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                       LISTING BACKGROUND DOCUMENT

           GI-CS  CHLORINATED ALIPHATIC HYDROCARBON  PRODUCTION
               UTILIZING FREE RADICAL CATALYZED  PROCESSES
                            TABLE OF CONTENTS

                                                           Page No,
     I.   Summary  of  basis for listing
     II. Sources  of  waste and typical disposal
         practices	............              4

         A.   Industry profile.,,	              4

         B.   Manufacturing processes and waste
              generation points	              8
          C.   Waste  generation, composition,
              and  management	             20

              1.   Current waste generation rate
                  and  management practices	             20

              2.   Current management practices               22

              3.   Composition of wastes as
                  predicted by chemical reaction             22
                  theory	

              4.   Composition ranges of waste as
                  determined by sampling and
                  chemical analyses	             25

              5.   Hazardous toxicant concentrations
                  in wastes as determined by samp-
                  ling and analysis.	             27

    III.  Discussion of basis for listing	             35

          A.   Migration, mobility and persistence
              of the listed waste constituents,
              and  potential for mismanagement...             35
                                     U.S. Environmental Protection Agency.
                                     Reajon V, Library
                                     230 South Dearborn Street
                                     Chicago, Illinois  60604

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'V..'
 U,S.  Environmental Protection  Agency.

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                      TABLE OF CONTENTS (continued)


                                              Page No,
        1.  Predicted migration, mobility
            and persistence. . .'.	 35

        2.  Actual mobility and
            persistence of specific waste
            constituents	 37

        3.  Actual damage cases
            illustrating environmental
            behavior of wastes  and
            potential for mismangement	 38

     B.  Hazardous properties of >the
         wastes	 45

     C.  Hazardous properties of the consti-
         tuents of concern	 52

     D.  Existing regulations and
         guidelines	 65

         1.  Existing RCRA regulations	 65

         2.  Other regulations  and
             guidelines	 66
IV.  RESPONSE TO COMENTS                       70

REFERENCES                                     73

APPENDIX A.  Process flow diagrams for inte-
             grated chlorinated aliphatic
             hydrocarbon manufacture	 A-1

APPENDIX B.  Selected damage incidents
             relating to the manufacture
             or environmental release of
             the chlorinated constituents
             of concern	 C-l

APPENDIX C.  Physical/Chemical constants,
             toxic constituents of concern.... D-l

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                       LISTS OF TABLES
                                                      Page No.
Table 1.   Production volumes and producers
           of major C± - €5 chlorinated
           aliphatic hydrocarbons ,	  9

Table 2.   Chemical reaction processes used to
           manufacture chlorinated aliphatic
           hydrocarbons	 11

Table 3.   Summary of waste management practices
           reported by manufacturers of Cj - C^
           chlorinated aliphatic hydrocarbons	 22

Table 4.   Published Analyses of One Plant's
           Chlorinated Propane Manufacturing
           Residuals	 33

Table 5.   Ambient Water Ouality Criteria
           levels for toxicants, of
           concern	  47

Table 6.   Representative Federal regulation
           controlling the constituents
           of concern	  66


                       LIST OF FIGURES


Figure 1.  Representative chemical conversions
           used in C2 chlorinated hydrocarbon
           production facility	  10

Figure 2.  Generalized, simplified hypothetical
           unit process within integrated
           chlorinated hydrocarbon manufacturing
           plant	  17
                             111

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                 LISTING BACKGROUND DOCUMENT

F024  WASTES, INCLUDING BUT NOT LIMITED TO, DISTILLATION
      RESIDUES, HEAVY ENDS, TARS, AND REACTOR  CLEAN-OUT
      WASTES FROM THE PRODUCTION BY FREE RADICAL CATALYZED
      PROCESSES  OF CHLORINATED ALIPHATIC  HYDROCARBONS HAVING
      CARBON CONTENT FROM ONE TO FIVE BUT  NOT  INCLUDING LIGHT
      ENDS, SPENT FILTERS AND FILTER AIDS, DESSICANT WASTES,
      WASTEWATERS, WASTEWATER TREATMENT SLUDGES AND SPENT
      CATALYSTS * (T)

F025  LIGHT ENDS, SPENT FILTERS AND FILTER AIDS, AND DESSICANT
      WASTES GENERATED DURING THE PRODUCTION BY FREE RADICAL
      CATALYZED PROCESSES OF CHLORINATED ALIPHATIC HYDROCARBONS
      HAVING A CARBON CONTENT RANGING FROM ONE TO FIVE (T)

I.  SUMMARY OF BASIS FOR LISTING

     Certain residuals from the production by  free radical  catalyzed
processes  of chlorinated aliphatic hydrocarbons having carbon
content ranging from one to five ("C]_-C5"  including, but not
limited to, distillation residues, heavy ends, tars, reactor clean-ou
wastes, light ends, spent filters, and filter  aids, and dess-icants**)
have been determined by the Administrator  to pose a substantial
present or potential hazard to human health and the environment
when improperly treated, stored, disposed  of or otherwise managed,
and therefore should be subject to controlled management under
Subtitle C of RCRA.  This conclusion is based  on the following
considerations:
* This listing does not include the following wastes already
  listed in 40 CFR 261.32:
  K016 - Heavy ends or distillation residues from the produc-
         tion of carbon tetrachloride.
  K018 - Heavy ends from the fractionation column in ethyl
         chloride production.
  K019 - Heavy ends from the distillation of ethylene
         dichloride in ethylene dichloride production.
  KD20 - Heavy ends from the distillation of vinyl chloride
         in vinyl chloride monomer production.
  K028 - Spent catalyst from the hydrochlorinator reactor
         in the production of 1,1,1-trichloroethane.
  K029 - Waste from the product stripper  in the production
         of 1,1,1-trichloroethane.
  K030 - Column bottoms or heavy ends from the combined
         production of trichloroethylene and perchloroethylene.
  K034 - Filter solids from the filtration of hexachloro-
         cyclopentadiene in the production of chlordane.
  K095 - Distillation bottoms from the production of 1,1,1-
         trichloroethane.
  K096 - Heavy ends from the heavy ends column from the pro-
         duction of 1,1,1-trichloroethane.

**  These wastes do not include wastewaters, wastewater
    treatment sludges and spent catalysts, since the Agency

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 1.  These wastes are likely to contain significant aggregate
     concentrations of one or more of the following toxic
     substances (although each waste does not containe all of
     the individual toxicants of concern).

      Methyl chloride (Chloromethane) tt         F*"^, ^ "  "^  rj
                                                SLs& fl *L •*"
      Methylene chloride (Dichloromethane)tt

      Chloroform (Trichloromethane)t

      Carbon tetrachloridet

      vinyl chloride (Chloroethene)  t

      1,1-Dichloroethane (Ethylidene dichloride)tt

      1,2-Dichloroethane (Ethylene dichloride)t

      trans-1,2-Dichloroethylene

      I,1-Dichloroethylene (Vinylidene chloride) t

      1,1,1-Trichloroethane (Methyl chloroform) tt
 ** (continued from previous page)

    has an insufficient amount of data to determine the hazardous-
    ness of these wastes on a generic basis.  However, as our
    data base becomes more complete, we will re-evaluate
    these listings to determine whether they should also be
    included.

    The Agency has limited this listing to C]_-C_5 chlorinated
    aliphatics for two reasons.  First, C^-C^Q chlorinated
    aliphatic hydrocarbons are not produced in significant quantity
    in the U.S. by the generic chemical reaction processes addressed
    by these listings.  Second, and more importantly, the higher
    molecular weight chlorinated paraffin manufacturing processes
    typically do not produce organic residuals.

 t  Indicates compounds that have been determined by the U,s. EPA's
    Carcinogen Assessment Group as having evidence of carcinogenicity,
    The weight of evidence for carcinogenicity varies.  Some of
    the chemicals have human evidence (epidemiology data) while
    others have only animal evidence.  Depending on the amount and
    quality of the data the evidence could be classified as limited
    or sufficient using criteria developed by the International
    Agency for Research on Cancer.  The Agency has established
    Ambient Water Quality Criteria Levels based on their potential
    carcinogenic effects.

tt  Indicates compounds for which Ambient Water Duality Criteria
    Levels have been determined by the Agency for chronic human
    health risks other than carcinogenicity.

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1,1,2-Trichloroethanet




Trichloroethene (Trichloroethylene) t



1,1,1,2-Tetrachloroethane



1,1,2,2-Tetrachloroethanet




Perchloroethylene (Tetrachloroethylene)t




Pentachloroethane



Hexachloroethanet




Allyl chloride (3-chloropropene)




Dichloropropane



Dichloropropene tt



2-Chloro-l,3-butadiene (chloroprene)




Hexachloro-1,3-butadienet



Hexachlorocyclopentadienett




alpha-Hexachlorocyclohexanet




beta-Hexachlorocyclohexanet




gamma-Hexachlorocylohexane (lindane)t



delta-Hexachlorocylohexanett— —



Benzenet



Chlorobenzenett



Dichlorobenzenes tt



1,2,4-Trichlorobenzene



Tetrachlorobenzenett



Pentachlorobenzenett



Hexachlorobenzenett



Toluenett




Naphthalene

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2.  Significant quantities of these wastes are generated,
    increasing the opportunity for exposure if waste mismanagement
    occurs.

3.  Many of  the toxicants in the wastes are regulated by other
    EPA regulations as well as regulations by other governmental
    agencies.

4.  Improper waste management procedures could result in
    harmful  exposures.  For example, improper incineration
    could lead to exposure to products of incomplete combustion.
    Disposal in unlined or inadequately lined land disposal
    facilities could lead to contamination of groundwater, surface
    water,  and soil.

5.  The Agency has documented damage incidents involving
    mismanagement of these wastes resulting in surface and ground-
    water contamination.  These incidents show the potential of
    these wastes to cause substantial harm if mismanaged.
    In addition, the constituents of concern in the listed
    wastes have been shown in other damage incidents to have
    migratory potential and the ability to persist in harmful
    concentrations after migrating from waste matrices.

II.  SOURCES OF WASTE AND TYPICAL DISPOSAL PRACTICES

     A.  Industry Profile

     According to information published by the U.S. International

Trade Commission (USITC) (1) approximately 29 domestic companies

produced over 21 billion pounds (9.5 million metric tons)

of the major C]_ - 05 chlorinated aliphatic hydrocarbons* in
   "Chlorinated aliphatic hydrocarbons" refers to a class of
   organic compounds.  "Hydrocarbons" are organic compounds
   (molecules)  composed solely of the atoms hydrogen and carbon,
   "Aliphatic"  designates that the chemical bonding between the
   carbon atoms are single, double, or triple covalent bonds,
   (not aromatic bonds).   (Cyclic aliphatic hydrocarbons are
   included in  this class.)  "Chlorinated" means that the
   hydrogen atoms in the "aliphatic hydrocarbon" have been
   chemically replaced with chlorine atoms, at different
   positions and also in multiple positions.

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                                              	  ! !
                                                 ^ A
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1981.*  (See Table 1).  The information in Table 1 is derived

from published data supplied by manufacturers, however, it

may not reflect current production in all cases.  Ci~C$

chlorinated aliphatic compounds other than the more commercially

significant products listed, such as specialty chemicals

manufactured on demand, may be produced in smaller quantities,

and are also included in this listing, as well as any potential

new commercial C]_-C5 chlorinated aliphatic hydrocarbons.

     B.  Manufacturing Processes and Waste Generation Points

         The basic feedstock chemicals for the manufacture

of chlorinated aliphatic hydrocarbons are the corresponding

alkanes or alkenes (e.g. , methane, propane, propene) or

alcohol (e.g., methanol), and a chlorine source which may be

either molecular chlorine (Cl2) or hydrogen chloride (HC1).

Within a given plant, chlorinated"~~pf oduct or by-product

streams are often further converted to other chlorinated

materials with some flexibility, according to changing market

demand.

     The bulk of chlorinated aliphatic hydrocarbon manufacture

in the U.S. is based on five general chemical processes(3):

    0  Free radical initiated addition, substitution, and
       pyrolysis reactions, using molecular chlorine as  a
       feedstock.
*  Hexachlorocyclopentadiene finds captive use as an  inter-
mediate in the manufacture of pesticides and flame retardants.
Chloroprene and dichlorobutene are also used as captive  inter-
mediates in synthetic rubber manufacture.  Therefore, their
production volumes are not published by the USITC.

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     0 Lewis acid catalyzed addition and substitution reactions,
       using molecular chlorine as a feedstock.

     0 Oxychlorination, utilizing hydrogen chloride, air and a
       copper catalyst.

     0 Base catalyzed dehydrochlorination.

     0 Zinc chloride catalyzed chlorination of alcohols.

     Table 2 lists major commercial products from these

chemical processes, along with typical process conditions.

Within a given facility, several of these chemical processes

are integrated to efficiently convert the feedstock material

into a variety of saleable products.  This listing applies

when free radical catalyzed processes are utilized solely or

in combination with other types of reaction processes.

Figure 1 illustrates schematically the typical chemical

conversions currently employed within one plant from one

organic feedstock chemical, ethylene.

     Although individual plants differ in size and design,

depending on the technology available and the market outlook

for specific products at the time when the plant was built,

there exists a common factor between chlorinated aliphatic

manufacturing plants.  An integrated series of chemical reactors

and associated purification equipment are employed to produce

a range of desired chlorinated aliphatic hydrocarbons.  Usually

one or more of the series of chemical conversions are catalyzed

by "free radicals", which generally require high reactor

temperatures.  These free radical catalyzed reactions are

not totally specific in producing the desired chemical product;

thus, reactor conditions can only be arranged to maximize

the desired products.

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     The wastes covered by these listings are formed as




residuals at several points in an integrated series of reactors



and associated purification units utilizing one or more free




radical catalyzed chemical conservation steps to produce a



range of desired chlorinated aliphatic hydrocarbons.  These




listings cover wastes from all sources of within all intergrated




process utilizing free radical catalyzed conversions, whether




or not the integrated process utilizes free radical catalyzed



conversions solely or in conjunction with other types of




chemically catalyzed conversions.



     A flow diagram of a generalized unit process associated




with one chemical reactor unit is shown in Figure 2.  Sguares




represent residuals which generally have a higher boiling



point than the product or intermediates (distillation bottoms,



heavy ends, tars, clean-out wastes) and which are not typically




treated in wastewater treatment systems.  Circles represent



residuals which are treated in plant wastewater treatment



systems, and which usually have a high water content.




Triangles represent residuals initially generated in the



gaseous state because of a lower boiling point than the



product or intermediates.



     First, an organic material, which may be either a raw



feedstock material or a stream from some other process unit,



is fed into the chemical reactor.  The second feedstock




material to the reactor is a chlorine source, which may



either be molecular chlorine (C^) or hydrochloric acid
                              16

-------
(HCl).  (No chlorine source is needed for dehydrochlorination



reactions.)




     In the reactor, the desired chemical conversion is




catalyzed by either heat, a combination of heat and UV




radiation, or chemicals such as FeCl3, CuCl2r ZnCl2r or



NaOH.  The reactions may be conducted in either the gas



phase or liquid phase.  The wastes associated with the reactor




process are reactor residues,  tars or periodic clean-out wastes




(Point 6)  and any spent catalysts (Point 7), and condensable




vent gas or light ends wastes which are part of the reactor



overhead stream (Points 1 and 2).




     After the chemical conversion is completed, the components



are separated and purified.  The process stream may be quenched




or cooled with water to collect the product stream as well




as to prevent decomposition of the product.  Condensable vent



gases and light ends (Point 2), and unreacted feedstock



materials may also be collected from the quenching step.




     In most cases, hydrochloric acid is a major co-product



subject to recovery either from vent gases generated from the



reactor or from the cooling/quenching step.  A wastewater may



be generated from hydrochloric acid recovery (Point 4).



     The organic product/water acid phase from the cooling



and quenching step may be sent to an intermediate steam



stripping or neutralization process for product separation




from the acidic aqueous phase.  In some cases, the chlorinated



organic stream may by-pass this process.  Wastewaters collected
                              17

-------
from this step are neutralized and sent to central wastewater

treatment (Point 5).       $Jy •'•*'**>  '       '•

     Purification and separation of the different components of

the chlorinated organic product stream is further achieved

by fractional distillation or filtration.  The separated

chlorinated organic streams are either saleable products

or used as intermediates in other process units or are

recycled.  The wastes from these fractionation and puri-

fication steps are condensable light ends (Point 3);

heavy ends, distillation bottoms, column residues, clean-out

wastes, spent solvents used to extract the organic product

(Point 8); and spent filters, filter aids, and dessicants

(Point 9).

     Wastewaters from combined sources within the process

unit (Points 4 and 5) are subjected to various wastewater

treatment processes which usually involve neutralization,

biological degradation, activated carbon filtration,  or

other treatment.  A treated wastewater and various wastewater

treatment sludges (Point 10)  result.

     The waste streams covered by this listing described above

include the high boiling organic residuals generated at

Points 7 and S, the condensable vent gases and light ends

generated at Points 1, 2, and 3, and any spent filters,

filter aids and dessicants generated at Point 9.*
* The Agency is not including wastewaters, wastewater treatment
  sludge, and spent catalysts as part of this listing since the Agency
  has an insufficient amount of analytical data to determine the
  hazardousness of these wastes on a generic basis.  However, as our
  data base becomes more complete, we will re-evaluate these listings
  to determine whethery they should also be included.

                            18

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The heavy ends covered by this listing include any reactor

residues, heavy ends or bottoms as well as purification heavy ends.

The distillation residues and heavy ends also include any spent

solvents which have been used to trap or extract the organic process

stream.

     The reactor clean-out wastes category refers to any

periodic clean-out wastes from reactor equipment.  The term "tars"

can also describe some reactor clean-out wastes as well as wastes

from distillation, fractionation, or other processes.

     The usual plant sources of the light ends wastes derive from

the hot, gaseous overhead streams from reactor vessels and/or

associated purification and distillation equipment.  The light

ends component of these overheads are in fact liquids at ambient

temperature and pressure, but because of elevated temperature

and admixture with gases (e.g., hydrogen, methane) they require

some form of physical condensation to be isolated as liquids.

For example, freon condensers coupled with water condensers are

currently used by industry to recover light ends, products,

unreacted feedstock, or wastes from overheads.*
*   The Agency considers these light ends to be solid wastes
    within the meaning of section 1004(28) of RCRA.  Although
    these wastes are generated as gases, they are condensable
    to liquids at ambient temperature and pressure, and can feasibly
    be condensed to the liquid phase after generation.  The exclusion
    from RCRA of "gaseous materials" that are not contained
    (section 1004(28)), in the Agency's view, applies only to
    true gases, namely those which are not capable of being
    condensed and remain gases at standard temperature and
    pressure (for example, the hydrogen and methane admixed with
    the light ends).  The Agency, of course, is not requiring
    that these light ends be condensed; however, as a RCRA
    hazardous wastes, these light ends remain subject to applicable
    regulations even if left in the gaseous state.  Otherwise,
    one could evade regulation under RCRA simply by heating every
    waste to the gaseous state.

                                  19

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                                                 /""\ ~-
                                                    =•  J
     Spent filters and filter aids, and spent dessicants covered



by these listings include any residual materials made out of



paper, cloth, plastic, clay, or other granular or sheet-like




material generated during product, intermediate, or feedstock




purification.  Spent dessicants, including any granular or surface



absorption agents either added to the process stream or through




which the process stream passes, are used for the purpose of water




removal, and may also serve as filter materials.  These spent




filters, filter aids, and dessicants become wastes at the time



of removal from the process equipment.




     Appendix A gives 18 specific flow diagrams for repre-



sentative manufacturing processes of several chlorinated



aliphatic hydrocarbons.  These give specific examples of the




generalized unit processes described above and illustrate




the integration of several unit processes by way of recycling



and/or sequential chemical conversions.




     C.  Waste Generation, Composition and Management



     1.  Current Waste Generation Rate



     Available information in the Section 3007 RCRA Industry



Studies data base indicates that approximately 229 million



pounds (104,000 metric tons) per year of new wastes are covered



by these listings.  The listing of distillation residues, heavy



ends, tars, and reactor clean-out wastes covers 166 million




pounds (75,000 metric tons), and the listing of light ends,



spent filters and filter aids, and dessicant wastes covers 63




million pounds (29,000 metric tons) of new wastes.  Approximately
                                20

-------
                                             A
                                             -
3.3 billion pounds (1,509,000 metric tons) of wastes associated



with these manufacturing process are already regulated under




§261.32, as discussed above.




    2 .  Current Management Practices



     A survey of chlorinated organic chemical manufacturers



through the Section 3007 RCRA Industry Studies Program as well



as sampling and analysis plant visits provided information




on management of wastes from the production of Cj -€5 chlorinated



aliphatic hydrocarbons.  Reported waste management practices




included landfilling and incineration of the wastes covered



by this listing.  Wastewater treatment and disposal in underground




injection wells was practiced for managing wastewaters and



spent acids.  Some waste streams, particularly some specific




heavy and light ends, are recycled.  Commonly incinerated wastes



include heavy ends and light ends.  Incineration, flaring, or



release to the atmosphere of light ends, without either partial



or complete condensation to ambient temperature, is also practiced,



Spent f ilters/dessicants and heavy ends are reported to be



disposed in landfills in some instances.  Table 3 summarizes



waste management practices of the listed wastes currently



employed by the manufacturers of C\-C<^ chlorinated aliphatic



hydrocarbons utilizing free radical catalyzed processes.



