
Hepta-
0.81
120
0.76

12
1600
56
3
400
62
ND
ND
Octa-
0.24
65
0.72

1.0
120
22
NDe
41
12
ND
ND
Totalb
Tetra-Octa
190
735
4.8

260
11,600
120
150
5300
250
ND
ND
                                                                                                              H"
                                                                                                              U)
ang/dscm @ 3% 02 = nanograms per standard cubic meter of  flue gas,  normalized to 3 percent oxygen.
lumbers across may not add up to totals due to rounding.
°Not reported.
^nly three of eleven tests conducted at this site  reported  2, 3, 7, 8-JTCDF.
eND = Not detected, generally at less than   1 ng/dscm  @  3%  02»

-------
                                    IV-1 4
TABLE 4-6.  TIER 4* AND OTHER SOURCES LISTED  IN RANK ORDER  BY
            2,3,7, 8-TCDD CONCENTRATIONS
                                                a
                               (ng/dscm @ 3% 02)
Source
*Secondary Copper Smelter
Municipal Waste Combustor - Plant B
Municipal Waste Combustor - Plant E
•Industrial Waste Incinerator
Hazardous Waste Incinerator
Municipal Waste Combustor - Plant D
Municipal Waste Combustor - Plant A
*Wood-fired Boiler
*Sewage Sludge Incinerator - Plant C
*Wire Reclamation Incinerator
*Sewage Sludge Incinerator - Plant A
*Drum and Barrel Furnace
Hospital Incinerator
Municipal Waste Combustor - Plant F
Municipal Waste Combustor - Plant C
*Industrial Carbon Regenerator
Municipal Carbon Regenerator
*Kraft Paper Recovery Boiler - Plant C
*Sewage Sludge Incinerator - Plant B
*Kraft Paper Recovery Boiler - Plant B
*Kraft Paper Recovery Boiler - Plant A
Co-fired Boiler (coal and municipal waste)
Coal-fired Utility Boilers (7 Plants)
2, 3, 7, 8-TCDD
170
26
16
4.5
1.4
0.8
0.7
.28
.14
.07
.05
.05
NDC
NRd
NR
ND
ND
ND
ND
ND
ND
ND
NR
Total CDDs
16,000
6,400
4,300
630
77
710
53
200
53
440
20
5
330
210
46
3.7
3.3
2.9
1.6
1.2
0.7
ND
ND
Total CDFs
65,000
11 ,600
5,300
2,400
190
150
260
83
450
580
44
27
735
250
120
3.3
4.8
2.1
28
0.7
0.5
ND
ND
 ng/dscm @ 3% 02 = nanograms per standard cubic meter of flue
 gas, normalized to 3 percent oxygen.
 Data reported for this site are "estimated minimum".  The  true
 value may be higher.
CND = Not detected, generally at less than 1 ng/dscm @ 3% 02«
dNR = Not reported.

-------
                              IV-15
concentrations.  These parameters were entered into the
dispersion component of the Human Exposure Model (HEM) to
estimate the annual average ground level concentration in the
vicinity of the source.  In the application of this model to the
tier 4 data, it is assumed that the CDD and CDF emitted from the
stack is a gas.  This assumption is believed to be a reasonable
one for these sources.  While different calculated ambient air
concentrations could result from particle deposition, it is
believed that such effects would not be significant because
1) these sources are generally low level emitters; and 2) the
particle size is likely to be small enough that the effect of
deposition on ambient air concentration will not be a significant
factor.
     As discussed in Chapter 1, EPA uses "2,3,7,8-TCDD toxic
equivalency factors" (TEFs) to estimate the toxicity of other
CDDs and CDFs.  The TEFs for the various CDDs and CDFs were
presented in Table 1-1.  In applying the TEF approach, CDDs/CDFs
for a particular homologue were assumed to be the most toxic
isomer, thus yielding an upper bound estimate.  The particular
TEF values used in this tier are presented in Table 4-7.
     The calculated maximum ground level concentration, estimated
annual loadings, and 2,3,7,8-TCDD equivalents for the tier 4
sources and for most of the sources from the literature are
presented in Table 4-8.*  To place these results in some
perspective, the cancer risk from inhalation exposure to a ground
level concentration of 1 picogram per cubic meter of 2,3,7,8-TCDD
equivalents is estimated at 3.3 chances in 100,000, assuming 70
years of continuous exposure.  As with the stack concentration
data, there is considerable variability among the various sources
*Ground level concentrations were not calculated for the eight
 sources with nondetectable CDD/CDF emissions.  Neither the
 hospital incinerator nor the municipal waste combustor, Plant
 F, are included in Table 4-8.

-------
                                   IV-16
     TABLE 4-7.  RELATIVE POTENCY FACTORS USED IN ESTIMATING
                 2,3,7,8-TCDD EQUIVALENTS
Compound ( s )
2,3,7,8-TCDD
Other TCDDs*
Penta-CDDs
Hexa-CDDs
Hepta-CDDs
Octa-CDDs
2,3,7,8-TCDF
Other TCDFs*
Penta CDFs
Hexa-CDFs
Hepta-CDFs
Octa-CDFs
Relative Potency Factor
1.0
0.01
0.5
0.04
0.001
0.000
0.1
0.001
0.1
0.01
0.001
0.000
* NOTE;  In situations where 2,3,7,8-TCDD or 2,3,7,8-TCDF  were  not
         chemically analyzed in the sample, then TCDDs  and
         TCDFs will have a relative potency factor of 1.0  and
         0.1, respectively.

