;'-'-909
                             LISTING WASTE OIL AS A HAZARDOUS WASTE

                                       Report to Congress
                            This report (SW-909) was  prepared by the
                       Office of Solid Waste as required  by section 8(2)
                   of the Used Oil Recycling Act of 1980  (Public Law 96-463)
                       and was delivered to Congress  on January 16,  1981
                                      US. Ervi'omeptai  PiCt2cl:on Agency.
                                      Rep/.on  V. Libr.ry
                                      230 C-X'l^  Duller-  Street
                                      Chicago, Illinois  60604
                               U.S.  ENVIRONMENTAL PROTECTION AGENCY
                                               1981

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'-909
                            LISTING WASTE OIL AS A HAZARDOUS WASTE

                                      Report to Congress
                           This report (SW-909) was prepared by the
                      Office  of Solid Waste as required by section 8(2)
                 of  the  Used Oil Recycling Act of 1980 (Public Law 96-463)
                      and was delivered to Congress on January 16, 1981
                                    U.S.  Environmental  Protection Agency.
                                    Region V. Library
                                    230 S.'X't'i Dcaiborn Street    ^
                                    Chicago, Illinois  60604
                            U.S. ENVIRONMENTAL  PROTECTION AGENCY
                                             1981

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US. Enwfoonments! Protection Agency

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON. DC  20460

                             JAN 1 6 1981
                                                THE A
Honorable Walter F. Mondale
President of the Senate
Washington, D.C. 20510

Dear Mr. President:

    I am pleased to transmit the Report to Congress "Listing
of Waste Oil as a Hazardous Waste" pursuant to Section  (8)(2)
of the Used Oil Recycling Act of 1980, Public Law 96-463.

    The Report presents the Agency's basis for determining
that certain waste oils are hazardous wastes according to the
criteria promulgated under subsections (a) and (b) of Section
3001 of the Solid Waste Disposal Act, as amended by the Resource
Conservation and Recovery Act (RCRA) of 1976.  The information
presented here will be used later this year to support the
proposed listing of these waste oils as hazardous wastes under
Section 3001 of RCRA.  At that time, the Agency will also pro-
mulgate proposed rules under Sections 3002 through 3004 and
3012 of RCRA for the transportation, treatment, storage, dis-
posal, and recycling of waste oils determined to be hazardous
wastes.

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       3  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
      
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                                CONTENTS
INTRODUCTION   	    1

DEFINITION OF  WASTE  OIL   	    2

SUMMARY OF LISTING DETERMINATIONS  	    3

UNUSED WASTE OIL   	    5
  I. Chemical  compos It Ion	    5
     A. Crude  Oil  	    5
     B. Refined oil  products   	    6
 II. Sources and Management Pract ices   	    9
     A. Spills  	    9
     B. Vessel Operat ions   	   14
     C. Inadequate Handling or Formulation   	   15
III. Basis for Listing   	   16
     A. Adverse effects of crude and refined oil
        products:  	   16
        1. Aquatic environment   	   16
        2. Human health  	   21
        3. Drinking  water  	   33
     0. Hazards posed by mismanagement  	   35

USED OIL  	   42
  I. Constituents and Management Practices   	 	   42
     A. Automotive   	   42
     B. Industr ial   	   52
        1. Lube Oils   	   53
           a. Metalworking  	   53
           b. Railroad and Marine   	   57
        2. Non-lube  Oils   	   58
           a - Hydraui ic Oils   	   58
           b. Transformer Oils   	   59
           c. Turbine Oils  	   60
           d. Quenching Oils   	   61
 II. Basis for Listing   	   63
     A. Adverse effects of contaminants  in used oil  	   63
     B. Hazards posed by mismanagement  	   71

References  	   79

Appendices  	   87

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                            INTRODUCTION






     This document  presents  the  Administrator's basis  for  list-



  ing waste oil  as a hazardous  waste.   Under  Section  3001 of  the



  Resource Conservation and  Recovery Act  (RCRA), the  listing  of a



  solid waste as a hazardous  waste brings  it  under the  control of



  a comprehensive management  system which  regulates the transport-



  ation, treatment,  storage,  and  disposal  of  hazardous  wastes.



     Section 3001 of RCRA directs EPA  to  identify those solid



  wastes Which should be subject  to the hazardous waste regulations



  prescribed under Sections  3002  through  3004 of RCRA.  In  addition,



  recognizing the significant threat to human health  and the  envi-



  ronment posed when used oil*  is improperly  managed, the Congress



  passed the Used Oil Recycling Act (P.L.  96-463).  Section 8 of this



  Act requires, no later than January 13,  1981, for the Administrator



  to: (1) determine whether used oil is a hazardous waste, as defined



  in Section 3001 of RCRA? and  (2) report  to  the Congress the basis



  for this determination.  The Act also directs EPA,  no later than



  October I"), 1931,  to promulgate regulations which protect human



 health and the environment from the hazards associated with



 recycled used oil.



    The purpose of this document is to present the Admiristrator' s



 basis for listing certain waste oils  (including certain used oils)



 as hazardous wastes.  Later this year, the  Agency plans to  issue



'proposed rules to  (1) list, these oils as hazardous wastes and (2)
 * As explained below, used oils are a subset of waste oils.

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establish regulations for their transportation, treatment, stor-

age, disposal, and recycling.


                      DEFINITION OF WASTE OIL

   This section desci'ibes the universe of waste oil covered  i.n

this document.  First, this document addresses only pet.coieum-

darived oil.  Oils derived from vegetable or aninal fats are not

included because they are generally not toxic to humans or aquatic

life.1  Additionally, the Used Oil Recycling Act limits the

statutory definition of "used oil" to oil derived from petroleum

and, thus, it is appropriate for EPA to similarly restrict the

regulatory definition of "waste oil".

   Second, EPA is defining petroleum-derived oils as those which

meet the following three characteristics:

     (1) lack a defined chemical structure;

     (2) contain mixtures of isomers*; and

     (3) contain three or more members of an homologous

         series which differ by a fixed carbon-containing

         increment.**

Petroleum-derived wastes meeting the above criteria are defined as

waste oils; petroleum-derived wastes not meeting these criteria are
*   An isomer is a molecule having the same number and kind of
atoms as another molecule, but differing from it in respect to
atomic arrangement or configuration.

**  An homologous series  is a series of organic compounds in
which each successive member differs by a fixed increment in
certain constituents from the proceeding member.  For example,
CH3H (methanoi), C2H50H (ethanol), and C3H7OH (butanol) form
an homologous series.

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                                -  3  -


candidates  for designation as  "other hazardous wastes"*.   This

method of distinguishing waste  oils from other petroleum-derived

hazardous wastes  is the same as that used by EPA to  implement

regulations  for oil vs. other hazardous materials under Section

311 of the  Clean  Water Act (CWA).**2

   Finally,  this  document addresses both unused and  used waste

oil.  Unused oil  generally becomes  a waste oil when  it is  spilled,

when  it mixes with other wastes (e.g., a ship's ballast water),

or when it  fails  specifications for its intended use and is dis-

carded (e.g., ASTM D396 specifications for fuel oils).  Used oil

becomes a waste oil when it is  contaminated with physical  or

chemical impurities resulting  from  use, such that, the oil  cannot

be reused for its original purpose  without, first removing  these

impurit ies.



                SUMMARY OF LISTING  DETERMINATIONS

    In regulations prescribed pursuant to Section 3001 of  RCRA,

solid wastes are  listed as toxic hazardous wastes if they  contain
*  Thus, using this approach, waste automotive crankcase oil is
deemed to be a waste oil rather than an "other hazardous waste"
because  it  (I) lacks a definite chemical structure, (2) contains
multiples of isomers, and  (3) contains members of an homologous
series in which each successive member has one more CfH group
in its molecule than the next preceeding member.  By contrast,
petroleum-derived, waste PCBs are regulated as "other hazardous
wastes"  rather than as waste oils because the members of the
homologous series that they contain do not. differ by a carbon-
containing increment.  The homologous series increment, instead
of containing carbon, is made up of a chlorine atom.

** It is important that the regulated community be able to dif-
ferent iate between waste oils and other petroleum-derived wastes
because  there will be different requirements under RCRA for these
two types of wastes.

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                                - 4 -


any of a number-of desigated constituents* unless, after con-

sideration of multiple factors, EPA concludes that the waste

does not pose a substantial present or potential threat to human

health and the environment when improperly treated, stored, trans-

ported, disposed of, or otherwise managed.  These multiple factors

include the type of toxic threat posed; the concentrations of the

toxic constituents in the waste; the migration potential, persist-

ance and degradation potent.ial of the toxic constituents; the

degree to which the toxic constituent.s bioaccumulate in ecosystems;

the plausible types of improper management to which the waste

could be subjected; the quantities of waste generated; damage

incidents involving wastes containing the toxic constituents; and

actions taken by other governmental agencies with respect to the

waste or its toxic constituents.3

   Using these criteria, the Administrator has determined that
                   r
the following waste oils are hazardous wastes, and thus should

be subject to the regulations prescribed under Sections 3002

through 3004 of RCRA:

   1. Oil spilled to land, and oily debris generated from

      cleaning-up spills to land or surface water;

   2. Used automotive oils; and

   3. Used industrial oils.

The exception to this are any of the above waste oils whose pet-

roleum base is white oil.
* These constituents are ones which have been shown in reputable
scientific studi.es to have toxic, carcinogenic, mutagenic, or
teratogenic effects on humans or other life forms.

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                               - 5  -






                         UNUSED WASTE  OIL



     This  chapter  first  discusses the chemical  composition of



unused oil.  The  sources and quantities generated of several



categories of  unused  waste oil,  and the management practices



typically used to store, treat,  recycle, or dispose of  it are



presented next.   This  is followed  by the Agency's rationale for



listing certain unused  waste oils  as hazardous wastes,  including



a description  of  the potential human health and environmental



hazards posed  by  improper management of these waste oils.






I. Chemical composition



   The chemical composition of crude oil and refined oil pro-



ducts are described below.  As explained later in this chapter,



certain constituents  in the oil-component of wastes containing



unused oil pose a potential threat to human health and the



environment when  these  wastes are  improperly managed.



A. Crude  oil



   Crude  oil is not a chemically well-defined substance, but a



complex mixture containing literally thousands of compounds,



including hydrocarbons, sulfur-  oxygen- and nitrogen-containing



compounds, and metallo-organic compounds.   Although oils from



various parts of the world differ widely in their content of



the above substances, they are generally divided into three main



groups on the basis of their predominant hydrocarbon structure:



paraffinic,  naphthenic, and aromatic.



   Paraffinic  (alTcanic) crude oils contain mostly saturated



straight and branch-chained carbon compounds,  along with lesser



amounts of cycloaikanes and aromatics.   Naphthenic crudes contain

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                               - 6 -


appreciable quantities of compounds with at least one saturated

ring structure  (cycloakanes).  Aromatic crude oils contain a

large concentration of unsaturated benzene ring structures.  The

varying proportion of these three classes of compounds (alkanes,

cycioalkanes, and aromatic hydrocarbons) determine the physical,

as well as the chemical properties of crude oils.

   Although the relative quantities of these compounds differ in
                          t
crude oils, an average of the gross compositional data on all

world crude yields the following approximate composition for the

"average" crude oil:4

     paraffin hydrocarbons (alkanes)                  30%

     naphthene hydrocarbons (cycloalkanes)            50%

     aromatic hydrocarbons                           15%

     nitrogen, sulfur and oxygen-                     5%

        containing compounds

Although any specific crude may differ appreciably from these

average values, it can be assumed that all  crude oils contain

some of all three types of hydrocarbons identified above.



B. Refined oil products

   Refined oil products (e.g., lubricating  oils) also lack

constant chemical compositions.  The  two factors responsible for

this variation are crude oil source and the process used to refine

the oil.  The first factor was described above; the second is dis-

cussed below.

   A complex combination of inter-dependent processes form the

basis of refinery operations.  These  may include fractionation,

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                               -  7  -


cracking, polymerization, and  hydrotreating.  The particular

combination of processes used  at a refinery determines the com-

position of the final product.  For example, catalytic cracking

and related conversion processes favor the formation of olefins,*

aromatics, and branched paraffins  at the expense of other types

of hydrocarbons.  Solvent treating, on the other hand, removes

aromatics, cycloparaffins and  olefins.5  The processes used at a

refinery are chosen based on the type (e.g., fuel oil, lubricating

oil) and characteristics (e.g., high octane, low freezing point)

of the products that are desired.

   Despite the fact that the composition of refined products is

highly variable, the following general characterizations can be *

made.  The compounds in refined products are similar to those found

in crude oils with the addition of (1) the olefin class of hydro-

carbons, and (2) chemical additives** designed to make the product

perform more efficiently.  Table 1 presents "average" values for

the percentage of hydrocarbon  compounds found in various refined

products.

   As noted earlier, a refinery's products may vary significantly

from these values, depending on the source of crude oil and the

methods used to refine it.   And,  because the categories in Table 1
*  Olefins are straight or branched-chained aliphatic hydrocarbons
with at least one double bond.  They are used as feedstocks in
certain refinery processes (e.g., alkylation and polymerization)
to yield high octane blending components for motor gasoline and
some jet fuels.

** The additive package differs depending on how the oil is to be
used.  For example, chemicals added to automotive engine oil to
decrease engine knock differ from those added to an oil to lower
its freezing point.

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                               - 8 -
                              TABLE 1

                Relative Percentages of Hydrocarbons
                 in "Average" Refined Oil Products
 Petroleum Product
 Motor Gasoline
 Jet
 Kerosene
 Distillate Fuel Oils
 Residual Fuel Oils*
 Naphtha, Petroleum Solvents
 Lubricating Oils and Greases
Paraffins
 40-50
   35
   40
   30
   15
 20-35
 20-40
Naphthenes
  30-40
    50
    45
    45
    45
  30-45
  30-55
Aromatics
  10-35
    15
    15
  25-40
    25
  20-50
  15-45
*  includes 15% non-hydrocarbon compounds containing oxygen,
   nitrogen or sulfur
NOTE:  Olefins are often not measured, although they are present

       in most products to some degree
Source: reference 4, p. 86

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                                -  9  -


are quite broad, there are  instances where the  "average" values

for a particular category do  not  reflect the  composition of certain

groups of hydrocarbons within a category*.  However, the table is

useful because  it  illustrates that, like crude  oils, most refined

products contain significant  quantities of all  three classes of

hydrocarbons  (i.e., alkanes,  cycloalkanes, and  aromatic).


II.  Sources  arid Management Practices

     Most unused waste oil  fits into three general categories:

(1) spilled oil, (2) oily wast.e from tank-cleaning and deballasting

operations, and (3) oil unfit for its intended  use because it has

been improperly handled or  fails to meets specifications.  These

three sources of unused waste oil are discussed below.

A.  Spills

Surface Water; About 10,000 oil spills totalling 10 to 20 million

gallons of oil enter the territorial waters of the United States

every year.6  Through the provisions of the National Oil and

Hazardous Substances Pollution Contingency Plan**, the National

Response Team*** ensures that appropriate cleanup operations of

this spilled oil are undertaken by the discharger or by federal,

state,  or local authorities.  Removal of the spilled oil from
*   E.g., white oils, which are a subset of the "lubricating
oils and greases" category, are refined such that they contain
essentially no aromatic hydrocarbons.  Therefore, the "average"
value of 15 to 45 percent aromatics is inaccurate for white oils.

**  This plan is designed to guide federal spill response actions
under Section 311 of the CWA.

*** The National Response Team is a multi-agency organization
responsible for oil spill contingency planning at the national
level.

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                                - 10 -


surface waters results  In the creation of an oily debris which

must be disposed of.  Currently there are no federal regulations

controlling the treatment, storage, or disposal of the oily

debris resulting from these cleanup operations.

   Efforts by emergency response teams to locate adequate sites

to manage  (i.e., store, treat, or dispose) oily debris are often

frustrated.  Local residents are always anxious to have the debris

removed from sight, but frequently are unwilling to allow it to

be disposed of in their sanitary landfills.  Citizen opposition

is even worse when neighboring communities are asked to accept

another's debris, regardless of whether their landfill is better

able to contain it.

   Because of the intense emotional atmosphere associated with oil

spill cleanup, the resulting oily debris must often be temporairily

stored until an appropriate site is found.  Sometimes, either

because of citizen pressure or the absence of a suitable nearby

site, the debris is disposed of in a landfill which is inadequate

to contain it.*^


Land; The Coast Guard and EPA. receive notification of only oil

spills that:

       cause a film or sheen upon or discoloration of the
       surface of the water or adjoining shorelines or
       cause a sludge or emulsion to be deposited beneath
       the surface of the water or upon adjoining shorelines.

                                          (40 CFR Part 110).   -
*  There is growing recognition among local officials that the
time to identify appropriate sites to dispose of oily debris Ls
before rather than after an oil spill occurs.  To encourage this
type of advance planning,  EPA has prepared a detailed, how-to-
do-it manual (EPA-600/7-80-016) and an accompanying film for oil
spill debris disposal for state and local officials.

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                               -  11  -


    Oil  spills  also  occur  to  land.   They  are  typically  caused

by  tank failures, pipeline ruptures or leaks,  spillage during

transfer from  one container  to another,  and  indiscriminate dumping,

Because the  Agency  has  no reporting requirements  for tJiese spills,

it  is difficult  to  estimate  the  quantity of  waste oil  generated

from them.   However,  several states require  persons to file re-

ports on oil spills to  the land  as  well  as water.  The following

is  a summary of  data  collected in these  reports.


MAINE:  Nearly  90,000  gallons of  oil were spilled  in Maine in
1979.   Table 2 illustrates the environmental media (i.e., surface
water,  ground water,  or land)  affected by these spills.  Although
the majority of  the spills entered  surface water, a significant
number  occurred  on  land.  Note also that several of the spills
resulted in ground-water  contamination.®


MICHIGAN:  During 1976, approximately 500 spills to ground water
were reported to the  Michigan Department of  Natural Resources.
The largest of these  was  a spill of 360,000  gallons of fuel oil.9


NEW HAMPSHIRE:   Table 3 summarizes  the reported oil spills that
occurred in New  Hampshire over the  past  six  years.  Note that of
the 219,368 gallons of oil spilled  during that, period, nearly
half of the oil  spilled on land.10


NEW YORK:  4,287 oil  spills  totaling over 9  million gallons were
reported  to New  York's Department of Conservation from January,
1976 to September,  1979.  Approximately  25%  of these spills
occurred  on land, involving  over 1.5 million gallons. New York's
records  indicate that 238,983  gallons of the oil spilled on the
ground  was not cleaned up.H


   While  not comprehensive,   data from these  few states indicate

that the  amount  of oil generated from spills to land is signifi-

cant and, therefore,  should  not be  overlooked'when assessing the

magnitude of the potential environmental threat posed by unused

waste oil.

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                           - 12 -






                          TABLE 2




                       State of Maine




       Environmental Media Affected by Spills in 1979








     Medium Affected                  Number of Spills




     Land                                    95




     Surface Water                          153




     Land to Surface Water                   66




     Ground Water                             6




     Ground Water to Surface Water           17




     Land to Ground Water                     4
                            Total Spills    341
Source: reference 3.

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                                   -  13  -


                                 TABLE  3

                           State of New  Hampshire

                     Oil Spill Summary  for  1975-1980

Year
'75
'76
'77
'78
'79
'80**

# Spills
Reported
45
53
52
59
79
52

* Spills
12
17
13
11
27
23
TO LAND
Gallons
Spilled
19632
23441
6210
8855
27985
15816

(*)*
(2)
(4)
(4)
(2)
(10)
(7)

# Spills
33
36
39
48
52
29
TO WATER
Gallons
Spilled
22335
19430
6687
30323
29692
8962

(f)*
(12)
(21)
(23)
(21)
(33)
(17)
                Total
101939
117429
*(#) Indicates number of spills with an unestimated amount
     of spilled oil

**   Through November, 1980
Source: reference 10.

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                               - 14 -


    Unlike oil spilled to surface water, oil spilled to land is

 not subject to federal regulation (unless it ultimately reaches

 surface water) and, therefore, its cleanup is not supervised by

 a federal organization comparable to the National Response Team.

 In fact, there is no federal law which even requires oil spilled

 to land to be removed from the ground.

    Some states send officials to oversee cleanup operations of

 large oil spills to land.  But, in most cases, the treatment,

 storage, arid disposal of oily debris resulting from this type of

 spill is not. subject to control.


 B. Vessel Operations

    Ships arid vessels generate two types of wastewaters which

contain unused waste oil: ballast water* and tank cleaning water**

    The discharge to surface water of ballast and tank-cleaning

water is subject to regulations (33 CFR Part 157) administered by

the Coast Guard.  If oily water is brought ashore (as is often

done during deballasting operations), it is usually first pumped

to on-shore storage tanks, and ultimately released to refinery

wastewater treatment plants.  Oil recovered onboard from tank-

cleaning water is generally used as a feedstock at oil refineries
*  Ballast water;  After crude oil or petroleum products are off-
loaded from a tanker, water or seawater is pumped into the vessel's
storage tank to maintain stability.  Oil adhering to the tank's
wall mixes with the water as a result of ship motion, thus creating
an oily wastewater.

** Tank-cleaning water:  Before a change in fuel oil cargo is made,
cargo tanks are washed.  Oily wastewaters generated by tank cleaning
are either added to a ship's ballast water or processed through an
oil-water separator.  In the latter case, water which has passed
through a separator is discharged at sea, whereas the oil component
is retained on-board and is eventually brought ashore.

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                                -  15  -


when  it  is brought ashore.^

    Of the unused waste oil generated onboard vessels, nearly

300 thousand metric tons of it  are discharged to surface waters

each  year.13  The Agency has no data on the quantity of waste oil

brought  ashore  in ballast  and tank-cleaning waters.


C. Inadequate Handling or  Formulation

   Unused oil may become unsuitable  for its intended use and,

thereby, a waste oil when  it is improperly handled.  An example

of this  occurred in North  Carolina in 1978 when several barrels of

the federal government's automotive  lubricating oil could not be

used  in  its military vehicles because the oil had been stored

for longer than its recommended shelf life.*^-^

   Unused oil may also become waste oil if it is formulated in

a way that does not meet specifications for its intended use.

Oil purchased by the government,  for example, must meet certain

specifications.  These specifications differ depending on how

the oil  Is to be used (e.g., the  requirements for fuel oil differ

from those for lubricating oil).  If oil is 'off-spec1, it is

generally returned to the  seller.  The oil can then either be

re-formulated, sold for another use, or disposed of.

    The  Agency has no data on how much of these types of unused

waste oil are generated, nor on how they are ultimately reused or

disposed of.
*  The oil was ultimately given to a state-operated re-refinery
to be used as a feedstock for lubricating oil.

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                                - 16 -


III. Basts for Listing

A. Adverse effects of crude oils and refined products

   Crude or refined oils are the major component of the unused

waste oils described earlier.  In this section, the toxic effects

of these components are discussed, first with respect to aquatic

organisms and, second, with respect to humans.  This is followed by

a brief description of the organoleptic (taste and odor) properties

of oil-tainted ground water.

1. Aquatic Environment

   EPA has already established that oil discharged to surface

water poses a significant threat to the environment.  In response

to a court challenge in 1974, EPA successfully defended its posit-

ion that an oil spill sufficient to produce a film or sheen* on

the surface of the water is large enough to cause harm to the

environment.15 in its deposition (see Appendix 1), EPA documented

that oil produces a harmful effect on aquatic organisms not only

by physically coating them, but also by causing adverse chemical

changes within the organism.

   Appendix 4(a) of this deposition includes descriptions of the

following types of damage to aquatic organisms caused by floating

oily layers: inability of ducks to swim or dive for food in the

presence of oil films; loss of insulating ability of feathers con-

taminated with oil and subsequent loss of normal body temperature

and death; reduced viability of duck eggs due to oil-soaked plum-
*  An oil layer at. least 150 nanometers thick (1 nanometer = 1
biiltoneth of a meter), or 39.37 billioneths of an inch, is
required to produce such a sheen.

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                               - 17 -






age; and pneumonia and gastro-tntesttnal  irritations in waterfowl



following preening of oil-coated feathers.



   Appendices 4(b),  5 and 6 of the deposition document some of



the adverse physiological changes to aquatic organisms resulting



from small spills of oil to surface water.  Harmful effects cited



in these appendices  include: inhibition of marsh grasses to



reproduce; blocked chemoreception in fish lax-vae; increased



susceptibility of seagrasses to parasites; abnormal development



of herring larvae; and the killing of various organisms including



copepods, shrimp, and white mullet.



   The deposition's claim that oil poses a significant threat to



the environment when discharged to surface water is supported



by information presented in Tables 4 and 5.  Table 4 is a compil-



ation of data on the lethal toxicity of various oils to aquatic



organisms. 1-6 The table is presented here for two reasons.   First,



to confirm that low concentrations of oil can be lethal.  And



second, to point out that,  in nearly all cases, oil's water soluble



hydrocarbons (aromatic) are toxic at lower concentrations than the



other components or types of oil listed in the table.



   Table 5 summarizes the sublethal effects of crude oil and re-



fined oil products on aquatic organisms.17 The purpose of including



the table in this document is to re-emphasize that the sublethal



effects of oil are significant (e.g., disruption of feeding, breed-



ing,  and locomotive behavior;  interference with thermoregulatLon;



etc.),  and that the concentrations necessary to bring about these



effects are often very small.

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                            -  18  -

                          TABLE  4
(a  thorough
 Summary of
discussion of
 lethal toxicities of various petroleum product* to aquatic organism*
duration and test condition* is found in Moore, Dwyer, and  Katz, 1973)
, Type
orfuisa
Marine Fioni



Finfish 	



Larvae and
Eces ..



Pelagic
Crustacea ....