     These listings cover the described wastes from all




sources within an integrated process utilizing free radical



catalyzed conversions, whether or not the integrated process
                                21

-------
utilized free radical catalyzed conversions solely or in

conjunction with other types of chemically catalyzed conversions.

This is because there is carry-over of toxic by-products as

well as intrinsically toxic intermediates and products formed

during the free radical catalyzed conversion steps into all

of the wastes from these processes.

    3.  Composition of Wastes as Predicted by Chemical
        Reaction Theory

     Our decision to list these wastes by means of a generic

process, rather than by individual processes, is based on the

similarity of types of chemical reactions and by product

formation within C^-C5 free radical catalyzed chemical

conversion processes.  Thorough discussions of this reaction

theory may be found in standard texts, (7,8) chemical technology

encyclopedias, (4,5) as well as in summaries prepared for

EPA's Office of Solid Waste (3,6).

     These free radical catalyzed reactions are not totally

specific in producing the desired chemical product; thus,

reactor conditions can only be arranged to maximize the

desired products.  Therefore, for any given C-±-C$ process,

a range of by-products will be formed having both higher

and lower carbon atoms and higher and lower amounts of

chlorine substitution.  For example, the thermal free radical

chlorination of ethylene will yield primarily the initial

desired products, ethyl chloride and dichloroethane. However,

-------
polychlorinated C^ compounds and longer carbon chain length



chlorinated compounds and tars are also produced.  The primary




side reactions which are predicted to produce the majority



of waste constituents are free radical initiated polymeriza-




tions, polychlorinations, and dechlorinations, carbon bond




cleavages, and cyclizations (4, 7, 8).  Even when a specific



reactor utilizes relatively mild temperature conditions




(e.g. , a Lewis acid catalyzed reaction) other reactor vessels




within the intergrated process may utilize free radical



reactions.



     Therefore, free radical side reactions (as well as




other types of side reactions) will theoretically lead to



many different chemical species having greater and lesser



carbon chain lengths, different skeletal structures, degree
                              23

-------
        TABLE 3   SUMMARY OF WASTE MANAGEMENT PRACTICES BY MANUFACTURERS OF C1-C5
                  ALIPHATIC HYDROCARBONS UTILIZING FREE RADICAL CATALYZED PROCESSES.


DRAFT




WASTE TYPE

H L
E I
A G
V H
S
P
E
N
Y T T

PRODUCTS E E
N N
D D
S S
**





Carbon Tetrachloride x


Chloromethanes x

Ethyl Chloride x

F
I
L
T
E
R
S




x


X

x
Rthylene Dichloride x
x
Tetrachlorethylene x T n
x
Trichloroethane x
Trichloroethylene x T
Vinylidene Chloride x x
x
Vinyl Chloride x
x
Chlorobutane | x
Allyl Chloride x

Methallyl Chloride x

Trichloropropene

Trichloropropane
Dichloropropene/
Di ch loropropane
Chloroprene

x
X
X
X
X
X
X
X








S
P
E
N
T

D
E
S
S
I
C
A
N
T
S


x







































X































REPORTED MANAGEMENT
PRACTICES
L
A
N
D
F
I
L
L








x
X
X

X


X


X








X









I
N
C
I
n
E
R
A
T
I
0
N




x


x

X
X
X
X
X

X
X

X
X
X

X

X
X
X

X
X
X
X
X
R
E
C
o
V
E
R
Y
/
R
E
U
S
E


x
.

X
X
X
X
X
X
X

X

X

X
X
X





X




X
 *Management practices are shown only for wastes streams included in the C^-K^ chlorinated
  aliphatic hazardous waste listing.   Only those practices actually reported in the RCRA
  Section 3007 Industry Studies data base are shown;  therefore, not all waste types
  associated with each product appear.
**For this table,  "HEAVY ENDS" include all reactor,  fractionation and distillation wastes,
  such as bottoms,  tars, residuals,  clean-out wastes and solvent extraction wastes.

-------
                 . -. _	^ m ~*w*l«4H|
                     ..- 1-J" I
of bond saturation, and degree and position of chlorination.
The fact that tars and heavy ends are formed from these free
radical catalyzed processes demonstrates empirically the
increases in carbon chain length and polychlorinations
leading to high molecular weight viscous materials through
these free radical type side reactions.  Carbon chain cleavage
is also observed as one of these side reactions, and is, in
fact, intentionally employed in some cases to produce, for
example, carbon tetrachloride from higher chain length feed-
stocks.  Differing degrees of chlorination also occur
under many of the processing conditions, and form the basis
for the industrial production of a range of chlorinated
organic products at integrated facilities.  These by-product
constituents will be found in the purification wastes from
these processes; this is the express purpose of purification.
Carry over or retention of what in most cases is a toxic
product into these wastes also typically occurs.
     Reference 3 predicts the different chemical species
which may be formed by competitive side reactions.  The
predicted wide range of by-products will also include the
hazardous constituents for which these wastes are listed.
For example, a two-carbon chain feedstock (e.g., ethylene)
side product will include one carbon chlorinated species
(chloromethane, dichloromethane) as well as chlorinated
coupling products (chlorinated butanes, polychlorinated
polymers, and tars).   An almost infinite number of waste
                              25

-------
                    FEB lo
constituents can be predicted from organic chemical mechanistic

considerations.  These same types of reactions will occur

within any of the processes .for manufacturing Cj_ through 0.5

chlorinated aliphatic hydrocarbons, utilizing free radical

generating conditions.

     The predicted range of hazardous constituents discussed

above has been compared with the actual chemical analyses of

wastes from these processes which were obtained by RPA.  The

aggregate concentrations of hazardous constituents found

during these analyses have been found to be high enough to

substantiate the listing of these wastes as hazardous as

will be discussed in the following sections.*

       4.  Composition Ranges of Waste As Determined by
           Sampling and Chemical Analyses.

     The Agency has obtained representative samples of the

various process residuals comprising the wastes covered by

this listing, including distillation bottoms, reactor clean-out

wastes, spent filters, and other organic residuals.  High

resolution gas chromatography coupled with mass spectrometry

was used to analyze the samples.  Results of the complete

chemical analyses are summarized in these confidential indivi-

dual plant reports.  Company data obtained during the course

of this study and through the examination of hazardous waste
* Permit writers, at a minimum, should consider all the
  toxicants identified in Appendix VII of Part 261 for waste
  numbers F024  and F025 in evaluating their RCRA permit.  In
  addition, permits for the treatment, storage and disposal
  of waste numbers K016, K018, K019, K020, K028, K029, K030,
  K034, K095, and K096 in Part 261.32 should also be evaluated
  for the same toxic constituents identified for waste numbers
  F024 and F025.

                              26

-------
manifests, although usually not as exhaustive as the analyses



obtained under this program, confirm the results of the



current study.




     While a given individual waste stream from a plant




employing a free-radical catalyzed reactor process may




contain lower concentrations of organic constituents as a



result of plant design, compensatorily greater concentrations




will then be in another waste stream.  In other words, plant



design will affect the partitioning of by-products into




various waste streams, including wastewaters and wastewaster



treatment sludges, as well as the listed wastes.  It will not




significantly alter the type and amount of waste constituents



in the listed wastes, to the extent of rendering the listed



wastes non-hazardous.  The Agency's sampling program, as




described in the following section confirms these predictions.



     The Agency also predicted and has confirmed with sampling



data that processes employing only low temperature acid



catalyzed reactor units do not generate the contaminated



wastes found from integrated free radical catalyzed processes.



Consequently, the listing descriptions apply only to wastes



generated by free radical catalyzed integrated processes.



(Phrased another way, this listing does not include those



wastes generated from processes that only use low temperature




acid catalyzed reactor units.)  These listings are intended




to cover the described wastes from all sources within an




integrated process utilizing free radical catalyzed conversions,



whether or not the integrated process utilizes free radical






                              27

-------
                                   FEB lo 1934

catalyzed conversions solely or in conjunction with other

types of chemically catalyzed conversions.  As stated above,

this is because there is carry-over of toxic by-products as

well as intrinsically toxic intermediates and products formed

during the free radical catalyzed conversion steps into all

of the wastes from these processes.

       5.  Hazardous Toxicant Concentrations Determined by
           Sampling and Chemical Analysis

     The Agency sampled representative plants manufacturing

C;L and C2 chlorinated aliphatic hydrocarbons by free radical

catalyzed processes.  Data was obtained for all current

product processes for €3, C^ , and 05 chlorinated aliphatic

hydrocarbon manufacture.  The Agency obtained representative

samples of the various process residuals generated during

the manufacture of C]_-C5 chlorinated aliphatic hydrocarbons.

High resolution gas chromatography coupled with mass spectrometry

was used to analyze the samples.  in addition, many other

company supplied waste analyses were available through the

RCRA Section 3007 Industry Studies data base.  These waste

analyses demonstrate empirically similar high concentrations

of toxicants in the wastes covered by these listings.  Averages

and ranges are reported below for these organic residues

generated from C]_-C5 manufacturing processes in order to

mask the claimed confidential business information.  Although

there were many differences between these wastes, both qualitatively

and quanititatively, in all cases there were one or more of

the toxicants of concern present at levels which could present

a substantial environmental hazard if the wastes are mismanaged.


                              28

-------
     For wastes from the manufacture of GI chlorinated

aliphatic hydrocarbons, wastes were obtained from both a

plant manufacturing methyl chloride by an acid catalyzed process

and from plants manufacturing a range of C^ products (methyl

chloride to carbon tetrachloride)  by a free radical catalyzed

processes.  The aggregate concentration of the toxicants of

concern (listed below) found in the wastes from the free

radical processes ranged from a low of 9 percent to a high

of over 24 percent.  The toxicants found in these wastes are

listed below.

          Dichloromethane
          Trichloromethane
          Carbon tetrachloride
          1 ,'l, 2-Trichloroethane
          Trichloroethylene
          1,I,2, 2-Tetrachloroethane
          1,1,1,2-Tetrachloroethane
          1,1,2,2-Tetrachloroethylene
          Pentachloroethane
          Hexachloroethane
          Dichloropropanes
          Dichloropropenes
          Hexachloro-1,3-butadiene
          Dichlorobenzenes
          1,2,4-Trichlorobenzene
          Hexachlorobenzene

     Low concentrations of toxicants were found in the

wastewaters from the plant using an acid catalyzed substitution

chlorination of methyl alcohol to manufacture methyl chloride, wherein

the process streams were not subject to high free radical generating

temperatures.  Furthermore, no organic distillation residues, heavy

ends, tars, reactor clean-out wastes, and waste light ends were

generated by this process.  As stated above, wastes from this process

which uses no free radical catalysis chemical conversion mechanisms

are not covered by this listing.
                                29

-------
C2 :

     For wastes from the manufacture of C2 chlorinated

aliphatic hydrocarbons, seven samples of distillation bottoms,

heavy ends, tars, and filters were obtained and analyzed

from four different plants manufacturing a range of products.

The  aggregate concentration of the toxicants (listed below)

ranged from 4-97 percent, with an average of 48 percent.

Carbon tetrachloride concentrations were in the percent

range for several samples.  The major toxic constituents in

these wastes were C? chlorinated aliphatic hydrocarbons,

reflecting contamination by the commercial products manufactured

as well as by-products.  Significant higher molecular

weight toxicants were also found in these wastes, such as

hexachlorobutadiene, hexachlorocyclopentadiene, and halogenated

aromatic compounds.  The toxicants found in these C2 chlorinated

aliphatic hydrocarbon manufacturing wastes include:


          Dichloromethane              — —
          Trichloromethane
          Carbon tetrachloride
          1,1-Dichloroethane
          1,2-Dichloroethane
          trans-1,2-Oichloroethylene
          1,1-Dichloroethylene
          1,1,1-Trichloroethane
          1,1,2-Trichloroethane
          Trichloroethylene
          1,1,1,2-Tetrachloroethane
          1,1,2,2-Tetrachloroethane
          1,1,2,2,-Tetrachloroethylene
          Pentachloroethane
          Hexachloroethane
          Dichloropropanes
          Dichloropropenes
          Hexachloro-1,3-butadiene
          Hexachlorocyclopentadiene
          Benzene
          Chlorobenzene
                              30

-------
          Dichlorobenzenes
          1,2,4-Trichlorobenzene
          Tetrachlorobenzene
          Pentachlorobenzene             J~^2 19 <:" "•
          Hexachlorobenzene              ".
          Toluene
          Naphthalene


     A published EPA report (17) provides the  following analysis

for one company's vinyl chloride manufacturing distillation

residue or tar, and illustrates the aggregate  toxic constituent

concentrations found in these wastes:

                                         Percent

        1,2-Dichloroethane                36.0
        1,1,1-Trichloroethane                .4
        1,1,2-Trichloroethane             15.0
        Trichloroethylene                    .2
        1,1,2,2-Tetrachloroethane            .2
        Dichlorobutenes                     1.8
        Dichlorobutane & butadiene           .3
        Chlorobenzene                        .7

     Light ends from the manufacture of vinyl  chloride monomer

also exhibit  a range of hazardous toxicants  in significant

concentrations.  Confidential information from vinyl chloride

manufacturing facilities responding to the  RCRA Section 3007

data base indicates vinyl chloride concentrations ranging

from 1% to greater than 50% in light ends.   1,2-Dichloroethane

was reported  in the 10-50% range, and chloroform  in the

1-50% range where organic contaminants were  specifically

identified.  Other toxicants of concern were in concentrations

from 100 parts per million to 50%, including those listed

below:

          Chloroform
          Carbon tetrachloride
          Vinyl chloride
          lf1-Dichloroethane
          1,2-Dichloroethane

                              31

-------
          1,1-Dichloroethylene
          trans-l,2-Dichloroethylene
          1,1,2-Trichloroethane
          Trichloroethylene
          1,1,1, 2-Tetrachlo'roethane
          3 -Chi or op rope ne
          Chloroprene
     From the manufacture of €3 chlorinated aliphatic

hydrocarbons, waste analyses were obtained from plants

manufacturing dichloropropanes/dichloropropenes and tri-

chloropropenes .  The aggregate concentration of the toxicants

of concern (listed below) in the wastes ranged from 0.7

percent (7000 ppm) to 48 percent.  Significantly high concen-

trations of dichloromethane were found in some waste samples,

as well as polychlorinated 03 compounds, benzene, toluene,

chlorinated aromatics and polychlorinated higher molecular

weight compounds, including the toxicants listed below:

          Dichloromethane
          1,1, 1-Trichloroe thane
          1,1,2 ,2-Tetrachloroethylene
          He xachloroe thane
          3-Chloropropene
          Dichloropropanes
          Dichloropropenes
          Hexachlorocyclohexanes
          He xachloro-1, 3- butadiene
          Benzene
          Dichloro benzenes
          1,2, 4 -Trichloro benzene
          Tetrachlorobenzene
          Pentachlorobenzene
          Hexachlorobenzene
          Toluene

     Additional information obtained through the RCRA Section

3007 industry Studies Questionnaire (20) confirms the Agency

sampling analysis results for heavy and light ends from

chlorinated propane and propene manufacture, as well as
                              32

-------
providing additional confirmatory information on reactor

clean out wastes and spent dessicants.  A published study

(17) gives three analyses of organic residuals from the

manufacture of chlorinated propanes and propenes at a

Shell Oil plant, which are given in Table 4.  Information

in the RCRA Section 3007 data base information for the

production of trichloropropanes (and epichlorohydrin

simultaneously) by way of allyl chloride as an intermediate

revealed aggregate toxicant concentrations ranging from 0.1

percent (1000 ppm) to 80 percent.  The toxicants present in

significant concentrations included:
                chloride
          Epichlorohydrin
          Dichloropropane
          Dichloropropene
          Benzene
C4
     From the manufacture of C4 chlorinated aliphatic

hydrocarbons, representative analyses were obtained for four

different product/process types from four different plants.

Aggregate concentrations of the toxicants of concern listed

below ranged from several hundred parts per million to nearly

100%.  The average aggregate concentration of the listed

hazardous constituents for the 13 samples obtained from

these four plants was 18 percent.  Concentrations of dichloro-

methane were in the 0.1 to 1 percent (1000 - 10,000 ppm) range

in several samples.  In addition, chloroform was found in

concentrations of one to several hundred parts per million

in the wastes from 3 plants.

          Dichlorome thane
          Trichlorome thane
          Carbon tetrachloride

                              33

-------
TARLE 4.  Published Analyses of One Plant's Chlorinated Propane
          Manufacturing Organic Residuals
                                                                           ~

Constituent (%):
dichlorome thane and
isopropyl alcohol
chloroform, acetonitrile
and dichloropropene
ethyl chloride and
2-chloropropanes/propenes
1, 1-dichloroethane
1 , 2-dichloroethane
ch loropropane
ch loropropene
chloroallyl alcohol
chlorodihydroxypropanes
d ich loropropanes
d i ch loropropenes
d ich loropropanols
tr ich loropropanes
t r i ch loropropene s
epichlorohydrin
tetrachloropropyl ethers


still
Bottoms (%)
- -
- -
- -
_ _
_ _
— 	
0.3
_ _,
— —
17. 0
31.5
_ _
4.0
4.0
— —
_ _

I
Heavy
Ends (%)
	
_ _
_ -
— _
_ •
^ ^
«. H
0.5
0.2
_ _
0.1
10.7
70.0
_ _
2.0
14.0

:EB 10 :9M
Light
Ends (%)
0.7
4.0
17.0
4.0
0.2
22.0
18.0
_ _
0.2
12.0
14.4
0.2
_ _
_ __
0.4
_ _

benzene
                                0.2
0.7
                                            34

-------
          1,1-Dichloroethane             ;-£3 10 T334
          1,2-Dichloroethane
          trans-1,2-Dichloroethylene
          1,1,1-Trichloroethane
          1,1,2-Trichloroethane
          Trichloroethylene
          1,1,2,2-Tetrachloroethane
          1,1,2,2-Tetrachloroethylene
          Hexachloroethane
          Dichloropropanes
          Dichloropropenes
          Chloroprene
          Benzene
          Chlorobenzene
          Toluene
          Napthalene

     The organic residuals from the one €4 plant sampled

which utilized a low temperature acid catalyzed process were

found to contain substantially lower amounts and concentrations

of specific toxicants in the by-products as compared to

other €4 processes utilizing free radical catalyzed chemical

conversions.  As discussed earlier, wastes from this process

would not be covered "by ttiis~ trstingr


C5:

     For €5 chlorinated aliphatic hydrocarbon manufacture,

samples of representative wastes were not available because

no plant currently manufactures a commercial product of this

class.  An existing patent (18) for the purification of crude

hexachlorocyclopentadiene contains information that organic

waste residues from this and any other €5 chlorinated aliphatic

hydrocarbon manufacturing process will also contain the same

wide range of chlorinated by-products as found in C^ - C^

wastes.  The distillation bottoms from the first step in the


                              35

-------
                                             10 i
purification procedure was reported to contain 100 parts per

million hexachlorobutadiene, 4.24% octachlorocyclopentene,

and 95.74% hexachlorocyclopentadiene.  The distillation overhead,

from which light ends would be condensed, was described as

containing 2.6% perchloroethylene, in which other by-products

were undoubtedly present but not identified by the analytical

procedure used.

III.  DISCUSSION OF BASIS FOR LISTING

A.  Migration, Mobility and Persistence of the Listed Waste
    and Waste Constituents, and Potential for Mismanagement

1.  Predicted Migration, Mobility, and Persistence

     For the constituents of concern contained in these

wastes, predictions may be made as to their potential for

reaching human or environmental receptors to produce adverse

affects based on chemical, physical, and biological considerations.

A constituent of concern must first be capable of migration

from the waste itself, such as by volatilization to the atmosphere

or extraction by leachate present in a land disposal facility.

Next, the constituent must be mobile; it must be able to travel

through the environment to contaminate either groundwater, surface

water, soil, or the air.  After a constituent has migrated

from the waste and achieved this prerequisite mobility in

the environment, it must persist for a sufficient time for

exposure to occur and not be degraded by hydrolysis, photolysis,

or biodegradation.  The predictions discussed in this section

are based on physical/chemical properties of the compounds,

and are augmented by actual empirical evidence of migration,

mobility, and persistence.

-------
                                  fES 3 0 190.^
     One possible path of environmental exposure to the hazardous

constituents in these wastes is from release of unburned toxicants

to the atmosphere as a consequence of improper incineration.

This could be a result from insufficiently high combustion

temperature, too short a dwell time or an inappropriate feed

rate.  Emissions could result in release of the toxicants

themselves, and additionally, products of incomplete combustion

(including hydrochloric acid and phosgene).

     Possible paths to soil, groundwater, and surface water

contamination include leaching after disposal in unlined or

inadequately lined land disposal facilities, spillage, or

runoff from surface impoundments.  In addition to simple

percolation of the waste itself through the soil, there is

the possibility of enhanced migration and mobility by co-disposal

of wastes with solvents, especially in landfills which accept

a variety of industrial wastes.

     Most of these toxicants are capable of migrating from

the wastes via leaching action and of persisting in the

environment in concentrations sufficient to cause substanitial

harm to environmental receptors.  The water solubilities of

the hazardous constituents of concern (Appendix C) are in

all cases several orders of magnitude greater than the corresponding

levels recommended in the Ambient Water Quality Criteria

(16) for protection of human health (see Table 5 in Section

II.B.).
                              37

-------
Thus, only small fraction of the toxicants present in these



wastes need migrate and reach environmental receptors to pose




the potential for substantial harm if these wastes are




land disposed improperly.