-------
                                TABLE  4-8.  TIER 4 AND OTHER SOURCES LISTED IN RANK ORDER BY  2,3,7,8-TCDD EQUIVALENTS'
Source
*Secondary Copper Smelter6
Municipal Waste Combustor - Plant B
Municipal Waste Combustor - Plant E
Municipal Waste Combustor - Plant D
*Industrial Waste Incinerator
Municipal Waste Combustor - Plant A
*Wood-fired Boiler
*Sewage Sludge Incinerator - Plant C
*Wire Reclamation Incinerator6
Hazardous Waste Incinerator
Municipal Waste Combustor - Plant C
*Sewage Sludge Incinerator - Plant A
*Drum and Barrel Furnace
*Sewage Sludge Incinerator - Plant B
* Indus trial Carbon Regenerator
Municipal Carbon Regenerator
*Kraf t Paper Recovery Boiler - Plant C
*Kraf t Paper Recovery Boiler - Plant A
*Kraft Paper Recovery Boiler - Plant B
2,3,7,8-TCDD
Equivalents
(ng/dscm @ 3% 02)b
3900
1400
1300
140
130
56
29
25
10
7.4
5.7
1.3
1.2
0.52
0.31
0.20
0.12
0.01
<0.01
Annual Average
Maximum Ground
Level Concentration0
(pg/m3)
1.5
9.1
1 .5
3.0 x 10~2
1.2 x ID"2
0.3
6.1 x ID"2
0.91
9.1 x 10~3
9.1 x 10~2
0.24
3.0 x 10~3
6.1 x 10~5
1.2 x 1Q~3
3.0 x 10~4
1.5 x 10~3
1.5 x 10~4
3.0 x 10~5
3.0 x 10~5
2378-TCDD
Equivalent Emissions
(g/year)d
800
500
140
95
0.7
80
0.6
2
1 x 10~2
2
1 x 10~5
2 x 10~2
9 x 10~3
4 x 10~2
2 x ID"2
4 x 10"5
0.3
3.0 x 10~2
3.0 x 10~2
                                                                                                                            H
  Sources tested by Tier 4.
a Isomer-specific data are generally not available.  Homologue data are considered to be composed
  of the most toxic isomers.
  ng/dscm @ 3% 02 = Nanograms per standard cubic meter of flue gas, normalized to 3 percent oxygen.
c Ground level concentration calculation assumes compounds are present at analysis detection
  limits when reported as not detected (ND).
  Assumes 8160 operating hours per year.
6 These values are estimated.  True values may be higher.

-------
                              IV-18
for all three of these parameters.  In general the sources with
the highest stack concentrations of 2,3,7,8-TCDD, CDDs and CDFs
also had the highest ground level concentrations.  One notable
exception is the sewage sludge incinerator, Plant C.  Stack
concentrations at this plant are about two to three orders of
magnitude less than those of the secondary copper smelter, yet
the ground level concentrations from the two sources differ by
less than a factor of two.  The sewage sludge incinerator has a
relatively low stack with low temperature flue gas coupled with a
high plant throughput, which leads to a relatively high ground
level concentration impacting a small area very near the plant.
On the other hand, the secondary copper smelter has a relatively
tall stack with high temperature flue gas which results in a
comparable ground level concentration, but at a significantly
greater distance from the plant.  The area impacted by this
concentration is much greater.
     In addition to estimating ground level concentrations, EPA
has prepared a preliminary assessment of the potential cancer
risks from inhalation associated with emissions from these facil-
ities.  A detailed discussion of the risk assessment is not
included in this report due to the concerns raised by EPA's
Science Advisory Board (SAB) during its review of the study.  The
SAB cautioned that risks were likely to be higher than estimated
if exposure pathways other than inhalation were considered  (e.g.,
food chain), and if more sources had been tested.  EPA agrees
with these comments and is currently developing a procedure to
consider the risks associated with secondary pathways of
exposure.  Further testing of other sources may be considered as
the Agency moves forward with its ongoing effort to decide
whether CDDs/CDFs should be listed as hazardous air pollutants.
     Tier 4 stack test program results and preliminary risk
assessments have been provided to appropriate State air pollution
control agencies for their information and use.

-------
                              IV-19
4.6  Tier 4 Ash Sampling Results
     Three different types of samples were collected:  bottom
ash, fly ash, and scrubber water effluent.  Bottom ash is the
residue left in the combustion chamber as a result of the
combustion process.  Fly ash is the material collected by air
pollution control devices which would otherwise be released to
the ambient air.  Scrubber water effluent samples are samples
obtained from wet scrubbers, an air pollution control device
which uses water to filter both particulate and gaseous
pollutants from the exhaust gas stream.
     Ash sample results for the 72 tier 4 sites are summarized in
Tables 4-9 and 4-10.  Table 4-9 presents data from the source
categories with detectable values of 2,3,7,8-TCDD equivalent
while Table 4-10 is a listing of the source categories where
2,3,7,8-TCDD equivalent was not detected in the ash.  A total of
87 samples were analyzed from the 72 sites.
     CDDs and CDFs were found in about one-third of the bottom
ash and fly ash samples and one-half of the scrubber effluent
samples.  The highest concentrations were typically found in fly
ash samples.  Ash samples were collected from 21 different source
categories.  Twelve of the source categories had one or more ash
samples with detectable concentrations.
     It is presently difficult to interpret the significance of
the ash data from an air pollution perspective.  One of the
objectives of the study was to determine a correlation between
fly ash and stack emission concentrations.  While the presence of
CDDs and CDFs in the fly ash appears to be a good indicator of
the presence of CDDs and CDFs in the stack emissions, no
quantitative relationship has yet been observed that could
reliably predict the magnitude of CDD/CDF emissions in the stack
gases.

-------
                IV-20
TABLE 4-9.  TIER 4 ASH SAMPLING RESULTS
Source Category/Source Sampled
Wire Reclamation Incinerator
Source-C
Source-A
Source -A
Source-A
Source-A
Source-B
Source -D
Secondary Copper Smelter
Source-B
Source-A
Wood Fired Boiler
Source-A
Source-C
Source-B
Source-D
Source-A
Source -E
Source -F
Source -G
Source-H
Municipal Waste Combustor
Source-C
Source-D
Source-B
Source-B
Source-B
Source-C
Hazardous Waste Incinerator
Source-B
Source-A
Source-C
Carbon Regeneration Furnace
Source-C
Source-A
Source-B
Sample Type

Fly Ash
Fly Ash
Bottom Ash
Fly Ash
Bottom Ash
Fly Ash
Fly Ash

Fly Ash
Fly Ash

Fly Ash
Fly Ash
Fly Ash
Scrubber Effluent
Bottom Ash (2 Samples)
Fly Ash
Fly Ash
Fly Ash
Fly Ash

Fly Ash
Fly Ash
Scrubber Effluent
Scrubber Effluent
Bottom Ash
Scrubber Effluent

Scrubber Effluent
Bottom Ash
Scrubber Effluent

Fly Ash
Fly Ash
Scrubber Effluent
2,3,7,8-TCDD
Equivalent
(ppb)