Benthjc
Cr-us'-acet —

Soluble
H-autor?
10 ppm»--
650 ppm»'


5 ppms'-
50 oprfl**



0.1 ppm5*"-
1 ppm*"



1 ppm1*'-
10 ppm**'



1 ppm1*"-
10 ppro**'
Dujpe~*anu
1_2 ppm»-
313 mg/1
[ppmpi

1 pprr">
10,000 mg/I
[ppw]"


1 ppns**-
42 ppm"



5 ppm**-
100 ppm"



2 ppm»-
100 ppms
*2 Fuel oil/
Kerosene
<100 ul/1
tppm]"


550 ug/ml
[ppm]"



0.1 ul/l[ppm}"

4 ug/ml
[ppm?1

5 porrw>-
50 ppmw



5 ppm""-
50 ppm*"
Fresh
crude
Toxic to man;
salt marsh
planu."

88 mg/1
[ppm)"
If ml/1
[xlO> o/oo]

0.1 ul/l[ppm)»

100 ppm" »


0.1 ml/1
[XJO> ppm]»
40 ppt
[X10> ppni}»

0.56 mg/1
IppmJ"
Guofaae




91 ppm»
















D>Ml
fud




204-420 ppm»
















Refioen
eff)uenu





















WaiK
oil
10 ppm"



1.700 ppm"




l->25 ppm"




15- >» ppm"






Lubrieuu





















Boiauab




2,000-10,000
n«/Hppm)»



No eff«*
reported"








> 10.000 ppm"

Wothend
crude
Coating more
HCniTieaat
than lethal
toxieity."

















G-wpod,....





Bivalves 	


Other Benthk
Invertebrate

Freshwater
Finfish 	


^
Flora 	

Mammals i
Birds

10 ppm2*'-
5 ppro2*-
100 pprr-3*' ! 2.000 pprr35




5 ppm3"-
SOC ppa*


1 ppm**'-
10 ppm»-

5.6 ppm11-
4,924 ppm*








0.5 ppm2*-
100 pDm»


5 ppro»-
100,000 ppm*

10 ppm3'



200 DDm31
«*^w yp*"
50 ppm*1"-
500 pom""




30-40 ml/1
(xlO3 ppm}3'


5 ppm2**-
50 ppm"'

1,000-150,000
mg/lfppm}30




Toxicity re-
ported for
several
species, but
- concentra-
tion given *
1 ml/1
[xlO3 ppmpi
10s pprn»

100 ppn>-
6,100 ppm™

0.3 mg/1
[ppm]" '
500 mg/1
tppmp°















40 mg/1
[ppmp»
180 mg/1
[ppmP'















160-4.000
mg/Uppmp1

















160-1.000
mg/Uppmp'

















-39 ppm"


















3,000-180,000
mg/UppmP'




No effect
reported. is




Incorpon.
tion.™


1352-2,417
mg/Uppmp1




























Most lethal (or sublethal) effects are caused b> phvsica) coating, entanglement.
ingestion of &TJC oil dropleu, or incorporation of hydrocarbons through food chains
Note: (1) Numbers in brackets represent reported values (volume to volume or weight to (5) The manner in which the above values are reported is only an attempt to exemplify
volu roe basis) c««rt«5 to ppm. the ranges in threshold tetnal toxicities, based on some'of the existing published '
(2) Superscript numbers refer to references, data, and should therefore not be regarded as absolute limits of toxicity for a givei
(3) Asterisks indict* values estimsted by Moore, Dwyer, and Kali, 1973. (However, category of toxicant or test organism. It must be understood that there exist
estimates are supported by examples given therein). numerous additional published data that fall within the ranges suggested above,
(4) In some cases, the above values have been taken from summary type presentations md possiblv data that may suggest further widening these ranges. It is not the
(for example: Moore, Dwyer, and Katz, 1973), the corresponding reference numbers author's intention u> herein summarize all of the uxieity valuw reported thus far
therefore do no: necessarily refer to the original publication. for petroleum and petroleum product*.

-------
                                                         TABLE   5
                             —Summary of some  sublethai effect* of petroleum .product*  on nurine lite—Continued
Typ* oTfwimr.

Fish

Crustaceans'
,

Si««s '• K*f«rcnot
Bamacit lanae
(Exaanus bQWninQts}. . .Mirono',. 19*0
Crab larvae \
( f'Qch 1/7^12 pflUf \
Chinook si'mon t
(Oneorhynchus j
Baiiey. 1973"
Atlantic siiversides
1973
Lobster (Homarus
11973
Polhnpcf
pcitvmcrus 	 Straughan. 197]
Lobster (H '
cnmcnuf) 	 (Atema & Steir., 1972
Pachycr-cvhus i
crc&sipes 	 Kittredge. 1971"
i
Uca puoncn 	 ; Krebs. 1973 •'•
i
TT» pcvoMtiir. pnduei
-or
Benzene
Crode (whole fractions)
(water soluble!
(water insoluble)
Crude, kerosene
Crude-Santa Barbara
La Rosa crude
Crude
No. 2 fue! oil
ConontntMB
1C-- IOC' ul'l ipprr.i
10-100 ul/1 (ppm)
5,10 ppm
140 ppm (v/v)
12 ppm estimated
5SS ppm (v/v)
10 ppm
Field studv
after blowout
Extracts
Dilutions of diethyl
ether extracts (1.100)
Field observations
after W. FaJmouth spill
SuUtUii, rttfaatt
Abnormt development
Initial increase
in respiratior,
Initial increase
in respiration
rustoiogical damage
to chemoreceptors
Effects on chemo-
reception. feeding times.
stress behavior,
aggression
Apparent decrease in
aaull breeding; no
recruitment in oiled
areas
Delay in feeding
Inhibition of
feeding
Adverse effects
on sexual behavior
Molluscs'







Other benthic
invertebrates
Mussel (Myttiu!
edulis) 	
I
Snail (.Vcusanuf
&6so/^rw^) 	
Snail (Xasscnus
titSOtftlLb) 	
C;am (Mya
crenuna) . ..
Oyster (Crasf-
oftrva virginica] 	

littona) 	
Ch-ster (Crass-
ostrea virgiitifc) 	
Mussel (Mytiliu
edulis) 	

Polychaeta
(Ccpitelic capuala.) 	
Gilfi'lan. 1973-'
Blumer e* al.
1973
J&cobson & Box ian
1973
Bam' & Yevich 1974
Mackin & Hopkins,
1961
Perkins, 1970"
Menzel. 194S; in
Nelson-Smith, 1973
Biumer, et al
1971"
Bellan, et al.
1972'
Crude
Kerosene
No 2 fuel oil
Bleedwaler

BP 1002
"Oil"
No. 2 fuel oil

Detergent
1 ppm
Saturated* extract
diluted 10">
Collected from field


30 ppm
0.01 ppm
Collected from
field after spill
0.01-10 ppm
Reduction in carbon
budge* (1171^0 cc jn
respi^'- ;_se
in feeding)
chemotactic perception
of food
Gonadal tumors
Reduced grou-th and
glycogen content
iignificanl infiib- — -
ition to growth
Marked taintine
Inhibition in devel-
opment of gonads
Decrease in
survival, fecundity
Note- '1 Uktn from NtUouJ Acaotmy of Seienea, 1VTI
     •2 uk«n from Moore, Dw>cr an
-------
             TABLE  5  (Cont'd)



—Summary of some gublethal effect* of petroleum product* on marine life
Type MT*niur.
Marine fiors.






Lar\ae and eggs:





Sptcw
Fnywi'iar.ivlon
(Chwrclic vaiganf). . . . .
Phytoplankton
(duiiiims and
dmofiaoilicicf') 	
Phytoplankton
(Aslenanclm
taponica ) 	
Phytoplankton
(Phaecdaetylum
tncomutum) 	
Phytoplankton
(Moncchrysif
\vihcri) 	
Phytoplankton
(Phatttdaelyi-un,
tricornu'um,
Ske'ClcmeTT^a
costatum. Cfiivrflla
ST>.. Ouamy-
Phvtopiankton . .
iKelp (.\facrirjifiif
anpusliful in 	
Lichen (Lichen
pyQInceC ) 	
Pink salmon fry
( Oncark yr.chus
gwlnu-chc) 	
Black Sea turbot
(Rnjcmiras maeoticuf)..
Plaice larvae
(PifruTuntcies
platessa) 	
Cod fish larvae
(Gccus morhuc)
Lobster larvae
[Homaruf
amcricanus) 	
Sea Urchin larvae
StrvnffylGcentrotus
purp-uratus) 	

Relerenet
Knauss. ei a!. 197?
Mironcn. 1970'1-1
Aubert, et al. 1969"'
Lacaze, 1967"
Strand, et al. 1971*'
Kuzzi 1973' >
Gordon and Prouse,
1973' '
Wither I'-GS'2
Brown 197°*'
Rice 1^73
Mironov, 1967
Wilson 1970"
Kuhnhold 1970*
Wells 1972'
Allen 1971*

Trpe pcWbieui* product
Crude Naptnalene
"Oil'
Kerosene
Kuwait crude
Kuwait crude;
cispersant
emulsion:
Extracts of outboard
motor oils. No. 6
fuel oil, No. 2 fuel oil
Venezuelan crude.
No. 2 and 6
fuel oils

BPioo!
"02"
BP 1002


Extracts of Bunker C

Conceits* tior.
1 ppm
3 ppm
1C'1
10"* ppm
38 ppm
Ml ppm"
20-100 ppm

10-300 mg/Kppm)



0.01 ppm

from 103 ppm, 104
ppm
nil nnm

Subttui* mponM
Suppi-esf pro»th;
reduction of
bcarixinau uptake
Inhibition or delay-
in cellular division
Depression of
growth rate
Depression of
growth rate
Inhibition of growth;
reduction of bicarbonate
uptake at 50 ppm
Stimulation of photo-
synthesis at 1&-30
mg/1; decrease in phoU
synthesis at 100-200
ug'l No. 2 fuel oil
i57c reduction in
photosynthesis within
5*6 hours
1 ppm emulsifier
decrease; total C*
fixation
Avoidance effects; cou
have effect on
migration behavior
Irregularity and delay
in hatching; resulting
lar\'ae deformed and
inactive
Disruption of
feeding behavior
Adverse effect on
Dehavior, leading to
death

fertilized egg
development

-------
 2. Human  Health




   Thera  are  several  substances  listed  in  Appendix VIII of




 40 CFR  Part 261 that,  are present in oil's  aromatic or water




 soluble fraction.  These include naphthalene, phenols, benzene,




 benz(a)anthracene, and benzo(a)pyrene.  The  last three have been




 identified by EPA's Carcinogen Assessment  Group as exhibiting




 substantial evidence  of carcinogenicity.   Detailed discussion of




 the toxic and carcinogenic effects of these  substances are con-




 tained  in the Agency's water quality criteria document.s prepared




 under Section 304(a)(l) of the CWA.18




   The substances listed in Appendix VIII have been shown to have




 toxic, carcinogenic,  mutagenic or teratogenic effects on humans or




 other life forms.  The presence  of any of these constituents in a




 solid waste is presumed to be sufficient to  the list the waste as




 a hazardous waste unless, after  consideration of designated mul-




 tiple factors, EPA concludes the waste is not hazardous.19 These




 multiple factors were described  earlier (see page 4).




   Table 6 presents the relative concentration of some of these




 substances in both crude oils and certain refined oil products.




 The authors of the table found that benzene, naphthalene and



phenols accounted for about 90% by weight of the identified




 organics in the water soluble fraction of samples of crude and




 #2 fuel oil.   For bunker C fuel oil, phenols and naphthalenes



were among the most abundant class of compound found, with each




present at a concentration of about 1 m

-------
                                  -  22  -
                                TABLE  6

                      Water  Soluble Components  of
                         Crude, and Refined Oils
  Compound C^ass
   Crude
(4 samples)
  #2 Fuel
(5 samples)
 Bunker C
(1 sample)
* Benzene

  Indans

* Naphthalenes

  Tetraliris

  Biphenyls

  Anilines

  Quinolines

  Indoies

  Benzothiophes

* Phenols

  Phthalides

  Benzaldehydes

  Aromat ic Ketones
    44-

    4-44

    44

    4
    44 i-
    44

    ++4

    44

    +

    44
                                     +4
                     4-4-+
  4+4- =  High relative concentration
  44  =  Low relative concentration
  4   =  Trace amounts
      =  Not detected
  *   =  Substances listed in Appendix VIII of 40 CFR Part  261

  NOTE:  Although no absolute concentrations (i.e., ppm)  for most of
  these substances were given, the levels for phenols and naphtha-
  lenes in Bunker C fuel oil were reported to both be about 1 ppm.
  Thus, it seems likely that substances with relative concentrations
  of (444) have absolute concentrations in the ppm, as opposed to
  the ppb range.
  Source: reference 20.

-------
                                -  23  -


   The  fact that  carcinogens  are  found  in  oil  is  especially

 important  in determining  whether  oil-containing solid  wastes  are

 hazardous  wastes.   EPA has  in the past  employed the  assumption

 that "carcinogenlcity  is a non-threshold phenomenom.  As  such,

 "safe1  or  "no effect" levels  for  carcinogens cannot  be estab-

 lished  because even extremely small  doses  will elicit  a  finite

 increase in the  Incidence of  cancer. Accordingly, the  water

 quality criteria promulgated  under Section 304(a)(l) of  the CWA

 state that, for maximum protection of human health,  the  ambient

 water concentrations  for  carcinogens should be zero.*21

   Similarly, under RCRA, the  fact that  a  solid waste  contains

 known or proven carcinogens generally is sufficient  cause to list

 the waste  as hazardous, unless there is  strong indication that the

 waste's constituents will not migrate and  persist if the waste is

 improperly managed.22

   Of the  carcinogens present  in  oil, benzo(a)pyrene or  BaP is a

highly  potent carcinogen.  It has been  reported to be  present in

 crude oil  an! refined oil products.23   Because the BaP molecule

 is hydrophobic, it  will partition preferentially  into  lipids,

where it is subject to both bioaccumulat ion and biomagriif icat ion

 effects.24  Samples of crude oil  from the  Persian Gulf,  Libya,

 and Venezuela have  been found to  contain 400, 1,320, and 1,600
*  However, because zero concentration may not attainable at the
present time, the criteria specify ranges for carcinogens associ-
ated with incremental cancer risks.  Cancer risk levels provide
an estimate of the additional incidence of cancer that may be
expected in an exposed population.  A risk of 10~5 for example,
indicates a probability of one additional case of cancer for every
100,000 people exposed; a risk of 10~6 indicates one additional
case of cancer for every million people exposed, and so forth.

-------
                                - 24 -


ug/kg respectively of BaP.*25

   Data on other levels of carcinogens found in crude oils

(e.g., benz(a)anthracene) are scarce. It has been estimated,

however, that the carcinogenic hydrocarbon content of crude oils

generally falls within the 100 to 1,000 ug/kg range.26

   Data on the carcinogenic hydrocarbon content of refined oils

is also limited.  However, unless an oil product has been refined

with processes that remove aromatic hydrocarbons (e.g./ solvent.

washing), it can be assumed that the product will contain cctrcin-

ogens similar to those found in the parent crude.  In fact, since

most refining processes enrich rather than diminish the aromatic

content of refined products relative to the crude oils from which

they are derived, it is likely that the carcinogenic hydrocarbon

content of most refined products is at least, as high as that of

crude oils.  For example/ the level of benzene found in motor

gasolines generally exceeds 10,000 ppm.**27

   The above substances are harmful whether- ingested from surface

water or ground water, and thus aquatic organisms as well as humans

could be adversely affected by consuming oil-tainted surface water
*   At the 10~6 cancer risk level, the ambient water quality cri-
teria for protection of human health from chronic exposure are
2.8 ng/1 (parts per trillion) for both benzo(a)pyrene and benz(a)
anthracene.

**  Benzene is known to cause leukemia and other adverse effects
in humans at concentrations of 25-100 ppm (see Industrial Union
Dept., AFL-CIO v. American Petroleum Institute, __ U.S. _ ,  _
fJuiy^1980)(slip op. at 7, 20-21, reviewing regulations of the
Occupational Safety and Health Administration).
    At the 10~6 cancer risk level, the ambient water quality cri-
teria for protection of human health from chronic exposure is .66
ug/1  (parts per billion) for benzene.

-------
                                -  25  -
or gix>und water.  However, because the previous section already



documented the harmful  effects that oil  in  surface water has on



aquatic organisms, the  following discussion will  focus on the



potent, ial threat to human health posed by  ingest ion of these



substances in oil-contaminated ground water.



   Two factors play a significant role in determining the toxic



effects of oil in ground water: the types of hydrocarbons the



oil contains, and the solubility of these hydrocarbons in water.



   To begin with, the more reactive a compound, the more likely



it will be to interfere with biological  functions.  The probable



mechanism whereby hydrocarbons exert this interference is through



cell membrane disruption and incorporation.^  The relative



reactivity and, hence, toxicity of the classes of hydrocarbons



found  in oil increases from paraffins to naphthenes to olefins to



aromatics.29 oils containing a predominance of aromatic compounds



are generally more toxic than those containing mostly paraffinic



or naphthenic hydrocarbons.30f31  Note that the Appendix VIII



substances described earlier are all aromatic hydrocarbons.



   As discussed in more detail below, the solubility of the hydro-



carbons in oil is also a significant factor in determining the



effects of oil in ground water.  Unless these hydrocarbons are water



soluble,  they may either never reach ground water or will not mix



with it sufficiently to pose a threat to humans that use it.  The



water solubility of hydrocarbons also increases from paraffins, to



naphthenes,  to aromatics.32  Benzene, for example, has a saturation



solubility of 1,800 ppm in distilled water, as compared to about

-------
                               - 26 -


10 ppm for the alkane of equivalent, molecular weight.*33  Thus,

the aromatic portion of oil tends not only to be the most toxic,

but is also the most likely to migrate to ground water.

   Toxtclogicai data on oil ingest.ton by humans and other non-

aquatic organisms is scarce. The Agency is unaware of any studies

on the effects of crude oils on terrestiai organisms.  Research

on the effects of refined oil products is also scant.  However,

the small amount of research that, has been conducted on refined

oils offers some insight into the potential adverse effects of

all oils on terrestiai organisms, including humans.


                         Toxicity Studies

   This discussion deals with three types of refined oil: middle

distillate fuels, lubricating oils, and white oils.  The middle

distillate category includes kerosene, diesel fuel, and fuel oils

No. 1 arid 2.  The general hydrocarbon composition of this category

of oil is shown in Table 7.

   Table 8 summarizes the general hydrocarbon composition of
                               )

lubricating oil stocks.   Like the middle distillat.es, lube oils

generally contain all three types of hydrocarbons.  However, be-

cause aromatic hydrocarbons produce poor viscosity characteristics

and are unstable towards oxidation, some or all of these aromatics

are often removed from lube oil stocks.  The degree to which the

aromatics are removed depends upon the use to which the oil is to
*   Solubility is also a function of molecular weight (i.e.,
solubility increases as molecular weight decreases). This is why
compounds of similar molecular weights are compared when assessing
the effect of hydrocarbon type on. solubility.

-------














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-------
                         - 28 -
                         TABLE 8

                Hydrocarbon Composition of
                  Lubricating Oil Stocks
              n Type                       Percent
                                         (by we ight)

    Alkane                                  45-76

    Cycioalkane                             13-45

    Aromatic                                19-30
                         TABLE 9

                Hydrocarbon Composition of
                    White Mineral Oils
    Hydrocarbon Type                       Percent
                                         (6 samples)

 Straight and branched alkaries                26.8

 Cyclic aikanes
    noncondensed  (1 ring)                    26.8

    condensed
    2 rings                                   22.1

    3 rings                                   13.6

    4 rings                                    6.7

    5 rings                                    2.9

    6 rings                                    0.9

 Aromat ic hydrocarbons                         0
Sources: reference 5, pg.  20 for Table 8:
   reference 5, pg. 23 for Table 9

-------
                               -  29  -






be  put.   Lube  oils  from which  all aromatic hydrocarbons are re-



moved are called whits oils.   White oils are transparent, color-



less  and odorless  and tasteless when cold. They are used for



medicinal purposes, as food additives, as finishing oils, and



other uses requiring a very pure lubricant. Table 9 provides the



general composition of white oils.



    The point to remember about the  chemical composition of these



oils is that white  oils contain no  aromatics, whereas the middle



distillates and lube oils do.  The  toxic effects on terrestial



organisms to each of these three types of oil is discussed below.



    The majority of  the literature on oil toxicity to terrestial



organisms  stems from a concern for  workers exposed to oil while



performing their jobs.  Workers are usually exposed to oil



either when it splashes from machinery onto their bodies,  when



they lean  against oil-coated machines, or when they inhale oil



mists (generated when oil contacts hot pieces of machinery).



Studies conducted on humans and test animals therefore,  tend to



focus on  dermal or aerosol exposure to oil.   Few occupations call



for the oral ingestion of oil and,  consequently, little data has



been collected on this mode of exposure.   The exception to this



is data collected on white oils.   Because white oils are used as



laxatives, their biomedical effects when ingested by humans  and



test animals have been studied.



  Data on human toxicity to the three types  of oil will  be pre-



sented first.*
* All damage incidents taken from reference 5.

-------
                              - 30 -


Middle distillates

Acute skin contact with kerosene soaked clothing caused severe
epidermal riecrolysis in a 12-year old boy.  Extensive erythema
and detachment of epidermal tissue overlying a purulent exudate
occurred.  Skin patch tests with kerosene for 24 hours caused skin
irritations of varying degree in humans; a highly aromatic middle
distillate fuel produced the strongest skin irritation.

A worker who swallowed fuel oil during a siphoning procedure
developed acute gastritis with hematomesis.  Gastric mucosai
lesions, observed on X-ray, healed in about 1.5 months.  Intense
gastrointestinal irritation has been noted after kerosene
swallowing.

Diesel fuel ingestion by young children often causes pneumonia,
due to entry of the fuel into the lungs (i.e., aspiration
pneumonitis).  Cough, dyspnea and a blood-tinged frothy discharge
have been noted in these cases.
Extensive bilateral pulmonary necrosis and gangrene occurred
a 44-year old man who aspirated diesel fuel.
in
Folliculitis, furuncles, pyoderma, abscesses and papular erupt-
ions have been reported due to repeated exposures to diesel fuel.


Lubr ic at ing oils;

Squamous cell carcinoma of the hands, face, and groin after

chronic oil exposure in industry has an occurrence which parallels

the degree of refining an oil underwent prior to use. The poly-

cyclic aromatic hydrocarbons present in all but white oils are

believed to be responsible for their carcinogenicity.34

   Cases of skin cancer due to petroleum oil used in industries

such as cotton mule spinning and metalworking reached a peak in

1928 and declined slowly by 1945.  This is due to the introduction

of concentrated suifuric acid washing in the 1930's and later on,

solvent extraction, which removes polycylcic aromatics from lub-

ricating oils.*
*  The degree of washing (either acidic or solvent) determines
the amount of aromatics remaining in the oil.

-------
                               - 31 -


   The following are data collected from two studies on lube

oil-induced skin cancer:

In Great Britain, skin cancer studies have revealed that over 86%
of skin cancer cases that could be traced have been found to occur
in association with oil exposure, although the type of oil was
not related to incidence.

In France, in a study conducted on 5,000 workers exposed to
lubricating oils and oil aerosols, it was found that the scrotal
skin cancer rate for these workers was 36 times higher than that
of the general unexposed population.


White oils;

Ingest ion of white mineral oil, as a laxative, causes lub-

rication of the rectal sigmoid.  The oil prevents absorption of

fat soluble vitamins A, D, E, and K, with resultant problems

related to deficiencies of these vitamins (alteration of calcium

arid phosphorous metabolism through interference with vitamin D

absorption; hypoprothrombinemia due to interference with vitamin K

absorption).  It also coats particles of food in the intestine,

interfering with absorption, and sometimes contributing to severe

weight loss.35

   Nonetheless,  the Food and Drug Administration allows the use

of mineral oil in food, subject to stringent quality and quantity

standards.*
* These standards include provisions which regulate:
1. the quality and quantity of white mineral oils added to food
   for human consumption.
2. the use of mineral oil as a component of non-food articles
   which come in contact with food for human consumption (21 CFR
   Part 178).  These standards restrict oils that can be used for
   this purpose to white oils.  The quality and quantity limit-
   ations prescribed in Part 172 for white oils are incorporated
   by reference in these rules for non-food articles.
3. the addition of mineral oil to animal feed. Quality and
   quantity specifications are prescribed for using white oils
   for this and other animal-related purposes (CFR Part 573).

-------
                               - 32 -






   Bronchial  inflammation, distortion, and plugging with oil has



been observed in persons who have aspirated white mineral oil. The



symptoms of oil pneumonia are non-specific, but include dyspnea,



cough, wheezing, and chest pain.








   Data on animal toxicity to these three types of oils are more



extensive.  However, again the literature is heavily weighted



towards descriptions of aerosol and dermal, rather than oral ex-



posure to oil.  Appendix 2 contains the results of aerosol and



dermal studies conducted on animals.  These studies indicate



that both aromat ic and non-aromatic oils can be harmful to ani-



mals either when they ingest it through their lungs, or when it is



applied to their skin.  The data suggests that hemorraghic lungs



and various blood ailments are the cause of illness (and sometimes




death) in animals exposed to aerosols containing aromatic oils.



Exposure to non-aromatic aerosols, on the other hand,  usually re-



sults in oil accumulations in the lungs.  The differential response



to the two types of oil mirrors that described earlier on human



toxicity to aromatic and non-aromatic containing aerosols.



   The data on dermal exposure of animals to oils is also similar



to that on humans.  The effects of exposing animals to aromatic-



containing oils (e.g., hair loss, blood abnormalities, severe skin



ailments) appears to be generally more severe than to oils contain-



ing no aromatic hydrocarbons.  In the latter case, only minor skin



irritations developed.