2.  Actual Mobility and Persistence of Specific Constituents




     The constituents of concern in the listed wastes have



been shown in many studies to have migratory potential and




the ability to persist in harmful concentrations after




migrating from waste matrices.  In one study, New Jersey



groundwater was contaminated with 20 of the chlorinated




hydrocarbon constituents of concern (10).  This study analyzed



samples from over 1000 different wells throughout New Jersey




and samples of surface water collected from over 600 different




sites.  Concentrations in both the ground and surface waters




were found to be similar, with the high concentrations of



the chlorinated compounds ranging from several parts per



billion to over 1 percent.




     Many studies demonstrate that the constituents of concern



are likely to persist in the environment and are quite capable



of migration via ground water and surface water pathways.



Specific damage incidents compiled by the EPA provide the



most comprehensive evidence available of persistence and



adequate potential for migration of several of the chlorinated




organic constituents of concern (and therefore, by inference



from their chemical similarity, to the others).  In many




instances, hazardous concentrations have been found in ground
                              38

-------
                                            FEE -
                                            ' uu - '< ' _• :-t
water, drinking water wells, and soil years after a typical

industrial disposal incident, such as landfarming, burial,


or treatment in unlined lagoons.  In addition,  these  incidents

demonstrate clearly that these wastes have the  potential to

cause sufficient harm if mismanaged.


3.  Actual Damage Cases Illustrating Environmental
    Behavior of Wastes and Potential for Mismanagement

     As stated, examples of improper management which could

realistically occur include disposal in unlined or inadequately


lined land disposal facilities, which could lead to contamination

of groundwater, surface water, and soil.  Improper incineration

could also lead to exposure to unburned toxicants in  the

wastes, and also could lead to exposure to products of

incomplete combustion, including phosgene and hydrochloric

acid.  These predictions of substantial harm all have occurred

in actual management of these wastes.


      The Agency has documented numerous damage incidents which

relate to mismanagement of wastes from the manufacture of

chlorinated aliphatic hydrocarbons or to wastes which contain

the toxicants of concern, resulting in surface  and ground-water

contamination, and contamination of soil and air as well.

These damage incidents illustrate two bases for this  listing.

First, they provide empirical evidence that the constituents

of concern have migratory potential and the ability to persist

in harmful concentrations after migrating from waste matrices.


Second, they provide proof that these wastes are capable of

substantial harm to human health and the environment  if

mismanaged, the statutory standard for determining if wastes

are hazardous.


                              39

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                                                    RE:  WCBCJ0503
     The capability of specific chlorinated aliphatic and




aromatic hydrocarbons which are constituents of concern for



these wastes to persist in the environment for an adequate




length of time to cause harmful effects  is shown _a priori by



every damage incident involving these substances.  Appendix




C contains a compilation of representative cases from EPA



Regional Office files.




     The ability of the constituents of concern to migrate




from the wastes is obvious when the wastes are fluid.  However,




in many instances these wastes are in the form of tars or



sludges, and elution of hazardous constituents from a solid




or semi-solid waste must first take place.  Most of the



damage incident files do not contain adequate information to



ascertain if the contaminants causing the damage originated




from liquid wastes, from tarry residues or sludges or, as is



probably the case, a combination of all of these.  In addition




to the inherent hazards of these wastes, co-disposal of



these wastes with solvents, especially in the incidents of



landfill operations, could lead to increased hazards through



solubil ization and greater migration.  Incident Mos. 4, 7,



72, 82, 90, 91 and 95 (in Appendix C) were the result of



waste residues from the manufacture of vinyl chloride and



polyvinyl chloride, and can be assumed to be typical tarry



wastes from which the vinyl chloride migrated by elution.



Incident No. 72 shows air contamination by vinyl chloride




from vinyl chloride manufacturing wastes (another exposure
                              40

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                         DRAFT
                          FEB 1 0 T93-J
pathway),  which were presumably tary or  viscous  in  nature.
Examples of migration of  chlorinated organic  consitituents
from wastes which were described as sludges  include Incident
Nos. 6, 30, 52, 58,  71, and  82.  Distillation bottom wastes
from solvent recovery operations are usually  tarry materials,
and might be expected to  be  similar to the distillation
residues generated during the manufacture of  these  solvents.
Incident Nos. 1, 25, and  29  represent environmental contamination
by solvent recovery distillation residues which  resulted  in
hazardous chlorinated constitutents migrating from  a viscous
solvent recovery waste.  Thus,  the constituents  of  concern
have proven capable of migration from non-aqueous waste
matrices when land disposed.
     The potential for substantial environmental harm  from
mismanagement of the listed  wastes by the chlorinated  organic
chemical manufacturing industry is shown by  the  many historical
examples of inappropriate disposal practices  or  inappropriate
treatment techniques, which  led to damage which, in many  cases,
was extensive.  These incidents demonstrate  clearly that  the
wastes meet the statutory definition of  a hazardous waste.
Several incidents in Appendix C are briefly  described  which
relate directly to the wastes from manufacture of C^-Cc;
chlorinated aliphatic organic compounds  and  also to wastes
containing the same toxicants of concern.  These incidents
demonstrate clearly what  could  result if these wastes  are
not controlled by RCRA.  These  are described  below:
                              41

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                  DRAFT
     A major chemical manufacturer of  vinyl  chloride deposited




residues in open catch basins  in  sandy soil,  resulting  in the



contamination of 14  wells (Incident No.  4).   Polyvinyl  chloride




skins and emulsions  from another  major chemical company were




deposited in a non-secure landfill,  which  has resulted  in



the ground water contamination (Incident No.  7).  Several




chlorinated aliphatic and aromatic constituents have migrated




in hazardous levels  from a non-secure  landfill used by  a



manufacturer of these chemicals (Incident  No.  8).




     Another abandoned landfill used by this  same company is




still causing environmental and human  health  effects from



toxic chlorinated and other organic chemicals (Incident No. 9).




This company also deposited 70,400 tons of hazardous materials




at another site, resulting in  the contamination of the  public



water supply by tetrachloroethylene and benzene hexachloride




(Incident No. 10).



     A previous manufacturer of chlorinated  benzenes used an



unlined lagoon for waste treatment,  resulting in contamination



of ground water and  the public water supply  with chlorinated



organic chemicals (Incident No. 28).   A manufacturer of



trichloroethylene and perchloroethylene discharged 500




tons per year of wastes to waterways or allowed wastes  to



settle in on-site pits, resulting in soil  and ground water




contamination.  This same company stored wastes insecurely




in drums and railroad tank cars,  creating  a  risk of additional




contamination on-site (Incident No.  68).
                              42

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     A manufacturer of vinyl chloride sent its wastes to a
private hazardous waste facility which used unlined excavations,
resulting in documented air contamination of vinyl chloride.
Another major chemical company discarded 5,100 tons of
vinyl chloride production wastes at a private landfill resulting
in the contamination of ground water and a nearby drinking water
well with vinyl chloride, dichloroethane, trichloroethylene,
and other hazardous chlorinated compounds (Incident No. 90).
     Ground water was contaminated with vinyl chloride, chloro-
form, and chlorobenzene by a major chemical manufacturer
making vinyl chloride intermediate, polyvinyl chloride, and
other chemicals as a result of using non-secure waste lagoons
and landfills (Incident No. 91).  Soil, surface and ground
water contamination by vinyl chloride, dichloroethane and
trichloroethylene took place at another major vinyl chloride/	
polyvinyl chloride manufacturing plant (Incident No. 95).
Confirmed soil contamination from drummed wastes occurred
at the site of a manufacturer of what was described as a
wide range of chlorinated and brominated organic chemcials
(Incident No. 99).
     Incident No. 114 describes vinyl chloride contamination
of drinking water in a plant adjacent to an active landfill
which accepted polyvinyl chloride manufacturing wastes.
Drinking wells were contaminated with vinyl chloride from
anothr vinyl chloride manufacturing site (Incident No. 116).
     Thus, environmental releases of chemicals from buried
drums of chemical manufacturing wastes have been demonstrated
numerous times.  Improper management of these wastes in
                              43

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                     DRAFT
surface impoundments--r--another recurring  management practice—




likewise has caused substantial  harm.  The  use  of unlined




holding ponds, lagoons,  or other surface impoundments may,




and historically have,  resulted  in  significant  contaminations



of groud water and subsequently  contamination of drinking




water sources or surface waters.



     Incident Nos. 4,  6, 11,  26, 27,  28, 29, 31, 42, 52, 53,




58, 59, 62, 64, 66, 68,  70,  75,  78,  81,  82,  84, 87, 88, 91,




94, 103, and 105 describe environmental  contamination of



ground water by the chlorinated  constituents of concern from-



inadequately managed waste treatment lagoons and storage




ponds.  (Other ground  water contamination incidents are



assumed to arise in large part from unlined  or  inadequately




contained surface impoundments.)




     The chemical similarity of  other chlorinated toxicants



which were either not  present or not detected by the analytical



method imployed in these damage  incidents,  makes intuitive




predictions of similar behavior  in  the environment reasonable.



Therefore these compounds are all likely to be  mobile and



persist under most typical environmental release situations.



     Air releases of hazardous chemicals from  the improper



handling of these wastes is also possible,  such as from fires



or explosions, as in Incident Nos.  46, 79,-and  112.  Again,




co-disposal of other wastes or solvents  can  enhance the



hazard of harmful releases of these wastes  by providing



mechanisms for heating from fires or explosions.  Midnight




dumping (Incident No.  54) at another site contaminated with
                              &.&.

-------
                     DRAFT
                     (r£B 10 V^4





chlorinated organic chemicals  lead  to  resident  complaints of




nasal/throat symptoms.



     Incident No.  57 describes evaporation  of solvents, some



of which would probably be chlorinated and  are  constituents




of concern in the  wastes at issue  here.   Another waste  treat-



ment facility (Incident No. 62)  used a lagoon to evaporate




volatile wastes.   Vinyl chloride and other  hazardous organic




compounds were present  in ground water from this lagoon source



and therefore could be  assumed to  be in part the substances




which were being  evaporated and released to the air.




     Vinyl chloride was measured in air at  another  facility



using unlined excavation pits  (Incident No. 72).  A municipal




landfill with associated chlorinated organic ground water




contamination had  high  but unidentified air concentrations



of organic compounds (Incident No.  86).   Three  other municipal




landfill facilities had documented  vent releases of hazardous



chlorinated aliphatic constituents  (Incidents Nos.  101, 102,



103).  In addition, Incident No. 102 describes  vinyl chloride



being detected in  the air of a school  as a  result of the



landfill operation.



     Chlorinated  organic compounds were found  in the urine of



workers at a municipal  waste treatment facility as  a result




of industrial discharges (Incident No. 19), again demonstrating



the potential for  significant  air  releases  from wastes




containing the constituents of concern.  Also,  because  most




of the damage incidents are the result of historical improper
                               45

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                  DRAF
waste disposal, many more undocumented  air releases  could  be



assumed to have occurred.




     Incident Nos. 1, 2,  21,  25,  49,  50,  51,  92,  and 96  describe



waste incineration sites  where wastes containing  the toxicants



of concern was accompanied by poor waste  handling and storage




procedures, resulting in  ground water contamination.




B.  Hazardous Properties  of the Wastes



     The Agency considered many factors in making a  judgement




as to whether the concentration levels  of the toxicants  of




concern found in these wastes pose a  significant  hazard  to,



human health or the environment.   One comparison  is  with the




levels found in these wastes  and Agency derived  risk assessments



for water contaminated with individual  toxicants, the Ambient



Water Quality Criteria Levels (AWQCL) (16).  The  Agency  has




calculated the increased  risk to human  health (carcinogenicity




or other irreversible systemic toxic  effects) or  aquatic organisms



as a result of a lifetime ingestion of  water  and  aquatic organisms




(fish, etc.) living in such water contaminated at levels above



the AWQCL.  (See Table 5).  The Agency  has considered evidence



of the potential for the  toxicants of concern in  these wastes to



either contaminate ambient waters at  these levels or to  reach




humans through direct contact or other  routes at  these levels.



     Second, the Agency has taken into  consideration that the




AWQCL were developed considering the  adverse  effect  of individual




toxicants acting singly.   Both theoretical predictions and data



obtained by the Agency show that these  wastes are complex mixtures




of many hazardous constituents.




                               46

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                 DRAF1
                   B 10 1934
The probability of aggregate toxic  effects,  whether  additive

or synergistic, must  be judged  probable.   An AWQCL risk  level

for a single hazardous constituent  found  in  these wastes

is therefore not likely to be adequately  protective.

     The hazardous constituents of  concern generally are

present in these wastes in concentrations many  orders of

magnitude above the levels which are  related to increased

health risks.   In all cases, the solubilities of the toxicants

of concern (Appendix  C) are many orders of magnitude greater

than the Ambient Water Quality  Criteria Levels.  Thus, only

a small fraction of the toxicants present in these wastes

need migrate and reach environmental  receptors  to pose the

potential for substantial harm.  As shown in the previous

section, this potential for harm actually has occurred many

times, demonstrating  the hazardous  character of these wastes

and waste constituents.  Furthermore,  these  wastes contain

many complex polychlorinated compounds for which there is

less definitive toxicological data.  These chlorinated hydrocarbons

share many structural features  of those which have been

studied, almost all of which exhibit  significant chronic

systemic effects of concern (viz. CNS, liver and kidney

toxicity), and a high proportion of which are proven carcinogens.

We do not know what additional  expansion  of  the toxicological

data base will occur  in the future  for these waste constituents.

The structural similarity between these compounds and those

for which adequate informa tion is  available gives rise  to

concern.

                               47

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                        DRAFT
TABLE 5.   AMBIENT WATER QUALITY CRITERIA LEVELS  FOR  CONSTITUENTS
          OF  CONCERN  (Ref. 16)
Cancer Risk  Level:
Other Chronic
Health Risk Level
Lowest Aquatic
Organism Adverse
Effect Level:
Concentration  calculated to pose a 1 per
million increased  risk of cancer as a result
of ingestion of  contaminated water and organisms
living in that water.

Concentration  calculated to increase the risk
of other chronic health effects as a result of
ingestion of contaminated water and organisms
living in that water.

Lowest levels  found  to be chronically or acutely
toxic to aquatic organisms.
Constituent
Chloromethane *
Drchlorome-tharre *-
(methylene chloride)
Trichlorome thane
( chloroform)
Carbon tetrachloride
Vinyl chloride
HUMAN HEALTH EFFECTS
Cancer Risk
Level
(mg/1 or ppm)
0.00019 *
0.00019 *
0.00019
0.0004
0.002
Other Chronic
Health Risk
Level
(mg/1 or ppm)












AQUATIC LIFE
Lowest
Organ!
Level
(mg/1
Aquat
sm Efi
or ppn
11.0
11.0
1.24
35.2

                                   49

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Constituent
DRAFT
• * .~<- -j z> -.-.,. j
1 , 2-Dichloroethane^
trans-1, 2-Dichloroethy lene
If 1-Dichloroethy lene
1,1, 1 -Tr i ch lor oe thane
1,1, 2-Trichloroethane
Tr ich lor oe thy lene
1,1,1, 2-Tetrachloroethane
1,1,2, 2-Tetrachloroethane
1,1,2,2 Tetrachloroethy lene
(perchloroethy lene )
Pen tachloroe thane
HUMAN HEALTH EFFECTS
Cancer Risk
Level
(mg/1 or ppm)
0.00094

0.00003

0.0006
0. 0027

0.00017
0.0008

Other
Chronic
Health Risk
Level
(mg/1 or ppm)

i

18.4


i


£












AQUATIC LIFE
Lowest Aquat
Organism Adv
Effect Level
(mg/1 or ppm
113.0
11.0
11.0

18.0
2.0
9.320
2.40
0.450
0.390
50

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DRAFT
•PEB Ifl 1&J4
Constituent
He xach lor oe thane
Dichloropropane
Dichloropropene
Hexachloro-1 , 3 -butadiene
Hexachlorocylopentadiene
Hexachlorocyclohexane
technical grade
alpha isomer
beta isomer
gamma isomer
Benzene
Chlorobenzene
Dichlorobenzenes
1,2, 4 -Tri Chlorobenzene
Tetra chlorobenzene
Pentachlorobenzene
Hexachlorobenzene
HUMAN HEALTH EFFECTS
Cancer Risk
Level
(mg/1 or ppm)
0.0019


0.00045

5.2 x 10~5
2.2 x 10~5
1.3 x 10~4
1. 9 x 10-4
0.00066





7.2 x 10~7
Other Chronic
Health Risk
Level
(mg/1 or ppm)

i
0.087

.206 (0.001 -
organolept ic


0.488 (0.20
organoleptic )
0.400
i
0.038
0.074

AQUATIC LIE
Lowest Aqua
Organism Ac
Effect Leve
(mg/1 or pp
0.540
3.04
0.79
0.0093
0.0052
0.00008
( lindane , f re
water )
0.00016
(lindane, sa
water }
0.700
0.050
0.763
0.05
0.05
0.05
0.05
          51

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         DRAFT
     X
Constituent
Toluene
HUMAN HEALTH EFFECTS
Cancer Risk
Leve 1
(mg/1 or ppm)

Ethy Ibenzene
Naphthalene
Polychlorinated Biphenyls

7.9 x 1CT7
Other Chronic
Health Risk
Level
(mg/1 or ppm)
14.3
1.4
i

AQUATIC LIF
Lowest Aqua
Organism Ad
Effect Leve
(mg/1 or pp
5.0
0.430
0.620
1.4 x 10~5
(fresh)
3.0 x 10~5
(salt)
* Ambient Water Ouality Criteria  are currently being revised and
  updated for chlororaethane and dichloromethane

i Insufficient evidence was available to establish a human health
  effect Ambient Water Ouality Criterion recommendation
                               52

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  DRAFT
    -Zu 10 1334



     Not only are these complex chlorinated  substances



suspected of having adverse  rather  than  beneficial effects



on living organisms, but they may also have  the  potential to




break down in the environment to other compounds with greater




toxicity, through biological degradation pathways  in soil or



groundwater or as a result of improper incineration.




     Other factors considered in addition to the inherent




toxicity of these wastes were presented  in the preceding



sections, and include the large aggregate volume of  the




wastes,  current methods of disposal,  exposure potential as a



result of the mobility and persistence of the constituents,




and actual damage cases resulting from mismanagement of these




and similar wastes.




C.  Hazardous Properties of  the Constituents of  Concern




     The following discussion summarizes the toxicological




effects for individual hazardous constituents.   As discussed




earlier, the most common constituents found  or predicted  to



be present in these wastes are chlorinated hydrocarbons.



Typical concentrations of these constituents of  concern were



presented in the preceding section.   Additional  consideration



must be given to the composite toxicity  of these wastes.



Comparison of toxicity of individual  of  individual waste



constitutents is likely to understate the toxicity of these




wastes.   This is because these wastes are complex  mixtures




of many hazardous waste constituents. Individual  constituents



could be predicted to have at least additive, if not synergistic
                               53

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DRAFT
     10 ij;.,
effects, especially if the same organ system or ultimate


systemic effect (e.g., carcinogenicity)  is involved.


     Pertinent mammalian adverse health  effects of  some  individual


constituents of concern are dicussed briefly below.   Additional


information on each constituent is contained in Appendix  A -


Health and Environmental Effects Profiles of RCRA Subtitle C -


Identification and Listing of Hazardous  Waste.   In  addition,


two new toxicants have been added to Appendix VIII  -  Hazardous


Constituents, as reasons for listing hazardous  wastes.  Thus,


two new Health and Environmental Effects Profiles were prepared


to support this listing, for 3-chloropropene and 2-chloro-


1,3-butadiene, and are summarized in the preceding  discussion.


     Many of these toxicants of concern  have been determined


by the Agency's Carcinogen Assessment Group (CAG) to  be


potential human carcinogens, and are so  indicated.  The weight


of evidence for carcinogenicity varies.   Some of the  chemicals


have human evidence (epidemiology data)  while others  have


only animal evidence.   Depending on the  amount  and  quality of


the data the evidence could be classified as limited  or


sufficient using criteria developed by the International  Agency


for Research on Cancer.


Chloromethane (Methyl Chloride)


     Chloromethane is acutely toxic to human beings by  its action


on the central nervous system, causing loss of  coordination,


blurring vision, mental confusion, nausea and vomiting.   In both


humans and experimental animals, central nervous system
                               54

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 DRAFT
effects appear to be the most sensitive  indicator  of  subchronic



chloromethane toxicity.   Information  is  not  available on chronic




toxicity, teratogenicity,  or carcinogenicity.   Chloromethane




was highly mutagenic in  the Ames  test.




Dichloromethane (Methylene Chloride)




     Dichloromethane is  a central nervous  system depressant




resulting in narcosis at high concentrations.   Dichloromethane




is metabolized to carbon monoxide and  causes an increase in




carboxyhemoglobin.   Thus,  exposure poses a special risk toi




persons with cardiovascular problems.




     The National Cancer Institute has completed evaluation




of a two year gavage bioassay in  rats  and  mice  (an inhalation



study is in progress).  The draft summary  of this  study notes




that dichloromethane was carcinogenic  for  both male and female




B6C3F2 mice, including hepatocellular  carcinomas in both sexes.