656a
87
32
21
4
0.3
NDb

117a
13

158
135
51
0.1
ND
ND
ND
ND
ND

142
44
4
3
0.3
0.1

42.9
ND
ND

18
0.1
ND

-------
                                  IV-21
            TABLE 4-9.  TIER 4 ASH SAMPLING RESULTS (continued)
Source Category/Source Sampled
Sewage Sludge Incinerator
Source -C
Source-F
.Source -B
Source -A
Source -C
Source-C
Source-D
Source -G
Source -H
Source -I
Source-J
Industrial Waste Incinerator
Source-A
Commercial Boiler
Source -B
Source-A
Hospital Incinerator
Source-D
Source-B
Source-A
Source-D
Source-C
Drum and Barrel Furnace
Source-B
Source-E
Source-C
Source-A
Source-B
Source-D
Apartment House Incinerator
Source-A
Source-B
Source-C
Source-D
Sample Type

Scrubber Effluent
Scrubber Effluent
Bottom Ash
Bottom Ash
Bottom Ash
Scrubber Effluent
Scrubber Effluent
Bottom Ash
Bottom Ash
Bottom Ash
Scrubber Effluent

Bottom Ash

Fly Ash
Fly Ash

Fly Ash
Fly Ash
Bottom Ash
Bottom Ash
Bottom Ash

Bottom Ash
Bottom Ash
Bottom Ash
Bottom Ash
Bottom Ash
Bottom Ash

Bottom Ash
Bottom Ash
Bottom Ash
Bottom Ash
2,3,7,8-TCDD
Equivalent
(ppb)

8
5
0.1
ND
ND
ND
ND
ND
ND
ND
ND

2

1
ND

0.9
0.6
0.4
0.4
ND

0.5
0.3
0.2
ND
ND
ND

0.3
0.1
ND
ND
       values are estimated.  The true values may be higher.
"ND = Not detected, generally less than 0.08 ppb.

-------
                                  IV-22
           TABLE 4-10.  TIER 4 ASH SAMPLING RESULTS WITH BELOW
                   DETECTION LIMIT ASH SAMPLE RESULTS'
Source Category Sampled
Charcoal Grill
Charcoal Manufacturing Oven
Kiln Burning Hazardous Wastes
Kraft Paper Recovery Boiler
Open Burning/Accidental Fires
Small Spreader Stoker Coal Fired Boiler
Sulfite Liquor Boiler
Utility Boiler
Wood Stove
Number of Samples
Fly
Ash
-
2
3
5
-
3
-
3
-
Bottom
• Ash
1
1
-
-
2
1
-
-
3
Scrubber
Effluent
-
-
-
-
-
-
4
-
-
Detection limit generally less  than 0.08 ppb.   Listed alphabetically.

-------
                               IV-23
     Table  4-11 provides  a  comparison  of  the  data  from sources
with both fly ash  and  stack test  samples.   This  table  illustrates
the apparent lack  of correlation  between  the  two types of
samples.  For example,  the  secondary copper smelter, which  had
significantly higher stack  concentrations  than any other source,
has fly ash concentrations  more than an order of magnitude  lower
than some other sources.  Other sources with  relatively low stack
emissions had fairly high fly ash  concentrations.   At  this  time,
ash data do not appear  to be a reliable indicator  of the relative
magnitude of CDD/CDF emissions in  the  stack.  Fly  ash  samples,  on
the other hand, are believed to be  fairly  reliable indicators of
the presence of CDDs/CDFs in stack  emissions.
     The ash sampling  results have  been transmitted through EPA's
Regional Offices to the appropriate State  and local agencies for
their consideration.  Although of  limited  usefulness for air pol-
lution control purposes,  the data  do provide  a measure of the
level of contamination  in the ash  that is  disposed of  as a  solid
waste.

4.7  Findings and  Conclusions
     This investigation included a  review  of  information in the
literature and a sampling program  for  the  combustion source
categories believed to have the greatest potential  to  emit  CDDs
and CDFs.  The findings from this  investigation  are presented
below.
     (a)  CDDs and CDFs have been detected  in the  stack emissions
from most, though  not all, combustion source  categories tested to
date.   All of the  sources stack tested under  tier  4, and most of
the combustion source categories tested by  others  reported  in the
literature,  had detectable concentrations  of CDDs  and  CDFs.
     (b)  There is considerable variability in the  emission  rates
among  source categories.  For example, measured  CDD emissions
ranged more  than four orders of magnitude  from "nondetected" at
seven  coal fired power plants tested (detection  limit  at less
than 1 ng/dscm)  to approximately 16,000 ng/dscm  of  total CDDs at

-------
                                 IV-24




            TABLE 4-11.   COMPARISON OF ASH AND STACK EMISSIONS

                 AT SOURCES WITH CONCURRENT MEASUREMENTS
Source
Wood Fired Boiler
Municipal Waste Combustor - Plant C
Secondary Copper Smelter
Industrial Carbon Regenerator
Kraft Paper Recovery Boiler C
Kraft Paper Recovery Boiler A
2,3,7,8-TCDD Equivalents
Fly Ash
(ppb)
158
142
13
0.1
ND
ND
Stack Emissions
(ng/dscm @ 3% O2)a
29
5.7
3900b
0.31
0.12
0.01
ang/dscm @ 3% O- = Nanograms per standard cubic meter of flue gas,
 normalized to 3 percent oxygen.
bThese values are estimated.  The true values may be higher.

-------
                              IV-25
a secondary copper smelting facility.  Most of  the  combustion
source categories fell within an  intermediate range, generally
two to three orders of magnitude  less than the  concentrations at
the secondary copper smelting facility.
      (c)  EPA has not yet determined the magnitude  of the
potential population risk from these sources.   An effort is
underway to consider risk from all routes of exposure (e.g.,
inhalation, ingestion, dermal contact) and for  evaluating
procedures for estimating nationwide impacts from these sources.
      (d)  The presence of CDD/CDF in the fly ash from a control
device appears to be a good indicator of the likely presence of
CDD/CDF in the stack emissions.   Presently, however, it does not
appear that the ash samples can be used to reliably estimate the
magnitude of CDD and CDF stack emissions from a particular
source.  Continued use of expensive stack test  methods appears to
be necessary.