   Animal studies conducted on oral ingestion of oil are perhaps



more pertinent when assessing the hazards of oil-tainted ground

-------
                              - 33 -






water.  This  is because  it  is by this means of exposure that oily



ground water  poses  its chief potential threat.  Table 3 in Appen-



dix 2 summarizes available  data on the toxic effects of orally



administei   • oil to test animals.  Again, the data seems to



suggest tl   both aromatic  and non-aromatic oils can be harmful




to terrestial organisms.  However, unlike the data on aerosol and



dermal toxicity, the studies on ingestion of aromatic and non-



aromatic oils do not lend themselves easily to comparison.  This



is because the types of animals tested and the oil dosages adminis-



tered are less similar for  the aromatic and non-aromatic oils than



is the case with the aerosol and dermal studies.  Also, there are



fewer studies on oral toxicity from which to make generalizations.



However, the data in Table  3 are useful for the purposes of this



document because they illustrate that oral ingestion of oil can




pose serious health hazards to terrestial organisms.






3. Drinking Water



   Aside from the toxic effects that oil can have on consumers



of oil-tainted ground water, the contamination of drinking water



with oil is also of ^reat concern because of oil's organoieptic



propert ies.



   The previous discussion  described, in qualitative terms, the



toxic effects of oil to humans and other terrestial organisms.



Mo quantitative toxicity value for oil was provided because oil's



toxicity varies with its chemical composition.   Quantitative



values have been reported, however, for the concentration at



which oil renders water objectionable to drink.

-------
                               - 34 -






   Human taste is very sensitive to oil and, depending on the



 individual, a concentration between 0.005 and 0.5 pounds in



 100,000 gallons of water will produce water which will be



 described as having a bad taste.36  Oil also has a strong odor



 which, for many people, makes oil-contaminated water unpleasant



 to drink.  For these reasons, mismanaged waste oil poses a sig-



 nificant potential threat to ground water supplies of drinking



 water.



   Ground water is, of course, an essential environmental re-



 source; at least half the population of the United States depends



 on it for their drinking water.3?  Congress expressed special



 concern for protection of ground water in the legislative history



 of RCRA.  The Agency views the potential contamination of large



 portions of ground water as posing a "substantial" hazard to human



health and the environment, within the meaning of Section 3004 of



 RCRA, even if the contamination results not in a direct threat to



human health, but rather to the destruction of ground-water



 resources.



   It has been suggested that because petroleum is organo-



 leptically objectionable at very low concentrations, it is



 unlikely that oil-polluted drinking water will pose a toxic



 threat to humans.  This, however, has never been scientifically



 determined to be true.  Nonetheless, regardless of whether oil



 produces an adverse organoieptic or toxic threat to consumers



 of ground water, either threat is significant and detrimental




 to humans.

-------
                              - 35 -


 B.   Hazards  posed  by mismanagement

 f;'   As  stated  earlier,  there  are  three  principal  sources  of

 unused  waste oil:  spills,  vessel  operations,  and  inadequate

 storage and  formulation.   This section  explains why  unused

 waste oil  derived  from  spills poses a significant threat  to

 human health and the environment,  while that  derived from the

 other two  sources  poses a  minimal  threat.

     Existing regulations and  management practices ensure  that

 waste oil  derived  from vessel operations does not pose a

 sufficient environmental threat to warrant  its listing as a

 hazardous  waste under RCRA.   The  first  section of this document

 described  how  unused waste oil brought  ashore* from  vessels is

 normally processed at oil  refineries.   In the case of oily

 wastewaters  (e.g., ballast water),  the  wastewater is stored in

 tanks for  a  short time until  it is  released to a refinery's

 wastewater treatment system.** In  the case of oil separated

 from wastewater (e.g., tank-cleaning water) on board a vessel,

 the oil  is typically used as  a feedstock at oil refineries

when brought ashore.  Thus, in both cases, the unused waste oil

 is managed in  a manner which  maximizes  its recovery.

    Additionally,  EPA believes that economic considerations

will minimize  the threat of improper management of waste oil

 resulting  from inadequate storage  and formulation.  Because oil
*  Unused waste oil discharged to surface water is subject to
regulations administered by the Coast Guard (33 CFR Part 157).

** These treatment systems are designed to recover oil from
various wastewater streams.

-------
                             - 36 -


 is becoming px-ogressiveiy more expensive, the Agency be-

 lieves that less and less waste oil will be generated from

 poor handling practices (e.g., letting oil exceed its shelf

 life) other than spills.  That is, as the cost of oil rises,

handling practices should improve.  For this same reason, the

Agency believes that negligible quantities of waste oil will

be generated when unused oil flunks certain specifications.

Off-spec oil will either be reblended to meet specifications,

or will be used for lower quality uses.*  Thus,  because the

quantity of unused oil that becomes a waste due to inadequate

handling or formulation practices is small, the environmental

threat posed by this oil should also be small.

   Unused waste oil derived from spills does, however, pose a

potential significant threat to the environment.** The follow-

ing discussion will focus on the environmental hazards posed by

 (1) oil spilled to land, and (2) oily debris generated from

cleaning-up spills to land and surface water.

   As indicated earlier, the aromatic component of oil is toxic,

and contains several substances (including three carcinogens)

listed in Appendix VIII of Part 261.  If unused oil is spilled

or otherwise improperly managed on land overlying an aquifer,

 its aromatic component may migrate to ground water. The degree
*  E.g., 'off-spec' oil destined for use in military vehicles
could be sold to retail stores as low cost motor oil.

** Oil spilled to surface water In sufficient quantities to
create a sheen has been shown to be harmful to the environment.
While in the water, such oil is subject to regulations {40 CFR
Part 110) pursuant to Section 311 of the CWA and, thus, no
further regulatory control under RCRA is warranted.

-------
                               - 37  -


 to  which  oil  and  its  components are transferred  to  ground

 water  is  governed by  several  processes which  include:

    1.  the extraction  of  soluble components  from  the oil
       into residual water  in  the soil;

    2.  the transport of dissolved components to the  ground-
       water body,  for example by rain water;  and

    3.  the adsorption  of  oil components on the soil.


    The influence  of each of these processes depends on the

 amount and composition of  the oil,  on the nature of the soil,

 on  the rate of  rainfall, and  on the gx'ound-water level and its

 grade.38  Figures  1 and 2 illustrate the effect of several of

 these  factors on  oil  migration to ground water.39 As can be

 seen,  oil released into  soil  tends  to flow downward, with some

 lateral spreading.  As oil moves  down through the soil, some of

 its components  become trapped between individual soil particles

 and remain behind the main body of  oil.  Other components con-

 tinue  to  travel through  the soil, and may eventually reach

 ground water.40

    In  order to  study  the behavior of oil spilled to land,  soil

 core samples were taken  at the  sites of several known oil spills

 in  Alberta, Canada.41 in general, the total concentration of oil

 declined  with depth,   with the  total concentration of the aromatic

 fraction  appearing to increase  relative to the other two fractions

 (i.e., naphthenic and parrafinic).  Oil was detected in the ground

water below several of these  sites. These findings are significant

 for two reasons.  First,  they document that oil can migrate to

 ground water.  Second, they lend support to the commonly held,

-------
                                       -  38  -
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-------
                              - 40 -


theory that, oil traveling through soil becomes enriched in

aromatic hydrocarbons relative to the source of the oil spill.

   Contamination of ground water supplies by oil has been

reported in all Canadian provinces, in the United States, and

in Europe.42  jn 1968, for example, a major ground watar re-

source in southern California was contaminated with hundreds

of thousands of gallons of gasoline.*43

   In addition to oil spills, another significant potential

source of ground-water contamination is oily debris generated

from cleaning-up oil spills to land or surface water.  Oily

debris is typically disposed of at landfills, landfarms, or

incinerators.  The facilities used to manage this debris are

not always adequate for this purpose.  In at least one instance,

oil spill debris has been washed from a landfill by fiooclwaters

simply because the disposal site was located in a known flood-

plain.44 In another case, oil was detected in soil samples 7

meters (20 feet) below a iandfarm disposing of oily debris.  Oil

was also found in the ground water below the site.""

   Oil that has either migrated through soil or has reached

ground water is subject only to anaerobic degradation.  It has

been estimated that anaerobic degradation of oil takes on the

order of 100 years.46,47 Thus, damage to water resources from

oil can be very long-lived.
*  Gasoline meets the definition of petroleum-derived oil
described earlier and, thus, would be considered to be a waste
oil when spilled.

-------
                               - 41  -






                             Summary






   Oil spilled to land, and oily debris generated from



cleaning-up spills to  land or  surface water, pose a significant



threat to ground water supplies.  Substantial quantities of both



of these types of unused waste oils are generated each year.



Past, management practices suggest a risk of  improper management.



The oils have been known to enter ground water when improperly



managed.  The aromatic component of these oils is not. only the



most likely to migrate to ground water, but  also is the most



toxic.  Oil is organoleptically objectionable to humans at very



low concentrations.  Oil that reaches ground water does not




readily degrade.



   The Agency believes that all of these considerations support



the proposed listing as a hazardous waste of (1) oil spilled to



land, and (2) oily debris generated from cleaning-up spills to



land or surface water.  The exception to this is unused waste



oil that, has essentially no aromatic hydrocarbons (i.e., white



oils).  Because these oils are used for medicinal purposes, arid



are allowed to be used in food, the Agency believes it would be



inappropriate to list either- of the above two types of unused



waste oils as hazardous wastes if their petroleum base is



white oil.

-------
                               - 42 -

                              USED OIL

   Used oil is generally categorized as automotive, industrial,

or aviation oil.* Used oil is similar to unused oil in that it

contains an oil component that poses a potential threat to human

health and the environment when improperly managed.  Thus, for the

same reasons given earlier for unused oil, the Agency believes that

used oil should be listed as a toxic (T) hazardous waste.  In add-

ition, many used oils contain contaminants which cause them to be

hazardous for reasons other than their oil component.   The identi-

fication of these contaminants and the additional hazards posed by

them are the focus of this chapter.

   The first part of this chapter describes the quantities gen-

erated, typical hazardous contaminants, and the practices commonly

used to manage used automotive and industrial oils.  This is

followed by the Agency's rationale for listing used automotive and

industrial oils as hazardous wastes.


I. Constituents and Management Practices

A. Automotive

   The Bureau of the Census1  most recent (1977) compilation pro-

vides the following breakdown of U.S.  sales of lubricating oil:48
*  Used aviation oils are not. addressed in this document for two
reasons.  First, aviation oils make up less than one percent of
total oil sales and, thus, relatively little used oil is generated
from this source compared to automotive and industrial oils.
Second, because of centralized servicing areas, most used aviation
oils are collected, segregated, and treated, or — in the case of
synthetic jet fuels — returned to the manufacturer for reclaiming.
The Agency believes that because relatively little used aviation oil
is generated, and because that which is generated is usually managed
in an environmentally sound manner, it is not imperative that this
oil be subject to the hazardous waste management rules at this time.

-------
                                - 43 -
                                   Billion of gallons
                automotive                1.29
                aviation                    .02
                industrial
                 lube                     1.03
                 other                 _    .53	

                                          2.86
According to this source, automotive lube oil sales made up about

45% of the total market  in 1977.  The Bureau of Census  includes

the following types of oils in the automotive lube oil  category:

engine oil, gear lubes, hydraulic oils, and transmission fluids.

1. Const ituents

   At present, additives comprise greater than 15% by volume of

automotive oils.49  Table 10 presents the chemical composition

and functions of these additives.  During service, the  additives

are chemically changed or consumed.,  and the oil itself becomes

contaminated from both internal* or external** sources.^0

   Table 11 is a comparison of the properties and components of

used automotive oils with that of various virgin oils.  The table

is divided by dotted lines into 3 sections.  The first  section

presents some of the physical properties and chemical components

of used automotive oils.  The second section shows other physical

and chemical properties and components which reflect the additive
*  The primary source of internal contamination is breakdown of
   the additive package and subsequent interaction among its
   chemical components.  These components may be oxidized during
   combustion, forming corrosive acids.

** Examples of external sources of contamination include soot and
   lead compounds from engine blowby, dirt and dust; engine wear
   metal particles; rust; gasoline from incomplete combustion;
   coolant from imperfect engine seals; water from blowby vapor.

-------
                             - 44  -


                             TABLE 10

        Lube Oil Additives, Automotive and Industrial Oil
        ADDITIVE
Antiwear/Extreme Pressure
  Zinc Dithiophosphate
  Organic phosphates
  Organic sulfur &
    chlorine compounds
  Lead compounds
  Amines

Corrosion & Rust Inhibitors
  Zinc dithiophosphates
  Basic sulfates
  Metal phenolates
  Fatty acids and amines
  Alkenyl-succinic acids

Detergents/Dispersants
  Barium,  calcium & mag-
    nesium phenolates
  Organic phosphates &
    sulfates
  Polymeric alkyl thio-
    phosphates
  Alkyl succinimides

Friction Modifiers
  Yatty acids and amines
  Lard oil
  Organic phosphorous
  Phosphoric acid esters
  Molybdenum disulfi.de

Antioxidants
  Zinc dithiophosphate
  Aromatic amines
  Hindered and sulfurized
    phenols
  Nitrogen & sulfur compounds

  Metal Deactivators
   Weak organic acids
   Organic complexes of
     amines, sulfides,
     phosphates
      FUNCTION
Forms protective film,
  reduces wear
Prevents corrosion by
  forming protective film
  or by neutralizing acids
Disperses insoluble con-
  taminants by keeping them
  suspended in the oil
Used in automatic trans-
  missions and limited
  slip differentials
Reduces foam in cx'ankcase
 Reduces oxidation and pre-
   vents rust and corrosion
   by forming a protective
   film on metal surfaces

-------
                               -  45  -
                          TABLE  10  (Cont'd)

         Lube  Oil  Additives, Automotive  and  Industrial Oils
       ADDITIVE
 Pour Point Depressants
   Polymethacrylates
   Alkylated naphthalenes
   Chlorinated paraffins
   Phenolic polymers

 Viscosity Index Improvers
   Methacrylate polymers
   Butadiene
   Olefins
   Alkylated styrene

 Emuisifiers (industrial
              lubes only)
   Sulfonates
   Surfactants
   Naphthenates
   Fatty acid soaps

 Biocides/Fungicides
   (industrial lubes only)
       FUNCTION
Lowers freezing point, thus
  allowing free flow at low
  temperatures
Minimizes viscosity changes
  as temperature fluctuates
Holds oil-water mixtures in
  suspension
Kills bacteria and fungus
which cause odor problems
* Sources: References 55; 49, Table 2-2;
    and 51, Table 2.

-------
                                    - 46 -
                                   TABLE 11
               Properties and Components of Used Automotive Oil
                     Compared with Selected Virgin Oils
Property/Component
Used Automotive
  Oil - Range
Virgin Distillate
      Range
Virgin Residua;
     Range
Bottom Settlings &
Water (BS&W) %
Water %
Fuel Dilution %
Flash Point °F
Chlorine ppm
Br ppm
Carbon Residue %
Ash %
N ppm
S ppm
Ba ppm
Ca
Mg
Na
P
Zn
Ai
Cr
Cu
Fe
K
Mn
Ni
Pb
Si
Sn
Cd
0

.2 -
.4 -
175
1700
1000
1.82
.03
530
2100
10
700
10
16
500
300
.0
8
5
50
5
5
3
800
10
5

- 22

33.8 **
9.7 **
- 415
- 4700***
- 3000 ***
- 4.43**
- 3.78
- 1770**
- 6500**
- 2000
- 3000
- 1108
- 300
- 2000
- 3000
- 800
- 50
- 348
- 2000
- 79
- 10
- 30
- 11,200
- 875
- 112
4
0 - 1.5 0

0
0
126 - 204 150



.002 - .005 0

200 - 5900 3000

.7
.4
• 1


.5
13

10.5


3
1.7
8.2


mm

0
0
-



-


0
-
-
-
0
0
-
-
*
-
0
0
-
-
-
0
0
3



270



.5

4000

95
27.9
480


219
14
5
230


118
4.1
164


NOTE:  The term "distillate" in column 3 refers to middle distillate
oils (e.g. Nos. 1 and 2 fuel oils); the term "residual" in column 4
refers to heavier fuel oils (e.g., Nos. 4 and 5 fuel oils).
  * Source:  Unless otherwise indicated,
      data are taken from reference 134.
 ** Data from reference 53, Tables 2, 3, and 4.
*** Data from reference 49, Table 3.

-------
                                  -  47  -


content of the oils.   The  third  section  shows  the metal  content  of

the oilsr the first  six  elements (Ba,  Ca,  Mg,  Na, P,  and Zn)  are

associated with additive compounds;  the  remainder are wear  and

contaminant metals.   This  table  offers an  overall picture of  the

make-up of used automotive oil,  and  highlights the general  differ-

ences between these  and  virgin oils.   The  remainder of this

discussion will focus  on the specific  toxic components of used

automotive oil which provide support (in addition to  that provided

for unused oil) for  its  listing  as a hazardous waste.


    Polynuclear aromatic hydrocarbons  (PNA's or PAH's);

    As stated above  in the discussion  of unused oil,  PNA's  as

    a class ax-e toxic, and many  are  potent carcinogens as well.

    Already found  in virgin oils, PNA's  are "known to concentrate

    in used automotive lubricating oils, apparently coming  from

    the gasoline or diesel fuel  and  their combustion  products."51

    The National Bureau  of Standards  (NBS) uses benzo(a)pyrene

    (BaP), as an indicator of total  PNA  content.  According to

    NBS analyses as summarized in a  RECON report,52 the  BaP levels

    in used motor oils may be as much  as 900 times greater  than

    those found in unused  motor  oil basestocks (see Table 12)*.

    In absolute terms, a 1975 BERJ (Bartlesv ^e " ier~ •  Research

    Center) analysis of  ten used automotive oils found the  concen-

    tration ranges for three specific  PNA's to be: phenanthrerie

    40-110 ppm;  pyrene 30-100 ppm; and 1,2-benzanthracene

    3-30 ppm.53
* Note, however, that the BaP content of used diesel oil is
less than .15ug/g.  This is considerably lower than the levels
measured in used gas engine oils.

-------
                              - 48 -
                             TABLE 12
                 Benzo(a)pyrene Concentrations as
         Measure of PNA Content In Used and Virgin Oils
             Oil                          BaP in ug/g

    #2 virgin (distillate)                  .03 - .6

    #6 virgin (residual)                    2.9 - 44

    virgin motor oil basestocks             .03 - .28



    used motor & waste oils                 3.2 - 28

    used diesel motor oil                     < .15

    used industrial oil                        5.9
Source:  reference 50,  Table 14.

-------
                           -  49  -


Trace metals;

Trace metals of concern  in used automotive oil derive

from several different sources.  The extremely high  lead

content  (800-11,200 ppm; see Table  11)  is attributed chiefly

to piston blowby  in engines  using leaded gasoline*.  Lead

compounds may also be a minor component of some antiwear/

extreme pressure  additives (see Table 10).

    Barium, which like lead  is  absent from automotive lube"

oil stocks, is generally found  in used automotive oil in

the range of 10-2000 ppm (see Table 11)**.  Barium derives

from detergent/dispersant  additives (see Table 10),  which

make up 6.8% by volume of  SE quality multigrade motor oil.55

   According to Table 11,  the chromium concentration of

used automotive oil ranges from 8 to 50 ppm; cadmium was

measured at 4 ppm.  The presence of both these trace metals

in used automotive oil derives  from engine wear.

Nitrosamines;

Nitrosamines are  formed when secondary amines react  with

the following nitrogen compounds: nitrites, nitrates, and

nitrogen oxides.  A report to the National Science Foundation

indicates that, since both nitrogen and amine compounds are

found in used automotive oils,  the formation of nitrosamines

is possible.56  Furthermore,  various nitrosamines have been

patented for use  as anti-oxidants in fuels and as a  lube
*  However, because diesel fuel is unleaded, the lead content
of used diesel lube oil is negligible.
**
   NBS analyses have reported barium levels as high as
3906 ppm in some crankcase oils.54

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                        - 50 -


oil additive.5"7  Other precursors to nitrosamine formation

are currently used as lube oil additives.  These include

various aryl and aikyl amines which serve as anti-oxidants,

and morpholine which is a corrosion inhibitor.58  These

"precursors" react with nitrogen compounds in the used oil,

in the environment, or in the human body, to form nitros-

amines.59

Chlorinated hydrocarbons*:                                 '

    Petroleum is composed of a mixture of hydrocarbons,

including benzene and naphthalene.  When these and other

hydrocarbons are exposed to the significant levels of halo-

gens introduced during automotive use (see chlorine and

bromine concentrations,  Table 11), halogenated hydrocarbons

(e.g., chlorinated benzene and chlorinated naphthalene)

may be formed.  The halogen content of used automotive oil

derives from two sources:   additive package breakdown (see

Table 10); and addition of chlorine and bromine, as lead

scavengers, to leaded gas.
* Until the early 1970's, small amounts of poiychiorinated
biphenyls (PCS) were added to certain automobile transmission
fluids to enhance controlled swelling of rubber seals. Trans-
mission fluids from older automobiles thus may be a source of
low level PCS contamination of some used automotive oils ,,60
EPA's regulations under the Toxic Substances Control Act
(TSCA) presume that all used oil is contaminated with PCBs.^l
Although information from an independent testing laboratory
specializing in used automotive oil analysis indicates that
used automotive oil samples are, for the most part, free of
PCB contamination, the common collection practice is to mix
used oils taken from various sources.^2 jn this way, used
automotive oil may be contaminated through contact with PCB-
laden hydraulic or transformer oil collected from industrial
sources (see section on industrial oils).

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                                 - 51  -


 2.  Management  Practices

    In  1978,  an estimated  50-65%  of the motor  oil  sold  for

 passenger  car  use  was  sold  to  people  who  change their  own  oil.6-*

 These  people are "known in the  industry as "do-it-yourselfers"

 (DIYs).  Within the  next  5  years,  this group  is expected to  comprise

 75-80% of  such sales.6^   Currently, most  used oil generated  from

 DIYs  (over 200 million gallons)  is dumped on  the ground or into

 streams or sewers, or  is  placed  in containers and put  out  for trash

 collection.65'66

    Service stations  and automobile dealerships collect waste oil

 on  their premises  in 500-1000  gallon  tanks*.  The oil  collected at

 service stations is  derived from both on-site maintenance  of auto-

 mobiles and  DIYs who bring their used oil to  these stations.  No

 attempt is made at either service  stations or automobile dealer-

 ships  to segregate used oil from engines  using unleaded fuel from

 that of engines using  leaded gasoline.

    Used oil  tanks at service stations  and automobile dealerships

 are emptied  by  independent collectors.  The collector's trucks

 generally  hold between 2000-6000 gallons.  Used oil from several

 service stations or  dealerships  is  usually placed in the same

 truck.  The  collectors normally  sell  the  oil  for use as a  fuel,

 a dust control agent, a pesticide/ herbicide  carrier, or as  a
*  In addition to used oil, brake and transmission fluids, gas-
oline, kerosene, antifreeze (ethylene glycol), and such solvents
as benzene, trichlorethane, and perchloroethylene are often placed
in used oil tanks at service stations and automobile dealerships.
The low flash points, toxicity, and possible carcinogenicity of
many of these substances further increase the hazards posed by
the used oil.

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                               -  52 -


 feedstock to rereflners.*  Other uses which claim small amounts

 of used oil are asphalt mixes, and use as a herbicide.

   Used lube oil from diesel engines generated by large commercial

 trucking fleets may remain segregated from other used automotive

 oil  in the collection process.  Much of this oil goes to rerefiners,

 with the exception of that produced by the mining and construct-

 ion  industry (about 20% of all diesel vehicles).  The practice in

 these industries is to change the oil in the field, where  it

 is simply flumped on the ground. 6?  Some trucking fleets also mix

 low levels (2-6.5%) of used diesei lube oil with diesel fuel and

 burn the resulting blend in their engines.*>8


 B. Industrial

   The Bureau of Census data cited earlier (see page 43) indicate

 that industrial oil sales made up about 55% of the total lube oil

market in 1977.  The industrial category is subdivided into two

 groups:  lube oil,  including metalworking oils and oil used in

 railroad and marine diesel engines; and non-lube oils, including

hydraulic,  transformer, turbine,  and quenching oils.^9/70

   In general,  industrial oils contain an additive package similar

 to that of automotive oil (see Table 10).  Table 13 shows some of

the physical properties and chemical components of used industrial

oils.  Table 12 compares the PNA level of used industrial oil to

that of various other used and virgin oils.
* Some collectors treat the oil before selling it, to remove water
and solids, and small amounts of oxidation products.  Although such
"reclaiming" before sale and reuse may produce a cleaner and more
marketable oil, the properties and components of concern discussed
in this document are not removed or mitigated.

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                              - 53 -
                             TABLE 13

         Properties and Components of Used Industrial Oil
Property/Component

     Water %

  Plash Point °F

     Cl ppm

     S ppm

     Pb ppm

     Ba ppm

     Cr ppm

     Cd ppm
   Range

25.7 - 26.2

 315 - 355

1000 - 8300

5400 - 10,030
Mean
Max imum
125
59.7
7,9
2.7
2000
550
45
21
Source for data on first four properties/components
  reference 51, Table 3.
Soui'ce for data on last four components:
  reference 141, Table 3-7.

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                              - 54 -


   The data contained in these tables must be treated, however,

as only a rough sketch of the contaminants that may be found in

used  industrial oils.  The used industrial oil category is much

riore diverse than that of used automotive oil because industrial

oils perform a wider variety of functions compared to automotive

oils.  The contaminants in industrial oils vary with each function*,

as does the type of additive package used.  The components of these

additive packages are less predictable than those in automotive

oils because users of industrial oils frequently have their add-

itive packages custom-blended for their particular needs.  Thus,

unlike used automotive oil, it is impossible to identify a set of

contaminants that can be expected to be present in used industrial

oil per se.