Thyroid C-cell carcinomas in male rats and leukemia and



aveolar/bronchial adenomas in female mice  may have been




associated with the administration of  dichloromethane (19).



Other studies have  indicated carcinogenicity of dichloromethane



in Strain A mice; i.p.,  administration resulted in a  significant



increase in lung adenomas.  Dow Chemical Company's two year



oncogenicity inhalation  study showed  statistically significant



increase in salivary gland sarcomas in Sprague-Dawley rats




(3500 ppm) and benign mammary tumors  in  male and female rats.




     In two studies, dichloromethane was not teratogenic for



experimental animals, but positive results have been  obtained
                                55

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 FEB 1
in mutagenicity screening assays and at the lowest dose



tested in the Strain A mouse pulmonary adenoma assay.




Trichloromethane (Chloroform)



     U.S. EPA's CAG has determined that trichloromethane




(chloroform) is a potential human carcinogen.  Chloroform




has been found to induce hepatocellular carcinomas in mice



and kidney epithelial tumors in rats.  Hepatomas have also




been induced in mice.  Bacterial assays involving chloroform




have yielded no mutagenic effects.  Chloroform has produced



teratogenic effects when administered to pregnant rats.   ' '




Carbon tetrachloride




     U.S. EPA's CAG has determined that carbon tetrachloride



is a potential human carcinogen.  Toxicological data for




non-human mammals are extensive and show that it causes



liver and kidney damage, changes in liver function, and



neurological damage.  Mutagenic effects have not been observed




and teratogenic effects have not been conclusively demonstrated.



Vinyl chloride



     U.S. EPA's CAG has determined that vinyl chloride is a



potential human carcinogen.  Vinyl chloride has been found



to be carcinogenic in laboratory animals and has caused



angiosarcoma in humans.  "Vinyl chloride disease", a multisystem



disorder, has been described in workers exposed to vinyl




chloride.



1,1-Dichloroethane




     There is no available evidence to indicate that 1,1-




dichloroethane is carcinogenic, mutagenic, or teratogenic.




                              56

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     In
DRAF
 Symptoms produced by human poisoning with 1,1-dichloro-

 ethane  include respiratory tract irritation, central nervous

 system  depression, and cardiac effects.  Animal studies also

 indicate that 1,1-dichloroethane may produce liver damage.

 1,2-Dichloroethane (Ethylene dichloride)

      U.S. EPA1s CAG has determined that 1,2-dichloroethane

 is a potential human carcinogen.  Results of an NCI carci-

 nogenesis bioassay in rats and mice have shown that 1,2-dichloroethar

 may produce a wide variety of tumors, including squamous

 cell carcinomas, hemangiosarcomas, mammary adenocarcinomas,

 and hepatocelluar carcinomas.  Mutagenic effects have been

 shown in the Ames Salmonella system and E_.  coli;  metabolites

 of 1,2-dichloroethane have also shown mutagenic effects in

 the Ames assay.

      One study failed to indicate teratogenic effects following

 inhalation exposure to 1,2-dichloroethane; however reproductive

 toxicity was demonstrated.  Chronic human exposure to 1,2-

 dichloroethane has produced neurological symptoms and liver

 damage.  Poisoning victims have shown diffuse dystrophic

 changes in the brain and spinal cord.

 1,1-Dichloroethylene (Vinylidene chloride) and Cis- and
 Trans-1,2-Dichloroethylene

      Most of the health effects information available is

 related to the 1,1-dichloroethylene isomer.  Of the three

 isomers, 1,1-dichloroethylene is the most toxic.  Qualitatively

 the toxicity of the cis and trans-1,2-dichloroethylene isomers

 appears to be similar, with depression of the central nervous


                               57

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     .:AFT
     ^0 IS34
system and liver and kidney damage.   Both 1,1-dichloroethylene
and trans-1,2-dichloroethylene are mutagenic  in bacterial
systems.  U.S. EPA's CAG has determined that  1,1-dichloroethylene
is a potential human carcinogen.   Both kidney adenocarcinomas
and mammary adenocarcinomas were  produced in  mice  after
exposure to 1,1-dichloroethylene  by inhalation.
     The primary effect of acute  and chronic  occupational
exposure to 1,1-dichloroethylene  is depression  of  the  central
nervous system.  In experimental  animals, both  liver and
kidney damage have been noted after exposure, regardless  af-
the route of  administration.  1,1-Dichloroethylene has been
shown to be a mutagen in bacterial systems.
1,1,2-Trichloroethane
     U.S. EPA's CAG has determined that 1,1,2-trichloroethane
is a potential human carcinogen.   It has been shown to produce
tumors in experimental animal studies conducted by the National
Cancer Institute.   Symptoms produced by toxic exposure to
the chloroethanes  include central nervous system disorders,
liver and kidney damage, and cardiac effects.
1,1,1-Trichloroethane
     Results  of an National Cancer Institute  (NCI)  carcinogenesis
bioassay have indicated that oral administration of 1,1,1-
trichloroethane produced a variety of neoplasms.  However,
re-testing of this compound is in progress  since a high
incidence of  premature deaths was observed  in this initial
study.  There is no evidence to indicate that 1,1,1-trichloro-
ethane has mutagenic or teratogenic activity.
                              58

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     DRAFT
     Human toxic effects seen  after exposure  to  1,1,1-




trichloroethane include central  nervous  system disorders.



Animal studies indicate that toxic  effects  may be  produced  in




the central nervous system,  pulmonary  system, heart,  kidney,



and liver.



Trichloroethylene




     U.S. EPA1s CAG has determined  that  trichloroethylene




is a potential human carcinogen.  Trichloroethylene has not



been shown to be a teratogen.   Data suggesting mutagenicity



and carcinogenic!ty have been  complicated by  the presence of




contaminants with known carcinogenic and mutagenic activity.



Both acute and chronic exposure  to  high  levels of  trichloroethylene



produce central nervous system depression and other neurological




effects.  Trichloroethylene  also causes  some  kidney and



liver damage.




1,1,1,2-Tetrachloroethane




     Animal experiments indicate that  chronic exposure to




1,1,1,2-tetrachloroethane may  produce  liver damage.   1,1,1,2-



Tetrachloroethane is currently being tested by the




National Cancer Insitute for possible  carcinogenicity.  The



compound was reported to be  non-mutagenic in  the Ames assay.




Other data indicates that 1,1,1,2-tetrachloroethane is embryotoxic.



1,1,2 ,2-Tetrachloroethane




     U.S. EPA's CAG has determined  that  1,1,2,2-tetrachloroethane




is a potential human carcinogen.  An increased incidence of



hepatocellular carcinomas occurs in mice following oral




administration of 1,1,2,2-tetrachloroethane.  Mutagenic

-------
   DRAFT
effects have been reported  in  the  Ames  Salmonella assay and



in _E. co 1 i.   There is no available evidence  to  indicate that




1,1,2,2-tetrachloroethane produces teratogenic  effects.




Occupational exposure to 1,1,2,2-tetrachloroethane has



produced several toxic effects  including  neurological symptoms,




liver and kidney damage, pulmonary edema,  and fatty degeneration




of heart muscle.




Tetrachloroethylene (Perchloroethylene)




     U.S. EPA's CAG has determined that  tetrachloroethylene




is a potential human carcinogen.   Tetrachloroethylene has



caused  mild  intoxication and  liver dysfunction  following




chronic exposure to high levels  in human  beings.  Tetrachloro-



ethylene has not been shown  to  be  teratogenic,  but it was



mutagenic in bacterial assays.




Pentachloroethane



     Pentachloroethane was  carcinogenic  in mice, giving rise to




hepatocellular carcinomas,  in  a  study  conducted by the National



Toxicology Program (9).  There  is  no  information in the




available literature regarding  the possible  mutagenic, teratogenic,



or adverse reproductive effects  of pentachloroethane.  Studies




in cats, dogs and sheep indicate that  pentachloroethane



produces adverse effects on  the  kidney,  liver,  and lungs.



Pentachloroethane has narcotic  activity  and  may produce




greater central nervous system  (CNS) effects than either



chloroform or tetrachloroethane  from acute exposures.
                              60

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  DRAFT
Hexachloroethane



     U.S. EPA1s CAG has determined  that  hexachloroethane  is  a




potential human carcinogen.   Results  of  a National  Cancer




Institute (NCI) carcinogenesis bioassay  showed  that hexachloro-




ethane produced an increase  in the  incidence  of  hepatocellular




carcinoma in mice.  Toxic effects on  fetal development  were



observed in rats.   Toxic symptoms produced in human beings




following hexachloroethane exposure include central nervous




system depression  and liver,  kidney,  and heart  degeneration.




3-Chloropropene (Allyl chloride)



     In subchronic studies in animals, 3-chloropropene  exhibited




adverse effects in the liver, kidney,  and lungs  following



inhalation at an exposure level of  8  ppm for  1  month.   There




is some support for these conclusions from casual observations




of workers exposed to 3-chloropropene.   Mutagenicity assays




with 3-chloropropene in the  Ames system  were  strongly positive



when vapor exposure was used.  Other  mutagenicity assays




indicate a smaller but still  positive response.  An NCI  (1978)



bioassay of 3-chloropropene  concluded that there was only



suggestive evidence of carcinogenicity in mice,  since some



tumor types were unique to the treated animals,  although  not



statistically greater than the control values.   Evidence  for



teratogenicity in  one preliminary study  indicated that  3-




chloropropene is both teratogenic and fetotoxic.



Epichlorohydrin (l-Chloro-2,3-epoxypropane)




     U.S. EPA1s CAG has determined  that  epichlorohydrin  is




a potential human  carcinogen.  Recent studies have  demonstrated




                              61

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epichlorohydrin to be potent carcinogen to the nasal tissue



of rats.  Epidemiological studies have suggested the risk of




human cancer as a result of occupational exposure, including




respiratory cancer and leukemia.



     Acute adverse health effects include extreme irritation




to the eyes, skin, and respiratory tract.  Epichlorohydrin




can be absorbed through the skin as well as being inhaled




or ingested as possible routes of exposure.




Dichloropropane and Dichloropropene




     Both dichloropropane and dichloropropene are mutagenic



to bacteria and yeast, but information on teratogenicity is




not available.  Chronic exposure to 1,2-dichloropropane has



caused signs of severe liver and kidney damage in several




species.  Mild kidney damage has been observed in rats chronically




exposed to 1,3-dichloropropene.  Data are not available to




demonstrate that these compounds are carcinogenic.



2-Chloro-l,3-butadiene (Chloroprene)




     Chloroprene has been shown to be mutagenic in bacterial



systems and in experimental animals and clastogenic in humans.



There are epidemiological data which indicate that occupational



exposure to Chloroprene may be linked to increased incidence



of lung and skin cancer.  The International Agency for Research



on Cancer (IARC) has determined that it may be linked to




human cancer.




     Repeated exposure to Chloroprene results in central



nervous system, cardiovascular, and reproductive abnormalities.




Acute effects of Chloroprene exposure include central nervous






                               62

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    FE3
system depression, lung injury, liver and kidney damage,




irritation of the skin and mucous membranes, respiratory



difficulties, dermatitis, and alopecia.




Hexachloro-1,3-butadiene




     U.S. EPA1s CAG has determined that hexachlorobutadiene




is a potential human carcinogen.  Hexachlorobutadiene induces



renal neoplasia in rats.  One bacterial assay suggests a




positive mutagenicity effect.  Two studies of the possible



teratogenic effects of hexachlorobutadiene produced conflicting




results.




Hexachlorocyclopentad iene                                 • '




     Evidence is not sufficient to categorize hexachlorocyclo-



pentadiene as a carcinogen.  Hexachlorocyclopentadiene was




not mutagenic in either short-term in vitro assays or a mouse




dominant lethal study.  The median oral LD50 is between 420




to 620 mg/kg in rabbits and 530 to 630 mg/kg in rats.  This



compound is rapidly absorbed through the skin.  The LD50 by



dermal application (rats) was similar; between 430 and 630




mg/kg.  It is classified as "highly toxic by dermal exposure"



by Federal Hazardous Substances Act criteria.



Hexachlorocyclohexane (HCH, Lindane)



     U.S. EPA's Carcingen Assessment Group (CAG) has determined




that the alpha, beta, and gamma isomers of hexachlorocyclohexane



are potential human carcinogens.  Technical hexachlorocyclohexane



(HCH), alpha-HCH, beta-HCH, and gamma-HCH (lindane) have all



been shown to induce liver tumors in mice.  Most of the




studies on hexachlorocyclohexanes deal only with lindane.






                               63

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 DRAFT
Evidence for mutagenicity of  lindane  is  equivocal.   Lindane




was not teratogenic for rats,  but  reduced  reproductive capacity



in rats in a four generation  study.   Long  term  low  level exposure




of animals to lindane caused  liver enlargement  and,  at higher




doses, some liver damage and  nephritic changes.   Humans




chronically exposed to HCH suffered liver  damage.




Benzene




     U.S.  EPA's CAG has determined that  benzene  is  a potential




human carcinogen, causing leukemia and aplastic  anemia in




humans.  Benzene is not mutagenic  to  bacteria.   Howver, there



is suggestive evidence that benzene may  be teratogenic and



may cause reduced fertility.




Chlorinated Benzenes



     EPA's CAG has determined  that hexachlorobenzene is a



potential human carcinogen.  Chronic  exposure to the chlorinated




benzenes causes liver, spleen, kidney, and central  nervous




system changes in animals. The degree of  toxicity  increases



with the degree of chlorination.   The chlorinated benzenes




are lipophilic and are therefore  retained  in  the fatty tissues



of the body.  The chlorinated  benzenes have not  been shown



to be teratogens or mutagens.




Toluene



     Controlled exposures of  800  ppm  toluene  for eight hours



in humans resulted in central  nervous system  effects, and




after affects of nervousness,  muscular fatigue,  and insomnia




persisting for several days.   Chronic occupational  exposures



to toluene have resulted in neurologic effects,  such as






                              64

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DRAFT
  3io i::-i
   impaired performance  on  tests  for  intellectual and psychomotor
   ability, and  muscular function.  Chronic  inhalation or
   subchronic inhalation and  oral exposure to toluene has not
   produced carcinogenic or other histopathologic treatment
   related effects  in  animals.  The preponderance of data
   indicates that toluene is  not  mutagenic or clastogenic.
   Napthalene
        Naphthalene can  be  absorbed by  any route, although the
   efficiency of absorption has not been determined.  The
   toxicological properties are due to  the formation of highly.
   reactive metabolites.  In  particular, chronic exposure produces
   cataracts, hemolytic  anemia, and kidney disease  in humans.
   Studies on the carcinogenic!ty of  naphthalene have not reported
   any significant incidence  of tumor formation or  mutagenicity in
   microsomal/bacterial  assay systems.
   D.  Existing  Regulations and Guidelines
        The hazardous  nature  of these wastes and their contained
   constituents  already  has been  recognized  by this program and
   by many other regulatory programs, as summarized below.
   These regulations not only illustrate the hazardous character
   of the wastes and waste  constituents, but show that all likely
   exposure pathways are of significant concern.
   1.   Existing RCRA Regulations
        Several  of the specific waste streams included in this
   generic listing are currently  regulated as toxic wastes
   as listed below:
                                 65

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 FEB 10 1334








K016  -  Heavy ends or distillation residues from the production




         of carbon tetrachloride.



K018  -  Heavy ends from the fractionation column in ethyl




         chloride production.




K019  -  Heavy ends from the distillation of ethylene dichloride



         in ethylene dichloride production.




K020  -  Heavy ends from the distillation of vinyl chloride




         in vinyl chloride production.



K028  -  Spent catalyst from the hydrochlorinator reactor in



         the production of 1,1,1-trichloroethane.




K029  -  Waste from the product stripper in the production




         of 1,1,1-trichloroethane.



K030  -  Column bottoms or heavy ends from the combined




         production of trichloroethylene and perchloroethylene.



K034 -   Filter solids from  the filtration of hexachlorocyclo-



         pentadiene in the production of chlorodane.




K095  -  Distillation bottoms from the production of 1,1,1-



         trichloroethane.



K096  -  Heavy ends from the heavy ends column from the




         production of 1,1,1-trichloroethane.






     In addition  to the specific industry waste streams



currently regulated under RCRA, many of the streams may exhibit




one or more characteristics  (i.e., ignitable, corrosive, EP Toxic,




or reactive).  In addition,  40 CFR 261.33 regulates many of the



specific constituents of concern when these are disposed of in the
                              66

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    1 0  1384
form of commercial chemical products, manufacturing intermediates,

or spill residues as summarized in Table 6.

2.   Other Regulations or Guidelines

     Table 6 summarizes representative federal regulations

controlling the constituents of concern.  In addition to

these regulations, agencies involved in implementing other

environmental statutes, such as the Clean Air Act, are

currently examining regulatory strategies for these substances.

     An Advance Notice of Proposed Rulemaking* under the Safe

Drinking Water Act could set maximum contamination levels for

trichloroethylene, tetrachloroethylene, carbon tetrachloride,

1,2-dichloroethane, and vinyl chloride in drinking water.

     Several of the constituents of concern have received

attention under Section 4(a) of the Toxic Substances Control

Act (TSCA) , which authorized the EPA to requi^?^-testing by

industry to develop data relevant to determining the risks

that such chemicals may present to health and the environment.

Dichloroemethane and 1,1-trichloroethane have been proposed for
mandatory testing by the Agency.** A voluntary testing program
for 2-chlorotoluene has been proposed by a consortium of
manufacturers in  lieu of EPA proposing a TSCA Section 4(a)
rule.***  Test rule implementation for hexachloroethane has
been deferred.****
*    40 CFR Part 141 National Revised Primary Drinking Water
     Regulations, Volatile Synthetic Organic Chemicals in
     Drinking Water.  FR 9350, March 4, 1982.
**   Dichloromethane, Nitrobenzene and 1,1,1-Trichloroethane;
     Proposed Test Rule, 46 £R 30300, June 5, 1981.

***  Chlorinated Paraffins; Response to the Interagency
     Testing Committee.  47 FR 1017, January 8, 1982.
     2-Chlorotoluene; Response to the Interagency Testing
     Committee.  47 JTR 18172, April 28, 1982.

**** Hexachloroethane; Response to the Interagency Testing
     Committee.  47 FR 18175, April 28, 1982.

                              67

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           t'^ 10  i::4
   TABLE 6.  Representative Federal Regulations Currently Controlling the Toxicants
             of Concern

   RCRA  -  Resource Conservation and Recovery Act, Section 261.33,
   CWA   -  Clean Water Act, Section 304 (a).(l), Ambient Water
            Duality Criteria level recommendation,
   OSHA  -  Occupational Safety and Health Administration,
            Section 1910, 1000, Toxic and Hazardous Substances,
   CPSC  -  Consumer Product Safety Commission
   FIFRA -  Federal Insecticide, Fungicide and Rodenticide Act
   FDA   -  Food and Drug Act
   OAOPS -  Office of Air Quality Planning & Standards
   COT   -  Department of Transportation, Hazardous Materials List
	RCRA  CWA  OSHA  CPSC  FIFRA  FDA   OAQPS    DOT

 Methyl chloride              XXX                                X
   (Chloromethane)

 Methylene chloride           XXX                                X
   (Dichloromethane)

 Chloroform                   XXX          XX               X
 (Trichloromethane)

 Carbon tetrachloride         X     X     X    X           X               X

 Vinyl chloride               X     X     X    X     X     X               X
   (Chloroethene)

 1,1-Dichloroethane           XXX                                X
   (Ethylidene dichloride)

 1,2-Dichloroethane           XXX                X               X
   (Ethylene dichloride)

 trans-l,2-Dichloroethylene   XXX                                X

 1,1-Dichloroethylene         XXX
   (hvinylidene chloride)                                                   X

 1,1,1-Trichloroethane        XXX                                X
   (Methyl chloroform)

 1,1,2-Trichloroethane        XXX

 Trichloroethene              XXX                     'X
   (Trichloroethylene)

 1,1,1,2-Tetrachloroethane    X                                            X

 1,1,2,2-Tetrachloroethane    XXX                                X
                                           68

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      DRAFT
  TABLE 6 (continued)

Tetrachloroethene
( Pe rch loroe thy le ne )
Pentachloroethane
Hexach loroethane
Allyl chloride
( 3-Chloropropene )
Ep i ch lorohy dr i n
( l-Chloro-2, 3-epoxypropane )
Dich loropropa ne
Dichloropropene
2-Chloro-l , 3-butadiene
(Chloroprene)
Hexachloro-1, 3-butadiene
He xach lorocy c lope ntad i e ne
alpha-Hexachlorocyclohexane
beta-Hexachlorocyclohexane
de .1 ta-Hexach lorocyclohexane
gamma -He xach lorocy c lohe xane
Benzene
Chlorobenzene
Dichlorobenzenes
1, 2, 4-Trichlorobenzene
Tetrachlorobanzene
Pentachlorobenzene
Hexachlorobenzene
Toluene
Naphthalene
RCRA
X
X
X
*
X
X
X
*
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
CWA
X
X
X



X

X
X
X
X
X
X
X
X
X

X
X
X
X
X
OSHA CPSC FIFRA FDA OAQPS
X

X
X
X


X

X
X X
X X
X X
X X
X X
X

X



X
X
DOT
X
X
X
X
X
X
X
X

X



X
X
X
X




X
X
* This listing adds 3-chloropropene and 2-chloro-l,3-butadiene to 40 CFR §261, Appendix

 VIII; Hazardous Constituents

-------
  DRA
   -                                          RE:   WCBCJ0503
a
   FEB 10 1984


IV.  RESPONSE TO COMMENTS

     On August 22, 1979, the Agency proposed to list by generic

description sixteen wastes (generic listings) from the production

of chlorinated organics as hazardous.*  This proposal covered

all of the wastes listed in today's regulations (and some of

which are not, at this time, being promulgated as final rules).