4.8  Continuing Efforts
     Although the tier 4 study has been completed,  the Agency
plans a number of continuing efforts with respect to CDD
emissions from combustion sources.  These include:
      (a)  A detailed technical report describing the tier 4
program is being finalized.
      (b)  EPA issued a report to Congress on July 1, 1987
responding to the requirements of section 102 of the Hazardous
and Solid Waste Amendments of 1984 concerning CDD emissions from
municipal waste combustors.  This effort also identified design
and operating guidelines to minimize CDD emissions.
      (c)  EPA has decided that additional Federal regulation of
municipal waste combustor emissions is warranted under section
111 of the Clean Air Act.  The regulatory determination was
published in the Federal Register on July 7, 1987 (52 FR 25399).
     (d)  EPA plans to continue its evaluation  of CDD/CDF
emissions from various sources.   EPA has not yet determined

-------
                              IV-26
whether CDDs/CDFs should be listed as a hazardous air pollutant
under section 112 or otherwise regulated under other sections of
the Clean Air Act.
     (e)  EPA is continuing its efforts to standardize and refine
stack sampling and analysis procedures to reflect improvements in
the state-of-the-art.  The recommended ASTM stack test
methodologies for municipal waste combustors are currently being
validated by the Agency.

-------
                           Chapter Five
                      REGULATORY ACTIVITIES

     EPA has issued regulations under  the authorities of RCRA,
TSCA, and FIFRA to control the generation, use, and disposal of
many CDD/CDF containing materials and  their precursors.  This
chapter reviews the highlights of several completed or ongoing
regulatory initiatives.

5.1  RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) LISTING OF
     DIOXIN CONTAINING WASTES AS HAZARDOUS WASTES  (OFFICE OF
     SOLID WASTE)
     EPA's rulemaking regarding dioxin containing wastes was
published in the Federal Register on January 14, 1985, and became
effective on July 15, 1985.  The regulation designates as acutely
hazardous a number of waste streams containing tetra-, penta-,
and hexachlorodibenzo-jD_-dioxins and dibenzof urans:
     -  Wastes from the production or manufacturing use of tri-,
        tetra-, and pentachlorophenol  and their chlorophenoxy
        derivatives.
        Wastes from the manufacturing use of tetra-, penta-, or
        hexachlorobenzene under alkaline conditions.
     -  Discarded, unused formulations of tri-, tetra- or
        pentachlorophenol and their derivatives.
        Wastes from equipment previously used for production or
        manufacturing use of tri- and  tetrachlorophenol.
     Residues from the incineration or thermal treatment of soil
contaminated with the listed wastes are designated as hazardous
rather than acutely hazardous.
     Generators, treaters, storers, and disposers of the listed
wastes are subject to stringent management and disposal
standards:
     -  Generators are subject to the  1 kg/month exclusion limit,
        i.e., facilities generating more than 1 kg/month are
        subject to the listing.
        Incinerator and thermal treatment units must be fully
        permitted or be certified by the Assistant
        Administrator/OSWER as meeting the Technical Standards in
        40 CFR Part 264.  These units must demonstrate the "6-

-------
                               V-2
        9's" (i.e., 99.9999 percent) Destruction and Removal
        Efficiency (ORE) that is also required for PCB
        destruction.

        Land disposal facilities which plan to accept dioxin
        wastes must be fully permitted and must submit a Waste
        Management Plan with the permit application.


5.2  PCB TRANSFORMER FIRE RULE  (OFFICE OF TOXIC SUBSTANCES)

     5.2.1  Summary of the Rule

     EPA recently strengthened its August 25, 1982, rule

regarding PCB transformers by placing additional restrictions and
conditions on their continued use.  These requirements are

intended to reduce the fire-related risks posed by the continued

use of PCB transformers.

     5.2.2  Background

     Fires involving PCB transformers can cause the rupture of

PCB transformers, the release of PCBs, and the formation and

distribution of PCBs and toxic products of incomplete

combustion.  Products formed from the incomplete combustion of

PCB dielectric fluid containing tetrachlorobenzene include

2,3,7,8-TCDF and 2,3,7,8-TCDD.  When PCB transformer fires occur

in or near buildings, building occupants as well as emergency
response personnel, cleanup crews, and members of the general
public can be exposed.

     The PCB transformer fire rule established the following
requirements:

     (1)  High secondary voltage PCB transformers (480 volts and
          above) configured in a network fashion and used in or
          near commercial buildings must be removed from use,
          placed into storage or disposal, disposed of, or
          reclassified to PCB-contaminated or non-PCB status by
          Oct. 1, 1990.

     (2)  PCB transformers can no longer be installed in
          commercial buildings after Oct. 1, 1985.

     (3)  PCB transformers used in or near commercial buildings
          (other than high secondary voltage network PCB
          transformers) must be equipped with enhanced electrical
          protection by Oct. 1, 1990, to avoid failures and fires
          from sustained electrical faults.

-------
                                V-3
      (4)  All  transformers  must  be  registered  with  appropriate
          emergency  response  personnel  and  with  building  owners
          by Dec.  1,  1985.
      (5)  All  PCB  transformer locations  must be  cleared of  stored
          combustible materials  by  Dec.  1,  1985.
      (6)  All  PCB  transformer fire-related  incidents  must be
          immediately reported to the National Response Center,
          and  measures must be taken as  soon as  practically and
          safely possible to  contain potential releases of  PCBs
          and  incomplete combustion products to  waterways.

      EPA defines commercial buildings to include  all  types  of
buildings other than  industrial  facilities  and would  include
locations such as  office buildings, shopping centers,  hospitals,
and colleges.
      In addition,  while EPA concluded that  there  are  several
substitutes for PCBs  in electrical  transformers,  preliminary data
indicate that  chlorinated benzenes  and perchloroethylene  (both of
which have been proposed as substitutes  for PCBs) may  also  lead
to the formation of CDFs and  CDDs in combustion  situations.  EPA
advised that the replacement  of  PCB dielectric fluid with
materials which in fire situations  may also lead  to the formation
of CDFs and CDDs should be  carefully considered  in light  of  the
Agency's decision  in this rule to place  conditions and
restrictions on the use of  PCB transformers.   EPA will evaluate
the need for additional action should this type of substitution
occur.

5.3  CANCELLATION OF REGISTRATION OF 2,4,5-T (OFFICE OF PESTICIDE
     PROGRAMS)
     Registered in 1948, the phenoxy herbicides 2,4,5-T and
silvex were used to control broad leaf weeds in or on forests,
rangelands, pasturelands, orchards and other crop lands,  homes
and gardens, certain aquatic areas, and  rights-of-way such as
roads, railroads, and electric utility lines.  In 1970, acting on
the basis of animal tests showing potential teratogenic (birth
defects)  effects of 2,4,5-T, the U.S.  Department of Agriculture
halted uses of  this pesticide in instances where there was a high

-------
                               V-4
exposure potential:  home and garden, recreational areas, and
aquatic sites.  All food uses of 2,4,5-T, except for rice, were
halted as well.
     In February 1979, EPA took emergency action immediately
suspending all use of 2,4,5-T and silvex herbicides on forests,
pastures, and rights-of-way, and use of silvex on or around
aquatic sites, homes and gardens, recreational areas, and
ornamental turf.
     All registrations for 2,4,5-T and silvex have now been
cancelled.