   The Agency has limited data on contaminants found in some of

the larger sub-categories of used industrial oil.   This data will

be presented next, along with a description of how these types of

industrial oil are currently being disposed of or reused.  The

section is divided into two parts: lube and non-lube oils.

1.  Lube Oils

Metalworking oils:

Metalworking oils are lube oils used for catting,  grinding,

drilling,  and machining metals.   They range from 100% oil (neat

oil) to low concentrations of oil in water emulsions (soluble

oils).
* E.g., the trace metals in used metalworking oils vary with the
type of metal that is being cut, ground,  drilled,  etc.

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                               - 55 -


a. Constituents:

   Chlorinated hydrocarbons*:

   The chlorine content of used metaiworking oils is high,  which

   can lead to significant chlorinated hydrocarbon emissions when

   the oil is burned.  In the neat metaiworking oils,  the chlorine

   is derived from the additive package.   Metaiworking oils require

   enhanced extreme pressure additives which may contain as much

   as 18% active chlorine.73

      Used soluble metaiworking oils are  also likely to have a

   high chlorine content.   When the oil is recovered from the oil-

   water emulsion, the recovery process typically includes  breaking

   the emulsion with hydrochloric acid.  Chlorine from the  acid  may

   react with the oil's hydrocarbons to form chlorohydrocarbons.

   Nitrosamines;

   Recent studies indicate that "soluble  cutting oils  may contain

   nitrosamines,  either as contaminants in amines,  or  as products

   from reactions between  amines  and nitrites".74  The nitrosamine

   content  of metaiworking oils is  attributed to the additive

   package,  specifically to the antiwear/extreme pressure,  cor-

   rosion and rust inhibitors;  friction modifiers;  antioxidants;

   and metal  deactivator additives  (see Table 10).
  *  PCBs can enter metaiworking oil through  "tramp oil" accu-
  mulations.  Tramp oil  is oil  (usually hydraulic oil) from other
  parts of the machine which leaks or drips into metaiworking oil.
  Hydraulic oil  is likely to be contaminated  with PCBs (as explained
  later in the discussion on hydraulic oil),  and it can accumulate
  in metaiworking oil in sufficient amounts to raise a 5% oil/water
  emulsion to 10% oil.71 In addition, PCB additives were used in
  industrial lube oils prior to 1973.72 These could still be con-
  tributing to the PCB contamination of used  metaiworking oils.

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                                   -  56 -


        Use  of  synthetic  lubricants   in metalworking oils  is

    increasing, 77 anfl concentrations  of nitrosamines in synthetic

    cutting  oils have been measured at 1-1000 ppm.78

    Trace metals:

    Used metaiworking oils are heavily contaminated by fine wear-

    metal particles  (see  Table 13), and with barium from detergent/

    dispersant  additives.

b.  Management  Practices:

    Over 64  million gallons of metaiworking oils were sold in

1978.79 Because the typical metalworking operation does not con-

sume oil, about 60 million gallons of used oil are generated and

must, be disposed of or reused annually.

    The neat oils have an extremely high metal content, the soluble

oils have a high water content — both pose problems for rerefining,

The high chlorine arid sulfur content of the neat oils, and of the

acidified and recovered soluble oils, makes burning undesirable.

As  a result, only a small amount of these oils -- about 20% or 12.8

million gallons -- is being collected for reuse.80  ^he remainder,

is being disposed of by dumping, uncontrolled burning, ox- by land

applicat ion.
* Defined as a product made by chemically reacting lower molecu-
lar weight materials to produce a fluid of higher molecular weight
with planned and predictable properties.7^ The princj_pie types are
esters, silicones, flouro- and chlorocarbons, and polyoxyalkanes .
In 1980, synthetics made up 2% of the total lube (automotive and
industrial) market.  This figure may be up to 10% by 1985.76

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                                - 57  -


 Railroad  and  marine  oils:

 a.  Constituents:

    Because  railroad  and  marine  use of engine  lube  oils  parallels

 that  of automotive applications, ^1   the  trace metal  content,  of  used

 railroad  and  marine  diesel  engine lube oils should be similar to

 that  of used  automotive  oil (see Table 11), with the exception  of

 lead.  Diesel fuel is unleaded,  so there should be little or no

 lead  in any used diesei  engine  lube  oil.

    The additive package  required by  railroads consists  of deter-

 gents, 10.5%  by volume.^2   This  may  result in significant, barium

 concentrations in used railroad  diesel engine lube oil  (see

 Table 10).

    Marine diesel engine  lube oils* also  require an alkaline  det-

 ergent additive, up  to 15%  by volume  in  the crankcase oils.

 This  too may  lead to high barium levels  in used marine  oil (see

 Table 10).

 b.  Management Practices:

    About 80%  of railroad oil is  consumed  in use, leaving about

 10.3 million  gallons to be  disposed of or reused.  The  vast  major-

 ity (greater  than 95%) of this amount  is collected,  rerefined, and

 returned to the railroads for reuse.^3  Like  automotive diesel

 fleets, the railroads also mix their used lube oil with virgin

 diesel fuel,  at very low blend ratios.

    In 1978,  about 35.5 million gallons of marine cylinder arid

 crankcase lube oils were sold.  Much of the cylinder oil is  con-
* All information on marine oils is taken from reference 55,
pp. 48-52.

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                                 -  58 -


sumed  in use; the remainder  is drained out of the engine  into

the bilge tank.  Crankcase oil,  when changed, is also placed in

the bilge tank.  In the past, these bilge oils have been  dumped

at sea.  Now, naval and some commercial shipyards collect these

used oils.

   About 60% of all marine oils  are consumed in use. Of the re-

mainder, 16% is collected for reuse as fuel  (marine facilities

also blend low levels of used lube oils with virgin diesel fuel)

or for rerefining.  The remaining twenty-four percent (or 8.5

million gallons) is dumped at sea or on the land.


2. Non-Lube Oils:

   Hydraulic oils:

   Hydraulic oils are widely used in industry, primarily  in dies-

   casting, steel foundry operations, automobile production, and

   mining.

   a. Constituents:

      Chlorinated hydrocarbons;

      Until 1972, PCB-based hydraulic fluids were commonly used.

      When manufacture of these  fluids was discontinued,  it was

      not recommended that hydraulic systems be drained, flushed, or

      refilled*.   Rather,  the public was advised to merely replace

      these fluids (without PCBs) as leaks and spills occurred..  As

      a result,  PCB levels in hydraulic systems range from 60 to

      500,000 ppm.84
*  The extreme complexity of hydraulic systems makes it very
difficult to eradicate all PCB contamination from these systems

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                              -  59  -








    Nitrosamines:




    Nitrosamine precurors may be present  in  the  form of




    nitrogen and amine compounds,  deriving from  the  anti-rust,




    anti-oxidant, and anti-wear additives found  in hydraulic




    oils.85



b. Management Practice:




   In 1978, 234 million gallons of hydraulic oils were sold.




Small quantities of this oil  were  consumed in use or lost




through leakage and spills.




   Large industrial facilities recover much of their used




hydraulic oil, which may be sold to collectors, burned as a




fuel supplement in the plant  itself, or used as a dust control




agent on plant site roads arid parking lots.  At construction




sites and mining operations, however, hydraulic oils  are not




recovered.  It is estimated that 40% of these hydraulic oils,




or about. 94 million gallons,  are disposed of annually. ^






Transformer Oil;




a. Constituents:




   Chlorinated hydrocarbons;




   Transformer oils, used in electrical transformers as a




   heat transfer  medium,  are straight mineral oils with no add-




   itives.^"7  However,  until 1977,  PCBs were widely used as a




   dielectric  fluid in transformers and other electrical equip-




   ment.  These PCBs still remain  in many transfox-mer systems,




   contaminating  transformer oil.

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                                - 60 -


        The preamble to EPA's PCB regulations states that as

     many as 38% of the 35 million transformers using mineral oil

     contain between 50 and 500 ppm PCBs.^8  &n independent test-

     ing laboratory estimates that about 50% of all transformer

     oils show greater than 50 ppm PCB contamination. This occurs

     because, even if transformers are drained and cleaned out,

     they have "long memories",  and PCBs are likely to remain in

     the system.89

        In addition to PCBs, transformer oils have also been found

     to contain trichiorobenzene, a persistent toxic substance.-'0

  b. Management Practice:

     About 98 million gallons of transformer oils were sold in

  1978.  This unusually high figure reflects an increased demand

  to replace PCB-contaminated oil.

     Transformer oils do not make a good rerefinery feedstock

  because of their low viscosity.  EPA's PCB regulations strictly

  control the disposal and reuse options of PCB-contaminated oils.

  At present, most used oil collectors are refusing all trans-

  former oil, thus putting the burden of proper disposal on the

  generators.91


Turbine oil*;

a. Constituents:

   Turbine oils are used in steam, natural gas, or dual cycle

turbines that generate electricity or run compressors.  The oils

require a high temperature oxidation inhibitor, about 2% by volume.
* All information on turbine oils is taken from reference 55,
pp. 61-62.

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                                 - 61 -






 Because  ashless  additives  such as aromatic amines or hindered



 phenols  are preferred,  nitrosamine precursors may be present in



 the  turbine oils as  a  result  of the additive package.



 b. Management  Practice:



   Eighty-four million  gallons of turbine oil were sold in 1978.



 Turbine  oils may be  changed as often as  once a year,  or may be



 treated  and reused for  up  to  20 years.



   Most  turbine  oil  is  used in large industrial plants,  which



 tend to  collect  their used oil.   It is estimated that about 50.4



 million  gallons  of used turbine  oil is recovered and  either



 disposed of or reused.






 Quench ing oil;



 a. Constituents:



   Quenching oils act as a cooling  medium for hot metals.   These



 oils contain numerous additives,  including barium sulfonate,  z iric



 compounds,  sodium nitrate, and antimony  trioxide.^2



 b. Management  Practice:



   About 50% of  the  7.5 million  gallons  of quenching  oils  sold in



 1978 were collected  from metalworking  shops.   At  shops which  place



 used quenching arid metalworking  oils  in  the  same  container, the



 quenching oils become tainted  with  the contaminants found  in  used



 metalworking oils.





                        *****




   On the whole,  mixing of used  industrial oils  from  different



 sources does not. occur to the  extent it  does  with  automotive  oils.



Many users of  industrial oil find it more  cost-effective to burn

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                               - 62 -






their used oil as a fuel or otherwise manage it (e.g., by



using the oil as a dust suppressant on unpaved roads or parking



lots on their property), rather than give or sell it to used oil



collectors.  This is not to say that mixing of different types of



used industrial oils does not occur within industrial plants.  For



financial and space constraints often operate against providing



separate storage facilities for,  say,  neat metalworking oils and



soluble oil-water emulsions.93  Nonetheless,  the opportunity to



segregate oils with different contaminants is greater when gen-



erators reuse their oil on-site rather than give it to used oil



collectors.



   Some used industrial oil is, however,  consigned to used oil



collectors.   The collectors usually transport different types of



used oil in the same compartment  of their trucks,  so that the



various contaminants in the individual waste streams become mixed



throughout the composite tfaste oil.

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                                - 63  -


 II.  Basis  for  Listing

 A. Adverse effects  of  contaminants  in  used  oil

   This  section briefly  describes the  toxic effects of the var-

 ious contaminants found  in  certain used  oils*.   In addition,  for

 each contaminant, the  discussion notes if substances  containing

 these contaminants  are subject  to controls  under regulatory pro-

 grams other than those concerned with  solid waste management.


 Polynuclear aromatic hydrocarbons (PNAs);

   The toxic and carcinogenic effects  of PNAs were described

 earlier  in the chapter on unused oil.  SC>2,  which is  present  in

 the  vapor  produced  when  used oil is  burned,  is considered to have

 a synergistic effect on  PNA-induced  carcinogenesis. ^4


 Halogentaed Hydrocarbons;

 1.   Polychlorinated biphenyls (PCBs):

     a.   Health Effects:  PCBs have been identified by  EPA's Car-

 cinogen  Assessment  Group as exhibiting substantial evidence of

 care inogenicity. 95  PCBS  are also highly toxic. They are absorbed

 through  the lungs,  the skin, and the gastrointestinal tract; then

 are  circulated throughout the body in  the blood, and  are stored

 in the liver, kidneys, lungs,  adrenal  glands, brain,  heart, and

 sk in.96

   Yusho disease (human PCB poisoning) affected at least 1000

people who ate rice bran oil contaminated with PCBs.   These
*  Detailed discussions of the adverse environmental effects of
many of these contaminants are contained in the criteria docu-
ments prepared under Section 304(a)(l) of the CWA. See 45 PR
79318 (November 28, 1^80).

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                               - 64-






victims also evidenced an abnormally high cancer rate of the



stomach and liver.  It is estimated that the Yusho victims in-



gested PCBs at a rate as low as 67 ug/kg of body weight per day



for 3 months.97




   Skin lesions have developed among workers exposed to air



containing PCBs at levels as low as .1 mg/m3.^^




   b. Ecological Effects:  PCBs are inert and persistent, having



a tendency to accumulate in waterways and to bioaccumulate in



fish.  PCB levels of 1 ppb may adversely affect aquatic insects



and crustaceans.  Concentrations as low as .1 ppb have been shown



to depress photosynthesis in phytoplarikton and to retard their



rate of cell growth arid division. ^9



   c. Other Regulations:   EPA has designated PCBs as a toxic



pollutant arid has set effluent standards prohibiting any discharge




of PCBs into navigable waters by PCB manufacturers, electrical



capacitor manufacturers and electrical transformer manufacturers.



      The ambient water criterion for PCBs is .001 ug/l.100 There



are no ambient air quality standards for PCBs.  However, disposal



of PCB-contaminated wastes is governed under TSCA by 40 CFR Part



761. Wastes (specifically used oil) containing less than 50 ppm



PCBs may be rerefLned or burned without controls, but may not be



used as a road oil, dust suppressant,  or sealing and coating agent.



Used oil with 50-500 ppm PCBs must be burned in a high-efficiency



boiler or approved incinerator, where the destruction efficiency



is 99.9%; it may also be disposed of in approved chemical landfills



Used oil with greater than 500 ppm PCBs must be disposed of only



by high temperature incineration.

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                                -  65  -






      PCBs  are  listed  a hazardous  constituent  in  Appendix VIII,



 40  CFR Part  261;  thus raising  the presumption that  any wastes



 containing these  substances  are hazardous wastes.



    The National Institute of Occupational Health and  Safety has



 determined that levels  in the  workplace  for two  types of PCB



 compounds  must not exceed 1  mg/m^ (Arochlor 1242) and  .5 mg/m^



 (Arochlor  1254).101



 2.  Other halogenated  hydrocarbons:



    a.  Health Effects:  Chlorinated benzenes and  chlorinated



 naphthalenes, among other halogenated hydrocarbons, may be found



 in  used oil.  Both of these  compounds are toxic  when  ingested or



 inhaled.   Chlorinated naphthalenes are also toxic when applied to



 the skin,  and may produce skin  lesions,  as well  as  acute liver



 atrophy.!02



    These compounds emit toxic  fumes when heated  to  decomposition;



 they may react with oxidizing materials.103






 Nitrosamines:



   a.  Health Effects:  Nitrosamines are  suspected human, and



known  animal carcinogens.  Evidence of a causal  relationship of



 nitrosamines to human cancer is supported by the following facts:



 all mammals studied are susceptible to carcinoma induction by at



 least  one nitrosamine; nitrosamines are effective carcinogens by



 inhalation, ingest ion, and dermal contact; nitrosamines can be



 formed in vivo in mammals through the interaction of nitrosamine



precursors, (specifically,  injested secondary amines and nitrites)



   Nitrosamines are carcinogenic and mutagenic in a wide range of



animal species, with tumors affecting all vital organs.

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                                - 66 -


   b.  Ecological  Effects*:  Plants are capable of assimilating

nitrosamines and their precursor compounds from the soil and from

water cultures,  and can  form nitrosamines by metabolic activity.

The presence of  nitrosamines in plants appears to have no detri-

mental effect on the plant itself, but may pose a hazard to

animals  ingesting these  plants.

   c.  Other Regulations:  Nitrosamines and their precursors are

widely distributed in the environment.  Currently available data

do not provide sufficient information to estimate total or relative

human exposure via ingestion or inhalation, nor are they sufficient

to set criteria  for maximum exposure.  However, nitrosamines are

listed as hazardous constituents in Appendix VIII, 40 CFR Part. 261,

thus  raising t.he presumption that any waste containing these sub-

stances  is hazardous.

   As to nitrosamine precursors, the national primary drinking

water standard (NPDWS) for nitrate nitrogen is 10 mg/1.106  The

national primary ambient air quality standard for nitrogen dioxide

is 100 ug/m^ (.05 ppm),  annual arithmetic mean.107


Trace Met.als

1. Lead :

   a. Health Effects:  When ingested or inhaled,  lead and its

compounds are highly toxic.108  Lead is a cumulative poison, and

can attack the liver and kidneys,  the brain and nervous system,

as well as the blood vessels and other tissues.  Lead poisoning

can be fatal.
*  Information on the ecological effects of nitrosamines is
taken from reference 105.

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                                -  67  -






    It  is believed  that  the human  intake  rate  at which  lead



 accumulation begins  to  exceed  excretion  is  about  1 mg/day.109



 However, chronic ingest ion of  .1  mg/day  over  several years has



 been reported to cause  lead poisoning.



    b.  Ecological Effects:  Lead is rarely taken up by  plant



 roots, but can contaminate vegetation exposed to  airborne parti-



 cles of the metal.   If  such plants are used for forage or fodder,



 their  lead content may  enter the  food chain.11^   Lead has also



 been shown to be toxic  to aquatic organisms,  with the degree of



 toxicity depending on such variables as  water temperature and



 alkalinity. 11:L



    c.  Other Regulations:  EPA has set .05 mg/1 as the NPDWS for



 lead.  5 mg/1 (or  100 times the NPDWS) is the threshold concen-



 tration for lead, above which the extract from any lead-containing



 waste  meets the characteristic  of "EP Toxicity" pursuant to 40 CFR



 Part 261.



       The ambient air quality standard for  lead is 1.5 ug/m3,



 averaged over 3 months.  The OSHA standard  is 50 ug/m3, based on



 an  8-hour workday. H2



 2.  Barium



    a. Health Effects:  Ingestion of soluble barium compounds



 results in severe gastrointestinal distress and muscular paralysis.



 Inhalation of barium compounds can lead to baritosis, a benign



 respiratory affliction.113



     Fatalities from inhalation of barium oxide,114 and from



 ingest ion of barium carbonate11^ have occurred.   The fatal dose



of barium for humans is reported to be 550-600 mg.11^

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                                -  68  -


     b.  Ecological  Effects:   The existence of  soluble barium

 compounds  toxic  to aquatic  species is  unlikely under normal

 marine  and freshwater  conditions.H?

    c. CH-her Regulations:  The NPDWS  for barium is 1 mg/1.  100

 mg/1 is the threshold  concentration  for barium, above which the

 extract from any barium-containing waste meets the characteristic

 of  "EP  Toxicity" under 40 CFR Part 261.

    The  OSHA criterion  for soluble barium compounds is .5 mg/m^.


 3.  Chromium*

    a. Health Effects:  Hexavalent chromium compounds are highly

 toxic when ingested/ inhaled, or applied to the skin.H8  Control-

 led  experiments with animals indicate that hexavalent chromium

 compounds  are toxic and possibly fatal to animals, with the skin,

 mucosa,  lungs, and kidneys being affected.H9 Chromium is also

 a suspected cause of lung cancer.120

   b. Ecological Effects:

    Low  levels of hexavalent chromium (.03-64 ppm) inhibit algae

•growth.   Sigrnficant adverse effects on fish have been observed

 at  .2 mg/1  of hexavalent chromium.121

   Chromium  is taken up through plant roots.  Although natural

 soil contains some chromium  (40 ppm,  mean),  additions of even

 small amounts (5-50 ppm) have been shown to damage vegetation.122

   c. Other Regulations:  The NPDWS for chromium is .05 mg/1.

 The waste  extract concentration for chromium triggering the
*  When incinerated- chromium oxidizes to hexavalent chromium,
thus rendering potentially hazardous all chromium-containing
wastes that are burned.

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                                - 69  -


 "EP Toxicity" characteristic for hazardous wastes under 40 CFR

 Part  261 is  5 mg/1*.

   OSHA standards are I mg/m^  for the metal and  its  insoluble

 salts, and  .5 mg/m^ for its soluble  chromium salts.


 4. Cadmium

   a. Health Effects:  Cadmium  compounds are extremely toxic and

may be fatal when ingested or  inhaled.1^3  when  ingested, little

absorption  is likely to occur because of rapid elimination by

vomiting.  When inhaled, cadmium accumulates in the kidneys,

liver, pancreas, and thyroid, and is retained in the body for

many years. ^4

   The estimated fatal dose of  inhaled cadmium to humans is

about 50 mg/m^ for one hour.125

   b. Ecological Effects:  Cadmium is taken up from the soil

by plant roots. If present in the air as a dust contaminant, it

can also enter plants via precipitation.126  such cadmium uptake

can result in decreased crop yields.127  Furthermore, foods grown

in cadmium-contaminated soils irrigated with cadmium-polluted

water can accumulate sufficient quantities of the metal to pose

a human health hazard.128

   Cadmium levels of less than 1 ug/1 can have adverse effects

on certain fish species.129

   c. Other Regulations:   The NPDWS  for cadmium is .01 mg/1.

The waste extract concentration for cadmium triggering the
* On October 30, 1980, EPA proposed to amend the "EP toxicity"
characteristic for chromium to apply to hexavalent chromium
instead of total chromium, (see 45 FR 72029-34).

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                               - 70 -






"EP Toxictty" characteristic for hazardous wastes under 40 CFR



Part 261 is 1 mg/1.  Application of wastes containing cadmium



to food chain crops is controlled under 40 CFR 257.3-5 and



40 CFR 265.276.



   OSHA sets its cadmium standard at 2 mg/m^.

-------
                                - 71 -


 B.  Hazards  posed by mismanagement

    Accurate data on the quantity of used oil generated and the

 management  practices currently used to reuse or dispose of it

 are difficult  to obtain because there are so many sources of used

 oil and  no  national reporting  requirements for the oil's generation

 or  management.   Estimates  vary considerably as to how much used

 oil is generated each year,  with a  recent EPA draft report placing

 the amount  at  464 million  gallons for used automotive oils and

 380 million gallons for used industrial oiis.-^O

    The four most frequently  cited methods for managing used oil

 are: burning it  as a fuel; applying it to road surfaces or other

 land areas  as  a  dust suppressant or road oil;  re-refining it to

 produce  lube oil basestocks; and disposing of it either in land-

 fills or by indiscriminately dumping it into sewers or on the

 ground.  Again,  there is considerable disagreement  in the liter-

 ature as to how  much oil is  managed by each of these methods.

 The  following breakdown (by  percentage)  is consistent with most

 reports on  this  subject:


          Burned as  a  fuel                       55%

          Used as  a  road oil,  dust               15%
             suppressant or other land
             application use

          Re-refined  to a lube oil               10%
             basestock

          Disposed of  in landfills,              20%
             or indiscriminately  dumped


There are potential hazards associated  with many of these manage-

ment oractices.

-------
                                -  72  -








 Land  application:




   When  used  oil  is applied to  the land  (either as a road oil,



 dust  supressant, or when  indiscriminately dumped), the oil and



 its contaminants can migrate by flotation (precipitation-induced



 runoff), by percolation through the  soil, by direct runoff (if



 the application is excessive),  by volatilization, and by dust



 transport.131  The quantities of oil and contaminants transported




 by these various mechanisms varies greatly, depending on terrain,



 soil  porosity, wind and rain conditions, temperature, traffic



 volume, and rate of application.  Nonetheless, the potential for



 environmental contamination is  significant.



   The chapter on unused oil described the hazards posed when oil



migrates to surface water and ground water.  Trace metals in used



 oil may also pose a threat to human health and the environment



because they may be taken up by plant roots from oil-contaminated



 soil.  Volatilization of the oiled surface can produce toxic



metal-laden dust particles, which can enter vegetation via pre-



 cipitation .132  Such dust can also coat vegetation,  which may be



 used  as food for wild or domestic animals.  Thus, toxic metals in



 used  oil may enter the food chain.



   The toxic effects of other used oil contaminants  (specifically



halogented hydrocarbons, including PCBs, and nitrsoamines) were



described  in the previous section of this document.   These con-



taminants may migrate to surface and ground waters if used oils



 containing them are improperly applied to land surfaces.

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                               - 73 -



Landfill ing:

   When used oil  is disposed of in an insecure landfill, the

potential for contamination of ground water supplies is the same

as that described earlier for unused oil.  The potential harm is
     *
of course greater for used oil than with unused oil because the

former contains hazardous contaminants which may migrate to ground

water along with the oil component.



Burn Lng:

   When used oil is burned, either as a fuel or for the purpose

of thermal disposal, its contaminants may enter the atmosphere.

   Anywhere from 20 to 100% of the lead in used oil entering a

steam boiler can be expected to be emitted from the stack.  Most

of the remainder is deposited on tubes and elsewhere in the com-

bustion furnace.  Furnace deposits may be emitted during soot-

blowing,  where this is practiced,  or they may eventually be

removed during furnace and boiler cleaning.^33

   Seventy-six to 79% of the lead and 3 to 51% of the barium in

used oil burned as fuel are emitted in particles less than a micron

in size.134  These submicron size emissions remain suspended in the

atmosphere longer and,  therefore,  may have a wider dispersion range

than larger part icles. 135  Compared to large particles, submicron-

size particles tend to penetrate more deeply into the respiratory

tract, and are retained there longer.136

   Other trace metals in used oil may be expected to behave sim-

ilarly to lead with regard to stack emissions, but very limited

data are  available.