A number of commenters challenged both the Agency's legal

authority to list wastes generically and the Agency's technical

basis in supporting these listings.

     The Agency already has answered comments regarding its

authority to list wastes generically,  See 45 FR 33114 (May 19,

1980).  However, confusion remains about the factors the Agency

will consider when listing wastes on a generic basis.

     As this background document makes clear, the Agency intends

to base generic listings on the factors set out in 40 CFR

261.11(a)(3 ), the same factors considered in all other waste

listings.  Thus, in determining that wastes within the generic

class are typically and frequently hazardous (see 40 CFR

261.11(b)), the Agency will look to such factors as concentration

of toxic constituents in the wastes, mobility and persistence

of these constituents, potential of these constituents to

bioaccumulate, and whether the wastes  have caused substantial

harm when mismanaged.   The wastes listed here are typically
* These listings included wastes  from the  production  of
  chlorinated aliphatic hydrocarbons, chlorinated cyclic
  aliphatic hydrocarbons, chlorinated aromatic  hydrocarbon  and
  chlorinated polymers.
                               70

-------
and frequently hazardous under these criteria.  They typically



contain very high concentrations of a wide range of hazardous



constituents -- concentrations in some cases approaching a



billion times the level calculated by the Agency to pose an




increased risk of adverse health effects, such as cancer, in




humans from a lifetime ingestion of contaminated water and



aquatic organisms contaminated with these hazardous constituents.




There also is a distinct possibility of synergistic toxicological




effects from the various constituents.  The constituents typi-




cally and frequently are mobile and persistent, and many are



bioaccumulative.  These wastes have been mismanaged frequently



in the past and the mismanagement has resulted in substantial



harm.  They are generated in large quantities.  All of these



considerations strongly support the conclusion that those




wastes are typically and frequently hazardous under section



1004(5) of the Act.



     The generic listing description, rather than a listing of




wastes generated in the course of producing a particular C]_ -



Cn; product, also is the more accurate way of listing these



waste.  As discussed above, this is because the reactions that



lead to toxic by-product formation, and the conditions under



which these reactions occur, are essentially alike for this




entire group of wastes.  In fact, a wide range of marketable



chlorinated products can be made during one specific C^ to €5



process.   A listing linked to only one product — for example,




"wastes from the production of carbon tetrachloride" -- under-



states greatly the amount of wastes generated in this generic






                               71

-------
FFR 1 a  ico/i




C]_ production process, omitting wastes from the simultaneous




production of methyl chloride, methylene chloride, and chloroform.



The generic listing thus utilizes these underlying similarities




as a critical factor in establishing  its basis.




     Most of the comments critical of the August, 1979 proposal




were general comments critical of the Agency's scientific



methodology in predicting the inevitable chemical formation




of toxic by-product constituents as a result of the high




temperate/pressure free-radical generating conditions present



in the chemical reactor.  The Agency  recognizes that there are




process factors such as internal recycling or differences in




temperature, pressure, reactor configuration which may cause



variations in the wastes.  We do maintain though, that a sub-




stantial amount of toxic constituents will predictably be



.removed form the product process by the waste streams described




in these listings.  After evaluating  all of the data, however,  it




was seen that in all instances there  was significant contamination




by toxicants in the listed wastes to  create a degree of environmental



concern.  The background document demonstrates why these wastes,



which  are hazardous, are typically and frequently generated by



these  processes, taking into account  many of the  factors cited



by the commenters, and thus responding to their comments.



     We do agree, at least for the time being, with the




commenters who questioned the Agency's proposal to list wastes



from the production of chlorinated polymers in that our present




information suggests that no substantial volume of organic




wastes are generated from these processes; all potential






                              72

-------
DRAFT
FEB 10  1534
"wastes" are carried  along with the heavy viscous product
stream and incorporated  into the product.
     Finally, we note that the 1979 proposal also included
wastes from production of chlorinated aromatic hydrocarbons.
The Agency already has listed individually most of these wastes
through its listing of wastes from production of chlorobenzenes
and benzyl chloride.   The major process not yet covered  is
chlorotoluenes.   The  Agency is now sampling these wastes, and
will then make a final decision about whether to list  them.
                             73

-------
                                                       RE:   WCBCJ0503
   DRAFT
                           REFERENCES
1.   U.S. International Trade Commission (1982)  Synthetic
     Organic Chemicals, U.S.  Production and Sales,  1981.
     Pub. No. 1292.  Supt.  of  Documents, U.S.  Government
     Printing Office, Washington,  B.C.  20402.

2.   Stanford Research Institute (1980).  Directory of
     Chemical Producers, United States.  SRI.

3.   Mitre Corporation (1980) Identification  of  Pollutants  from
     Chlorinated and Related  Unit  Processes.  Grant  No.   R805620-1,
     Project No. 15810. U.S.  EPA,  Effluent  Guidelines  Division.

4.   Kirk Othmer, (1976) Encyclopedia of Chemical Technology,
     3rd Ed. Vol. 5, pp. 668-785.   John Wiley and Sons,  N.Y.,
     N.Y.

5.   Van Oss, J.F.  (1972)  Chemical Technology:   An  Encyclopedic
     Treatment.   pp. 191-220.  Barnes and Noble  Books, N.Y.,
     N.Y.

6.   Acurex Corporation (1980)  Chlorinated  Hydrocarbon Manufacture:
     An Overview.  Preliminary  Draft Report.   Contract No.
     68-02-2567.  TESC Task  4027.   Effluent Guidelines Division.
     U.S. EPA.

7.   Morrison,  R.T.  and R.N.  Boyd  (1980) Organic Chemistry,  4th
     Ed. Allan  and  Bacon,  N.Y., N.Y.

8.   Fieser & Fieser.  Advanced Organic Chemistry.

9.   NTP Technical  Report  on  the Carcinogenesis  Bioassay  of
     Pentachloroethane.  NIH  Publication No.  83-1788.  April,  1983.

10.   Page, G.W.  (1981) Comparison  of Groundwater and Surface
     Water for  Patterns and Levels of Contamination by Toxic
     Substances.  Environ. Sci. Tech.  15(2):1475.

11.   CEO report  (more info. )

12.   Buller, R.D.,  (1979)  Trichloroethylene  Contamination
     of Groundwater:   Case History and  Mitigative Technology,
     EOS 60: 827.

13.   Giger,  W.  et al.  Volatile chlorinated hydrocarbons  in
     ground and  lake waters.  p. 101-123.   In. 0. Hutzinger
     et al.  (ed) Aquatic pollutants:  transformation and
     bilogical  effects, Pergammon  Press,  N.Y.

14.   Weimer, R.A.  (1980).  Prevent  groundwater  contamination before
     it is too  late.   Water Wastes Eng. 17(2): 30-33, 63.


                             74

-------
15.
16
17
18
20
    DRAFT
FEB lo K-34
Zoeteman, B.C.J. et al.1 (1980).   Persistent  organic pollutants
in ground water of the Netherlands.   Chemoshere  9:231-249.
1980.
Ambient Water Quality Criteria Documents,  U.S.
Federal Register 45 (231):  79318.
                   EPA  (1980
U.S. EPA, Office of Water and Hazardous  Materials  (1980),
Disposal of Organochlorine Wastes  By  Incineration  at Sea,
EPA Pub.  No. 430/9-75-014.
Woehr, Hooker Chemicals and
U.S.  Patent No. 3,996,112.
cyclopentad iene.
Plastics Corp.  (Dec.  7,  1976.)
 Distillation of  Hexachlo-
n.S. DHHS (1982)  Technical Report  on  the  Carcinogenesis
Rioassay of Dichloromethane in F3441N  Rats and B6C3F1 Mice
(Gavage Study).  N.T.P.  Technical Report Draft.  Sept. 22.

U.S. EPA, Office of Solid Waste.  RCRA Section 3007     •  •
Ouestionnaire.  Organic  Chemicals Manufacturing  Industry
(1983).  (Confidential Business Information).
                              75

-------
                                                    RE:  WCBCJ0503
                           APPENDIX A

   PROCESS FLOW DIAGRAMS FOR INTFRGRATED CHLORINATED ALPHATIC
                   HYDROCARBON MANUFACTURING

Reference:  *   Mitre Corporation.  Indent if ication of Pollution
                from Chlorinated and Related Processes, EPA
                Grant No. R 805620-01 (February, 1980).

            **  Acurex Coporation.  Preliminary Draft Report.
                Chlorinated Hydrocarbon Manufacture:  An
                Overview.  EPA Contract No. 68-02-2567 (January,
                1980) .

1.  DOW process for the chlorination of methane for methyl
    chloride (CH3C1), methylene chloride chloroform (CHCl^)
    and carbon tetrachloride*

2.  Methyl chloride, methylene chloride, chloroform and carbon
    tetrachloride by the diret chlorination of methane**

3.  Chloromethanes by methanol hydrochlorinat ion and methyl
    chloride chlorination processes**

4.  Ethyl chloride via hydrochlorinat ion of ethene

5.  The balanced process for vinyl chloride**

6.  1 ,2-dichloroethane via direct chlorination**

7.  1 ,2-dichloroethane via oxychlorination**

8.  vinylidene choride from 1 , 1 , 2-trichloroethane**

9.  1 , 1 , 1-tr ichloroethane from ethane**

10. 1 , 1 , 1-tr ichloroethane from vinyl chloride**

11. Perchloroethylene and trichloroethylene by chlorination**

12. Perchloroethylene and trichloroethylene by oxychlorination**

13. Chloroprene manufacture via direct chlorination of butadiene**

14. Carbon tetrachloride and perchloroethylene by the direct
    chlorination of propane**

15. Perchloroethylene and carbon tetrachlore from propane**

16. Allyl chloride from propylene*

17. Allyl chloride via direct chlorination of propene**

-------
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  DRAFT
       RE:  WCBCJ0801
                         APPENDIX  B
   SELECTED  DAMAGE INCIDENTS RELATING TO THE MANUFACTURE
   OR ENVIRONMENTAL RELEASE OF THE  CHLORINATED CONSTITUENTS
   OF CONCERN
Reference

EPA Publication No. 430/80-9/004
  Damages  & Threats

Region I Files

Region V Files

Region VII Files

Region VIII Files

Region X Files

Region VI  Files

Region III Files

Region II  Files
Incident Nos

     1-20


    21-48

    49-57

    58-62

    63-67

    68-70

    71-75

    76-98

    99-130
                            C-l

-------
        DRAFT
         FE.B 10 1384
Damage Incident No.  1;   Contamination  of  city wells, possible
                        aic  releases from  incineration

     Source of  release;   Distillation,  recovery and disposal of
     industrial solvents.   Incineration may also have been used
     for disposal.   Open burning  of wastes on site.

     Resulting  Contamination;

     Chlorinated substances:        Concentration:         Medium:

     chloroform                     "hazardous          2 of 3 city
     carbon tetrachloride              levels"            water wells
     di chloroethane
     1,1,1-trichloroethane
     trichloroethylene
     tetrachloroethylene

     Citation;  EPA  Pub  #430/80-9/004,  p. 66
Damage Incident No.  2;   Reservoir  and water supply contamination


     Source of release;   Incinerator on site.  Spill of 30,000
     gallons to reservoir,  since no spill prevention measures.
     Evacuation of  residents  and fish kill resulted.


     Resulting contamination;

     Chlorinated substances:        Concentration:         Medium:

     dichloroethane                 not available          resevoir,
     trichloroethane                                       water supply
     toluene

     Citation: EPA,  Pub.  #430/80-9/004, p. 27
                             C-2

-------
         -r
    r- >• r, 1 r\ ' C n 4
    I ; •.-• LI. • - u -i



Damage Incident No. 3:  Water supply contamination


     Source  of release:  Chemical manufacturer using subsurface
     disposal of dichloroethylene, toluene, benzene, etc., as
     well as unlined lagoons.

     Resulting contamination:

     Chlorinated substances:        Concentration:         Medium:

     specific compounds not         not available          45% of
     listed; assumed to                                    municipal
     include dichloroethylene                              water supply

     Citation: EPA Pub. #430/9-80/004, p. 121
Damage Incident No. 4;  Well contamination



     Source of release:  VJastes from the manufacture  of many
     chemicals, including vinyl chloride.  Residues of vinyl
     chloride disposed of in open catch basins  in sandy soil,
     resulting in the infiltration of 14 wells.

     Resulting contamination;

     Chlorinated substances:        Concentration:         Medium:

     vinyl chloride                 not available          14 wells


     Citation: EPA Pub. #430/9-80/004, p. 196
                              C-3

-------
(continued)
Toxicant of Concern
Chlorobenzene
1 , 2-Dichlorobenzene
1 , 3-Dichlorobenzene
1 , 4-Dichlorobenzene
1,2, 4-Tr ichlorobenzene
1,2,4, 5-Tetrachlorobenzene
1,2,3, 4-Te trachlorobenzene
1,2,3, 5-Tetrachlorobenzene
Pentachlorobenzene
Hexachlorobenzene
Toluene
Naphthalene
Sol.
H20
20°
(pprv)
488
100
125
79
30
_ _
	
"slightly"
_ _
0.006
534.8
31.7
Kow
690
3.6x103
3.6x103
3.6xl03
1.9xl04
- -
- -
_ _
_ _
2.6xl06
620
1.95xl03
M.P.
°C
-45
-170
-24.7
51.1
16.95
138
47.5
51
85
230
-95
80
B.P.
°C
D2
180.5
173
174
213.5
246
254
246
27
322
110.6
218
                                           b-3

-------
  DRAF
     lo 1924
Damage Incident No.  5;   Discharges  to waterway, release of
                        fumes  and potential leakage of buried
                        drums  and tanks.

     Source of  release:  Waste disposal site.  Tank car overheated
     and leaked fumes  in 1976.   Buried drums and tanks on site
     contain 1  1/2  million  gallons  of organic  chemicals.
     Discharge  from plant to nearby canal and  river.

     Resulting  contamination;

     Chlorinated substances:         Concentration:         Medium:

     1,2-dichloroethane              discharged-            river, canal
     1,1,1-tr ichloroethane           unknown
     di chlorobenzene                concentrations
     benzene
     toluene

     Citation:  EPA  Pub.  #430/9-80/004, p. 206
Damage Incident No.6:   Well  contamination


     S our_ce of  re 1 ease ;   Old  sludge pits on an Air Force base.


     Resulting  contamination:

     Chlorinated substances:        Concentration;         Medium;

     trichloroethylene              not available          on site  well
     "other organics"

     Citation:  EPA Pub.  $430/80-9/004, p. 58
                              C-4

-------
     FE3 1C 13-?-]


    DRAFT
Damage Incident No. 8:  Ground water contamination


     Source  of release:  Major chemical  company disposed of
     hazardous wastes  containing chlorinated  organic pesticides,
     etc.

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium;

     trichloroethylene              "hazardous range"     "migration
     tetrachloroethylene                                  from landfill
     benzene
     chlorobenzene
     hexachlorobenzene
     benzene  hexachloride

     Citation; EPA Pub. #430/9-80/004, p.  178
                             C-5

-------

Damage Incident No.  9:  Ground water and soil contamination -
                        Adverse human health effects

     Source of release;  Abandoned landfill used by chemical
     company.   Wastes deposited 1942-1952 still causing problem.

     Resulting contamination:

     Chlorinated substances;        Concentration;         Medium;

     chloroform                     not available          various
     dichloroethane
     trichloroethylene
     tetrachloroethylene
     hexachlorobutadiene
     dichlorobenzene
     toluene

     Citation: EPA Pub. #430/9-80/004, p. 180
Damage Incident No.  10;  Water supply contamination


     Source of release;  Chemical company disposed of 70,400
     tons of hazardous materials in landfill, resulting in
     migration of hazardous chemicals to public water supply.

     Resulting contaminants;

     Chlorinated substances;        Concentration;         Medium;

     tetrachloroethylene            not available          public water
                                                           supply
     Citation; EPA Pub. #430/9-80/004, p. 182
                              C-6

-------
      A

      0 1984


Damage Incident No. 11;  Ground water contamination


     Source of release;  Inactive unlined hazardous waste site.
     1000 gals/day accepted, some containing: methylene  chloride,
     trichloroethane, carbon tetrachloride, chloroform,  benzene,
     and toluene.

     Resulting contamination;

     Chlorinated substances:        Concentration;         Medium;

     organics (above)               not available          monitoring
                                                           wells

     Citation: EPA Pub. # 430/9-80/004, p. 228
Damage Incident No. 12;  Drinking well contamination


     Source of release;  Landfill, unknown sources of wastes.

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium;

     1,1,1-trichloroethane          166 ppb                4 municipal
     tetrachloroethylene             61 ppb                drinking wells

     Citation: EPA Pub. #430/9-80/004, p. 227
                              C-7

-------
 DRAFT
    Fir :
Damage Incident No.  13:  Surface water, drinking well contamination


     Source  of release;  Three illegal dump sites of chemical
     wastes;  663  barrels removed.


     Resulting contamination:

     Chlorinated  substances;        Concentration;          Medium;

     trichloroethylene              detected               marshland;
     toluene                        detected               also at least
                                                          11  adjacent
                                                          drinking well

     Citation; EPA  Pub. #430/9-80/004, p. 227
Damage Incident  No.  14;  Ground water contamination.


     Source  of release;  Current landfill without liner  or  pumping
     system.

     Resulting contamination;

     Chlorinated substances:        Concentration;          Medium;

     chloroform                     not available          groundwater
     carbon  tetrachloride
     dichloroethylene
     tr i chloroethylene


     Citation; EPA  Pub.  #430/9-80/004, p. 170
                             C-8

-------
 DRAFT
       1C
Damage  Incident No. 15;   Drinking well contamination


     Source of release;   Dumping between 1969-1979  by chemical
     company.

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium:

     chloroform                    not available          11 drinking
     carbon tetrachloride                                wells
     tr i chlor oethylene

     Citation: EPA Pub/  #430/80-9/004, p.  69
                            C-9

-------
  FEB 10 ]c-..
Damage Incident No. 17:  Ground water and drinking well  contamination


     Source of release:   Inactive landfill site

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium;

     methylene chloride             "hazardous             groundwater,
     vinyl chloride                  concentrations"       drinking well
     1,2-dichloroethane
     tr ichloroethylene
     tetrachloroethylene
     benzene
     chlorobenzene

     Citation: EPA Pub. #430/80-9/004, p. 29
Damage Incident No. 18;  Drinking well contamination


     Source of release;  Industrial landfill

     Resulting contamination;

     Chlorinated substances;        Concentration:         Medium;

     chloroform                     "significant           residential
     trichloroethane                 levels"               wells
     tr ichloroethylene
     toluene

     Citation: EPA Pub. 1430/80-9/004, p. 25
                              C-10

-------
  DRAFT
Damage Incident  No.  19:  Air releases


     Source of release:  Industry waste discharge to sewers.
     Fumes in municipal wastewater treatment plant led to
     worker symptomatic complaints.

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium:

     chlorinated organics           low levels             urine  of work
                                                          in treatment
                                                          plant

     Citation: EPA  Pub. #430/9-80/004, p.  237
Damage Incident  No.  20:   Drinking well contamination


     Source  of release;   Unspecified company name as source

     Resulting contamination:

     Chlorinated substances;        Concentration;         Medium;

     carbon  tetrachloride           "contaminated"         private wells
     trichloroethylene              "      "     "
     tetrachloroethylene            "      "     "
     dichlorobenzene                "      "     "
     toluene                       "      "     "

     Citation; EPA  Pub. 4430/9-80/004, p. 213
                             C-ll

-------
           i .«,.<.,
Damage Incident No. 21;  Surface and drinking water  contamination


     Source of release:  Burning (incineration) and  drum  storage
     of waste oils (possibly transformer oils)  from  one industry
     source.  Hardened sludge material caked on site.
     Resulting contamination;

     Chlorinated substances;

     1,2-dichloroethylene
     1,1,1-tr ich lor oe thane
     tetrachloroethylene

     1, 2-dichloroethylene
     1,1,1-trichloroethane
     tetrachloroethylene
                     Concentration;
                     50-100 ppb each
                detected; less than 10 ppb
Medium:
  pond
  tap water
  (nearby
  restaurant)
     Citation; Fl-8103-02, Region I
Damage Incident No. 22;  Soil, ground,  surface water  contamination
     Source of release:
	   Nonsecure landfill, excavated pits with
chemical wastes.  Improper incineration of wastes
       of odors.  Brook and swamp water contaminated,
     discarded
     led to compaints
     with potential for drinking wells  in groundwater plume  path.
     Resulting contamination;

     Chlorinated substances:

     d i chl or ome thane
     chloroform
     carbon tetrachloride
     1,2-dichloroethane
     1,1-dichloroethylene
     trichloroethylene
     tetrachloroethylene
     benzene

     Citation: Fl-8101-09, Region  I
                     Concentration;

                     19,000 ppm
                     43,000
                      2,190
                      2,100
                     13,000
                     43,000
                     39,000
                      6,000
Medium:

groundwater
monitoring
wells
(also observe
in brooks and
swamp)
                              C-12

-------
   DRAF
      FEB _


Damage Incident No.  23:   Soil,  drinking water  contamination


     Source of release:   Abandoned  waste  site  with pit and
     incinerator,  asphalt lined lagoon, drums, and buried
     tank.   Wastes were  also discharged directly  to ground.
     Industrial wastes were  accepted  at site.