5.4  AMBIENT WATER QUALITY CRITERIA DOCUMENT  (OFFICE OF WATER)
     Under the Clean Water Act  (CWA), 2,3,7,8-TCDD is listed as
one of the 65 compounds and classes of compounds which EPA is
required to control in industrial effluents.
     In support of this requirement, EPA has published an Ambient
Water Quality Criteria Document  (EPA, 1984a) for 2,3,7,8-TCDD.
As specified  in section 304(a)(l) of the CWA, this document
reflects the  latest scientific  knowledge on the kinds and extent
of all identifiable effects on  health and welfare which may be
expected from the presence of 2,3,7,8-TCDD in any body of water,
including groundwater.
     States use EPA's ambient water  quality criteria  in setting
water quality standards.  These  standards take  into account
particular water bodies and their designated uses.  State water
quality standards  are enforceable maximum acceptable  levels of a
pollutant in  ambient water.

5.5  WOOD PRESERVATION PESTICIDES—PENTACHLOROPHENOL, CREOSOTE,
     INORGANIC ARSENICALS   (OFFICE OF PESTICIDE PROGRAMS)
     EPA rulemaking and a negotiated agreement  requires phased
reduction of  the hexachlorodibenzodioxin  (HxCDD)  level  in
pentachlorophenol  or  its salts  to 4  ppm.  The 2,3,7,8-TCDD  level
in this chemical must be below  the limits of detection  using gas
chromatography/mass spectrometry (GC/MS).

-------
                               V-5
     A number of additional use restrictions, handling

requirements and public information provisions are also included

in the document:

     -    All three chemicals are to be classified for Restricted
          Use Only by Certified Applicators except for brush-on
          treatment of inorganic arsenicals and except for
          creosote application on pilings, pole framing, and
          railroad ties.  For the latter use, the applicator must
          complete an EPA-approved training course.

          Impermeable gloves are required for all uses, plus
          additional clothing and respirators in certain
          situations.

          Eating, drinking, and smoking are prohibited during
          application of all three chemicals.

     -    A teratogenicity/fetotoxicity warning is required on
          the labels for all uses of pentachlorophenol and
          related salts.

     -    Application of pentachlorophenol (or its salts) or
          creosote to interiors is prohibited.

     -    EPA will also require information on health effects,
          worker/user exposure, and effectiveness of protective
          measures.

          Industry will put into effect a voluntary Consumer
          Awareness Program, the focus of which will be the
          distribution of a Consumer Information Sheet containing
          safe use and handling recommendations regarding treated
          wood products.  One recommendation is that treated wood
          shall not be used in contact with food, feed, or
          drinking water.  Another is that creosote- and
          pentachlorophenol-treated wood not be used in
          interiors, with certain exceptions.


5.6  TSCA §4/§8 RULEMAKING  (Office of Toxic Substances)
     On December 19, 1985, EPA proposed a Dioxin/Furan Testing

Rule in the Federal Register.   This purpose of the rule is to
develop information on additional chemicals which may contain

CDDs/CDFs as well as those containing other halogens (e.g.,

brominated compounds).  As previously discussed, EPA's National

Dioxin Strategy focused primarily on 2,3,7,8-TCDD contamination

associated with 2,4,5-trichlorophenol (TCP).

     The proposed rule under section 4 of the Toxic Substances

Control Act (TSCA) will require manufacturers and importers of 12

-------
                               V-6
commercial organic chemicals to test for the presence of certain
chlorinated and brominated dibenzo-j>-dioxins and dibenzofurans.
In addition, this testing will be required for 20 other
commercial organic chemicals not currently manufactured or
imported, should their manufacture or importation resume.
     EPA also proposes, under section 8(a) of TSCA, to require
manufacturers and importers of the 12 commercially produced
chemicals to submit existing test data on contamination of these
chemicals with CDDs or CDFs and to require similar information on
the 20 other chemicals, should commercial manufacture or
importation resume.
     If data from the testing proposed under this rule, or other
valid existing test data, show that these commercial chemicals
contain CDDs at concentrations at or above specified levels, EPA
proposes to require, with respect to the chemicals, the
submission of:  (1) production, process, use, exposure, and
disposal data under section 8(a) of TSCA; (2) unpublished health
and safety studies under section 8(d) of TSCA; and (3) records of
allegations of significant adverse reactions both to the
chemicals and to the CDDs/CDFs under section 8(c) of TSCA.
     The chemicals proposed for testing are listed below along
with their Chemical Abstract Services (CAS) registry numbers,
where available.
   CAS No.
    Chemical name
      79-94-7
     118-85-2
     118-79-6
     120-83-2
    1163-19-5
    4162-45-2
   21850-44-2
   25327-89-3
   32534-81-9
   32536-52-0
   37853-59-1
   55205-38-4
Tetrabromobisphenol A
2,3,5,6-Tetrachloro-2,5-cyclohexa-
  diene-1,4-dione
2,4,6-Tribromophenol
2,4-Dichlorophenol
Decabromodiphenyloxide
Tetrabromobisphenol A bisethoxylate
Bis(2,3-dibromopropyl) ether of
  tetrabromobisphenol A
Allyl ether of tetrabromobisphenol A
Pentabromodiphenyloxide
Octabromodiphenyloxide
1,2-Bis(tribromophenoxy)ethane
Tetrabromobisphenol A diacrylate

-------
                               V-7
5.7  LAND DISPOSAL BAN EVALUATION FOR DIOXIN CONTAINING WASTES
     (OSW)
     The 1984 Hazardous and Solid Waste Amendments to RCRA banned
certain untreated dioxin-contaminated wastes from land
disposal.  In the November 7, 1986 Federal Register, EPA promul-
gated treatment standards for those wastes based on Best Demon-
strated Available Technology (BOAT).  For thermal treatment pro-
cesses, BDAT for these wastes has been determined to be a
destruction and removal efficiency (DRE) of 99.9999 percent
("6-9's").  Following treatment, residues may be disposed of in a
permitted hazardous waste land disposal facility.
     Due to the current lack of disposal capacity for these
wastes, EPA has, as provided by law, extended the effective date
of the ban for 2 years.  In the interim, these wastes may be
placed in fully permitted facilities.  As of July 1987, no land
disposal facilities have applied for permits to handle the
affected wastes.