-------
                                -  74  -
    Stack burning tests measuring PNA emissions  from boilers

burning used oil indicate that PNA emissions are similar to those

resulting  from burning virgin oils
                            Damage Cases

   Used oil serving as a mask for dangerous substances has been

implicated in a number of damage incidents, as have many of the

contaminants discussed above.*  These incidents show empirically

the potential for substantial harm if used oil is managed

improperly.

  In Missouri in 1971, about 5000 gallons of waste oil con-
  taining 300 ppm dioxin were sprayed on the floor of a horse
  arena.  Sixty-three horses died; many other horses, dogs, cats
  and birds became ill after exposure to the arena.  One child
  who played in the area developed epistaxis,  gastrointestinal
  disorders,  and severe hemorrhagic cystitis.   Ten other persons
  were afflicted with diarrhea,  headaches, nausea, and persistent
  skin lesions.

  In Nebraska in 1958, an explosion attributed to burning used
  oil with a low flash point (possibly resulting from gasoline
  dilution) occurred in a meat packing plant.   As a consequence,
  the State enacted legislation establishing a minimum flash
  point for used oil burned as a
  In 1978, 33,000 gallons of transformer oil contaminated with
  PCBs wer-e dumped along 210 miles of secondary roads in North
  Carolina.  The North Carolina Agriculture Commissioner caut-
  ioned against any direct or indirect human consumption of
  crops grown within 100 yards of the spill.  Nearby residents
  reported nausea, dizziness and cramps. 140

  In Texas in 1978, used oil serving as a "mask" for toxic
  wastes was applied to roads as a dust suppressant.  Nearby
  residents suffered headaches and nausea; livestock died.
  The used oil was found to contain nitrobenzene and cyanide.
*  Unless otherwise indicated,  all information on damage cases
is taken from reference 138.   Many other damage incidents from
improper management of used oil are contained in EPA's collect-
ion of incidents from individual states.

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                                -  76  -


                              Summary

   When  used oil  is  improperly  managed,  its oil component poses

the  same potential threat to ground  and  surface waters as does

that of  unused oil.   In  addition  to  the  arguments made earlier

for  listing certain  waste unused  oils as hazardous wastes, the

Agency believes that the following points  lend further support

for  deeming some  used oils to be  hazardous wastes:
   1. Most used automotive oils, and certain  industrial oils,
   have been shown to contain significant concentrations of
   some or all of the following contaminants:

      a. polynuclear aromatic hydrocarbons such as benzo(a)-
         pyrerie, phenanthrene, and 1,2-benzanthracene, which
         are potent carcinogens;

      b. polychlorinated biphenyls (PCB's), which are carcino-
         genic, and other halogenated hydrocarbons, which are
         persistent toxics;

      c. nitrosamines, or their precursors, which are potent
         carcinogens;

      d. trace metals, such as lead, barium,  chromium, and
         cadmium, which are toxic as elements and in compounds.*

   2. Typical used oil storage, collection and transportation
   practices often result in related wastes,  such as anti-
   freeze and solvents, being mixed in with used oil. Further-
   more, used oil is sometimes deliberately contaminated, thus
   serving as a "mask" for such toxic substances as dioxin,
   nitrobenzene, and cyanide.

   3. Over 800 million gallons of used oil are generated in
   the United States each year.
*  The levels of these metals in used automotive oils, other
than used diesel lube oil, exceed that which triggers the
"EP toxicity" characteristic for hazardous waste under 40 CFR
Part 261 (see Table 11).  Used diesel oil contains negligible
quantities of lead and, thus, would meet the characteristic of
"EP toxicity" for only barium, chromium, and cadmium.

-------
                            - 75 -
In Kansas, 56 cattle died and 112 more had to be slaughtered
when used oil laden with PCBs was used on back-rubbers on a
farm.

In Minnesota, used oil, grease, various other hydrocarbons,
and phenols were disposed of in an unlined basin.   Soil and
ground water were found to be contaminated with PNAs up to
1400 feet from the basin.

In Massachusetts, one million gallons of solvents,  used oil,
toxic metals, and halogenated hydrocarbons leached from an
abandoned disposal site.  Rainwater runoff resulted in
contamination of the Concord River's aquatic environment.

-------
                               -  77  -


    4. Used otl applied  to the  land  (e.g., as a  road oil, dust
    suppressant, or when indiscriminately dumped) poses an
    environmental hazard resulting from the direct  release of
    the oil onto the  land, and  through percolation  and run-off
    into ground and surface waters.

    5. Used oir~"disposed of in  insecure landfills may also leach
    through the bottom of such  landfills, and subsequently
    contaminate ground water  supplies.

    6. Because of the presence  of contaminants,  uncontrolled
    burning of certain used oils, either as a fuel  or for the
    purpose of thermal disposal,  may result in significant levels
    of hazardous emissions to the environment.   This, in turn,
    may expose humans, wildlife,  and vegetation  in  the area to
    these harmful substances.

    7. Many of the contaminants in used oil are  persistent,
    bioaccumuiative, or  have  potential for increased penetration
    of the respiratory tract, thus magnifying the possibility of
    exposure and harm.

    3. Improper management of waste  oil has caused  many actual
    damage incident s.


    The Agency believes  that  ail  of  these considerations support

the listing of used automotive and  industrial oils as toxic (T)

hazardous wastes.

   Used, automotive oils will be  listed as hazardous wastes based

on the following constituents  :  polynuclear aromatic hydrocarbons

(including benzo(a)pyrene and benz(a)anthracene);  chlorinated

napthaiene;  chlorinated benzenes; nitrosamines; lead;  barium;

chromium and cadmium.   Though certain types of used automotive

oils may not contain one or more of these substances (e.g.,  used

diesel lube  oil does not contain lead),  the fact that  different

types of automotive oils are typically stored and transported in

the same container argues for the Agency's presumption that most

used automotive oil will eventually become contaminated with most

of the hazardous substances specified above.

-------
                                -  78  -


    Significant quantities of used industrial oils are source-

 segregated  and managed on-site  (e.g., burned as a fuel, used as

 a  dust  suppressant).  Therefore,  unlike used automotive oils,  it

 would be  inappropriate to generalize that all  industrial oils

 will eventually become contaminated with hazardous substances

 found in  individual types of used oils.  For this reason, a

 common  set  of contaminants has not been specified as the basis

 for listing used industrial oil per se as a hazardous waste.

    Instead, all used  industrial oil will be listed as a hazardous

 waste based on its aromatic oil component*.  This is the same as

 was done  for unused oil.  In addition, where the Agency has suf-

 ficient data on the hazardous contaminants of particular types of

 industrial  oils, these substances will be listed as additional

 reasons for deeming the oil to be hazardous.  For now, the follow-

 ing types of used industrial oils will be deemed to be hazardous

 wastes based on the following hazardous constituents in addition

 to aromatic hydrocarbons:

            Metaiworking:  nitrosamines; barium

            Railroad and marine:  barium

            Hydraulic:  PCBs**; nitrosamines

            Transformer:  PCBs

            Turbine:  nitrosamines
*   The exception to this are used industrial oils that have no
aromatic oil component (e.g., finishing oils made with white oil
basestocks).

**  Even though used oils containing greater than 50 ppm PCBs are
deemed to be hazardous wastes under RCRA, EPA intends to subject
these oils to the management standards under TSCA (40 CFR Part
761) rather than RCRA.

-------
                                - 79 -


                              References


 1.   EPA,  Quality  Criteria  for Water,  July,  1976,  p.  113.

 2.   Crump-Wiesner,  Hans  J.  and Allen L.  Jennings,  "Properties
     and  Effects of  Nonpetroleum Oils,"   Proceedings  of Joint
     Conference on Prevention  and Control of Oil  Pollution,
     Washington, D.C.,  American Petroleum Institute,  1975,
     pp.  31-32.

 3.   Federal  Register,  Vol.  45,  May  19, 1980,  p.  33107.

 4.   EPA,  Washington State  Refineries:  Petroleum,  Petroleum
     Derivatives,  and Wastewater Effluent Characteristics
     (EPA  600/7-78-040),  March 1978,  p. 38.

 5.   OSHA, Occupational Health and Safety Aspects  of  Fog Oils
     SGF No.  1 and SGF  No.  2 and Smoke  Screens Generated From Them
     TDAMD-17-77-C-7020), April  1978, p.  14.

 6.   EPA,  A Small  Oil Spill at West  Falmouth  (EPA  600/9-79-007),
     March 1979, p.  5.

 7.   EPA,  Oil Spill  Debris  - Where to Put the  Waste (EPA 600/7-
     80-016), January 1980, pp.  2-3.

 8.   State of Maine,  Department  of Environmental Protection,
     Statewide Oil Spill  Statistical  Report  for 1979, p. 9.

 9.   Dennis,  David M. "Effectively Recovering  Oil  Spills to
     Groundwater,"   Proceedings  of Joint  Conference on  Prevention
     and Control of  Oil Pollution, Washington,  D.C.,  American
     Petroleum Institute,  1977,  p. 255.

 10. Written correspondence from Thomas R. Beauiieu,  State of
    New Hampshire,  Water Supply and Pollution Control Commission,
    Nov.  24, 1980.

11. Written correspondence from Frank Estabrooks, State of
    New York, Department of Environmental Control, Nov. 1980.

12. Telephone conversation, Arline M. Sheehan, EPA,  OSW, HIWD,
    with Fritz Ybenga,  USCG,  Office of Merchant Marine Safety,
    Cargo and Hazardous Materials Division, Dec. 9,  1980.

13. EPA 600/9-79-007, p.  5.

14. Telephone conversation, Arline M. Sheehan with Gil Holland,
    North Carolina  Department of Corrections, Nov. 25, 1980.

-------
                              - 80 -
15.  Biglane, Kenneth, Affadavit supporting EPA's "Sheen Test",
     May 1974.

16.  EPA, Quality Criteria for Water, pp. 114-115.

17.  Ibid, pp.116-120.

18.  see 45 FR 79318  (November 28, 1980).

19.  45 FR 33107 (May 19, 1980).

20.  Winters, Kenneth and Patrick L. Parker, "Water Soluble
     Components of Crude Oils, Fuel Oils, and Used Oil Crankcase
     Oils," Proceedings of Joint Conference on Prevention and
     Control of Oil Pollution, Washington, D.C., American
     Petroleum Institute, 1977, pp. 579-580.

21.  see 45 FR 79318  (November 28, 1980).

22.  45 FR 33113 (May 19, 1980).

23.  Payne, Jerry.  F. and Robert Maloney, "Are Petroleum Hydro-
     carbons an Important Source of Mutagens in the Marine
     Environment?"  Proceedings of Joint Conference on Prevention
     and Control of Oil Pollution, Washington,  B.C., American
     Petroleum Institute, 1979, pp. 533-535.

24.  EPA, A Study on the Environmental Benefits of Proposed
     BAETA and NSPS Effluent Limitations for the Offshore
     Segment of the Oil and Gas Extraction Point Category
     (EPA 440/1-77-011), May 1977, pp. 188.

25.  ZoBell, Claude E., "Sources and Biodegradation of Carcino-
     genic Hydrocarbons,"  Proceedings of Joint Conference on
     Prevention and Control of Oil Pollution,  Washington,D.C.,
     1971,  p. 442.

26.  Ibid,  p. 448.

27.  DOE, Motor Gasolines,  Winter 1979-80 (DOE/BETC/PPS-80/3),
     Bartlesville Energy Technology Center,  Bartlesvilie, Oklahoma,
     July 1980.

28.  Hutchinson, Thomas C., e_t al. , "Relationship of Hydrocarbon
     Solubility to Toxicity in Algae and Cellular Membrane Effects,"
     Proceedings of Joint Conference on Prevention and Control of
     Oil Pollution, Washington, D.C.,  American Petroleum Institute,
     1979,  p. 541.

29.  EPA 600/7-73-040, p. 85.

30.  EPA 440/1-77-011, pp.  37, 156.

-------
                               - 81 -
 31.   Hutchinson,  p.  541.

 32.   EPA 600/7-78-040,  p.  47.

 33.   EPA 440/1-77-011,  p.  345.

 34.   Ibid, p.  111.

 35.   Ibid, p.  45.

 36.   Clean Environment  Commission,  Canada,  "Preliminary Report
      on  Contamination of Underground  Water  Sources by Refined
      Oil  Products,"  Ground Water, Vol.  44,  Jan./Feb.  1976,
      p.  37.

 37.   EPA, Report  to  Congress, Waste Disposal  Practices and
      Their Effects on Ground Water, January 1977,  p.  ii.

 38.   Van  Der Waarden, M.,  et al., "Transport  of  Mineral Oil
      Components to Groundwater -  I,"  Water  Research,  Vol.  5,
      1971, p.  213.

 39.   American  Petroleum Institute,  Underground  Spill  Cleanup
      Manual, API  Publication 1628,  June 1980, pp.  5,  8.

 40.   Ibid, p.  4.

 41.   Duffy, J.J., and M.F. Montadi, "Subsurface  Persistence of
      Crude Oil Spilled  on  Land and  Its  Transport in Groundwater,"
      Proceedings  of  Joint  Conference  on Prevention and Control
      of Oil Pollution,  Washington,  D.C.,  American  Petroleum
      Institute, 1977, p. 475.

 42.   Clean Environment  Commission,  Canada,  p. 38.

 43.   McKee, Jack  E., et al., "Gasoline  in Groundwater," Journal
     of Water Pollution Control Federation, Vol. 44, February
     1972.

44.  EPA, Oil Spill Debris: Decisions for Debris Disposal,
     (EPA 600/2-77-153b), August 1977, p. 40.

45.  Ibid, p. 58.

46.  Duffy, p. 477.

47.  EPA 600/2-77-l53b, p. 41.

48.  Bureau of the Census, "Sales of Lubricating and Industrial
     Oils and Greases," Current Industrial Reports, 1977.

-------
                               - 82 -
 49.  Mascetti,  G.J.  and  H.M.  V/hlte,  Utilization of Used Oil,
     prepared  for  DOE  by the  Aerospace Corporation,  August 1978,
     p.  2-5.

 50.  Ibid. , pp.  2-7, 2-8.

 51.  Becker, D.A.  and  J.J. Comeford,  Recycled Oil Program;
     Phase I -  Test.  Procedures  for  Recycled Oil Used as Burner
     Fuel, report  to the Federal  Trade Commission by the National
     Bureau of  Standards, October 1978,  p.  39.

 52.  Recon Systems,  Inc.  and  ETA  Engineering,  Inc.,  Used Oil
     Burned As  A Fuel, draft  report  prepared for EPA,  November
     1980, pp."7-28, 7-29, 7-30.

 53.  Whisman, M.L.,  et al., Waste Lubricating Oil Research:
     Characterization of Basestocks  From Used Lubricating Oils;,
     Part I, Bartlesvilie Energy  Research Center,  Bartlesville,
     OK, June 1975,  p. 18.

 54.  Becker and Corneford, p.  12.

 55.  Richard J. Bigda and Associates,  Review of All  Lubricants
     Used in the U.S. and Their Re-refining Potential,  prepared
     for DOE, June 1980, p. 25.              ~

 56.  Fine, David 'and R.Y. Fan, Report  to the National  Science
     Foundation, September 16, 1976,  as  referenced in  EPA,
     Assessment of Industrial Hazardous  Waste  Management,
     Petroleum  Re-refining Industry,  1977,  p.  14.

 57.  EPA, Scientific and Technical Assessment  Report on Nitre-
     samines, November 1976, pp.  9,  163.

 58.  Ibid., pp. 171, 173.

 59.  Ibad. , p.  13.

60.  Versar, Inc., Microeconomic  Impacts  of the Draft  "PCS
     Ban Regulations",  Final Task Report  submitted to  EPA,
     March 1979, p.  5.

61.  Federal Register,  Vol.  44, No.  106,  Thursday, May 31, 1979,
     p. 31525.

62.  Telephone conversation, Jane Castner,  EPA  student assistant
     with William Welbes, Chemical Analyst,  Twin Cities Testing
     Service, St. Paul, MN,  July  7,  1980.

63.  Richard J. Bigda and Associat.es,  p.  26.

-------
                               -  83  -



64.  National Petroleum Rerefiners  Association,  "1978  Report
     on U.S. Lubricating Oil  Sales,"  1978.

65.  Richard J. Bigda and Associates, p.  27.

66.  National Petroleum Rerefiners  Association.

67.  Richard J. Bigda and Associates, p.  37.

68.  Teknekron, Inc., Technical, Economic, and Environmental
     Assessment of Waste Oil  Recovery and Disposal, Volume  I,
     prepared for the Ontario^ Ministry of Transportation and
     Communications, March 1976, pp.  168-169.

69.  Bureau of the Census.

70.  Mascettl and White, p. 3-1.

71.  Richard J. Bigda and Associates, p.  66.

72.  Versar, Inc., PCB Manufacturing, Processing, Distribution
     in Commerce, and Use Ban  Regulation;  Economic Impact
     Analyses, Final Report submitted to  EPA, March 1979,
     p.  115.

73.  Richard J. Bigda and Associates, p.  63.

74.  Fishbein, Lawrence, Potential  Industrial Carcinogens and
     Mutagens, prepared for EPA, May  1977, p. 226.

75.  Mascetti and White, p. 2-4.

76.  Richard J. Bigda and Associates, p.  9.

77.  Ibid,  pp. 9-10.

78.  Fishbein, p. 226.

79.  Richard J. Bigda and Associates, p.  66.

80.  Ibid,  p. 66.

81.  Mascetti and White, p. 3-7.

82.  Richard J. Bigda and Associates, p.  47.

83.  Ibid,  pp. 46-47.

84.  Versar, Inc., 1979, p. 87.

85.  Richard J. Bigda and Associates, p.  56.

-------
                              - 84 -
86.  Ibid, p.  59.

87.  Ibid, p.  71.

88.  Federal Register, Vol. 44, No. 106, Thursday, May  31,  1979,
     p. 31517.

89.  Telephone conversation, Castner and Welbes.

90.  EPA Report to Congress, Waste Oil Study, April 1974, p.  20.

91.  Richard J. Bigda and Associates, p. 72.

92.  Wapora, Inc., Assessment of Industrial Hazardous Waste
     Practices - Special Machinery Manufacturing Industries,
     prepared  for EPA, March 1977, p. 83.

93.  Yates,  John J. et al., Oil Audit and Reuse Manual  for the
     Industrial Plant, prepared by ETA Engineering, Inc. for
     the Illinois Institute of Natural Resources, Chicago,  IL,
     November  1978, p. 19.

94.  Teknekron, Inc., p. 174.

95.  45 FR 79339 (November 28, 1980).

96.  EPA,  Support Document/Voluntary Environmental Impact
     Statement for PCBs, April 1979, p. 9.

97.  Ibid, p. 17.

98.  Ibid, p. 17.

99.  Ibid, p. 19.

100. 40 CFR 129,  Subpart A.

101. DHEW, National Institute for Occupational Health and Safety,
     Registry of Toxic Effects of Chemical Substances, Herbert E.
     Christensen, ed., June 1976,  p. 944.

102. Sax  Irving R.,  Dangerous Properties of Industrial Materials,
     3rd ed., New York: Van Nostrand Reinhold Company, 1968,
     p. 552.

103. Ibid.,  p.  552.

104. EPA,  Nitrosamines, p.  44.

105. Ibid.,  pp. 47-49.

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                                -  85  -



106.  40 CFR 141,  Subpart  B.

107.  40 CFR 50, Subchater C,  §11.

108.  Sax, pp. 865-866.

109.  Teknekrori, Inc., p.  160.

110.  Ibid, p. 160.

111.  EPA, Quality Criteria for Water, pp.  84-85.

112.  Federal Register, Vol. 43,  No. 220, Tuesday, November  14,
      1978, p. 52963.

113.  Browning, Ethel, Toxicity of Industrial Metals,  2nd ed.,
      New York:  Appleton-Century-Crofts, 1969, p. 62-63.

114.  Sax, p. 448.

115.  Browning, pp. 63.

116.  EPA, Quality Criteria for Water, p. 19.

117.  Ibid, p. 20.

118.  Sax, p. 572.

119.  National Academy of  Sciences, Medical and Biologic Effects
      of Environmental Pollutants;  Chromium, 1974, p. 82.

120.  Browning, p, 126.

121.  EPA, Quality Criteria for Water, p. 40.

122.  National Academy of  Sciences, pp. 84-85.

123.  Sax, pp.  516, 517.

124.  Browning, p. 99.

125.  Ibid.,  p. 102.

126.  Lagerwerff,  J.V. and A.W. Specht, "Contamination of Roadside
      Soil and Vegetation with Cadmium, Nickel,  Lead, and Zinc,"
      Environmental Science and Technology,  Vol. 4, 1970,
      p. 585.

127.  EPA,  Quality Criteria for Water,  pp. 30-31.

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                               - 86 -



128.  Ibid, p. 31.

129.  Ibid, pp. 29-30.

130.  Recon  Inc., p. 2-2.

131.  Teknetron, Inc., p. 155.

132.  Lagerwerff and Specht, p. 583-586.

133.  Recon, Inc./ p. 4-3.

134.  Chansky, Steven, et al. , Waste Automotive Lubricating
      Oil Reuse as a Fuel, prepared for EPA, September 1974,
      p. 81.

135.  Teknekron, Inc., p. 141.

136.  Ibid., p. 141.

137.  Recon, p. 4-6.

138. EPA, Damages and Threats Caused by Hazardous Material
     Sites, May 1980.

139. Statement by Duane Ekedahl, Executive Director,
     Association of Petroleum Rerefiners, to EPA on proposed
     hazardous waste guidelines and regulations as announced
     in the 5/2/77 Federal Register, July 1, 1977, p. 8.

140. Leepson,  Marc, "The Waste That Wouldn't Go Away",
     Environmental Action, October 7,  1978, p. 67.

141. Yates, John J., et_ al. , Used Oil Recycling in Illinois;
     Data Book, prepared by ETA Engineering, Inc. for the
     Illinois  Institute of Natural Resources, Chicago, IL,
     October 1978.

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              APPENDIX  1
AFFADAVIT SUPPORTING EPA'S  "SHEEN TEST"

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                                AFFIDAVIT

 DISTRICT OF                        )
                                      )
 COLUMBIA                          )                 SS
                                      )

      KENNETH BIGLANE, being duly sworn,  deposes and  says:

      I am the Director of the Division of Oil and Special

 Materials Control,  Office of Water Program Operations, of the

 United States Environmental Protection Agency.  It is my

 official duty to formulate and to direct national programs to re-

 spond to discharges of oil and hazardous materials and to prevent

 such  discharges,  pursuant to section 311 of the Federal Water >

 Pollution Control  Act,  as  amended,  P. L.  92-500,  86 Stat. , 816

 et seq. ,  33 USC 1251 (FWPCA).  I held the position equivalent to

my present one within the Federal Water Pollution Control Admin-

istration of the Department of the Interior  when the regulations

concerning discharges  of oil, now codified at 40 CFR 110, were

originally promulgated in September 1970 (Appendix I).

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     I hold a Bachelor of Science degree and a Master of Science



 degree in Zoology from Louisiana State University.  My graduate



 studies were in fisheries physiology, parasitology, histology,



 and fish toxicology.



     From 1952 to 1956, I served as an Aquatic biologist with the



 Louisiana Wildlife and Fisheries Commission.  Louisiana then



 had approximately 20, 000 oil and gas wells, and during that



 period I investigated and assessed the environmental impact of



 several hundred oil spills ranging in size from amounts barely



 sufficient to cause a sheen on the surface of the water to those



 of thousands of barrels.  During this same period, I  conducted



 a study of the environmental effects of oil and oil field brines



 which included field observations, chemical and biological



 laboratory analyses, and toxicity bioassays.



    From 1956 to 1962, I served as both the  Chief of the Division



 of Water  Pollution Control  of the Wildlife and Fisheries Com-



 mission a.nd as Executive Secretary of the Louisiana  Stream



 Control Commission.  My experience with oil pollution during



 this period included administering the State investigative and



 regulatory program which included the production, refining, and



 transportation of petroleum products.



    During the period 1962 to 1966, I served as Headquarters



Biologist  and  Operations Officer of the United States  Public



Health Service in Washington,  D. C., and in 1966 I began service



with the Federal Water Pollution Control Administration of the

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 Department of the Interior.  As a part of my duties with the




 Federal Water Pollution Control Administration and subse-



 quently with the U. S.  Environmental Protection Agency (EPA),




 I personally investigated and evaluated more than 20 oil dis-



 charges,  some examples are shown in Appendix 2(a).  These




 field investigations of oil discharges included: evaluation and



 survey of biological effects of oil discharges, review of methods




 and procedures employed in the oil  removal operations and




 countermeasures to mitigate damage to the environment,  and




 critique of oil spill response contingency planning including,




 organizational structure and notification and  coordination of Fed-




 eral, State and local authorities.



     In addition to the personal field investigations previously




 noted, I have, in my capacity as Director of the Oil and Special




 Materials Control Division,  participated in a supervisory and



 advisory capacity with respect to thousands of oil spills nation-



 ally and internationally.  My activities included advice on




 countermeasures and oil spill clean-up methods and procedures



 for minute spills in environmentally sensitive locations and large



 spills in similar areas, including the open sea.



     In addition to my  experience in the field and national program



 office supervision and  guidance,  I have participated in numerous




 international activities related to biological effects  of oil in the




 environment and oil spill contingency planning,  prevention and




 control.   I served as a U.S.  representative to the International




Conference on Oil Pollution of the Sea,  Rome, Italy, October  1968.

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 Upon my return from this Conference,  I once again visited the



 beaches and coasts of Brittany and Cornwall to re-evaluate the



 effects of cleanup efforts and the environmental impact of the




 Torrey Canyon oil spill of 1967.




