United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
August 1987
EPA/530-SW-87-025
Solid Waste
National Dioxin Study
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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
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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
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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
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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
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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
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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
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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.
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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
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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
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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.
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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.
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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.
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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
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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
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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:
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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
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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
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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
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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
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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).
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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.
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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)
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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.
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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.
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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.
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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.
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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.
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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
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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
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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.
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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
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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
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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.
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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.
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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.
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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.
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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.
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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
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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
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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
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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
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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.
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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.
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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.
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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.
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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).
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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.
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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 <
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P 17.6
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? 1.1-364
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£ 1.3
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——————— MH
9 10. 1
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-------
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.
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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
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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
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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
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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.
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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
-------
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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.
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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.
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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.
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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
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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.
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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.
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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
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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.
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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
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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.
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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-
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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.
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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
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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).
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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
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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
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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.
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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.
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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
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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.
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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.
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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
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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
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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).
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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.
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