-------
                           Chapter Six
                             RESEARCH

6.1  Introduction
     Dioxin research at EPA began in 1970, when 2,3,7,8-TCDD was
found to be a contaminant of the commonly used herbicide,
2,4,5-T.  This research effort was generally limited to
developing a methodology for detecting 2,3,7,8-TCDD in
environmental samples.  Additional impetus was generated in 1984,
when Congress enacted legislation specifically directed toward
this class of chemicals.  The 98th Congress appropriated specific
resources for dioxin research in human toxicity, disposal
methods, and sampling quality assurance.
     In response to Congressional concern, the Agency established
a dioxin research program during FY'1984, under the framework of
the National Dioxin Strategy.
     The Strategy specifically charged EPA's Office of Research
and Development (ORD) with the following tasks:  (1) pilot
testing of promising disposal/destruction techniques including a
comprehensive study of binding characteristics of 2,3,7,8-TCDD to
soils, and field validation of destruction techniques;
(2) guidance in sampling and analytical methods for detection and
quantification, including quality assurance; (3) conducting
hazard and exposure assessment for site-specific risk
assessments, including establishing exposure scenarios; and (4)
evaluation of the bioavailability of dioxins for use in food
chain models.
     The Agency began its research program by focusing on the
most toxic isomer, 2,3,7,8-TCDD. The scope of more recent
research has expanded to include other isomers and related
compounds such as chlorinated dibenzofurans.  The Agency is also
evaluating information on the toxicity of the brominated
CDDs/CDFs.

-------
                               VI-2
     By establishing an International Information Exchange under
the North Atlantic Treaty Organization (NATO) Committee on
Critical Challenges of Modern Society (CCMS), EPA has taken
initiative to coordinate its research with that of other
industrialized nations concerned with dioxins.  The United
States, the Federal Republic of Germany, and Italy are
coordinators of this project.
     There are four areas of EPA dioxin research:  technology
assessment research evaluates technologies for the control and
ultimate destruction or detoxification of dioxins; monitoring
research develops analytical methodologies and quality assurance
procedures for identifying and quantifying dioxins within biotic
and abiotic matrices; environmental effects research considers
the fate, mobility, and effects of dioxins in the environment,
and determines the uptake and bioavailability in plants and
living systems; health assessment research develops both the
methodologies and the data base necessary for evaluating human
health exposure and risks associated with CDDs/CDFs.

6.2  Technology Assessment
     Since the inception of this research program, the Agency has
made significant progress in evaluating and refining techniques
for cleanup of CDDs/CDFs and related compounds.  This includes
field work on detoxification of dioxin-contaminated soils using
Potassium Polyethylene Glycolate (KPEG) reagents; field testing
of the EPA Mobile Incineration System (MIS) at the Denney Farm
site near McDowell, Missouri; in situ stabilization testing using
Portland cement and lime-treated asphalt; and an evaluation of
the utility of surface mines as repositories for dioxin-
contaminated soils.  Controlled laboratory tests have shown that
the white rot fungus, Phanerochaete chrysosporium, is capable of
degrading 2,3,7,8-TCDD, DDT, lindane, PCBs, and other difficult
to degrade halogenated organics.
     EPA's Mobile Incineration System was designed and built  to
provide on-site thermal destruction of hazardous organic

-------
                               VI-3
substances.  The total system consists of:  (1) major
incineration and air pollution control equipment mounted on three
heavy-duty semitrailers; (2) combustion and stack gas monitoring
equipment housed within a fourth trailer; and  (3) ancillary
support equipment.
     In 1983, trial burns were conducted in Edison, New Jersey on
RCRA-listed surrogates, including di-, tri-, and tetra-
chlorobenzene, and tetrachloromethane.  Currently, the mobile
incinerator is installed at the Denney Farm site near McDowell,
Missouri, where tests were conducted using both clean soil and
soil contaminated with surrogates similar to those employed in
the earlier liquid waste tests.  Tests using dioxin-contaminated
liquid wastes and soils verified the destruction and removal
efficiency (DRE) and the effectiveness of the control devices.
Interim delisting guidelines were established and analyses were
conducted on ash, treated soils, filter materials, and
process/quench water.  The analyses determined that the
guidelines were attainable.
     The dioxin trial burns were successful, with DREs exceeding
99.9999 percent.  Particulate emission permit limitations  «180
mg/rn^ @ 7% 02) were achieved in three of four test runs.   The
fourth run exceeded the prescribed limit slightly, possibly due
to the accumulation of submicron-sized particles in the air
pollution control system.  The observed CO emission values (1.3-
7.7 ppm) are equivalent to those from the best available
incineration technologies and are indicative of very complete
combustion (Combustion Efficiencies  = 99.993-99.999 percent).
     The trial burn data supported the issuance of Federal and
State permits required for extended use of the system at the
Denney Farm site.
     As of February 1986, about 2 million pounds of dioxin-
contaminated solids (including soil, drums, and trash) and about
18,000 gallons of 2,3,7,8-TCDD containing liquid wastes have been
processed.

-------
                               VI-4
     The KPEG chemical destruction  technique was  used  success-
fully in the states of Montana and  Washington  to  detoxify
pentachlorophenol-oil (PCP) and spent solvent  waste  contaminated
with dioxin.
     A mobile treatment unit mounted on a  45-foot  trailer  was
used to process 8,650 gallons of PCP wood  treating chemical  waste
at the Montana Pole site in Butte,  Montana, and 7,550  gallons  of
an oily spent solvent waste at the  Western Processing  site in
Kent, Washington.  These wastes were contaminated  with as  much as
120 parts per billion (ppb) of 2,3,7,8-tetrachlorodibenzo-p-
dioxin and other CDDs/CDFs at levels as high as 125,000  ppb.   No
dioxins or furans were detected in  the treated oil at  limits of
detection in the parts per trillion  (ppt)  range.
     A battery of bioassay tests was used  to ascertain whether
KPEG by-products:  (a) bioaccumulated in tissues of  organisms;
(b) caused cell mutations; or (c) caused immediate harm  to fish
or mammals.  There was no evidence  that the by-products  were
toxic in any of the tests performed.