     I served as  a  U.S. Delegate  to the International Conference on




 Marine Pollution Damage, Brussels, 1969.   The results of this




 Conference produced two Conventions (1) the International Con-




 vention Relating to Intervention on the High  Seas  in Cases  of Oil




 Pollution Damage; and (2) the International Convention on Civil



 Liability for Oil Pollution Damage.




    In June 1971,  I was  invited  by the Australian  Government to




 testify and gave extensive testimony at  Brisbane, Australia, before




 the Royal Commission on the Great Barrier Reef with respect to




 the environmental impact of offshore oil drilling  and production




 operations.



    In December 1971, I received the EPA Gold Medal for  Exceptional




 Service for activities "in developing a national program responsive



 to the need for controlling spills of oil and hazardous materials."



    I was a member of an Interagency Task Force chaired  by the



 Department of State to develop the Great Lakes Water Quality



Agreement with the  Canadian Government which was jointly signed




 on April 15,  1972.  This International Agreement, which includes




 oil pollution standards for the Great Lakes,  marked the first time




two Heads of State committed their  Governments  to cooperate in



the cleanup and  preservation of such a large,  shared natural resource.

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      I served as a consultant to the Smithsonian Institute with respect




 to coastal zone oil pollution in Indonesia and attended a symposium




 hosted by the Indonesian Government in Jakarta, Indonesia,  in August




 1973.




     Since 1968, I have also  served as a member of the United States




 National Committee on Prevention of Marine Pollution which advises




 The United States  Department of State in the formulation of U.S. Policy




 on international oil pollution.




    I have published articles in  scientific and other journals  and have




 presented papers before technical and other groups.  A list of over




 30 such articles, ranging from  aquatic biology  and the environmental




 effects of oil and other pollutants  to oil spill prevention and regu-




 lation,  is attached as Appendix  2(b).






                #                       *                    *




    Section 311(b)(3) of the FWPCA prohibits discharges of oil in harm-




 ful quantities.  40  CFR Section 110 defines "harmful quantity  of oil" as




 a quantity sufficient to "cause a film  or sheen upon or discoloration  of




 the surface of the water or adjoining  shorelines or cause a sludge or




 emulsion to be deposited beneath the  surface of the water or  upon




 adjoining shorelines. "




    Each  year the U.S. Coast Guard and EPA receive notification,




pursuant  to the reporting requirements of Section 311(b)(5) of the




FWPCA,  of approximately 10, 000  spills of oil into or upon the nav-




igable waters of the United States.  The number of unreported spills




of oil is not known,  but I believe that  the number of oil spills




                                5

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 occurring annually substantially exceeds 10,000.  Eighty percent




 of the reported spills are of 10 barrels or less (one barrel is




 42 gallons at 60 degrees Fahrenheit).  Such smaller spills have




 a seriously degrading effect on the environment.  This is parti-




 cularly true of spills occuring on inland waters, in estuarine




 areas, and near the coastline, which generally are habitats for




 birds and other wildlife.  Estuarine and coastline areas are the




 productive zones for sea life, and are particularly important and




 sensitive to oil discharges.




    A recent report, The Appearance and Visibility of Thin Oil




 Films on Water (EPA-R2-72-039)(Appendix 3)  prepared by  EPA's




 Edison Water Quality Research Laboratory, demonstrates that




 there is a quantitative relationship  between the appearance  of an




 oily layer on water and its thickness.  This report states that  an




 oily layer of at least approximately 150 nanometers (nm) thick




 (1 nanometer  = 1 billionth of a meter or  39. 37  billionths of an




 inch is required in order to  produce a  sheen as defined in




 40 CFR 110.   Specific colors in an  oily layer denote specific




 thicknesses in the  range of 300 -  900 nm.  With thicknesses




 greater than 900 nm, colors become dull and grade into light and




 dark bands with little color.   These inherent appearances of oil were




 found to be a function of thickness and not a function of oil type or  of




water type.  The results of this study are confirmed by the  study of the




American Petroleum Institute and the General Research Corporation.




                                  6

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     This  same report (Appendix 3) demonstrates a direct correlation

  between thickness of an oily layer measured in nanometers and sur-

  face concentration measured in milligrams per  square meter.

  Thus,  for  example, an oily layer of 150 nanometers thickness, which

  would produce a sheen as defined in 40 CFR 110,  contains a surface

  concentration of 150 milligrams per square meter.

     Surface concentration may be mathematically converted to

  concentration in the water column for any given depth to which the

  oil  could be mixed.  If an oily layer of 150 nanometers were to be

 mixed into the top 1 centimeter of water, the resultant concen-

 tration would be 15 parts per million (ppm):

  150 mg  X  103cc =  150 X 10"1 mg    = 15  mg/liter or 15 ppm
   104       liter              liter

 If the same amount of oil were mixed into the upper 10 centimeters

 of water, the resultant concentration would be 1. 5 ppm.

     Although surface concentration can be mathematically con-

 verted into concentrations in the  water column, the physical and

 chemical properties of oil make uniform distribution extremely

 unlikely.  Oil is a complex mixture  of various components with

 differing  physical and chemical properties.  All  oil discharges

 contain components which float on the  surface and components

 which dissolve in the water.  Depending upon factors such as the

 wave action, the amount of suspended solids in the receiving

 waters and  the weather, floating oily layers may also result in

 oily  water emulsions and oily sludge.  Since oil discharges may

produce these various conditions  in the aquatic environment,  the
                        i
harmful effects of oil in the water cannot be measured by

                                  7

-------
 reference to concentrations of dissolved oil components alone.




 The harmful effects of floating oil, oily emulsions and oily sludge



 are widespread, obvious, and long-term.




    The attached Appendix 4(a) is an annotated bibliography, pre-




 pared under my direction, of scientific works documenting some




 aspects of the ecological damage that is caused by floating oily




 layers.  The devastating damage caused to waterfowl by floating oil




 needs no documentation.  In the presence of an oil film, ducks are




 imperiled when swimming or diving for food.  As a  result of  the



 loss of insulating ability of feathers contaminated by oil,  oil soaked




 ducks cannot maintain a normal body temperature and die from




 exposure.   The viability of duck eggs becomes greatly reduced as  a




 result of contamination from oil-soaked plumage.  While preening to




 cleanse their feathers of oil, waterfowl ingest oil and, as a result,



 become susceptible to pneumonia and gastro-intestinal irritation.




Amounts as small as a one-inch circle on the belly of one species



 of waterfowl (murre) is  sufficient to destroy the insulating air




 pocket and cause death from exposure.



    The scientific publications in Appendix 4(b) also show that  small



amounts of crude oil have damaging effects on other organisms as




well:  reproduction in marsh grasses  is inhibited, chemoreception




of fish larvae is blocked,  susceptibility of  seagrass to parasites is




increased, mangrove  seedlings are killed, herring larvae develop




abnormally.
                                      8

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     Appendix 5 is a report summarizing recent research carried




 out by an interdisciplinary team of scientists under the direction




 of Dr. L.  R. Brown of Mississippi State University to determine




 the environmental effects of crude oil in Gulf Coast estuaries.




 Dr.  Brown is a Professor of Microbiology and Associate Dean of •




 the College of Arts and Sciences of Mississippi State University.




 He.holds B. S.,  M.S., and Ph. D. degrees  in Bacteriology from




 Louisiana  State University.  He has  published more than 50 articles




 in scientific journals on biological and microbiological topics.




 Since 1958, he has been engaged in petroleum related microbiology.



 Examination of the interim results of this ongoing research reveals




the following salient points as  submitted by Dr.  Brown:




          "1. The sensitivity  of selected estuarine organisms to




              oil pollution varies between organisms and with




              time of year.




          "2.  Exposure  of shrimp,  Penaeus sp. , to as little as



               0.1 ml of oil in 130 liters  of water will  elicit




               anomalous behavior.   A 2 ppm oil  in water mixture




               results in demonstrable oil uptake and 15 ppm is



               sufficient  to produce a total kill  in most instances.



           "3.  While mullet,  Mugil cephalus, and oysters,



               Crassostrea virginica, can withstand the addition



               of a large volume of oil applied  at one time,




                fatalities are noted when small  (calculated to pro-




                duce  a 1 ppm mixture of oil in water), intermittent

-------
               applications are used.  Exposure to a single




               application (producing a 75 ppm oil in water




               mixture) causes significant alterations in the




               normal metabolic processes of these organisms.




          "4.  The addition of 1. 5 liters of crude oil per square




               meter causes a significant decrease in marsh




               productivity.




          "5.  Additions to experimental aquariums of emulsi-




               fied crude  oil calculated to  produce concen-




               trations of 0. 5-6. 0 ppm but analyzed to be




               0. 25-3. 0 ppm are sufficient to kill 50 percent




               of the copepods  [microscopic animals important




               in the fish  food chain], Acartia  sp. , present.




          "6.  Oysters exposed to  a  300 ppm mixture of crude




               oil in  water for  96 hours still demonstrate an




               "oily" taste after 3 months in clean water."




    Also attached as  Appendix 6,  is a copy of an extract from the




Report of the National Technical Advisory  Committee on Water




Quality Criteria, dated April 1, 1968 (U.S. Government  Printing




Office).  This  appendix contains a list of the scientists who pre-




pared the Report.  The Report shows scientific evidence of the




harmful effects of floating oily layers, oily emulsions, and oily




sludge on fresh water organisms; marine and estuarine organisms;




and wildlife such as waterbirds, muskrats and otters.
                               10

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     The  Committee recommended that, to protect marine life,




 oil should not be deposited into estuarine or coastal waters in




 sufficient quantities (1) to be detected as a visible film or sheen,




 or by odor; (2) to cause tainting of fish and/or edible invertebrates;




 (3) to form an oil-sludge deposit on the shores or bottom of the re-




 ceiving water;  or (4) to become  effective toxicants according  to the




 criteria  recommended in the "Toxicity"  section of the Report.




     The environmental damage caused by discharges  of oil in




 quantities sufficient to produce a sheen on the surface of the water




 has been widely recognized. Moreover, effective  enforcement of any  oil




 spill proscription requires that the spill  of a prohibited quantity be




 readily determinable.   Under the "sheen" provision of 40 CFR 110,




 it is a  simple matter for a  responsible person to know which  spills




 are prohibited. On the other hand, a spill limitation based on quanti-




 ties measured by volume (e.g.,  quarts,  gallons, barrels) or  weight




 (e.g.,  Ibs. ),  would be virtually impossible to enforce.  First,  only the




 spiller has any possible way of determining  the quantity of the spill.




 Second, it has been my experience in  investigating oil spills that




 persons at the scene and responsible for  the spill  are frequently




unaware of how much oil has been discharged and  its  effect  on the




environment,  even within very broad limits.  As a result,  the "sheen"




test is well suited to define a discharge which damages  the environ-




ment and  to provide a regulatory mechanism which will work.  This




combination of environmental harm and enforcement workability has




led other  nations and international organizations to adopt a visible




oil  standard to abate oil pollution.






                                  11

-------
    Recent amendments of the 1954 International Convention for the

 Prevention of the Pollution of the Sea by Oil,  to which mere than 70

 nations were parties,  confirmed the 1954 Convention's permission of

 vessel ballast discharges which "would produce no visible traces  of

 oil on the surface of the water." This same standard was adopted

 by Congress in the Oil Pollution Act Amendments of 1973 designed

 to implement the Convention.

    The Agreement between Canada and the United States of

America on Great Lakes Water  Quality,  signed by the President

and Prime Minister Trudeau at  Ottawa on April 15, 1972, defined

"harmful quantity of oil" to mean:

                 "any  quantity of oil that, if discharged
                 into receiving waters,  would produce
                 a film or sheen upon, or discoloration
                 of, the surface of the water or adjoining
                 shoreline or that would cause a sludge
                 or emulsion to be deposited beneath the
                 surface of the water or upon the adjoin-
                 ing shoreline"

This definition of "harmful quantity of oil" is identical to the defini-

tion at issue in this proceeding.
                                  12

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     Section 311(b)(4) of the FWPCA provides that a quantity of oil

 which:

                  "at such times, locations, circumstances,
                   and conditions, will be harmful to the public
                   health  or welfare of the United States,
                   including, but not limited to, fish,  shellfish,
                   wildlife,  and public and private property,
                   shorelines,  and beaches except that in the
                   case of the discharge of oil into or upon the
                   waters of the contiguous zone,  only those
                   discharges which threaten the fishery
                   resources of the contiguous zone or threaten
                   to pollute or contribute  to the pollution of the
                   territory or the territorial sea of the
                   United  States may be determined to
                   be harmful."

    Based on the foregoing and my experience  in evaluating the

 environmental effects of oil spills, it is my opinion that an oil

 spill sufficient to produce a film or sheen  on the surface of the

 water is large enough to cause harm to the environment.
Subscribed and sworn to before me,
A Notary Public,  in and for the
District of Columbia,  This
3rd day of May, 1974.
My Commission expires

POLLY P. ANDERSON
                                 .-.- 3o
                                      13

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ONLY APPENDICES  4 THROUGH 6 OF THE AFFADAVIT ARE PRESENTED  IN




THIS DOCUMENT BECAUSE  THE AFFADAVIT'S OTHER APPENDICES DO NOT




DEAL DIRECTLY WITH OIL'S  TOXIC EFFECTS ON AQUATIC ORGANISMS.

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                           APPENDIX 4 a
                DOCUMENTED HARMFUL EFFECTS OF
      SMALL QUANTITIES OF CRUDE OIL ON LIVING ORGANISMS
 1.     Baker,  J. M. 1971.  Seasonal effects.  In The Ecological Effects

 of Oil Pollution on Littoral Communities, Ed. Cowell, E. B.

 Institute of Petroleum, London.    •*-•• *

        Oiling of marsh plants during the early stages of flowering has

 drastic effects as a result of damage to buds or primordia.  Oiling of

 open flowers frustrates the formation of seed.

 2.      Blumer, M. 1973.  Interaction  between marine organisms  and

 oil pollution.  Environmental Protection Agency  Report number

 EPA-R3-73-042, May 1973.

        Hydrocarbons are remarkably stable in marine sediments and

 in the fatty tissues of marine organisms. Even chemically reactive

 hydrocarbons can move unaltered through several levels in the marine

 food web.

 3.      FWQA - 1969.  Report of the National Technical Advisory

 Subcommittee on Water Quality Criteria for Fish and Other Aquatic

 Life and Wildlife.

       British investigators have attributed the disappearance of eel

grass (Zostera sp.) to minute quantities of oil. Oil weakens the plant

and makes it susceptible to attack by the parasitic protozoa Labyrinthula.

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 4.     Gardner,  G.  R. 1972. Chemically induced lesions in estuarine
 or marine teleosts (fish).  Proceedings, Symposium on Fish Pathology.,
 Armed Forces Institute of Pathology, Washington, D. C.
        Deterioration of the chemoreceptor structures of (silverside
 fish) Menidia menidia was found after exposure to both soluble and
 insoluble components of Texas-Louisiana crude oil for 168 hours.
 5.  .   Glynn, P. W. et al.   1971.  Fundamental analysis for deter-
 mining the effects of oil pollution on the ecology of a tropical shore.
 Report,  Smithsonian Tropical Research Institute.
        Mangrove communmities are highly sensitive to crude oil
 contamination.  Major  elements  of the fauna have not returned after
 33 months.
 6.     Keinhold,  W. W.   1970.   The influence of  crude oils  on fish
 fry.  FAO Technical. Conference on Marine Pollution, Dec.  9-18,
 1970, Rome,  Italy.   10 pp.
       Toxic  components are dissolved  from oil films injuring herring
 larvae and younger stages of floating eggs.  Herring larvae  were
 unable to avoid oil contaminated  water because chemoreceptors are
 blocked very quickly upon contact with oil components.
 7.     Mackin, J. G.  1950.  A  comparison of the effects of the
 application of crude petroleum to marsh plants and to oysters.  Texas
A&M Research Foundation. As reported in IMCO Study VI,  Appendix 3.
       Seedlings of the mangrove Avicennia were  killed by application.
 of 25 ml of crude oil  per square foot of water area.

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 8.      Mironov, O. G.  1967.  The effects of low concentrations of
 oil and petroleum products on the development of eggs of Black Sea
 turbot.  Vop. Ikhtiol.  7: pp 577-580.
        Black Sea flatfish larvae were killed by exposure to 100 ppm
 fresh crude oil in 24 hours. .At 0.01 ppm mortality was delayed and
 23-40 percent of the larvae developed abnormally.
                                   f.
 9.      Smith, J. E. ed. 1968.  "Tbrrey Canyon" pollution and marine
 life.  Mar. Biol. Assoc.  U.K.  Cambridge Univ. Press.
        An indirect effect of oil pollution accounted for the death of
 intertidal crustaceans. As a result of biodegradation of oil, dissolved
 oxygen  was depleted and small crustaceans which had"sheltered under
 stones were suffocated.
 10.     Tuck,  L.  M.  1960.  The Murres. Dep.  Northern and Natl.
Resources, Natl. Parks Branch, Canadian Wildlife Service, Ser.  1.
       A patch of oil,  one  inch in diameter, on the belly of a murre
(waterfowl) was sufficient to destroy the insulating air pocket and
cause death from exposure.

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                           APPENDIX 4 b
         DOCUMENTED HARMFUL EFFECTS OF OILY LAYERS. '
      OILY EMULSIONS AND OILY SLUDGES ON LIVING ORGANISMS
 a)  ; Effects of free oil on waterfowl

       1.  Clark, R.  "Oil Pollution and the Conservation of Seabirds, "

 International Conference on Oil Pollution of the Sea,  Rome (1969), found

 that oiled bird feathers become matted together destroying the water

 repellant property and allowing water to replace the air normally

 trapped in them.

       2.  Erickson, R.  "Oil Pollution and Migratory Birds, "  Atlantic

 Naturalist,  IS  (1) 5-14, 1963,  found that bird plummage becomes oil-

 soaked and water-logged  such that birds loose bouyancy and their

 ability to fly.    -           •"         ...

      3. Chubb, J. "Observations on Oiled Birds,  1951-53, " Northwest

 Nature, (. S.) 2: 460-461, 1954, showed that in the presence of an oil

 film diving ducks were unable to dive  for food.

      4. Hartung,  R.   "Energy Metabolism in Oil Covered Ducks, "

J. Wildlife Management,  31 (4): 798-804, 1967, showed that as a result

of the loss of insulating air in the  feathers (ref. 1 above) oil-soaked

ducks lost more than twice the heat of unsoaked ducks.

      5.  Tuck,  L.  "The Murrs, " Department of Northern Affairs and

Natural Resources, National Parks Branch,  Canadian Wildlife Service,

Ser. 1, 1960,  documented that a patch of oil one inch in diameter is

-------
 sufficient to destroy the insulating air pocket and cause death from

 exposure to the chilling effect of the sea.

       6.  Hartung, R.  and Hunt, G.  "Toxicity of Some Oil to Waterfowl, "

 J.  Wildlife Management 31 (4) 798-804,  1966, in laboratory experiments

 found that various industrial oils caused lipid pneumonia,  gastro-

 intestinal irritation,  fatty livers and adreno-cortical hyperplasia when
                                    ,»:
 fed to ducks in doses which were regarded to be less than that which

 would be ingested during preening of oil  plumages.

       7.  Hartung, R.  "Some Effects of Oiling on Reproduction of Ducks, "

 J.  Wildlife Management 29 (4) 872-874,  1965, showed that the viability

 of embryos is greatly reduced when the eggshell becomes smeared with

 oil from the contaminated plumage of the female.

       8.  Rittinghaus.  "On the Indirect Distribution of the Oil Pest  in

 a Sea  Bird Sanctuary, " Onithol Mitteil, 8 (3), 1956, found that oiled

 tern eggs did not hatch.


 b)    Effects of free oil on water living organisms

       1. McKee and Wolf.  W?ter Quality Criteria: State of California

 Water Quality Control Board,  2nd Ed., 1963, reported studies showing

 that free oil inay act by direct contact  on the  epithelial surfaces; of fish

 and interfere with respiration, may coat and  destroy algae and other

plankton and.may interfere with the natural processes of aeration and

photosynthesis.

      2. Dr.  Clarence Tarzwell, Director of the National Marine Water

Quality Laboratory, in his testimony before the Senate Subcommittee on

-------
 On Oceans and International Environment,  1971, stated that surface oil




 may blanket the surface of the water and prevent the uptake of oxygen



 and may act as a contact toxicant for surface organisms or organisms



 that come to the surface may get it into their gills.  He also reported



 on studies with 300 plankton which showed growth inhibition-resulting



 from  surface oil concentrations of 0. 8 gallons per acre-foot of water.



 Based on studies at the Edison Water Quality Laboratory and by the



 American Petroleum Institute this represents a quantity of oil  causing



 a rainbow discoloration of the surface of-the water and a film only



 . 00008 cm in thickness.



       3.  Straughan, D.  ".Oil Pollution and the Environment," 1970



 Evangeline Section Regional Meeting of the  Societ}' of Petroleum



 Engineers,  1970, reported barnacles (c_.  fissus) smothered by free oil.



       4.  Kenyon (personal communication)  found that sheens of surface



 diesel oil were sufficient to coat the fur  of two sea otters and cause



 death  due to exposure in Alaskan  environments.



       5.  Massachusetts Institute of Technology, 1970,  Man's Impact on



 the Global Environment:  Report of the Study of Critital Environmental



 Problems noted that chlorinated hydrocarbons are much more easily



 dissolved in floating films of oil than in water and  can then be carried



into the water column upon dispersal of the film.  One study was reported



which  showed the concentration of chlorinated hydrocarbon (DDT) to be



10, 000 times  higher in an oil film than in the underlying water column.



     6.  Kunhold, W.  "The Influence of Crude Oils on the Fish



Fry: FAO, " Technical Conference on Marine Pollution, Dec. 9-18,

-------
 1970, Rome, Italy, reported that toxic components dissolved from



 floating oil films injured larvae and young stages of floating eggs.





 Likewise harmful effects from emulsified oils are found:



       1.  Mass. Institute of Technology "Man's Impact on the Global



 Environment: Report of the Study of Critical Environmental-Problems, "



 1970, stated that toxic effects of emulsified oils to fishes can result



 from direct contact coating of fins and asphixiation.



       2.  McKee and Wolf Water Quality Criteria: State of California



 Water Quality Control Board,  2nd Ed., reported studies indicating  that



 emulsified oils  act by direct contact on epithelial surfaces of fish to



 interfere with respiration'and may coat and destroy algae  and other



 plankton.



      3.  Clendenning, K. and North, W.  "Effects of Wastes on the Giant



 Kelp,  Macrocystis pyufere, " Waste  Disposal in the Marine Environment,



 Proc. 1st Itn. Conf.  Pergamon Press, N. Y.,  1960,  reported that



 emulsions of diesel oil in sea water  caused the death of sea urchins.



      4.  Tarzwell, C. - testimony referenced above, stated that when



 emulsified oil gets into the gills of gill-breathing organisms it can be



toxic.   They can also be ingested directly when the droplets are small.



 The ingested hydrocarbons in addition to direct toxic effect can be



incorporated into the flesh and passed up the food chain similar to the



persistant chlorinated hydrocarbons.

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 Finally,  the harmful effects of sludged oils include:



       1.  Zo Bell, C. "The Occurrance, Effects and Fate of Oil



 Polluting the Sea, " Int. Conf. Water Pollution Research, 1962, oil



 is readily adsorbed by clay and silt and after burial almost no    • •



 bacterial decomposition occurs.



       2.  Blumer, M.,  Souza,  and Sass, J.,  "Hydrocarbon Pollution



 of Edible Shellfish by An Oil Spill"., .Int. Jour,  on Life in Oceans



 Coastal Waters, Vol. 5, No. 3, March 1970,  describes widespread



 and long-term damage to bottom living organisms as a result of persis-



 tent sedimented diesel oil resulting from a barge spill.



       3.  Tarzwell, C.  - testimony cited above, states that oil going



 to the bottom and can blanket the bottom and kill through direct contact.



 When broken up it can be ingested  and  passed up the food chain.



       4.  Erickson, R.  "Effects of Oil Polluiton and Migratory Birds, "



 Biological Problems in  Water Pollution, 3rd Seminar (1962),  R. A.



 Taft San.  Eng. Center,  Cincinnati, Ohio,  1965, noted that migratory



 birds  are indirectly affected by deposits of oil on the bottom in shallow



 water or  along the shore that reduce the available food supply of both



 plant and  animal matter. Various  elements in food chains are eliminated



by chemical or physical properties of the oil,  or items  in the  diet of



waterfowl may become unavailable by being  overlaid or imbedded in tarry



materials.



      5.   Battelle  Memorial Institute Oil Spillage Study  Literature Search



and Critical Evaluation for  Selection of Promising Techniques to Control

-------
 and Prevent Damage,  1967,  points out that the accumulation of



 petroleum sludge on the bottom may prevent germination and growth



 of plants and the production  of invertebrates important as food, either



 by smothering or by toxic effects.



      6.  Water Quality Criteria, National  Technical'Advisory Committee,



 1968, states that  settleable oily substances may coat the bottom, destroy



 benthic organisms,  and interfere with spawning areas.  Oil may be



 absorbed quickly by suspended matter, such as clay, and then due  to



 wind action be transported over wide areas and deposited on the bottom



 far from the source.



      7.  North,  \V., etal.  "Successive Biological Changes Observed



 in a Marine Cove Exposed to a Large Spillage of Mineral Oil in



 Pollutions Marines par les Microorganismes et les  Produits Petroliers, "



 Symposium de  Monaco,  1964, documented long-term damage to bottom



fauna resulting from a spill of crude oil in 1957.  Populations of several



 species.had not recovered four years after  the incident.