     Resulting contamination;

     Chlorinated substances:        Concentration;         Medium;

     trichloroethane               detected               residential
     trichloroethylene             detected               well water

     1, 2-dichloroethane             "gross                 soil on site
     1,1,1-trichloroethane           contamination"
     tetrachloroethylene
     benzene
     toluene

     Citation: Reference Ol-ME-006  (Fl-8101-12)

Damage Incident No.  24:


     Source of release:   Incineration or  landfilling of liquid
     sludge wastes,  including  solvents.   Reddish  brown leachate
     around landfill.

     Resulting contamination;

     Chlorinated substances:        Concentration;         Medium;

     1,1 ,-dichloroethane           4.4   ppb               surface watej
     toluene                       45    ppb               (perimeter)

     vinyl  chloride                 10    ppb               private
     chlorobenzene                 10     "                drinking wel
     benzene                       30     "
     toluene                       10     "
     ethylbenzene                   30     "

     Citation: Ol-MH-0008(01-3103-10)  Region I
                              C-13

-------
   DRAFT
     FEB 1o 1904

Damage Incident No.  25;   Drinking  well  contamination


     Source of release;   Previous  incineration  of distillation
     residues, trichloroethylene  recovery.   Spill in  1970  or 1971
     of 100-300 gallons  of  trichloroethylene.   Deposition  of
     20,000 gals/yr  of  still  bottoms  in  an  on-site  landfill.
     Disposal of still  bottoms  in  tunnel under  river.   Drinking
     wells  adjacent  to  site affected, with  potential  for further
     contamination.

     Resulting contamination;

     Chlorinated substances;         Concentration:         Medium;

     dichloromethane                 4   ppb              drinking well
     1,1,1-trichloroethane           3-7   ppb
     trichloroethylene              11-13 ppb
     tetrachloroethylene            1-9   ppb

     Citation; Fl-8011-06-Region  I
Damage Incident No.  26;   Soil  and  ground  water  contamination


     Source of release;   Manufacturing  complex  using unlined
     lagoon for all  untreated  wastewaters.   Also  inactive
     lagoons and pits,  drum storage  with  leaking  contents.
     Site is over an aquifer for drinking wells.

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium;

     chloroform                     10,000  ppb             soil (spill
     benzene                         1,000  ppb             site)
     toluene                         3,000  ppb

     dichloromethane                    58  ppb             groundwater
     1,1,1-trichloroethane           "several hundred ppb"
        and tetrachloroethylene
     toluene                            14  ppb

     Citation; Reg.  I,  Lex  Ma, S&A Office
                              C-14

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  DRAFT
Damage Incident No.  27:   Soil  and  Ground  water  Contamination
     Source of release:   Seven  unlined  surface  impoundments  for
     liquid hazardous waste.  Groundwater  flows to  brook  feeding
     public water  supply reservoir.
     Resulting contamination;
     Chlorinated substances:
Soil:
Groundwater;

chloroform
1,1, 1-tr ichloroethane
trichloroethylene
tetrachloroethylene
benzene
toluene

1,
1,
—
3,

700 ppb
367
33
—
542
(A)
9,020
2,678
2,033
368
— —
21,560

ppb


Medium:
  (B)
                                                                54 ppb

                                                                 8
                                                                22
                                                               550
     Citation;  Region  I,  Lex.,  MA,  S&A.  Office
Damage Incident No.  28;   Contamination  of municipal water supply,
                         ground  water,  water main, etc.
     Source of  release;   Unlined  lagoon, wastewater treatment
     from the  current manufacture  of  chlorinated paraffins.
     Previously,  chlorinated  benzenes were manufactured at
     this site.
     Resulting  contamination:

     Chlorinated  substances:

     carbon  tetrachloride
     trichlorobenzene

     p-dichlorobenzene
     tri chlorobenzene
             t_
     chloroform

     chloroform
     carbon  tetrachloride
     chlorobenzene

     chloroform
     carbon  tetrachloride
     1,1,1-trichloroethane
     chlorobenzene
   Concentration;

130,000 - 1,790,000  ppb
 23,000 -    80,000

      84 ppb
      51 ppp

      80 ppb

     4.1 ppb
     2.7 ppb
     4.4 ppb

      52 ppb
     735 ppb
      30 ppb
      25 ppb
                Medium;

                wells,  on-site
                water  main,
                serving  city

                city well

                groundwater,
                city well
                field

                groundwater,
                plant  site
     Citation;  05-OH-0187  (F-5-8010-001) Region  I
                             C-15

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 DRAFT
     FEB 10 1954
Damage Incident No.  29:   Drinking  water  and  soil  contamination


     Source of release;    Two buried  sludge  pits, where still
     bottoms from solvent recovery were  buried.   Municipal
     water wells contaminated which are  downgradient  of the
     site.

     Resulting contamination;

     Chlorinated substances:        Concentration;         Medium;

     dichloromethane               100,000  ppb            soil  (core
     chloroform                       4,000  ppb            from  center
     1,1-dichloroethane               36,000  ppb            of pits)
     1,1,1-trichloroethane            1,200  ppb
     trans-1,2-dichloroethylene       18,500  ppb
     trichloroethylene                35,000  ppta
     toluene                         20,000  ppb
     ethyl benzene                    8,000  ppb

     dichloromethane                 1-10  ppb            drinking
     chloroform                      "    "   ""             well  (PW-4)
     1,1-dichloroethane               "    "    "
     1,1-dichloroethylene            "    "    "
     tetrachloroethylene              "    "    "
     trans-1,2-dichloroethylene       "    "    "
     trichloroethylene                "    "    "
     toluene

     Citation; Ol-CT-0001(01-8007-01)  Region I


Damage Incident No.  30;   Ground  and surface  water contamination


     Source of release;   Unlined surface  impoundment  lagoons,
     containing waste  organic sludge  at  a waste treatment site.

     Resulting contamination;

     Chlorinated substances:        Concentration;         Medium:

     dichloromethane                  640 ppb             ground water
     trichloroethane               11,000 "              and surface
     toluene                         2,400 "              water drainag
                                                          -highest valu
     Citation; Region  I,  Lex  MA, S&A  Office
                              C-16

-------
      FEB 1C 1934
Damage Incident No.
                    31;  Ground water contamination
     Source of release;  Inactive unlined, undiked lagoons
     at a waste disposal site.  Various contaminated waste
     oils were treated.  Oil sludges on site contaminated with
     benzene, toluene, xylene, as well as chlorinated organics.
     Suspected surface water and soil contamination.
Resulting contamination;

Chlorinated substances;

trichloroethylene
perchloroethylene
1, 1,1-trichloroethylene

Citation: 01-3101-07, Region I
                                    Concentration;
                               4.7
                               5.0
                               1.0
                                        ppb
                                        "
                                                           Medium
                                                           groundwater
Damage Incident Mo. 32:  Soil and surface water  contamination
     Source of release:  9000 buried drums of  chemicals  at a
     farm resulting in a major discharge source of contaminated
     groundwater.  Surface water from site feeds  into a  cranberry
     bog irrigition source.
     Resulting contamination
Chlorinated substances

dichl or ome thane
chloroform
1,1,1-trichloroethane
trichloroethylene
benzene
toluene
et'nylbenzene
                                    Soil
                                 (gravel pit)

                                 3200 ppb
                                 1000 "
                                  440 "
                                  780
                                                        Water
                                                   (adjacent swamp)

                                                        7700 ppb
                                                        1300 "
                                                        1600 "
                                                          840 "
                                                          510 "
                                                        2400 "
                                                          700 "
     Citation; 01-8102-03, Region I, RIDEM
                              C-17

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    DRAFT
    *W"   ._> f~ i-i ^ —  4 |
        FEB 10 1934
Damage Incident No.  33;   Drinking well  contamination
     Source of  release;   Active  landfill with unlabeled drums filled
     with liquids.   Major chemical  company deposited 2000-6000 drums.
     Surface water  from  site  appears to drain towards lake.
     Resulting contamination;

     Chlorinated  substances;

     di chloroethylene
     trichloroethylene
     benzene

     Citation: 01-8101-04,  Region  I
Concentration;

110 ppb, 130 ppb
 19 ppb,  41 ppb
4.1 ppb, 5.9 ppb
                           Medium;

                       2  drinking wells
Damage Incident No.  34;   Drinking well  contamination
     Source of release;   Inactive  chemical dump from which a
     series of private well  contamination incidents resulted.
     Resulting contamination;

     Chlorinated  substances;

     chloroform
     1,2-dichloroethane
     toluene
    Concentration:
   920 ppb
 8,000
16,000
          670 ppb
        2,600
        4,100
                        Medium:
two wells
"atop site"
     Citation;  01-81-1-10,  Region  I
                              C-18

-------
   DRAF
       1n 1984
Damage Incident Mo.  35
Drinking well contamination
     Source of release:   Inactive  liquid  drum  burial  site,
     damage to drums  in  1966  by fire  and  explosion.   40  con-
     taminated drinking  wells downsite.

     Resulting contamination;
     Chlorinated substances:
     1,1,1-trichlon oethane
     1,1,2,2-tetrachloroethane
     chlorobenzene
     o-dichlorobenzene
     p-di chlorobenzene
     toluene
           Concentration  (ppb)  in  7 wells
1 1
l#5 1
1 1
11401
1— 1
13201
1 701
1 151
1 10|
I 1
16

130
—
580
70
25
15

1
18 |
1
9601
-- 1
7901
651
151
25!
1
tio

90

1,100
90
15
20

#11

90
--
130
40
10
10

#12

40

120
30
10
15

#13

43
5.8



—

                                  (—  indicates  data not available)
     Citation:  01-8101-01,  Region  I
Damage Incident No.  36;   Surface  and  ground  water  contamination
     Source of release;  Inactive  landfill  with drums  of  chemical
     and industrial waste.   Contaminant  plume is  continuing to
     emanate from the site.
     Resulting contamination;

     Chlorinated substances;

     trans-l,2-dichloroethylene
     tr ichloroethylene
     toluene

     dichloromethane
     1,1-dichloroethane
     trans-1,2-dichloroethylene
     trichloroe thane
     toluene
     ethyl benzene
           Concentration;
              40
              40
               1

           2,000
             990
           9,600
             100
           2,900
             100
ppb
ppb
Medium;

surface  watec
(brook)
groundwater
     Citation:  Region I,  Lex.  MA,  S&A Office
                              C-19

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    FEB 10  i:-M
Damage Incident No. 37:  Soil contamination
     Source of release; Storage area at yacht company with
     leaking drums, with dichloromethane as one of wastes.
     Wastes were discharged to soil.
     Resulting contamination:

     Chlorinated substances;

     dichloromethane
     1,1,1-trichloroethane
     tr i chloroethylene
Concentration;

660 ppb
 80 ppb
 10 ppb
                     Medium:

                     soil
                     soil
                     soil
     Citation: Region I, Lex. MA, S&A Office
Damage Incident No. 38:  Ground water contamination
     Source of release; Inactive landfill; soil and liquid
     drummed waste scattered trhoughout.
     Resulting contamination;

     Chlorinated substances:

     chloroform
     carbon tetrachloride
     1,2-di chloroethane
     1,1-dichloroethylene
     tr i chloroethylene
Concentration:
3,
1,
500 ppb
100
000
700
500
                     Medium:
                       ground water
     Citation: 01-8103-06, 01-8108-02, Region I
                              C-20

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    Fr.
   DRAFT
Damage  Incident No. 39:  Surface and ground  water  contamination
     Source  of  release;  Inactive landfill,  bulk and drummed
     liquid,  sludge, and solid wastes buried in gravel pit.
     Drinking wells lie in path of groundwater flow.
     Resulting  contamination:

     Chlorinated substances;

     dichloroe thane
     toluene

     dichloromethane
     chloroform
     toluene
Concentration:

    81  ppb
5-10

123,000 ppb
 31,000
 29,000
Medium;

surface  water
(brooks)

ground water
(near site)
     Citation; Region I, Lex., MA, S&A Office
                             C-21

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   DRAFT
Damage Incident  No.  40:   Surface and ground water contamination


     Source  of release;  Illegal hazardous waste storage and
     disposal with  exposed and buried drums.  Surrounded by swamp
     and brook.

     Resulting contamination;

     Chlorinated substances:        Concentration;         Medium;

     dichloromethane                20 ppb                 brook
     1,1,1-trichloroethane          10
     tr ichloroethylene               4
     toluene                        9
     ethylbenzene                    5

     1,2-dichloroethane             20 ppb                 downstream
     1,1,1-trichloroethane           9                     swamp
     benzene                        4
     toluene                      470
     ethylbenzene                  140

     dichloromethane               230 ppb                 groundwater
     1,1-dichloroethane            160                     monitoting
     1,2-trans-dichloroethylene  2,600                     off-site
     vinyl  chloride                500                     (maximum  valu
     1,1,1-trichloroethane          76
     tetrachloroethylene         1,100
     toluene                    5,500
     ethylbenzene                1,600
     chlorobenzene                  67

     Citation; Ol-NH-001(F1-8008-01A), Region I
                             C-22

-------
       10 1534
Damage Incident No. 41;  Ground and surface water contamination


     Source of release;  Inactive landfill, buried drums of
     solvents and manufacturing wastes.  Small leachate outbreaks
     observed on adjacent property.  "Following analysis,
     these wastes were disposed of according to State of New
     Hampshire regulations."
     Resulting contamination

     Chlorinated substances;

     tcichloroethylene

     benzene
     toluene
                               Concentration:

                               detected

                               50 - 80 ppb
                                3-4  ppb
Medium:

groundwater

ground, surfat
water, soil
     Citation: Fl-8103-01(Ol-NH-0003), Region I
 Damage Incident No. 42;  Soil and surface water contamination
     Source of release;  Surface impoundment/tank storage
     facility of major chemical company with leaking tanks,
     leaching from acid pits, burial sites, and sewers.
     Soil samples were contaminated with oil.
                                    Concentration;
                                    "moderate to high"
Resulting contamination:

Chlorinated substances;

1,1-dichloroethane
1,1,1-tri chl or oe thane
trichloroethylene                       "
toluene                                 "
1,2-dichloroethylene                    "
1,1,2-trichloroethane                   "

Citation: Ol-MA-0002, 01-8005,OIF, Region I
Medium;

drainage pit
going to brook
                              C-23

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  DRAFT
Damage Incident No.  43:   Ground water  contamination


     Source of release;   Rusted drums, etc. on site of tannery.
     No definitive  source for  the  chlorinated aliphatics
     contamination  was determined.

     Resulting contamination;

     Chlorinated substances;         Concentration;         Medium;

     1,2-dichloroethane              54.9 ppb               well (on-site
     1,1,1-trichloroethane           104   "
     trichloroethylene               400   "

     Citation; Ol-MA-0002(F1-8005-01E-03), Region I
Damage Incident No.  44;   Well  water  contamination


     Source of release;    Inactive tannery next to site known
     to have used  solvents for hide  degreasing.  Wells on site
     used for production  water contaminated.  Trichlocoethylene
     detected in,  but at  acceptable  levels (FDA), food and
     industrial products  manufactured  at the site.

     Resulting contamination;

     Chlorinated substances;         Concentration;         Medium;

     1,1-dichl or oe thane                20    ppb            production
     1,1-dichloroethylene              3.9   "             wells (highest
     trans-1,2-dichloroethylene       91     "             values)
     1,1,1-trichloroethane            67     "
     trichloroethylene            2,290     "
     tetrachloroethylene                1.6   "


     Citation; Ol-MA-0002(F7-8005-07E-05) Region I
                              C-24

-------
 DRAFT
Damage Incident  No.  45;   Drinking well contamination
     Source of  release;   Inactive town dump which received large
     amount of  industrial wastes, including solvents.
     Resulting  contamination;

     Chlorinated  substances;

     1,2-dichloroethylene
     1,1,1-trichloroethane
     trichloroethylene
Concentration;

27 ppb
13  "
44  "
Medium;

drinking
water wells
     Citation;  Region  I,  Lex. MA, S&A Office
Damage Incident  No.  46;  Ground water contamination
     Source of  release;  Landfill with associated uncontrolled
     fire and explosion  incidents, surface water and leachate
     run-off.
     Resulting  contamination;

     Chlorinated  substances;

     chloroform
     benzene
     toluene
Concentration:

240 ppb
800  "
 15  "
Medium:
ground water
     Citation:  Ol-CT-006  (01-8101-10) Region I
                             C-25

-------
    B" 10 !°3
      RA
Damage Incident No.  47;   Ground water contamination


     Source of release;  Active municipal landfill which received
     hazardous wastes in past.  Leachate plume flows into river
     feeding water supply resevoir for Boston.

     Resulting contamination;

     Chlorinated substances;         Concentration;         Medium;

     vinyl chloride                  58 ppb                 groundwater
     1,1-dichloroethane               4                     (monitoring
     trans-1,2-dichloroethylene     32                      well)
     benzene                         9
     toluene                        67

     1,1-dichloroethane              59 ppb                 leachate stre
     trans-1,2-dichloroethylene     16
     1,1,1-trichloroethane          65
     toluene                        11
     ethylbenzene                    3

     Citation; F01-MA-0007(01-8012-03) Region I


Damage Incident No.  48;   Ground water contamination


     Source of release;   Active landfill, buried wastes migrating.
     Future migration of wastes and potential for affecting
     public water supplies is  being monitored.

     Resulting contamination;

     Chlorinated substances;         Concentration;         Medium;

     chloroform                     130   ppb              groundwater
     trichloroe thane                  4.3                  (monitoring
     benzene                        200                     wells)

     Citation; Ol-RI-0003(01-8101-08) (01-8107-03) (01-8012-01A)
               Region I
                              C-26

-------
 DRAFT
       A V.'
Damage Incident No.  53;   Ground  water  contamination


     Source of release;   Unlined lagoons, wastewater treatme
     from chemical  manufacturing,  also surface  impoundments.
     Plume from lagoon  reaches  creek.   Drinking wells in are
     closed 1977.
     Resulting contamination;

     Chlorinated substances;         Concentration;         Medium;

     trichlorethane                  not  available,         ground water
     chlorobenzene                   but  detected           plume from
     toluene                                              lagoon
     benzene

     Citation: 05-8105-2,  Region  V


Damage Incident No.  54:   Surface  water and  sediment contamination
                         possible airborne  releases

     Source of release;   Junkyard with stored drums.  Leachate
     areas drain to  creek,  which  may be  used for water supply.
     Overnight dumping  lead to resident  complaints of nasal/throat
     symptoms.

     Resulting contamination;

     Chlorinated substances;         Concentration;         Medium;

     dichl or ome thane                  135  ppb            stream and
     1 , 1-dichloroethane                  85                 sediment on
     1 ,1-dichloroethylene              149                 site
     trans-1 ,2-dichloroethylene       115
     1,1,1-trichloroethane            1,907
     trichloroethylene                 319
     tetrachloroethylene               195
     toluene                         6,572

     Citation; 05-8103-004, Region  V
                              C-27

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 DRAFT
Damage Incident No. 55:  Surface water  contamination


     Soucce  of release:  Inactive dump  site.  One thousand
     drums  corroded, buried and partially  buried, leaking, or
     open;  filled with liquids and sludges.   Eroded site,
     drainage to adjacent creek.  Kangaroos,  antelopes, cows
     and  pigs currently being raised on site.

     Resulting contamination;

     Chlorinated substances:         Concentration:         Medium:

     dichloromethane                                      standing
                                                         water
                                                         (on-site)

     Citation: 05-IN-0017(F05-8010-003) Region  V
                             C-28

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Damage Incident No.  58:  Drinking water contamination


     Source of release;  Landfills which accepted municipal wastes
     with some evidence of having accepted industrial wastes.
     Sludge pit with incompatible wastes was used.

     Resulting contamination;

     Chlorinated substances:        Concentration;         Medium;

     trichloroethylene              "in excess of human    drinking
                                     health risk level     water at
                                                           public resort
                                                           cave, etc.
     Citation: EPA file M0000010090, Region VII, Site U
                              C-29

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 FLB 10 1924
DRAFl
Damage Incident No. 59;  Surface and ground water contamination
     Source of release:  Waste disposal site with buried  drums,
     bulk wastes and evaporation ponds for leachate  and run-off
     collection waters.
     Chlorinated substances;        Concentration;          Medium;

     1,1,2,2-tetrachloroethane      "in excess of          monitoring
                                     10 x the human        well  and
                                     health risk level      private pond


     Citation; 07-8102-7, Region VII, Site K
Damage Incident No. 60;  Drinking and ground water  contamination
     Source of release;  Corporation which has historically
     spread trichloroethylene wastes on its property.   Dich-
     loroethylene and vinyl chloride presence in contaminated
     water was attributed to the breakdown of trichloroethylene.