6.3  Monitoring
     At the onset of the program, the existing analytical
capability was insufficient to routinely analyze a large number
of samples containing dioxins.  As  previously discussed, the
Agency has developed a collaborative network of three  of its
laboratories (ERL-Duluth, Minnesota; EMSL-Research Triangle  Park,
North Carolina; and ECL-Bay St.  Louis, Mississippi), referred  to
as the "Troika".  The Troika has significantly improved  the
Agency's analytical capability and  has made a major  contribution
to the state-of-the-art of analysis of 2,3,7,8-TCDD  and  other
CDDs/CDFs.
     A pilot round-robin survey of  trace analyses of CDDs  and
CDFs in adipose tissues has been completed.  Such methods  will
allow more accurate characterization of 2,3,7,8-TCDD exposure  by
measuring actual body burden.

-------
                               VI-5
     A monoclonal antibody to detect and measure dioxins has been
produced with sufficient specificity to warrant further
characterization.  These and other rapid screening techniques
show promise in terms of both sensitivity and selectivity  in
quickly determining the present (or absence) of 2,3,7,8-TCDD.

6.4  Environmental Effects
     Environmental effects studies have shown that dioxins are
very tightly sorbed onto soils and that both organic contaminant
content and actual organic matter are important factors  in
controlling dioxin movement in soils and the degree of binding  to
the soil matrix.  Recent studies indicate that in large  chemical
waste landfills and in wood preserving facilities, the physical
and chemical properties of the soils are quite different  from
other sites previously studied, and the dioxins are much  more
mobile.
     Bioavailability studies in laboratory samples of
contaminated soils from Missouri and New Jersey have shown that
differences in the bioavailability of 2,3,7,8-TCDD from  these two
soils correlate with its extractability.  These differences may
be related to the different compositions of the soils, the
differences in the types of application of dioxin to the  soil,
and the residence time of dioxin on the soil.  Thus, public
health risks may vary between sites as a function of contaminants
present and bioavailability from the matrix.
     Uptake studies have shown that, in comparison to other
isomers, 2,3,7,8-TCDD preferentially bioaccumulates in fish.
Limited plant uptake studies are being conducted to verify
hypotheses regarding dioxin movement into plants and thereafter
into food chains.  Uptake studies of dioxins by large animals
will also evaluate food chain contamination to humans through
animal products.
     EPA has also developed exposure assessment methods  for
2,3,7,8-TCDD for five scenarios through which humans could be
exposed to dioxin.  Nomographs were developed for approximating

-------
                               VI-6
upper bound carcinogenic risk.  In addition, the risk assessment
methods used by EPA for 2,3,7,8-TCDD were assembled and
contrasted to those which were adopted by CDC and FDA.

6.5  Health Assessment
     ORD has completed the Health Assessment Document for
Polychlorinated Dibenzo-p_-Dioxins, which provides a comprehensive
multimedia assessment of the analytical methodologies,
environmental levels, and ecological and health effects of four
chlorinated dioxins.  A similar document is being prepared for
2,3,7,8-TCDF.
     An ongoing pharmacokinetic study of 2,3,7,8-TCDD in rhesus
monkeys will provide results on distribution, accumulation,
depuration, and transfer of 2,3,7,8-TCDD in offspring.  A battery
of immunological tests to analyze the results of exposing female
rhesus monkeys and their offspring to 2,3,7,8-TCDD is also being
developed.
     Short-term in vitro bioassays and chemical analytical
techniques for specially synthesized higher chlorinated CDDs  and
CDFs are being developed for comparison to in vivo animal
assays.  These in vitro assays will be evaluated with regard  to
their usefulness in providing complementary information or in
serving as surrogates for in vivo toxicity assays.  Lack of
sufficient exposure information is often the reason that a causal
relationship cannot be drawn between an agent and a human effect.
NIOSH/CDC Mortality Study of Exposed Workers
     NIOSH has included 14 sites  in a dioxin registry.
Approximately 7,000 workers have  been identified, and standard
methods of followup are being used.  Inclusion  in the registry
requires company records showing  worker assignment to 2,4,5-T,
2,4,5-TCP, or pentachlorophenol processes.  Demographic data  have
been coded for all workers, and the coding of detailed work
histories  is in process.  Discussions of the chemical process and
job duties have been completed at all but one site and have been
initiated  for the remaining site.  Data have been collected on

-------
                              VI-7
analytic measurements of dioxin in products, wastes, and process
streams.  This information is being used in the construction of
the exposure matrix for the study.  Completion is expected in
1988.
     In addition to an Office of Health Research contribution to
begin the registry in FY'84, Superfund resources are being
provided to the register for a 3-year period that began in FY'84.
NIOSH/CDC Morbidity Study
     In November 1986 NIOSH initiated a study of occupationally
exposed workers at 2 of the 14 plants covered in the dioxin
registry.  The study was designed in cooperation with the States
of New Jersey and Missouri and is being conducted with Superfund
resources.
     Blood serum analysis procedures recently developed by CDC
will confirm exposure and establish body burdens.  Review of
medical records and testing during medical examinations will
investigate a number of health end points.  Results will be
compared to a control group of unexposed people from workers'
current neighborhoods.  The study is scheduled for completion in
1990.
     Because actual exposure to 2,3,7,8-TCDD has been confirmed
through blood sampling, this study may provide much needed
information on the human health consequences of 2,3,7,8-TCDD
exposure.
Missouri Health Effects Studies
     CDC conducted an immunological study of residents of the
Quail Run Mobile Home Park, Gray  Summit, MO, where contaminated
oil was used to control road dust.  Results were compared with
those from a group of residents of other mobile home parks where
no contamination was found.  Some members of the high risk group
did not respond to skin test antigens  (anergy).  Of those that
did respond, positive reactions were obtained for fewer antigens
than in the unexposed group  (relative  anergy).

-------
                               VI-8
     Unfortunately, there were significant methodological flaws
in the study (nearly 50% of the data had to be discarded due to
interpretation problems).  Further, there was no demonstrated
association between observed effects and clinical manifestations
of illness.
     Several other dioxin*-related studies have been conducted or
are underway in Missouri including the adipose tissue study
discussed in Chapter 1, a reproductive outcome study, and
comprehensive physical examinations of residents of Quail Run
Mobile Home Park.