-------
                     REPORT

                         to


DIVISION OF OIL AND SPECIAL MATERIALS  CONTROL
                              •

                       of the

     ENVIRONMENTAL PROTECTION AGENCY

                        on

           EPA Contract No. 68-01-0745
                   Lewis R. Brown
                  Program Director
            Mississippi State University
                   26 April 1974

-------
                          INTRODUCTION





        On June 30, 1972,  Mississippi State University was awarded


 a three-year contract by the Environmental Protection Agency to


 study "The Fate and Effect of Oil in the Aquatic Environment-Gulf


 Coast Region."  This contract (EPA Contract No.  68-01-0745) is an


 interdisciplinary, multiinstitutional effort involving senior


 scientists from Mississippi State University, the University of
                                      •

 Southern Mississippi and the Gulf Coast Research Laboratory.  In


 addition to being responsible for the microbiological aspects of


 the program, I serve as the Program Director. The major effort


 in this  program is directed toward investigating the chronic


 effects of subacute levels of oil on the ecosystem and it should  be


 emphasized that trie investigations include not only well replicated


 laboratory bioassay experiments but also field  studies.  To date


 all experiments have been conducted with Empire Mix crude oil


 and salinities in the range of 12-18 ppt.  This report is a synopsis


 of some of the more  salient results to date; specifics can  be


 found in Progress  Reports 1-6, the Interim Report and the forth-


 coming Seventh Quarterly Report.





                            RESULTS


                    _*


       Crude oil has only limited solubility in water,  albeit there


are some water soluble components present.  The total oil present

-------
 in the water column can be increased significantly by emulsifica-

 tion but a majority of the oil will become attached to particulate

 matter,  evaporate and/or rise to the  surface.  Under these condi-

 tions, the use of the phraseology "oil concentration in the water.

 column"  is of questionable value in-most bioassay tests even for
                                   f.
 tests of short duration.  Uptake o'tf oil by biological specimens  is

 dependent not only upon the concentration of oil in the water and the

 method of application but also on the total time of exposure and thus

 to the total amount of oil to which the  organism has been  exposed.

 For example, our results have shown that the greater the amount

 of oil in the water column, the greater the uptake by  shrimp when

 dosages of emulsified oil  calculated to yield 2,  4  and 8  ppnn oil were

 added to test aquaria  (29 gal) in the laboratory.  Significant uptake by

 the shrimp was demonstrated 12 hours after the addition of oil (the

 first sampling after the oil was added). It is noteworthy to point ou~

 that these data are based on analyses conducted  using a liquid  chrom-

 atographic technique which determines aromatic compounds rather

 than aliphatic compounds since in many instances gas chromatograpihic

 analyses failed to indicate oil uptake. As  expected the average  oil con-

 centration in dead organisms was considerably greater than in  organisms

 surviving, thus suggesting differences between individual organisms.

Another point of considerable  significance is the  fact that the TL5Q
                    (»
value varies seasonally and thus extrapolation from laboratory data

to the field must take this  factor into account.  In the presence of

-------
 emulsified oil (15 ppm) the shrimp exhibit a "spiraling phenomenon"




 which should make them far more susceptible to predation.  Upon




 removal from the oily water, the shrimp revert to normal behavior.




 Erratic behavior by shrimp'has been observed in the laboratory




 with the addition of as little as 1 drop of oil in a 29 gallon aquarium.




       In an experiment involving the spillage of oil into a brackish




 water pond, it was noted that menhaden which exhibited  erratic




 behavior at the surface were quickly devoured by other fish, once




 again illustrating the potential problem of oil altering normal be-




 havior patterns required for survival.




       Both mullet and oysters can survive high doses (350 ppm or




 greater) of emulsified oil in short term experiments but signifi-




 cant changes  in enzyme levels can be attributed to the presence




 of oil in tests employing 75 ppm oil added to the system. The true




 significance of these findings in regard to long term survival,




 reproduction, etc, are not clear  at this time,  but suffice to say,




 exposure to oil does alter the normal metabolic  activity  of the




 organisms.  In more recent studies it has been found that the




 addition  of  small amounts (1 ppm) of oil daily for 11 days, followed




 by 11 days with no oil additions,  11 more days of oil additions, etc.,




 drastically  alters the results.  Under these conditions oysters




began to die during the second oil addition period and mullet  began




to die during the third oil addition period.  Additional tests are




being conducted but the  results to date seem to imply that the

-------
 sequential addition of oil is far more toxic to mullet and oysters

 than is the addition of a large amount of oil at one time.

        Some histological abnormalities have been found in organisms

 exposed to oil, but on the basis of the  results to date it cannot be

 said with  certainty that they were caused by oil.


        There seems  to be a lot of controversy over the length of
                                  •t.
 time required for oysters to cleanse themselves of the "oily taste"

 after exposure to oil.  Our  studies have shown that after exposure

 of oysters to 300 ppm emulsified oil (rdose) for 96 hours,  the

 "oily taste" is still detectable even after 3 months'of depuration

 in clean water.  It should be pointed out that the exact length of

 time for depuration in the environment is dependent upon season,

 salinity, and other facts.

       Crude oil has  been shown to cause  significant decreases in


 marsh grass productivity in in situ experiments.

       Particularly germane to the present report are the results

 of recent tests just conducted on Acartia (found in brackish and

high salinity water).   Cultures  obtained from ths ecosystem ponds

to be employed in the field studies yielded TLcgvalues  (96 hr)

of 0. 5-2. 0 ppm (1. 25 ppm, average) for emulsified oil; cultures

obtained from the Gulf yielded TLgQ values (96  hr) of 1. 0-2. 0

ppm (1. 50  ppm, average) for the emulsified oil; and laboratory

cultures yielded TI^Q values (96 hr) of 2.0-6.0 ppm (4. 0 ppm,

average) for the emulsified oil.  The TL,QOvalues (96 hr) for the

above cultures were  6-10 ppm,  6-10 ppm,  and 10 ppm respectively.

-------
 These values are based on the quantities of oil added to the system




 and actual analyses of the water revealed oil concentrations of 50%



 of the values  reported above.








                       . '     SUMMARY        '   "   -








      In summation,  and within the  experimental procedures outlined




in the progress reports prepared for this contract, the following




points are  submitted.




      1. The sensitivity of selected estuarine organisms to




          oil  pollution varies between organisms and with time



          of year.




      2.  Exposure of shrimp,  Penaeus sp., to as little as 0.1 ml




          of oil in 130 liters of water will elicit anomalous behavior.




         A 2 ppm oil in water mixture results in demonstrable




         oil uptake and 15  ppm is  sufficient to produce a total kill




         in most instances.




      3. While mullet, Mugil cephalus,  and oysters,




         Crassostrea virginica,  can withstand the addition of a




         large volume of oil applied at one time, fatalaties are




         noted when small (calculated to produce a 1 ppm mixtura



         of oil in water),  intermittent applications are used.




         Exposure to a single application (producing a  75 ppm oil




         in water mixture) causes significant alterations in the




         normal metabolic processes of these organisms.

-------
4.  The addition of 1. 5 liters of crude oil per square



    meter causes a significant decrease in marsh



    productivity.



5.  Additions to experimental aquariums of emulsified



    crude oil calculated to produce concentrations



    of 0. 5-6. 0 ppm but anal/zed to be 0. 25-3. 0 ppm



    are sufficient to kill 50 percent of the copepods,



    Acartia  sp., present.



6.  Oysters exposed to a 300 ppm mixture of crude



    oil in'water for 96 hours still demonstrate an



    "oily" taste after 3 months in clean water.

-------
       ter  Quality  Criteria
               Report of the
     National Technical Advisory Committee
                  to the
            Secretary of the Interior

                APRIL 1, 1968
              WASHINGTON, D.C.
FEDERAL WATER POLLUTION CONTROL ADMINISTRATION

-------
•  .3*- CLASEXCS M. TARZ\VELL, Chairman, Diree-
;-. •  tor. Nation al Marine Water Quality Laboratory,
"  '-~ federal V/ater Pollution Control Admiaistra-
.  '_" • ikrz, U.S.  Department  of the  Interior, West
;r  KL-gston, R.L   -.-'.-...,   -,-   ..".*.'••.  ..   .  -.
-   MR.  VVTAUTAS  ADOMAITIS, Research  Chemist,
-..  Bureau cf Sport Fisheries and WDdlife, North
:,-;'  ?^*z Wildlife Res-arch Center, U.S. Depart-
. .J'  Eient of the Interior, Janaestovra, N.Dak.
^ DR. BERTTL G. ANDERSON, Professor cf Zoology,
'.* . Los Sciences BuDding, The Pennsylvania State
. x •'• Ush-ershj-, University park, Pa.  •  •  '• •-  '  ' .
-,\^*R-  GEORCH E.  -BURDICK,  SupervisiDg Aquatic'
**'•• BwJogjst (PoUution Research), New York Con- -
              Department, S^te  Campus, Albany,
    x. PK.T.I? A. BUTLER, Laboratory Director,JBu-
 ^-  reau of Conur.ercial Fisheries Biological Labo-
 •  " rstory,  U.S.  Dssartment of the Interior, Gulf
                   *          '
.
 D?_ ROBERT J. CONOVER, Atlantic Occinogrsphic
 «  Group, Fisheries Research Board, of Canada,
".-• Dssnnouth, Nova Scotia. ; -••••••:..-.-•.;•..•  ..;'•
 D?- OLIVER B. CO^E, Director, Rsh-Pesticids Re-.;-
   Sisrch LaboraJory, Bureau of Sport Fisieries '
   erd Wildiifa, U.S. Department of the Interior, - -
   Cchisbia, Mo.  -  .  :* •.-:-.--.*•-..... ••-.   '-:
 D?w }L'CHA?.JD F. FOSTER, >v'azager,' Earth Sciences
 . SKZQZ, Envircsrsenal and Radiological  Sci-
                    t,  PaciSc  Northwest Labo- ":
             riciis  Memorial Institute, RichJand,  :
  : Wash. -.-     .:.,.•....-,•.-. .-;:-'- - .•  •.:.-„;• '-.:  r ;. ..;
 Ds. F. E. J. F?.Y,  Professor of Zoology, Depart- '"•
 . 'nent of Zoojosy,  Unf\-ersity  of Toronto, To- ..•
           Depar
  Ds. PiUL S. GAL-SO?F, Conrjltaat, Woods Hole, '"
                                              ...
 Da. AJU3SS R_ GAUHN, Professor of Zoology, D*- .-
    parsnect of Zcclogy asd EnxmoJo^j', Univer-
•-•  ' sty of Utah, Salt Lake Gty,. Utah.  • •• -.-"'.: ... ' '  •
 Ms. Vv ILUAM F. GUSEV, Assistant Chief, Division  .
    of Wildlife  Services, Bureau of. Sport Fisheries
   - asd Wildlife, U.S. Department of the Interior, '
" :   Washiagtoa, D-.C. •   4 . • -' .-.  -^ •.-:--  -% -•; - ^
 I>7."Vv'iLiUii J. HASGIS, JR., Director, Vbpnis In-''''
    siisi^ of Marine Science, College of  WHD'aza
    p~tf Mar}' acd .University of Virginia, G!ou- -'
    crsrr ?oi=t, Va.  -.-,..,.' •• •/   -..    --•...,.•' ::
 MX. E!_:GES'E  p. HAVDU, Water Resources and -
    Management, -Weyerhaeuser  Co., Pulp  and ."
    Paperboard Divisica, Longview, Wash.  !;•  •  ••'":
 Ms. CKOS^VELL HENDERSON, Fishery Bio'.oaist,
 -•   Bureau of Sport Fubcries and Wjidlife, U.S. De-
    pim^ent of  the Interior,  Colorado S^iti Uni-
    versity, Fort Collins, Co'o. .    '••'.'
 MR. EOCENE T. JENSEN, Chief, OSes of Es'tunrbs
    Sr-JdJiS,  Federal V/ater Pollua'on Control Ad- .
    =-J=i'--2t'cn, U.S.. Department of the Interior, '
 Dx.  J. M,  LAWREKCE, Aubum Unxversitv,  A
    bum,Ala.     •- ••   . •  '"••.. .. •   -   .  **
 Da.  VICTOR L. LOOSAKOFT, Professor of M^las
            Marine Biological  Laboratory, Uni-
          of -ihe Pacific, Dillon Eeach, Cali
 Ds.  DONALD I. MOX.-NT, National Water Quality
   Laboratory,  Federal Water  Poliirtioa.  Control
   Adrainistradcn,. Deparnrrent of-ihe  3!n^rio^"
   Duliith, Mian,      ;      •--..-'
 DR. RUTH PATRICK, Cura^r and.Chzinna.2 of -as
   Limnology Department, Academy of  Naniral
 -  Sciences of Philadelphia, Philadelphia, ra.  •
 Da. BENJAMLS H. PMNGLE, Supervisory Chemist/
  ' Northeast Marbs Heali Sciences LabDrai3r>-
 .  PubUc. Health  Service, U.S.. ' Departssnt  cf
   Health, Education,  and Welfare, Narragznsts,
 •• R.L  .::--. .,    '.  -  •  .  . -• • ":
 DR. D. I. RASMUSSEN,  Dh^ctor, Division of W3d- .
 .  life ManajeEen^ Forest Service,  U.S. Depart-
 - "• cent of Agricdtsre, Washington, D.C
 DR. THEODORE  R. RICE, Director, Radiobioiosicaf
   Laboratory,  Bureau  cf  Commercial  Fishe"nis, '
   U^: Department of the Interior, Beaufoit, N.C. ;
 MR, JOHN L.' SLVCOCK, Chief, Section of Wetland
 _ Ecology,  -Pat^eat Wildlife  Research  .Ctzlir/
   Bureau of Sport Fisheries  and Wildlife, f~*"r~L
   Md...     , -.-;.-   . ......  *...%-.'.  .  . •_--
 Da. WiLLiAi^ A. SPOOR, Professor of Zooloey, De-
   partment  cf  Bioiogicai Sciences, Univzrs-ry  of
 •  Cbc'rcujy CincinnatJ, Ohio.     --  _- - .
 MR: Zuczs'E W.  SCRSSR, Commission of G--^.
•  aoc Inland Fisheries, Erownto wn,  Va. -.. • .
 Ms. WILLIAM E.  WEBB, Watrr Quality Bioioist, -
. "  "rho-  Fish  and GSJT.S ' I>eptrrtmen£. Boise.
          --  ".      .              -   ^^^
                                                         MR. ARTHUR N. WOCDALL, Assistzia Chid; Dhi-
                                                          . rloQ of Fishery Research, Bcrcau of S^ort Flsi—
                                                           eries and Wildlife, U^. Departaent of -die In-
                                                           terior, Washington, D.C, • .-.  -•-:•    •    -
                                                         DR. Ri.ROLDB=^csos, fechrlccl Execu±,-s Secrz.
                                                            zry, Federal Water Pollution Control .
                                                           tfadon, U.S. D=
                      ect of the Interior, Wash-

-------
     •0.

      Oil slicks am barely visible at a concentration of
    about 25 gaj/sq mi (Ainer. Petroleum Inst. 1949).
    At 50 gal/sq mi, an oil film is  3.0 x 10-* inches
    thick and is visible  as a silvery sheen on the sur-
".   fsct. Sources of oil  pollution are bilge and ballast
..   waters from  ships,  oil refinery wastes,  industrial
    plant wastes such as oil, grease, and fats from the
   lubrication of machinery,  reduction works, plants
   cacufscturing hydrogenated glycerides,  free fatty
   acids, and glycerine, rolling mills, county drains,
   storm-water oversows, gasoline filling stations, and
   bulk stations.
     Wiebe (1935) showed that direct contact by fish
   (bass and bream) with crude oil resulted in death
   caused  by a Sim over the gill-filaments. He also
   demonstrated that crude oil contains a water-solu-
   b'e fraction that is very toxic to fish. GaltsofT, et al.
   (1935) showed that crude oil contains substances
   soluble in sea water  that produce  an anaesthetic
   erTect on the ciliated epithelium  of the gills of
   oysters. Fjee  oil and__emulsions may act  on the
   epithelial surfaces of fish gills and interfere with
   respiration." They may coat _and destroy algae and
   other piankton'.jHereby removing a source of fish
  food, and _whta ingested by fish they rhay^tajnt\
 .their fi«h.
\   Settsable oily substances may coat the bottom,
 4; destroy  benthic  organisms,  and  interfere  with
 'spawning areas. Oil may be  absorbed quickly by
 ' suspended  matter, such as clay, and then  due to
  wind action or strong currents may be transports
  over wide areas asd deposited on the bottom f<
  from the source. Even when deposited on the bo
  torn, oil coniiauo-Jsly  yields water-soluble  sut
  stances that are to.xJc to aquatic life.
    Films of oil on the surface may interfere wit
  reaeration and photosynthesis  and  prevent  th
  respiration of aquatic insects such as water boat
  men, backswimiaers,  the larvae and adults  c
  many species of aquatic beetles, and some specie
  of aquatic Dipiera  (fiies).  These insects surfao
  and carry oxygen bubbles beneath the surface b;
  means of special setae which can be adversely af
  fected by oil. Berry (1951)  reported that oQ film.
  dai'the lower Detroit River are a constant threat t<
  waterfowl. Oil  is detrimental to waterfowl by de>
  stroying  the natural buoyancy and  insulation  o:
  their feathers.
    A  number  of  observations  made by  various
  authors in this country and abroad record the con-
  centrations of oO in fresh water  which are  dele-
  terious to different species. For instance, penetra-
  tion  of  motor  oil into a fresh  water reservoir
  used for  holding crayfish in Germany  caused the
  death of about ~20rCOO animals (Seydell, 1913).
  It was  established   experimentally  that crayfish
  weighing from 35 to  38 g  die in concentrations of
  5 to 50 mg/1 wiuiin 1S to 60 hours. Tests with two
 species of fresh water fish, ruff (small European
 perch), and whiteisn (fam. Coregonidae) showed
 that concentrations of 4 to 16 mg/1  are lethal to
 these species in  1S to 60 hours.
   The toxicity of crude oil from various oil fields
 in  Russia  varies depending on its chemical ecu-
 position. The oil used by Veselov (1948) in the
 studies of the pollution of  Belaya  River (a tribu-
 tary in the Kama in European Prussia) belongs TO a
 group of  raethaao-aroiaatic oils with a high  con-
 tent of asphalt, tar  compounds,  and  sulfur. It
 contains  little paraSa and considerable amo\ints
 of  benzene-ligroln. Small crucian carp  (Carcsslus
 carassius)  7-9  era long were used as the bioassay
 test animal This is considered to be a  hardy fish
 that easily withstands  adverse conditions.  The
 water  soluble fraction  of  oil  was  extracted by
 shaking 15 ml cf  cO in I liter of water  for 15
 minutes. The oO film was  removed  by filtration.
 Dissolved  oxygen was controlled. A total of 154
 tests were performed using 242 fishes. The average
 survival time was 17  cays at the concentration of
 0.4 ml/1 of oil but only 3 days at the concentration
of 4 ml/1.  Further increase in concentration had no
appreciable effect on fish mortality.
   Seydel!  (1913) stated that the toxicity of Rus-
sian oil is due to nsphlhenic acids, small quantities
of phenol, and  volatile acids  (Veselov, 194S).

-------
  Cidrss (1957; reports the following 96-hour TLa
  values of  naphrienic  acid  for bluegill sun5sh
  (Lgpomis  macrockirus)—5.6 mg/1;  pulmor.ate
  snail (P'nysa heterostropha)—6.1 to 7.5 rng/1 (in
  soil water), and diatom (speciss not identified)—
  41.8 to 43.4 mg/1 in soft water and 28.2 to 79.8
  ng/1 in hard water. Naphthenic acid (cyclohexane
  oirboxyJic  acid)  is. extracted from petroleum and
  is LLScd in  the manufacture of insecticides, paper,
•  and rubber.                ...
    Chipman and Galtsoff (1949) report that crude
  oil ia concentrations as low. as 0.3 rag/1 is ex-
  tremely toxic to  fresh water fish. Dorris, Gould,
  and Jenkins (1960) made an intensive study f>l the
  toxicity of oil refinery effluents to fathead-minnows
  in Oklahoma. By standard bioassay procedures,
  they found that mortality varied between 3.1 per-
  cent to 21.5 percent after 48 hours of exposure to
  untreated effluents.  They  concluded that toxicity
  jathsr than oxygen demand is the most important
.effect of ofl refinery efiuents on receiving streams.
    Pickering and Henderson (I966b) reported the
 results of acute toxicity studies of several impor-
  tant petrochemicals  to fathead minnows, bluegilis,
  goldfish, and gxippies in both soft water and hard
 •watsr. Standard bioassay methods were used. Be-
 caios  several of the compounds tested have low
 solubility  in water, stock solutions were prepared
 by blending the calculated concentrations into 500
 ml of  water before addition to the test container.
 "Where  necessary, pure  oxygen was supplied by
 bubbling at a slow rate. The petrochemicals tested
 •were benzene, chlorobenzene,  0-chlorophenol, 3-
 chloropropene,  0-cresol, cyclohexane,  ethyl ben-
 zene, isoprene, methyl  methacrylate, phenol, 0-
 ph'Jialic anhydride, styrene, toluene, \inyl acetate,
 and  xylene. These petrochemicals are similar in
 ihsir toxicities to fish, vvith 96-hour TL^ values
 ranging from 12 to 368 mg/1. Except for isoprens
 ar.d  methyl methacrylate,  which are  less toxic,
 values for all  four  species of fish  for the  other
 petrochemicals ranged from 12 to 97 mg/1, a rela-
 tively small variation. In general, 0-chlorophenol
 and "O-cresol are the most toxic and  methyl metii-
 acrvlate and isoprene are the least toxic.

 Rr«>mm*ndaric,n:  In view of available data, it is cca-
   c!:oieti iha: to provide suitable conditions for aqua'Jc
   L::'e, oil and petrochemicals should not be addsd  in
   %ueh quantities to the receiving watere that tbsy v-Hl:
   (i) prccuce a  visible  cofor  fiim on the surface, (2)
   impart aa  oily odor to water or an oily  lasts to fish
   ^:*l edfoie  Invsr.ebrates,  (3) coat the  backs and bot-
   van o£ tlw water course or taint any of the asiociated
   'ctoia,  or (4) become  effective toxicants according  to
   ih« criteria recommended in the 'Toxicity" section.

-------
EsW
.ar«
                      '  i
                      Crude oil and petroleum products

                        The discharge of crude oD and petroleum prod-
                      ucts into esruarine and coastal waters presents spe-
                      cial problems in water pollution abatement. Oils
                      from diferent sources have highly diverse proper-
                      ties and chemistry. Oils are relatively insoluble in
                      sea and brackish waters and surface action spreads
                      the oQ in thin surface  films of variable thickness,
                      depending on the'amount of oil present. Oil, when
                      adsorbed  on day and other particles suspended in
                      the water, forms large, heavy aggregates that sink
                      to  the bottom.  Additional  complications arise
                      from the  formation of emulsions in water, leach-
                      ing of water soluble fractions,  and coating and
                      tainting cf sedentary  animals,  rocks,  and tidal
                      flats.
                        Principal sources of oil pollutioa'are numerous.
                      Listed in  order of their dsstructiveness to ecosys-
                      tems, the}' are:
                        (1) Sadden  and  uncontrolled discharge-from
                            wells towards the end of drilling operation.
                        (2) Escape from wrecked and submerged 01!
                            talkers.
                        (3) Spillage of oil during loading and unload-
                            ing operations, leaky barges, and accidents
                            during transport.
                        (4) Discharge of oil-contarninated ballast and
                            bilge water into coastnl areas and on ths
                            high seas.
                        (5) C^-ing and flushing of  oil  tanks at sea.
                            On the average, a ship's  content of such
                            wastes is estimated to contain 2  to 3 per-
                            cent oH  in  1,000 to 2,000 tons of waste.
                        (d) Spillage  from various shore  installations,
                            refineries, railroads, city  dumps, garages,
                            and various industrial plants.