     Resulting contamination:

     Chlorinated substances;        Concentration;         Medium;

     trichloroethylene              "10 x health          drinking
     vinyl chloride                 standard trace         water,
                                                          township

     trichloroethylene              detected              on-site
     dichloroethylene                  "                  monitoring
     vinyl chloride                    "                  well

     Citation; F-708101-7, Region VII,  Site C
                              C-30

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  DRAF
Damage Incident No.  61;   Sediment contamination
     Source of release;   Much of river basin's industry is  located
     on this brook.   Contaminated bottom sediment.   This is
     said to be one  of the most contaminated areas  in the
     Great Lakes basin.   Removal of sediments is proposed
     solution.
     Resulting contamination;

     Chlorinated substances:

     trichloroethylene
     1,1, 2 , 2-tetrachloroethane
     pe ntachl or oe thane
     hexachloroethane
     tetrachlorobutadiene
     pentachlorobutadiene
     hexachlorobutadiene
     1-chloro-2-methylbenzene
     polychlorinated organics
Concentration:

506,000 ppb
329,000
391,000
778,000
323,700
 34,000
285,800
282,000
detected
Med ium;

bottom sedime
(1979 sample)
     Citation;  FIT # Not Available,  Region V

Damage Incident No.  62;   Spring contamination
     Source of release;   Corporation established  in  1976  to
     treat and store hazardous wastes from several states.
     Containerized wastes buried in pits.   Contamination
     attributed to evaporation lagoons which had  clay liners
     on bottom and no liners on side.  Spring 1 mile north
     of site contaminated.
     Resulting contamination:

     Chlorinated substances;

     1,2-dichloroethane
     1,1-dichloroethylene
     1,1,2-trichloroethane
     methylene chloride
     vinyl chloride
     trans-1,2-dichloroethylene
Concentration;

"All in excess  of
10 x the human
health risk of
10-6"

detected
Medium:
 spring
     Citation:  F07-8004-01,  Region VII,  Site  F.
                              C-31

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 DRAFT
Damage Incident No.  63;   Ground water  contamination


     Source of  release;   Industrial wastes from Army's toxic
     chemical  and  major  chemical  company's pesticide manufacturing
     processed  discharged  into two waste basins since 1942.
     In 1957,  a "low permeability" liner was installed.

     Resulting  contamination;

     Chlorinated substances;        Concentration;         Medium;

     methylene  chloride              70 ppb                ground water
     chloroform                    106                    (on-site)

     chloroform                     87 ppb                ground water
     tetrachloroethylene            297                    (off-site)
     hexachlorobutadiene             17

     Citation;  F-8005-2,  Region VIII
Damage Incident No.  64;   Ground  water  contamination


     Source of release;   Two cells  for disposal of industrial
     wastes in early 1970's  used by major  chemical companies.
     On site groundwater  affected.

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium;

     methylene chloride                12  ppb              ground water
     benzene                       3,515                    (on-site
     chlorobenzene                     445                   monitoring
     toluene                       7,369                   wells)

     Citation: F8-8008-3, Region VIII
                              C-32

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    DRAF
Damage Incident No.  65:   Air and  ground  water  contamination
     Source of release:   Disposal of  industrial  wastes  in
     unlined pits prior  to 1980.   Contamination  has  spread  1/4
     mile of site boundary.   Air  pollution  documented.   Samples
     collected in 1981  still show air  contamination  from
     wastes disposal prior to 1980.
     Resulting contamination;

     Chlorinated substances;

     chloroform
     vinyl chloride
     benzene
     toluene

     methylene chloride
     trichloroethylene
     toluene
 Concentration:
    7.7
    6.0
 65,700
 64,800

   26.7
1,062
  719
ppb
             Medium;
ground water
ppb
air
     Citation:  F8-8006,  Region VIII

Damage Incident No.  66;   Ground and  surface  contamination
     Source of release:   Inactive  site,  many types  of  wastes
     received from 1955-1965.   Contamination from  closed  drain
     discharge pipe,  overflow  from leachate  pond,  various seeps
     along landfill banks.
     Resulting contamination;

     Chlorinated substances:
 Concentration:
     vinyl chloride                   182  ppb
     dichloroethane                   224
     1,1-dichloroethane               413
     trans-l,2-dichloroethylene     5,697
     trichloroethylene              1,094
     tetrachloroethylene               616
     ethylbenzene                     100

     chloroethane                      18  ppb
     vinyl chloride                    15
     trans-l,2-dichloroethane          309
     benzene                           41

     Citation; F8-3005-2,  Region VIII
             Medium:

             groundwater
             (on-site)
                        surface wate
                        (on-site)
                              C-33

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      i n
Damage Tn^$
-------
  F£" I 0 .-"•*
Damage Incident No. 69:  Contamination of bay, surrounding groundwater,
                         surface water, soils, sediments


     Source of release;  Many industrial/chemical facilities in
     surrounding area which dumped and/or disposed their wastes
     directly on the ground on in the bay.

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium;

     chlorinated organics           not available          water and
     (not specified)                                       sediment

     Citation: Region X, FIT files
Damage Incident No. 70;  Potential aquifer contamination


     Source of release:  Unlined surface impoundments, central
     pond at waste disposal site which accepted industrial
     wastes, sludges, oils, solvents from 1955-1964.

     Resulting contamination:

     Chlorinated substances:        Concentration;         Medium:

     volatile halogenated           "hazardous levels"     ponds on
     organics                                              site

     Citation; Region X, 110-8005-001
                              C-35

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Damage Incident No.71 ;   Soil, surface, drinking and ground water
                         contamination

     Source of release;   Disposal site using open pit for oil-
     based mud as well as tanks and vessels.  Runoff from pit
     eventually reaches a river.

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium:

     methylene chloride             27 ppb                 ground water
     1,1,-trichloroethane          260
     tetrachloroethylene            40
     benzene                     1,500
     chlorobenzene               3,100
     1,2,4-trichlorobenzene         44

     benzene                     1,500 ppb                 dtinking wate

     Citation; F06-8008-035, Region VI


Damage Incident No. 72;    Soil, surface and ground water contamination,
                          air contamination indicated.

     Source of release;   Hazardous waste facility consisting of 7
     unlined excavations.  Has overflowed numerous times.  Vinyl
     chloride manufacturing wastes accepted, as well as other chemical
     wastes.  Drums also being stored.

     Resulting contamination;

     Chlorinated substances;        Concentration:         Medium;

     1,1-dichloroethane             17,800 ppb             soil
     benzene                        17,300
     PCB                            34,700

     1,1,2-trichloroethane           3,700 ppb             surface watei
     napthalene                    980,000
     vinyl chloride                     19 ppb             air

     Citation; TX 43, FIT files, Region VI
                              C-36

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:?~ 10 19C4
   age Incident No.  73;  Drinking water contamination
     Source of release;  Inactive surface impoundment with
     3 disposal pits, pond, and leaking deteriorated drums.
     Resulting contamination;

     Chlorinated substances;

     PCB's
     1,2-dichloroethane
     1,1,2-trichloroethane
     1,1,2,2-tetrachloroethylene
     benzene
     toluene
     ethyl benzene

     chloropropene
     benzene
     toluene

     Citation; TX 00027, Region VI
 Concentration;

 1.4  ppb,  1.2 ppb,
 1.0  ppb

 8,000,000 ppb
   250,000
   200,000
 2,000,000
   550,000
   250,000

         3 ppb
        20
         5
 Medium;

private wells


pond sludge
pond water
Damage Incident No.  74;  Ground water and soil contamination
     Source of release;  Inactive surface impoundment and storage
     tanks accepting a wide variety of wastes.
     Resulting contamination;

     Chlorinated substances;

     1,1,2,2-tetrachloroethane
     benzene
     1,2-dichlorobenzene
     hexachlorobenzene
 Concentration;

 11,000  ppb
     40
(not available)
  3,930  ppb
 Medium;

 groundwater
 (on-site)

 soil
     Citation; LA-00167, 06-LA-0041, Region VI
                              C-37

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 rr^ < •  *<-(-
 bRA
Damage Incident No.  75:   Soil  drinking well,  surface and ground-
                         water contamination

     Source of  release;   Open  dump,  surface impoundment, storage area
     for tanks  and drums,  solvent  recycling/reclamation, and a midnight
     dump area.   Waste  solvents  stored in numerous unlined pits.  A
     number of  leaks and  spills  have  occurred at the site.
     Resulting  contamination:

     Chlorinated  substances;

     methylene  chloride
 7 drinking wells

 26-42 ppb
     carbon  tetrachloride
     trichloroethylene
     benzene
     toluene
 lagoon surface;

 14 ppb
295  "
 10  "
174  "
lagoon waste
   water;

6,401  ppb
  443   -
4,983   "
     1,1,1-trichloroethane     440
     1,1,2-trichloroethane
     trichloroethane         1,100
     toluene                   200
     naphthalene
                                   soil samples, on site (ppb)
    560

    320
    290
    210
4,480
6,700
4,700
27,900
5,100
46,000
1,200
2,500
120
-
560
380
     Citation;   Region  VI,  OK108,  06-OK-0002  (F06-8005-006,
               8008-032,  and  8104-007)
                              C-38

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 FEB 10 1:'34
        rr
Damage Incident No. 76:   Ground water contamination


     Source of release:  Inactive landfill with deposited resin,
     solvent, and other wastes.

     Resulting contamination;

     Chlorinated substances:        Concentration:         Medium;

     vinyl chloride                 27 ppb                 ground water

     Citation; MD-0480, 03-MD-0003 (F3-8009-07, F3-8102,02)
               Region III
Damage Incident No.  77:   Ground water contamination


     Source of release;  Active landfill accepting industrial and
     other wastes, with no current disposal of hazardous wastes.

     Resulting contamination;

     Chlorinated substances;        Concentration:         Medium:

     benzene                        42 ppb                 ground water
                                                           (on site)

     vinyl chloride                 79 ppb                 leachate
                                                           stream

     Citation; Region III files
                              C-39

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FCB 10  ;S
Damage Incident No. 78:  Drinking well and air contamination


     Source of release;  Unlined surface impoundment with wastes
     containing high levels of trichloroethylene.  Drinking
     wells closed in area.   A documented death has been caused
     to a worker by trichloroethylene fumes.

     Resulting contamination;

     Chlorinated substances:        Concentration;         Medium;

     trichloroethylene              human mortality        air
                                    level

     trichloroethylene              not available          drinking
                                                           water wells

     Citation; 03-VA-0003 (F3-8102-06, F3-8010-17) Region III
Damage Incident No. 79;   Drinking well contamination


     Source of release;  Chemical manufacturing facility where
     an organic solvent spill is believed to have contaminated
     ground and drinkig water in area.

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium;

     carbon tetrachloride           86 ppb                 drinking well
     1,1,1-trichloroethane          99  "
     trichloroethylene             288  "
     tetrachloroethylene            80  "
     toluene                        83  "
     dichlorobenzene               108  "

     Citation; PA-01290, Region III
                              C-40

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FEB 10 19-4
DRAFT
  Damage Incident No.  80:   Drinking  and ground water contamination


       Source of release:   Old  iron  mine which accepted trichloroethylene
       wastes and PC3  wastes.

       Resulting contamination;

       Chlorinated substances;        Concentration:         Medium;

       trichloroethylene              43 ppb                 drinking wate.
                                                            wells and
                                                            groundwater

       Citation; PA-01360,  Region  III
  Damage Incident No.  81:   Surface water  contamination


       Source of  release;   Municipal landfill which accepted industrial
       wastes.   Leachate  lagoon  has leaked and contaminated adjacent
       surface  water.

       Resulting  contamination;

       Chlorinated substances;        Con centration;         Medium:

       methylene  chloride             1,000 ppb              surface water
       vinyl chloride                   200  "               (on site)
       1,1-dichloroethane                 20  "
       trans-1,2-dichloroethylene     1,000  "
       1,1,2-trichloroethane              30  "
       trichloroethylene                  70  "
       benzene                            20  "
       toluene                            90  "


       Citation:  PA-02120,  Region III
                               C-41

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  o 10  r;;.i
Damage Incident No. 82;  Water supply wells contaminated
     Source of release;  Historical disposal of a variety of
     industrial waste sludges in an abandoned lagoon.  Ten
     wells closed from contamination.
     Resulting contamination;

     Chlorinated substances;

     tr ichloroethylene
     perchloroethylene
     Concentration:
   Medium:
detected; concentrations    drinking wells
not available
     Citation: PA-01140, Region III
Damage Incident No. 83:  Public water supply wells and soil
                         contamination

     Source of release;  Documented extensive spills and leaks at
     a manufacturing facility using 1,1,1-trichloroethane and
     trichloroethylene for degreasing.
     Resulting contamination;

     Chlorinated substances:

     1,1-dichloroethane
     1,1,1-trichloroethane
     tr ichloroethylene
     tetrachloroethylene

     1,1,1-trichloroethane
     1, 2-d ichl or oe thane
     1,1-dichloroethylene
     1,1,1-trichloroethane
     tr ichloroethylene
     Concentration;

     not available
           H
     2.10 ppb
      .20  "

    28.    ppb
     0.70  "
     2.10  "
     2.2
     2.3
   Medium;

public drinking
water
   driveway soil
     Citation; PA-10100, PA-272 (FIT 03-8006-11), Region III
                              C-42

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DP A FT
    10 JUPJ
Damage Incident No.  84:  Air, soil and ground water contamination


     Source of release;  Chemical manufacturing company with poor
     housekeeping, leading to spillage and odors, decaying drum
     storage.   Wastewater too toxic for treatment is discharged
     to a lagoon.
     Resulting contamination;

     Chlorinated substances;        Concentration;          Medium:

     trichloroethylene              1,100 ppb              air
     toluene
     methylene chloride
     perchloroethylene
     benzene
 Concentration;

 1,100 ppb
27,000  "
 "ppm range"
  22-6,000 ppb
     methylene chloride
     chloroform
     1,2-dichloroethylene
     1,2-trans-dichloroethylene
     trichloroethylene
     tetrachloroethylene
     benzene
     toluene
     Citation; 03-PA-0071 (WV-0740, WV-71),  Region III
Damage Incident No.  85;   Soil and drinking well contamination
     Source of release:   Storage site and paint manufacturing
     facility containing leaky drums with organic solvents,
     paints and paint sludges.
  ground water
  (on site)
     Resulting contamination;

     Chlorinated substances:

     trichloroethylene
     tetrachloroethylene
     toluene
     ethyl benzene
 On-site  well
 129  ppb
 153   "
  Drinking well
  on adjacent
  property;	

  7 ppb
220  "
  2  "
     Citation;  PA-172,  PA-02970,  Region III
                              C-43

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Damage Incident No. 86;
                    Air, residential well, surface and ground
                    water contamination
     Source of release:  Municipal landfill which received industrial
     wastes which were buried in an old rock quarry.  Documented fish
     kills, oil spills.  Illegal hazardous waste disposal.  No cover
     on site.   Local drinking well is contaminated.
     Resulting contamination;

     Chlorinated substances:

     total hydrocarbons
     carbon tetrachloride
     chloroethane
     1,1-dichloroethane
     1,1-dichloroethylene
     1,1,1-trichloroethane
     benzene
     tr ichlorotoluene
                               Concentration:

                               60,000 ppb
                                   19 ppb
                                  318  "
                                  377  "
                                    4  "
                                  206  "
                                   14  "
                            3,000,000  "
Medium:
air
     Citation: PA-398, PA-10144 (03-8106-14) Region III

Damage Incident No. 87;  Surface and ground water contamination
     Source of release;  Injection of hazardous waste into a
     deep well.  Nearby reservoir in part contaminated by this
     source.
                                    Concentration;

                                    not available
Resulting contamination;

Chlorinated substances;

chloroform
1,1-dichlorethane
trichloroethylene
1,2-dichloropcopane
benzene
trichlorobenzene
toluene
naphthalene

Citation: PA-162, PA-2990 (03-PA-0040)  (F3-8009-013)
          Region III
Medium;

ground water
(nearby)
                              C-44

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    FED 1
Damage Incident No. 88:  Residential drinking watec and ground water
                         contamination
     Source of release;  Chemical waste disposal site with lagoons and
     a leachate collection system.  Contamination resulted from the
     lagoon despite collection system.
                                    Concentration:
                                    not available
Resulting contamination;

Chlorinated substances;

chloroform
ch1 oromethanes
chlorobenzenes
toluene

Citation; PA-181, PA-0112 (F3-8007-26) Region III
Medium:
drinking water
Damage Incident No. 89;   Drinking and groundwater contamination


     Source of release;  Landfill which allowed dumping of industrial
     and chemical wastes.  Sampling evidence suggests contamination
     has migrated to domestic wells.  Pools of leachate exist.
                                    Concentration:
                                    not available
Resulting contamination;

Chlorinated substances:

chloroform
vinyl chloride
1,1-dichloroethylene
tri chloroethylene

Citation: PA-290, PA-10061 (03-8105-39) Region III
Medium;

groundwater
(on sits)
                              C-45

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  FEB 1o  1934
Damage Incident No. 90:  Drinking well water,  surface water
     Source of release:  Major chemical  company discarded  5,100  tons
     of waste from vinyl chloride production, which  contained
     vinyl chloride, 1,2-dichloroethane  and trichloroethylene.
     Landfill is Inactive accepted industrial/chemical wastes
     from 19691971.  Organic vapors from leachate  stream
     detected.  Frequent fires and explosions.
     Resulting contamination;

     Chlorinated substances;

     methyl chloride
     chloroform
     chloroethane
     vinyl chloride
     1,2-dichloroethane
     1,1-di chloroethylene
     trans-1,2-dichloroethylene
     tri chloroethylene
     tetra chloroethylene
     toluene
     ethyl benzene
     napthanene

     methyl chloride
     chlor oethane
     vinyl chloride
     1,1-dichloroethane
     1,2-dichloroethane
     trans-1,2-dichloroethylene
     benzene
     toluene
     napthalene

     Citation: DE-28, DE-0130
 Concentration:

 38 ppb
 Not available
 1,300
 2,100
 1,900
 Not available
 38
 Not available
 158
 Not available
 Not available
 Not available

 Not available

 32 "
 41.	
351.	
Medium;

ground water
(on and off
  site)
drinking well
(nearby)
                              C-46

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 DRAFT
  fEB 10 1', . i
Damage  Incident No. 91:  Ground water  contamination


     Source  of release;  Polyvinyl  chloride manufacturing site
     of  major chemical manufacturer.   Facility has waste lagoons
     and landfills for waste disposal.

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium;

     chloroform                     Not available          ground water
     vinyl chloride
     chlorobenzene

     Citation: DE-9-1, DE-0260, Region III
                             C-47

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  DRA
  FEB lo !'.-•

Damage Incident No.  93:   Surface and  ground  water  contamination


     Source of release:   Industrial  landfill with  waste  storage
     piles.  Leachate stream flows  into surface  water.

     Resulting contamination;

     Chlorinated substances;        Concentration:          Medium:

     chloroform                     3 ppb                  leachate
                                                           stream
     carbon tetrachloride          20  "
     vinyl chloride                  2  "
     1,1-dichloroethane             20  "
     benzene                      100  "

     1,1-dichloroethane             30 ppb                  groundwater
     trichloroethylene             10  "
     tetrachloroethylene            0.3 "
     benzene                       10  "

     Citation: MD-9,  MD-0009,  Region  III
Damage Incident No.  94;   Potential drinking well  contamination


     Source of release;   Chemical manufacturing facility  with
     ^inactivecovered  waste lagoons.   Very high potential
     for drinking well contamination.

     Resulting contamination;

     Chlorinated substances;         Concentration;         Medium;

     chloroform                     Not available         waste  itself
     1,2-dichloroethane                  "
     1,1,1-trichloroethane              "
     toluene                            "
     napthalene                         "

     Citation; PA-2, PA-01810,  03-PA-0001  (F3-8010-26)  Region III
                              C-48

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DRAFT
    FEB I-, ' •-
Damage Incident  No.  95;   Soil, surface and ground water contamination


     Source  of release;   Polyvinyl chloride manufacturing plant
     of major chemical  company.

     Resulting contamination;

     Chlorinated substances;        Concentration;         Medium;

     1, 2-dichloroethane             Not available          surface water
     vinyl chloride                 Not available          groundwater
     tr ichloroethylene                     "

     Citation;

     DE-7-1, DE-0080  (2070-2 and 3) Region III
Damage Incident  No.  96;  Soil contamination


     Source  of release;    Incineration waste disposal facility with
     numerous spills  and leaking containers.

     Resulting contamination;

     Chlorinated substances;        Concentration;          Medium;

     carbon  tetrachloride           Not available          soil
     trichloroethylene                  "
     toluene                           "

     Citation:
                             C-49

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 DRAFT
 rr ~" " -  f o -• 1
 •'-'  '-1  , j .•->

Damage  Incident No.  97;    Drinking well  and  ground  water  contamination

     Source of release;   Chemical  company  that  stores hazardous wastes
     in  drums which  have leaked and spilled,  contaminating public
     drinking wells.

     Resulting contamination;

     Chlorinated substances;         Concentration;         Medium;

     tricolor: oethylene              Not  available          ground water
     perchloroethylene
     toluene

     Citation; DE-33,  DE-010001 (F3-8106-34)  Region III
Damage Incident No.  98;   Surface  and  groundwater  contamination


     Source of release;   Research and development facility.  Closed
     disposal site  on facility has contaminated vicinity.