-------
                            REFERENCES


EPA.  1987a.  Bellin, J. and Barnes D.   Interim Procedures for
Estimating Risks Associated with Exposures to Mixtures of
Chlorinated Dibenzo-p-dioxins and Dibenzofurans.  EPA/625-3-
87/012.March, 1987.

EPA.  1987b.  The National Dioxin Study, Tiers 3, 5, 6, and 7
Office of Water Regulations and Standards.  EPA 440/4-87-OU3.
February, 1987.

EPA.  1987c.  National Dioxin Strategy, Tier 1 and 2
Accomplishments.  Office of Solid Waste and Emergency Response.

EPA.  1986a.  National Dioxin Study - Tier 4 - Combustion
Sources, Project Summary Report, USEPA Office of Air Quality
Planning and Standards.

EPA.  1986b.  Analytical Procedures and Quality Assurance Plan
for the Analysis of Tetra through Qcta Chlorinated Dibenzo-p-
dioxins and Dibenzofurans in Samples from Tier 4 Incineration
Process, Draft.  Environmental Monitoring Systems Laboratory,
U.S* Environmental Protection Agency, Research Triangle Park,
North Carolina, January 1986.

EPA.  1986c.  National Dioxin Study, Tier 4 - Combustion Sources,
Engineering Analysis Report.  EPA Contract No. 68-02-3889, Radian
Corporation, Research Triangle Park, North Carolina, March 1986.

EPA.  1986d.  National Dioxin Study, Tier 4 - Combustion Sources,
Quality Assurance Evaluation.  EPA-450/4-84-014f, Office of Air
Quality Planning and Standards, U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina, January 1986.

EPA.  1985a.  Health Assessment Document For Polychlorinated
Dibenzo-p-Dioxin.  USEPA, Office of Health and Environmental
Assessment.  Washington, DC.  EPA 600/8-84/014F.

EPA.  1985b.  National Dioxin Study, Tier 4 - Combustion Sources,
Project Plan.  EPA-450/4-84-014a, Office of Air Quality Planning
and Standards, U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina, February 1985.

EPA.  1985c.  National Dioxin Study, Tier 4 - Combustion Sources,
Ash Program.  EPA-450/4-84-014d, Office of Air Quality Planning
and Standards, U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina, January 1985.

EPA.  1985d.  National Dioxin Study, Tier 4 - Combustion Sources,
Quality Assurance Project Plan.  EPA-450/4-84-014e, Office of Air
Quality Planning and Standards, U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina, June 1985.

-------
EPA.  1985e.  National Dioxin Study/ Tier 4 - Combustion Sources,
Final Literature Review^EPA Contract No. 68-02-3889, Radian
Corporation, Research Triangle Park, North Carolina, September
1985.

EPA.  1984a.  Ambient Water Quality Criteria for 2,3,7,8-
Tetrachlorodibenzo-p-d ioxin.  USEPA Office of Water Regulations
and Standards.  Washington, DC.  EPA-440/5-84-007.

EPA.  1984b.  Devaut, D. Polychlorinated Dioxins and
Polychlorinated Furans in Fish from the Greak Lakes and Mid-
West.  USEPA Great Lake National Program Office.

EPA.  1984c.  National Dioxin Study, Tier 4 - Combustion
Sources;  Initial Literature Review and Testing Options.  USEPA
Monitoring and Data Analysis Division, Research Triangle Park,
NC.  EPA-450/4-84-014b.

EPA.  1984d.  National Dioxin Study, Tier 4 - Combustion Source,
Sampling Procedures.  USEPA Office of Air Quality Planning and
Standards, Research Triangle Park, NC.  EPA-450/4-84-014c.

EPA.  1983.  Dioxin Strategy.  Office of Water Regulations and
Standards and Office of Solid Waste and Emergency Response in
Conjunction with Dioxin Management Task Force.  Washington, DC,
November 28, 1983.

EPA, 1980.  Dioxins.  Industrial Environmental Research
Laboratory, Cincinnati, Ohio.  EPA-600/2-80-197.

Adams, W.J., DeGraeve, G.M., Sabourin, T.D., Cooney, J.D. and
Mosher, G.M.  Toxicity and Bioconcentration of 2,3,7,8-TCDD to
Fathead Minnows  (Pimephales Promelas), Chemosphere, Vol.  15, Nos.
9-12, p. 1503, 1986.

DiDomenico, A.,  Silano, V., Viviano, G. and Zapponi, G.
Accidental  release of 2 , 3 ,7 ,8-_tetrachlorodibenzo-p-dioxin
(2,3,7,8-TCDD) at Seveso,  Italy.   IV.  Vertical distribution of
2,3,7,8-TCDD  in  soil.  Ecotoxicology and  Environmental  Safety
4:327-338,  1980.

Freeman, R.A., Shroy, J.M.  Modelling the Transport of  2,3,7,8-
TCDD and other low volatility  chemicals in soils.   Environ. Prog.
5(1), 1986.

Kimbrough,  R.D.,  Folk H.,  and  Stehr,  D.   Health  Implications of
2,3,7,8-TCDD  Contamination  of  Residential Soil.  Journal  of
Toxicology  and  Environmental  Health,  Vol.  14,  pp.  47-93,  1984.

Kuehl,  D.W.,  Cook, P.M.,  Batterman, A.R.,  Butterworth,  B.C.
Isomer  Dependent Bioavailability  of Polychlorinated Dibenzo-p-
dioxins and Dibenzofurans  from Municipal  Incineration  Fly Ash to
Carp.   Chemosphere,  1986  (in  press).

-------
Mehrle, P.M.  TCDD and TCDF impact on rainbow trout:  An
assessment of chronic toxicity and bioconcentration.  Columbia
National Fisheries Research Laboratory, Fish and Wildlife
Service.  Task Report to the Environmental Research Laboratory.
USEPA  1986.

Miller, R.A., Logan, N.A., and Hawkes, C.C.  Toxicity of 2,3,7,8-
TCDD in Aquatic Organisms, Environmental Health Perspectives
Sept. 5, 1973, pp. 177-186

Paterson, D.G., Jr., and others.  Level of 2,3,7,8-TCDD in
adipose tissue of exposed and control persons in Missouri.  An
Interim Report (Journal of the American Medical Association, in
press) 1986.

Umbreit, T.H., Hesse, E.J., Gallo, M.A.  Bioavailability of
Dioxin in Soil from a 2,4,5-T Manufacturing Site, Science, Vol.
232 pp. 497-499, April 25, 1986.

-------