                           Spillage From Wrecked  Oil Tankers

                       Even though wrecks  of oil  tankers along the
                     Atlantic coast and subsequent spillage of oil into
                     the sea ha%-e been reported several times, no thor-

-------
   ouch examination has been made of the effect of
   03~pollution on local  marine life, except for frc-
   c'jcnt references to the destruction of waterfowl.
   One of these disasters attracted the general atten-
   tion of the public and members of lie Audubon
 -  Society of New England.  One night in 1952, two
   rankers, the Fort Mercer and the Pendleton, went
   srround on the shoal oi Monomu> r'oint,  Cape
   Cod. Large amounts of oil spilled from the broken
   vessels, spread long distances ^loug the shore, and
   vers responsible for high mortality of ducks (scot-
   ers and  eiders). Many thousands of oil-smeared
   dying birds were seen along the coast. Attempts to
   save some of  the birds by removing the oil with
   various solvents failed. No published records are
   fouzd  en the effect of this  massive  spillage  on
   aquatic life. According to  the records of the Mas-
   sachusetts  Audubon Society,  serious  ofl spreads
   threatening fish and bird life have occurred at least
   six rimes since 1923  along  the beaches  of Cape
   Cc
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According  to data published by  'he  American
Petroleum Institute (1949), the first trace of color
that may be observed as a surface film on the sea
is  formed by 100 gallons of oil spread over  1
square mDe. Films of much darker colors  may
indicate 1,332 gallons of oil per square mile. Ex-
periments conducted  by the Conrnirteef oa the
Prevention of Pollution of the Seas U953) sLowcd
that 15 tons of  oil covered an area of 8 square
miles.  In  8  days,  it hnd drilled about 20 relies
from the point of  discharge. The same  comnrir.ee
(1953) indicated  another source of oil pollution
that should not bz neglected. It has beec f:-_i:id ur_.
unburned fuel oil  escaping through  the funnels^'
oD-burniag ships may comprise 1 to 2  percent of
the total oil  consumed and it may be deposited 'on
the sea surface. British investigators attributed the
disappearance of  eel grass  (Zos/era)  to minute
quantities cf oil. Oil weakens the plant ?jid makes
it  susceptible to attacks ^ a parasitic protozc^a
(Labyrinthula*).  Observations made  several  years
ago at Woods Hole showed that youcg Zosiera
that began to reappear in local bays after several
years  of  absence  were already infected by this
microorganism even though they aooeared  to be
healthy.
   Adsorption of Oil by Sand, Clay,  Silt,  and
           Dtnsr Suspended Particles

   Oil of  surface films is  easily adsorbed en clay
 particles and  other  suspended r^...crials, fomirg
 large and relatively  heavy aggregates that s:Jik to
 the bottom. The surface of u.e water may  appeir
 free from pollution, until the sediment is c.:L~ed by
 wave actioa and the  -leased oil iloats up again.
   During  World  War II,  a  product >_nown  L
 "carbonized sand" was manufactured for the U.S.
 Navy and used for the primary purpose of rapidly
 removing oil spilled  or leaked  from ships Car-'on-
 ized sand was used  principally as a rapid me'.hod
 to prevent and stop  fires.  Sand and oil aggr.-rales.
 being much heavier than  * :~ water, sank  •'.ery
 rapidly and remained on the bottom. "Experuzr-:-?'
 work has shown that the  toxic effect of oils Is not
 diminished by this method (Chipman and Gais-
 off,  1949). Since the end  of World War H,  a num-
 ber of preparations  to be used as solvents, emu!si-
 fters, and dispersing agents of oil slicks in harbor
 waters appeared in New Zealand, Western Europe,
 and the United  States. These  preparations  are be-
 ing  offered under various trade  names and their
 chemical composition is  not  always staled. It  is
 often claimed that  such  compounds remo'.e oil
 slicks more efficiently than mopping with straw or
coarse  canvas fabric  (sk/uu), a method  exten-
sively used in Auckland Harbor  (Chitry, 1943).
It  is hov>r ;   Generally  recognized that various
detergents and emulsifiers are toxic  to aquatic life
and  therefore compound  the danger of oil pollu-
tion. Mechanical  means  such as preventing the
spread of a  slick  by surrounding it with floating
barriers ^pia^tic booms), spreading' sawdust and
removing  an  oH aggregate by scooping or raking,
and  erecting grass or str?w barriers along the
beaches are  probably more  effective ^at present
than the chemical methods  of dispersing or dis-
solving oil.  Even  anchoring oil  by ccmbiobg it
with reUL,;iy heavy carbonized sand setms to be
preferable to chemical methods.


Tcxicity of  Cruos  Oi! and  Petroleum  Products

   Oil  may  in JUT; aquatic  life by  direct contact
with the organism, by poisoning with various water
soluble substances that may be leached from oil,
or by emulsions of oil which may  sraear the gills or
be swallowed with water and food.  A  heavy oil
aim o- the  water surface may interfere with the
exchange of gases and respiration.
   A number cf ch stations have been recorded
of the concentradons of oil  in sea water  which are
deleterious -> '•arieus species. Experimental data,
however, are scarce and  consequently the  toxicol-
ogy of oil to rr.ance organisms is not well under-
stood.
   NelsT. (1925)  observed marine mollusks (A--;'S
arenana) behg destroyed by oil on tidal flats of
Staten  I:'.^i,  N Y. Tne Pacific  coast sea urchin,
Slrongylocer.troius purpura:us,  dies  in abc-t  1
hour in a 0.1 percent emulsion of diesel oil. After
 20 to  40  minutes b '-his conc-.ntration the  auircols
fail to clins to the bottom and may be  washed
 away  (North, et a!., 1964).
   Crude c'.i  absorbed by carbonized sand does not
 lose its toxicity. This has been shown by  laboratory
 experiments r-rducted at Woods Hole  (Chiprzaa
 and Galtsoff, 1949). Tne amount of oil used was
 limited to th:  7-^:^7 held in the sand, hence no
 free oil was present  in the water.  The  oil-sand
 aggregates were placed in containers rilled with sea
 water but never came into contact with  the test
 animals.  Four species were bioassayed: the very
 hardy  toad fish (Opsar.us   ten')  in  the yolk  sac
 stase,  the modenteiy tolerant barnacle (Balanus
 balanoides'). and oyster (Crc.ssostrea  virgin'tca),
 and the extremely sensitive hydrozoan,  (Tubularia
 crocca).
    The sup.-ival of toadnsh embryos was indirectly
 proportional to the concentration of oil in water.

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    In 3 conccr.rr.ion of 0.5 percent, the embryos sur-
  '  VTVCO" for 13  cays (end of test); in 1.25 percent,
    Sj cays; in 2.5 percent, 6 days; and in 5 percent,
    4J  dcys. Earr.ades suffered 80  to  90-percent
    nonaiiry with::: 70 hours in 2.0-percent mixtures
  •  of oil in sea.  \vater. They became  inactive  in 23
    hours in concentrations of 2 percent  and above.
    Tub-ulzriz sufered  90  to  100-percent  mortality
 •  within 24 hours after being placed  in water con-
   tairiinc a  1:200  oil-carbonized sand aggregate.
   Water extracts of crude oil were-lethal within 24
   hours at concentrations  of 500 rag/1 and greater.
.' •   Experiments with oysters consisted primarily of
  determining the effect of oil adsorbed  on carbon-
  ized sand on  the number of hours trie oysters re-
  main open and  feeding and on the  rate  of  water
'_ transport, across the gills. A paste-lite, aggregate of
  02 in caibc'niied sand (50 ml crude oil to 127 g
  sand) was prepared, wiped clean of excess oil, and
  diced in the  mixing chamber. Sea ^ater was de-
  livered through this chamber to the recording ap-
  paratus at a rats slightly in excess of the rate of
  water transport by oyster  gills (Galtsoff, 1964;
  Chipman and  Galtsofi, 1949). There was a notice-
  able  decrease in  the cumber of hours  the test
  oysters remained open and in the daily water trans-
  port rats through the gills.  The time  open was re-
•  duced from 95 to 100 percent during  the first 4
  days of testing to  only 19-8 percent on the  14th
  day. The  total amount  of  water transported per
  day, and presumably used for feeding and respira-
  tion, was reduced from 207 to 310 liters during the
  first 6 da\s to orJy 2.9  to  1 liter per day during
  the period  between the eighth and  14th  day of
  conrirrjous  testing.  These  tests  indicate  that oil
  incorporated ir.io the sediments near oyster  beds
 continues to leach water-soluble substances which
  depress the normal functions of the mobusk.
    Critical observations are lacking on the effect of
 oil os pelagic  larvae of marine invertebrates, but
 there is good reason to assume that crude oil and
 petroleum products are highly  toxic to free-swira-
 —Ho  larvae  of oysters.  Spee*- (1928)  considers
 that they are killed by contact with surface oil  film.
 Laboratory experience  of Galtsoff  (unpublished
 records) shows that oyster larvae from 5 to 6  days
 old were Killed when minor quantities of fuel oil
 were spilled by ships in the Woods Hole harbor
 and the  contaminated water penetrated into the
 laboratory sea water supply.
    The tests described above, leave no doubt that
 water-soluble  substances  are  leached  from oil
 spilled into water and adversely afTect marine life.
 It  is reasonable to  assume that the water soluble '
 materials of ol'  may contain  various hydrocarbons,
 phenols,  suISces, and other substances toxic to
  aquatic life. The water-soluble  fraction leached
  from crude oil is easily oTJdizcd by aeration zuad
  loses its toxicity  (Chiprnan and  Galtsoff,  1949).


         Carcinogenic Substances From
               Oil-Polluted Waters

    Presence of hjdrocarboas  similar  to  beczo-
  pyrece in oil-polluted coastal waters and sediments
  of France in the  Mediterranean  was reported by
  Mallet (1965) and Mallet and  Sardou- (1965).
  The eSuents from the industrial establishments on
  the shores  at Villefranche Bay comprise tar sub-
 stances, which contain  benzopyrsnes, benzo-8,
 9-fiuoranthene, dibenzanthracenes, chrysene, 10-
 methyl  anthracene, and nitrogenous derivatives
 such as dimethylbenzacridine. These  substances
 are carried  out into the bay water and settle on the
 bottom. The pollution is augmented by incom-
 pletely burned  oiis  discharged by turbine  ships.
 The content of benzcpyrene in bottom sediments
 ranges from 500 micrograms b. 100 g sample col-
 lected at the depth of 8  to 13 crn to 1.6  micro-
 grams at 200 cm  Similar contamination is cf im-
 portance in the Gulf of Fos. Etang de Berne, and
 in the delta of the Rhone River.
   Carcinogenic hydrocarbons were  found  to be
 stored in plankton of the ba\ cf Villefranchs, in
 concentrations  van ing from 2.5 to 40 rnicrograrns
 per 100 g.  Fixation of benzopyrenes was found
 also in the bodies of holothurians (Lalou,  IS65)
 in a bay near Antibes. The reported concentration
 in  the visceral  mass of  holothurian was sli:;htly
 higher than that in the bottom sediment
   Observations on storage  of carcinogenic com-
 pounds found in oil-polluted water are biologically
 significant.  The important question cf  biological
 magrlScation as these compounds are ingested by
 plankton feeders remains unanswered and needs
 to be investigated.
      Sampling  of  Oii-Foiiutsd  Sea Water

   The question of the minimal concentration of oil
and petroleum  products consistent  with  unin-
hibited growth and reproduction of aquatic species
is more difficult  to answer than it is in the case of
other contaminants. As has been shown above, oil
is found in water in four distinct phases:  (1) sur-
face oil film, (2) emulsion in sea water, (3) ex-
tract of water soluble substances, and (4)  semi-
solid  aggregate of oil and sediment covering the
bottom. Obviously, no single sample could include
all four phases and the method of sampling should

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  vary accordingly. Collection of samples of a heavy
  oil slick near the origin of spillage presents no par-
  ticular difficulty because an adequate quantity may
  be scooped easily and placed in a proper container.
  Serious difficulty arises, however, in  case  of zn
  irridescent film of oil approaching the thickness of
  a  monomolecular layer. Garrett (1964), made  a
  special  study of slick-forming materials  naturally
  occurring OQ sea surfaces, and demonstrated their
.highly  complex composition. The.  collection of
  very thin layers  of'surface water was mads by
  means  of a specially  constructed plastic screen.
  The entrapped  compounds were washed ofrinto
  a large container (Garten, 1962). He found'sur-
  face-acting substances in all areas where jhe' -sea
  surface  was altered by monomolecular films, and
  concluded  that  "a  chemical  potential-'  exists
  whereby such surface alterations can occur  when
  conditions are  suitable for the  adsorption and
  compression of the  surface-active  molecules at
  the air/water   boundary."  The  oil  film at the
  air/water boundary may be composed of several
  interacting organic compounds. This complexity
  must be kept in mind in studies of oil pollution in
  sea water.
    If a relatively thick layer of contaminated water
  is  needed, the sample may be  scooped or sucked
  from an area of sea surface enclosed  by a floating
  frame. Interference due to  wave ripples  is mini-
  mized in this way.
    For analysis of an  oil emulsion  in  sea water, a
 sample of a desired  volume may be  collected by
 pump or by any type of self-closing  water bottle
 lowered within the surf area.
   For obtaining water soluble substances  leached
 from oil  sludge, sampling  should be  mads by
 pumping or by  using  a water sampler lowered as
 close as possible  to the oil-covered bottom.
   Samples of oil adsorbed  on sediments can be
 obtained  by using bottom samplers  designed to
 take quantitative samples.
   Contamination of beaches by floating  tar ballast
and cleaning water  discharged by ships sailing
along our coast is of such common occurrence that
at present it is almost impossible to find a public
beach free from  this nuisance. Cakes  of solidified
oil  tar can be picked by hand from the tidal zone
of any beach along the Atlantic and Gulf coasts.
Recommendation:  Until  IT. ore information  on the
  chemistry and toxicology of oil in sea water becomes
  available, the following requirements are recommended
  for the  protection of marine life. No oil  or petroleum
  products should be discharged into estuarins or C02s:il
  waters in quantities that (1) can be detected  as  a
  visible film or sheen, or by odor, (2) cause  tainting
  of fish and/or edible  invertebrates, (3)  form ar» oil-
  sludjs deposit on the shores or bottom of the receiving

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 Oil
   Waterblrds, musk rats, otters, and many other
 wildlife species require water that is free of surface
 oil.  Studies by Hartung (1965) demonstrated that
 egg laying  was inhibited \vhen ma'.lards ingested
 small quantities of oil. Whsr. oil from the plumage
 was  coated on mallard eggs, it  reduced hatching
 from SO.to 21 percent. The full significance of this
      Of dzinage to wildlife populate-as is unknown.
    Dr£32dc losses  of watarbirds (ducks, geese,
'""coot, •sv-'ass, gaanets, rnurres, and  others) result
!; frota contamination of the plum age by oil from the
 ' sszizsz of the water. Once the bird's plumage is
.  soaked vo:h oil, the bird loses its rarcrEl insula-
• tion to tie cold and dies. Many hundreds of thou-
  pgn^t  of birds have died  fxoa  oil pollution  in
.••soas \rars in North A men can waters.
 '..  Oii that sertlss  to the bottom of aquaas habitats
 can bJazi'et large areas and destroy the plants eud
 anisaJs of value  to  waterfowl. Reportedly, some
 oD sSudges oa the bottoms of aqusdc habitats tend
 to concentrate pesticides, thus creating a double
 hazard to waterfowl that would pick up these con-
       sts in their normal feeding process.

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       APPENDIX 2




ANIMAL TOXICITY STUDIES

-------
                               TABLE  1

                    Animal  Toxicity Resulting  from
                       Aerosol  Exposure to Oil
 Animal
   Experimental  Data
          Results
 1. Middle  Distillates
6 albino
 rats
25 rats
rats
rats
rats
rats
37 rats
 9600 mg/m3  aerosol  of
 deodorized  kerosene;
 6 hr/day  for  4
 consecutive days

 9600 mg/m3  aerosol  of
 deodorized  kerosene;
 6 hr/day, 5 days/wk
 for 13 weeks
14,400 mg/m  vapors of
(?9~C-10 aromatic dis-
tillate for 7 hours

3200-5200 mg/m3 vapors
of Cg-C^Q aromatic dis-
tillate; 18 hr/day;
up to 2,424 hours of
exposure
260-1000 mg/m3 vapors
of Cg-C^g aromatic dis-
tillate; 8 hr/day; 5
days/wk; 700 hr. total

4600 mg/m  vapors of
C^]_-C^2 aromatic dis-
tillate for 7 hours

3200 mg/m3 vapors of
C^^-C^2 aromatic dis-
tillate; 18 hr/day;
up to 1,683 hours of
exposure
 loss of  coordination;
 sluggishness; dermatitis;
 normal weight gain
 2 died after  16 and 30
 days; bronchopneumonia;
 elevated urine pH;
 erythrocytopenia; no
 progressive effects
acute LC
                                               50
decreased rate of weight
gain; neutrophilia; lympho-
cytopenia; decreased total
leukocyte count; bilateral
cataracts; hemorraghic
lungs, liver, kidneys,
spleen; increased myelotic
precursors in bone marrow

no adverse effects
acute LC
                                               50
50% died after 18 hr; de-
creased rate of weight gain;
hemorraghic lungs, liver;
splenic dystrophy; decreased
total leukocyte count; neutro-
philia; lymphocytopenia; watery
bone marrow; dermatitis

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                           TABLE 1 (Cont'd)

                    Animal Toxicity Resulting from
                       Aerosol Exposure to Oils
 Animal
 mice
 mice
 mice
 3  rhesus
   monk ays
 3 rhesus
  monkeys
4 rhesus
  monkeys
beagles
beagles

4 cats
  Experimental data
6900 mg/m3 deoderized
kerosene aerosol  (dur-
ation not specified)


9700 mg/m3 vapors of
C9~C10 aromatic dis-
tillate; 3.75 hr.
exposure

3400 mg/m  vapors of
Cn-Ci2 aromatic dis-
tillate; 3.75 hr.
exposure

1000 mg/m3 vapors of
C9~C10 aromatic dis-
tillate; 7 hr/day; 5
days/wk; 90 exposures
 260 mg/m3 of vapors of
 C9~C10  aromatic dis-
 tillate; 7 hr/day; 5
 days/wk; 90 exposures

 300 or  1280 mg/m3 vapors
 of Cn~Ci2 of aromatic
 distillate; 7 hr/day; 5
 days/wk; 90 exposures
100 mg/m3 deodorized
kerosene aerosol;
6 hr/day; 5 days/wk
for 13 weeks

20 mg/m3 given as above

6400 mg/m3 deodorized
kerosene aerosol; 6
hours/day for 14 days
      Results
                              slight  depression  in
                              breathing  rate;  no
                              respiratory  tract
                               irritation
                              Acute  LC
                                                    50
                              Acute  LC
                                                    50
hair loss; dry skin;
sedation; tremor; leuko-
cytopenia; neutrophilia;
lymphocytopenia;  decreased
erythrocytic and myelocytic
precursors in bone marrow

elevated hematocrit;
leukocytopenia;  neutro-
philia; lymphocytopenia
eye and skin irritation;
diarrhea; neutrophilia;
lymphocytopenia; increased
erythrocytic and decreased
myelocytic precursors in
bone marrow

no adverse effects
 mean weight increase

 no adverse effects

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                          TABLE 1 (Cont'd)

                   Animal Toxicity Resulting from
                      Aerosol Exposure to Oils
Animal
Experimental Data
        Results
2. Lubricating Oils
                           Acute exposure
6 albino
  mice
7 albino
  mice
6 albino
  mice
13 albino
  mice
4330 mg/m3 aerosol
of S.A-E. 10 motor
oil? 2 hr exposure


4330 mg/m3 aerosol
of S.A.E. 10 motor
oil; 92 hr exposure
total (intermittent
schedule)

4500 mg/m^ aerosol
of S.A.E. 10 motor
oil; 2 hr exposure


4500 mg/m^ aerosol
of S.A.E. 10 motor
oil; 90 hr exposure
total (intermittent
schedule)
oil retention in terminal
bronchioles and alveolar
ducts; vigorous oil
phagocytosis

one death; heavy oil reten-
tion in all divisions of
respiratory tree; pneumonia;
coalescence of oil into giant
droplets (>_ 30   diameter)

2 deaths; oil retention in
terminal bronchioles and
alveolar ducts; vigorous
oil phagocytosis

increased macrophage'S and
foam ceils in alveolar lumina
and septae; oil deposition
in 2 weeks; decreaecl ATP
activity of macrophages;
focal oil granulomas and
pneumonia in 3 weeks
                          Chronic exposure
6 rhesus
  monkeys
80 white
   mice
132 mg/m3 aerosol
of S.A.E. 10 motor
oil; 100 days;
schedule of 30 min
aerosol alternating
with 30 min air room
same as for monkeys
3 deaths; oil accumulation in
lungs followed by gradual
clearing over one year; pneu-
monia; bronchiolitis; pulmona
fibres is; pulmonary edema;
weight loss; atrophic stomach
fur loss

gradual accumulation in lung
macrophages in peripheral
and subpleural alveoli; no
free oil; oil macrophages in
tracheobronchial lymph nodes;
minimal toxicity

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                           TABLE 1 (Cont'd)

                    Animal Toxicity Resulting from
                       Aerosol Exposure to Oils
 Animal
   Experimental Data
        Results
 120 mice
 160. rats
30 rats
45 rats
 5 or 100 mg/m3  aerosol
 of lubricating  oil;
 6 hr/day; 5 days/wk;
 12 months

 same as  for mice
 13,  30,  or  60 mg/m3
 aerosols of industrial
 lubricating oils
 (without additives);
 5 hr/day for 6 months
same as above
 lung  oil macrophages
 scattered  randomly; no
 major lung response;  no
 other adverse  effects

 pulmonary  tissue damage
 indicated  by elevated lung
 alkaline phosphatenes;
 progressive interstitial
 pneumonia  only with
 higher concentration

 serum neuraminic acid levels
 increased  progressively;
 decrease of serum albumin
 and leukocyte  phagocytic
 activity;  increased serum
 globulins

 leukopenia; increased para-
 sympathetic tone; decrease in
 weight gain rate; decreased
 respiratory rate; increased
 neuromuscular  excitability
 threshold;  pulmonary infil-
 tration and inflammation;
 liver, kidney, heart and
 adrenal degeneration
3.  White Oils
20 rats
                           Acute exposure
30,000 mg/m3 aerosol
of mineral oil 6 hr/
day for 3 weeks
increased macrophages and
foam cells in alveolar lumina
and septae; oil deposition
in 2 weeks; decreased ATP
activity of macrophages;
focal oil granulomas and
pneumonia in 3 weeks

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                          TABLE 1 (Cont'd)

                   Animal Toxicity Resulting from
                      Aerosol Exposure to Oils
Animal
  Experimental Data
       Results
                          Chronic Exposure
218 hamsters
46 rabbits

18 dogs
5 or 100 mg/m3 aerosol
of mineral oil;
5 days/wk; 6 hr/day;
26 months
same as above

same as above
no major lung tissue
response; presence of oil
macrophages in alveoli;
no other pathological
findings

no adverse effects

pulmonary tissue damage
indicated by elevated lung
alkaline phosphatenes;
scattering and coalescence
of oil droplets in lungs;
granuiomas with intra-
cellular oil droplets

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                               TABLE  2

                    Animal  Toxicity Resulting  from
                        Dermal  Exposure to Oil
 Animal
 Expermental Data
        Results
 1. Middle Distillates
Wistar rats
5 albino
  guinea pigs


albino guinea
  pigs
20 guinea pigs
10 white
  Belgian
  rabbits

79 mice
100 mice
undiluted diesel  fuel
applied to tail skin
6 hr/day for 10 days
diesel  fuel applied
to  intracapular skin
5 times/wk for 19 days

various petroleum fuel
distillates applied to
skin every other day;
4 applications total

Landsteiner and Jacobs
skin sens itization
method with diesel fuel

Draize method with
diesei fuel
0.10-0.15 g/animal of
C$-Ci2 aromatic dis-
tillate applied to
skin 3 times/wk; 150
applications total

intrascapular skin;
daily application of
light grade diesel
fuels
dermatitis; hair loss;
decreased hemoglobin;
erythrocytpotenia
reticulocytosis;
leukocytosis; neutro-
philia; lymphocytopenia

erythema; desquamation;
hair loss; ulceration;
and crusting

hyperplasia; hyper-
keratosis; hair loss;
aromatic fuels more toxic
than paraffinic fuels

no skin sensitization
mild pimary irritant to
skin and conjunctiva
dry, thick, scaly skin;
hyperkeratosis; epidermal
atrophy; dermatitis;
ulcerat ion
dermatitis

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                    Animal Toxicity Resulting from
                        Dermal Exposure to Oil
 Animal
Experimental Data
    Result
 2.  Lubricating Oils

 albino guinea
   pigs
0.6 ml/animal of yellow
lubricating oil
desquamation and
hyperkeratos Ls
 3 .  White Oils

 two Holstein
   Friesian
   calves
 albino guinea
   pigs
0.13 ml/kg of body-
weight/day of white
lubricating oil for
8 weeks applied to
skin

0.6 ml/animal of white
lubricating oil applied
to skin every other day
for 4 days
 no gross skin
 pathology
 slight erythema
 and desquamation
,.c
              6°504

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                              TABLE 3

                    Animal  Toxicity Resulting  from
                      Oral  Adminstration  of  Oils
 Animal
 Experimental Data
        Results
 1.  Middle  Distillates
Wistar  rats
 138 Wistar
    rats
 5 Wistar
  rats
10 rabbits
cow
ewe
20-25 ml/kg of body-
weight/day diesel oil
by gastric intubation
for 14 days
16.0 ml/kg of body-
weight diesel oil by
gastric intubation

6.9 ml/kg of body-
weight/day diesel oil
by gastric intubation
for approx. 3 weeks

1.0 ml/kg of body-
weight of fuel oil
orally

approx. 7 liters of
diesel fuel ingested
accidently
ingestion of diesel
fuel-soaked grass
hemoglobinemia; reticulo-
cytosis; neutrophilia;
lymphocytopenia; thrombo-
cytopenia; elevated serum
raalate dehydrogenase,
apartate and alanine
aminotransferase

acute oral LD5Q
subacute LD5Q
23% drop in blood sugar
in 5-7 hr; return to
normal levels by 12 hr.

low grade fever; diarrhea;
constipation; lowered milk
production; stiff uncertain
gait; swelling of hind fet-
locks; recovery in 8 days

weakness; weight loss;
nodular lesions on inner
rumen wall; complete loss
of fleece; neutrophilia;
2.  Lubricating Oils
mice
chronic ingestion of
spindle oil for 20-
90 weeks (dose not
specified)
fatty infiltration and
degeneration of liver,
spleen,  overy and
adrenals

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                         TABLE  3   (Cont'd)

                   Animal Toxicity Resulting from
                     Oral Adminstration of Oils
 Animal
 Experimental Data
        Results
 3. White oils
mice
rats
1 monkey
1 monkey
 20 mi/kg of body-
 weight/day of white
 mineral oil ingested
 with diet
5 ml/kg of body-
weight/day of white
mineral oil ingested
with diet

2.2 ml/kg of body-
weight/day of white
mineral oil in diet;
total consumption
96 ml
1.1 ml/kg of body-
weight/day of white
mineral oil in duct;
total consumption
36 ml
rough, dry skin; pilo-
erection; restlessness;
weight loss in 5 days;
all died by 7 days; fatty
degeneration of liver;
proliferation of reticulo-
endothelial cells of spleen;
epidermal hyperkeratosis;
renal tubular degeneration

same as above in mice
weight loss; diarrhea;
death in 3 weeks; hepatic
and renal congestion;
ulceration and inflammation
of colon, heart, lung and
spleen

diarrhea; weight loss;
death in 11 days; same
pathological findings
as above
1 monkey
1.1 ml/kg of body-
weight/day of white
mineral oil in duct;
total consumption
195 ml in 3 months
no adverse effects;
slight hepatic and renal
congestion

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