     Resulting contamination:

     Chlorinated substances:        Groundwater:           Surface Water

     chloroform                    3,000  ppb              3,000 ppb
     carbon tetrachloride          1,000                  —
     1,2-dichloroethane             2,000
     1,1-dichloroethylene          30,000                  1,000
     1,2-dichloroethylene          2,000                  20,000
     trichloroethylene             3,000                  10,000
     1,1,2,2-tetrachloroethane     3,000                  30,000
     tetrachloroethylene           2,000                  9,000
     pentachloroethane            200,000
     hexachloroethane             200,000
     benzene                       2,000                  1,000
     chlorobenzene                 900,000                  1,000
     toluene                      400,000

     Citation; MD-65 (F3-8010-12)  Region  III
                              C-50

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 DRAF
    FEB 10 19 £4
Damage Incident No.99:   Soil  and potential  surface  and
groundwater contamination.

     Source of release;   Numerous spills  of product and  waste
     due to mishandling  at  facility which manufactures wide
     range of chlorinated and brominated  organic  chemicals.
     Wastes include  volatile  organic compounds, still bottom
     residues, alcohols,  lead residual, acids, alkalines,
     filter cakes,  acetone,  sludges, and  large quantity  of
     tr i chloroe thylene  and  polybrominated biphenyls.
     Resulting contamination;

     Chlorinated substances;

     drummed wastes,  not identified
         Concentration:         Medium:
         "confirmed spills"     ground
     Citation:  02-NJ-0062(02-3008-03-15),  Region  II
Damage Incident No.  100:   Soil  and  ground  water  contamination.
     Source of release;   Liquid  chemical  recycling  or treatment
     facility prior to 1973 with 6  lagoons.
     Resulting contamination;

     Chlorinated substances;

     hexachloroethane

     vinyl chloride
Concentration:

   40,000   ppb

7,300,000   ppb
Med ium:

soil

ground water
(monitoring well)
     Citation:  02-NJ-0043 (02-8010-33  and  02-8010-33A) Region II
                              C-51

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DRAFT
  FE3 i o  r :•
 Damage Incident No. 101;  Air contamination


      Source of release:  Municipal landfill with groundwater
      contamination and measured concentrations of vinyl chloride
      being emitted through the methane vents.


      Resulting contamination;

      Chlorinated substances;    Concentration:        Medium;

      vinyl chloride             20 - 100 ppb          3-5 vents

                               240 - 250 ppb          3 vents,
                                                        second monitorin

      Citation; 02-NY-0022 (02-8008-01) Region II
 Damage  Incident No. 102;  Air contamination


     Source of release;  Municipal facility located in resi-
     dential area.  Previous hazardous waste disposal at the
     site was not able to be documented.   Hazardous chemicals
     were detected in 4 of 6 vents tested.


     Resulting contamination;

     Chlorinated substances;     Concen tr at ion;         Medium;

     vinyl chloride              up to 43,000 ppb      4 of 6 air  vents
     methylene chloride           also found
     dichloroethylene
     tetrachloroethylene
     toluene

     vinyl chloride              60 - 80 ppb           school air


     Citation: 02-8009-02, Region II
                              C-52

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 DRAF
Damage Incident No.  103:   Drinking,  surface  and  ground water
contamination.

     Source of  release;   Storage  and treatment area  for waste
     organic chemicals and oils.   Unlined  lagoon.


     Resulting  contamination;

     Chlorinated substances;    Concentration;       Medium:

     1,2-dichloroethene         84 ppb               surface
     tr ichloroethylene         detected             water
     tetrachloroethylene        detected
     benzene                   90 ppb

     vinyl chloride             detected             lagoon
     1,2-dichloroethane            "
     trichloroethylene        1915 ppb
     tetrachloroethylene        detected
     benzene                   330 ppb

     benzene                     2 ppb            drinking
                                                  water

     Citation:  02-NJ-0003  (02-3010-01), Region II


Damage Incident No.  104:   Ground  and surface water contamination.


     Source of  release:   Solvent  reclamation and recovery
     facility.   EPA  files  document history of poor housekeeping,
     numerous spills,  and  leaks in the processing area.  Trench
     dug along  bay revealed  discharge of oily substance.


     Resulting  contamination;

     Chlorinated substances;      Concentration;       Medium:

     methylene  chloride           230,000 ppb          storm water
                                                       run-off

     chloroform                   50,000 ppb          groundwater
     dichloroethane                50,000 ppb            (trench)
     trichloroethane              18,000 ppb
     benzene                      1,050 ppb
     toluene                      25,000 ppb
     ethyl benzene                 3,000 ppb

     Citation;  02-NJ-0012  (02-8010-02), Region II
                              C-53

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DRAF
"r
Damage Incident No.  105:   Soil and potential drinking water
contamination.

     Source of  release: Unlined  lagoons used for wastewater
     treatment  by  printing  complex.
     Resulting  contamination;

     Chlorinated  substances;    Concentration;       Medium;

     methylene  chloride         "high levels"        outfall sewer
     chloroform                    "

     methylene  chloride             "                soil (lagoon
     chloroform                    "                vicinity)


     Citation:  02-NY-0005  (02-8006-03), Region II
Damage Incident  No.  106;   Ground water contamination


     Source of release;  Municipal landfill accepting industrial
     wastes.  Midnight dumping suspected.


     Resulting contamination;

     Chlorinated substances:     Concentration:             Medium;

     benzene                           15 ppb               groundwater,
     toluene                          1629 ppb               monitoring
                                                           wells
     Citation;  02-NY-0010  (02-8004-04), Region II
                             C-54

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DRA
FEB 10 1984

 Damage Incident No.  107;   Drinking and gcound water  contamination


      Source of release;   Municipal landfill  with confirmed
      allegationsofchemical dumping.   100 adjacent  drinking
      wells closed.   Residents have attributed adverse  physiological
      symptoms to this contamination.


      Resulting contamination;

      Chlorinated substances;      Concentration;         Medium;

      methylene chloride            275  - 2000 ppb        groundwater,
      chloroform                    75  -  535 ppb        monitoring wells
      1,1,1-trichloroethane        350  - 1360 ppb
      tetrachloroethylene                  7.6 ppb
      benzene                       50  -  220 ppb
      chlor o'oenzene                       27.1 ppb
      toluene                             3.2 ppb


      Citation;

      USEPA Region II files
 Damage Incident No.  108;   Ground water  contamination


      Source of release;   Landfill used  by  manufacturing  complex


      Resulting contamination:

      Chlorinated substances;      Concentration;      Medium:

      methylene chloride            2,500  ppb          ground water
      chloroform                   3,600  ppb
      carbon tetrachloride        30,000  ppb
      trichloroethylene             3,300  ppb
      benzene                      2,700  ppb
      toluene                      2,100  ppb
      ethyl benzene                   580  ppb


      Citation; 02-NY-0058 (02-8011-38)  Region  II
                               C-55

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FEB 10 1S:'
Damage Incident No. 109:  Air and ground water contamination
     Source of release:  Active municipal landfill
     Resulting contaminants:

     Chlorinated substances:

     vinyl chloride
     1,1,1-trichloroethane
     tetrachloroethylene
 Concentration;
 detected
 2.8 ppb
 3.4  "
   Medium:

   air - methanol
   vents

   ground water,
     leachate
     Citation; 02-NY-0080 (02-8011-60) Region II
Damage Incident No. 110:  Ground water contamination
     Source of release:  Abandoned site which may have received
     "midnight dumping" wastes.
     Resulting contaminants:

     Chlorinated substances

     1,2-dichloroethane
     tetrachloroethylene
     benzene
     chlorobenzene
Concentration;

4,065 ppb
2,157
  655
1,901
Medium;

ground water
  (monitoring well)
     Citation; 02-NJ-0004 (02-8006-04(8)), Region II
                              C-56

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FEB 1C 1984

Damage Incident No. Ill;  Ground water contamination
     Source of release;  Inactive landfill, which accepted
     large amounts of chemical wastes, with estimated burial of
     30,000 - 50,000 55-gallon drums.
     Resulting contamination;

     Chlorinated substances;

     methylene chloride
     chloroform
     chlorobenzene
 Concentration;

 50,600 ppb
 52,600 ppb
 36,600 ppb
   Medium;
   ground water
     (on- site)
     Citation; 02-NJ-0033 (02-8105-05), Region II
Damage Incident No.  112;  Surface water contaminaiton
     Source of release;  Active hazardous waste landfill.
     Explosion of drums containing unidentified waste chemicals
     killed bulldozer operation in 1974.  An estimated 71,000
     gallons of hazardous and chemical liquids, oil, sludge and
     other liquid wastes had been accepted.  Leachate observed
     escaping from landfill.  A pool seepage area collects
     leachate and then discharges into a creek.
     Resulting contamination;

     Chlorinated substances;

     trichloroethylene
     1,2,4-trichlorobenzene
Concentration;

 5,100 ppb
11,800 ppb
Medium;

surface water,
on-site leachate
pool
     Citation;  Region II files
                              C-57

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          1934
Damage Incident No. 113:  Drinking water and soil  contamination
     Source of release;  Inactive landfill which acceoted  large
     quantity of industrial and chemical wastes.
     Resulting contamination;

     Chlorinated substances;

     chloroform
     dichloroethane
     trichloroethylene
     benzene
     chlorobenzene
     toluene

     chloroform
     vinyl chloride
     1,2-dichloroethane
     trans-1,2-di chloroethylene
     tr i chlor oethylene
 Concentration;

   139 ppb
 2,300 ppb
   440 ppb
 1,400 ppb
   920 ppb
 5,000 ppb

  detected
   Medium;

   soil, outside
     landfill
     (highest
      concentratior
   adjacent drinkir
     wells
     Citation; 02-NJ-0005 (02-8006-05a), Region  II
Damage Incident No. 114;  Drinking water contamination
     Source of release;  Active municipal landfill which accepted
     300 drums per year and empty bags of raw materials still
     containing thousands of pounds of chemical  components  such
     as vinyl chloride, PVC, etc., from one major chemical
     manufacturer.
     Resulting contamination;

     Chlorinated substances;

     vinyl chloride
Concentration:
"detected"
Medium;

drinking water,
nearby plant
     Citation; USEPA S&A Division files, Region II
                              C-58

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Damage Incident No. 115;  Drinking well contamination


     Source of release: Landfill primarily for municipal wastes.
     Private drinking well closed after contamination.


     Resulting contamination;

     Chlorinated substances;      Concentration;        Medium;

     methylene chloride              4 ppb              drinking well
     chloroethane                    4  "                  (highest value:
     1,1-dichloroethane              1  "
     trans-1,2-dichloroethylene     11  "
     benzene                         2  "
     chlorobenzene                   4  "


     Citation; USEPA S&A Office files, Region II
Damage Incident No. 116;  Drinking Well Contamination


     Source of release;  Manufacturing facility of a large
     volume producer of vinyl chloride up to 1975.  Liquid
     wastes from this process were disposed of in at least 3
     of 6 recharge basins on site.  Since then, wastes were
     stored in unmarked drums.   14 wells on adjacent plant
     closed due to vinyl chloride contamination.

     Resulting contamination;

     Chlorinated substances:     Concentration:      Medium:

     vinyl chloride              detected            drinking wells
     Citation;  Region II files
                              C-59

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    FEB 10 19 >4

Damage Incident No.117 :  Potential ground water  contamination


     Source of release;  Municipal landfill which alledgedly
     received hazardous wastes illegally.


     Resulting contamination:

     Chlorinated substances;      Concentration;        Medium;

     methylene chloride           1.1 ppb               leachate pond
     chlorobenzene               71.   "                   sediments
     toluene                      6.6  "
     ethyl benzene


     Citation: Region II S&A Files
                              C-60

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   FEB 10 1934
Damage Incident No. 121;  Surface water contamination
     Source of release;  Abandoned landfill facility.
Resulting contamination;

Chlorinated substances;

carbon tetrachlor ide
toluene
ethyl benzene
m,p-xylene

toluene
ethyl benzene
o-xylene
 Concentration

 750,000 ppb
 750,000  "
   3,500  "
   3,000  "

     266  "
      80  "
      55  "
                                                        Medium;
                                                        pond
                                                        spring
     Citation: Region II S&A Files
Damage Incident No. 122;  Surface water contamination
     Source of release;  Inactive landfill
Resulting contamination;

Chlorinated substances;

methylene chloride
chlorobenzene
Concentration

58 ppb
28  "
                                                     Medium;

                                                     leachate
                                                       stream
     Citation ;  Region II S&A Files
                              C-61

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   FEB 10 \^A

Damage  Incident No. 123:
                          Drinking well and ground water
                          contamination
     Source of release:  Lanfill facility over water table at
     depth of 10 feet, directly over an aquifer recharge  zone.
     Six private drinking wells contaminated, with 50 more in
     path of leachate plume.  Site closed in 1976, opened in
     1978 and now under appeal.
     Resulting contamination;

     Chlorinated substances;

     chloroform
     tr i chlor oethane
     trichloroethylene
     toluene
     xylene
                                  Concentration;

                                  2,600 ppb
                                  1,500  "
                                    220  "
                                    390  "
                                    350  "
Medium;

ground water,
  near site,
     Citat i on;  Region II S&A Files
Damage Incident No. 124;  Ground water contamination
     Source of release;  Inactive landfill used by a major
     chemical manufacturing company since 1930.  Company
     voluntarily discontinued use of site and  capped it, as
     well as installing monitoring wells.
     Resulting contamination;

     Chlorinated substances:

     1,1,1-trichloroethane
     tr i chloroethylene
     tetrachloroethylene
                                 Concentration:
Medium:
                                 40,000 - 402,000 ppb   ground water
     Citation:  Region II S&A Files
                              C-62

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Damage Incident No. 125;  Ground water contamination
     Source of release;  Municipal landfill which was closed in
     1974.  An area of up to 100 buried drums was observed.
     Resulting contamination:

     Chlorinated substances;      Concentration;        Medium;

     dichloromethane              122 ppb               leachate
                                                          sediments

     vinyl chloride               150 ppb               leachate
                                                          stream


     Citation; Region II S&A Files
                              C-63

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Damage Incident No. 127;  Surface water contamination
     Source of release;  Site used by owner for dumping waste
     chemicals, solids, and carcasses.  Citizen complaints of
     odors.  Local chronic effects have rendered the site and
     acreage unsuitable for future development.
     Resulting contamination;

     Chlorinated substances:     Concentration:
     methylene chloride
     chloroform
     1,1-dichloroethane
     1,2-dichloroethane
     1,2-dichloroethylene
     1,1,1-trichloroethane
     tr ichloroethylene
     tetrachloroethylene
     benzene
     chlorobenzene
     xylene
     toluene
  (A)

  7 ppb
116
 13
717
  8
 98
 61
  8

  7
 15
 (B)

13,500  ppb

   120
 2,000

 1,800
 7,500

   500

   800
 2,000
                           Medium:
2 surface
  water sam
     Citation; 02-8009-03, Region II


Damage Incident No. 128;   Drinking and surface water contamination


     Source of release;  Active municipal landfill leachate
     streams and stains detected in several areas of site,
     entering surface ponds and subsequently flowing to creek.
     Strong odors detected at the leachate area, and slight
     headaches were developed by the inspection team.  Site is
     fenced only on one side.  Private resident drinking water
     well adjacent to site contaminated.
     Resulting contamination;

     Chlorinated substances;

     d i chlor ome thane
     1,1-d ichloroethylene
     1,2-dichloroethylene

     Citation: Region II files
Concentration:

   132 ppb
17,000 ppb
   720 ppb
               Medium;

               drinking water
                 well
                              C-64

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   nt> A rr
   1  j  ,  f
Damage Incident No.  125;   Surface water and possible  source  of
                          drinking well contamination.


     Source of release;   Landfill facility.   Leachate may be
     entering brook.   Private drinking wells closed  from
     contamination,  but  this site has not been determined to be
     the source.
     Resulting contaminants;

     Chlorinated substances;            leachate tank          leachate

     chloroethane                       1,200  ppb               ---
     1,1-dichloroethane                   590                    560
     trans-1, 2-dichloroethylene            480                    ---
     1,1 ,1-trichloroethane               ---                    250
     benzene                           33,000                    320
     chlorobenzene                      6,200                    920
     1 ,4-dichlorobenzene                1,400                    ---
     toluene                           54,000                  5,000
     ethyl benzene                     34,000                  1,400
     napthalene                        16,000                    700


     Citation; Region II,  S&A Files
                              C-65

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     DttAi
          0 7994
Damage Incident No. 1-30:  Ground water contamination


     Source of release:  Active chemical manufacturing site
     making various phenolic resines and related compounds.
     Sludges from wastewater treatment system are dewatered and
     placed on ground in piles.  On site incineration of waste
     distillates, solvents, and still bottoms currently practices
     leaking drum storage area.


     Resulting contamination;

     Chlorinated substances;          Concentration;       Medium;

     trans-1,2-dichloroethylene           16               ground water,
     trichloroethylene                    12                 at intercep
     benzene                             800
     chlorobenzene                     2,060
     toluene                          33,020
     ethyl benzene                    51,780

     * units of concentrations were not available


     Citation;  Region II, files
                              C-66

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      FEB 10 rgcj

Damage Incident No.  131;  Surface water contamination
     Source of release; . Improper storage of drums and barrels
     by a waste hauler.  Sewer system was contaminated, resulting
     in acute symptoms from hexachlorocyclopentadiene in workers
     at a municipal waste treatment plant.  Towns down river of
     the release of sewage containing the hexachlorocyclopentadiene
     had to be alerted.

     Resulting contamination;
     chlorinated substances
     hexachlorocyclopentadiene
"predominant contaminant"
     Citation;  Proceedings; The 1978 National Conference on
     Control of Hazardous Material Spills.  Miami Beach, Florida.
     April 11-13,  1978.
  Damage Incident 132;  Ground and surface contamination


     Source of release;  Drum burial of pesticide wastes
     containing hexachlorocyclopentadiene by manufacturer since
     1964.   Wastes migrated vertically 90 feet and laterally 25
     feet,  from a U.S.G.S.  sutvey taken in 1966-1967.  Adjacent
     drinking water wells were contaminated, as well as surface
     water  run-off.
     Resulting contamination;

     Chlorinated substance;

     hexachlorocyclopentadiene
                Medium;

         "drinking wells contaminated
          to a hazardous level."
     Citation;   OSW Hazardous Waste Division,
                Hazardous Waste Damage Incidents,
                unpublished, open file, 1978.
                              C-67

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                        APPENDIX C




PHYSICAL/CHEMICAL CONSTANTS, TOXIC CONSTITUENTS OF CONCERN
Toxicant of Concern
Methyl chloride (chlorcme thane)
Methylene chloride (dichlorcmethane)
Chloroform (trichlorcme thane)
Carbon tetrachloride
Vinyl chloride (chloroethene)
1, 1-Dichloroe thane
1 , 2-Dichloroe thane
trans- 1 , 2-Dichloroe thylene
1 , 1-Dichloroethene (vinylidene chloride)
1,1,1-Trichloroethane (methyl chloroform)
1,1, 2-Tr ichloroe thane
Trichloroethylene ( trichloroethylene)
1,1,1, 2-Tetrachloroethane
1 , 1 , 2 , 2-Te trachl oroe thane
Sol.
H20
20°
(ppm)
6.45xl03
2.0xl04
8.2x103
785
2.3x103
5.5x103
8.69xl03
600
400
720
4.5x103
1.1x103
- -
2.9x103
Kow
8.9
18.2
91
912
17
63
30
17
69
320
117
69
- -
460
M.P.
°C
-97.73
-95
-63.5
-22.99
-153.8
-96.98
-35.36
-50
-122.1
-30.41
-36.5
-73
_ _
-36
B.P.
°C
-24.2
39.75
61.7
76.54
-13.37
57.28
83.47
47.5
37
74.1
113.7
87
130.5
146.2
                                      b-1

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 t ••.-;; r.n--icnt;-! Protection Agency
    " •  '••'"•••/
 .  ' v~i D•>•,•< -M-crn St/iet
ago, iliinois   60604

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        JP!
(continued)
Toxicant of Concern
Perchloroethylene ( tetrachloroethylene)
Pentachloroe thane
Hexachloroethanet
Allyl chloride (3-chloropropene)
1 , 2-Dichloropropane
1 ,3-Dichloropropene
2-Chloro-l,3-butadiene (chloroprene)
Hexachloro-1 , 3-butadiene
Hexachlorocyc lopentad iene
alpha-Hexachlorocyc lohexane
beta-Hexach 1 orocyc lohexa ne
gamma-Hexachlorocylohexane (lindane)
delta-Hexachlorocylohexane
Benzene
Sol.
H2O
20°
(ppm)
200
120
50
3.6xl03
2.7xl03
2.7xl03
<17%
2.0
1.8
1.63
0.24
7.8
31.4
1.78xl03
KOW
280
3.64
4.2xl04
- -
105
54
- -
1.82xl03
l.OxlO4
7.8xl03
7.8xl03
7.8xl03
7.8xl03
135
M.P.
°C
-22.7
101.3
186.8
-134.5
-100
- -
-130
-21
-9.9
157
309
112.9
138
5.5
B.P.
°C
121
137.9
186
45
96.8
104.3
59.4
215
239
- -
- -
- -
- -
80.1
                                    b-2

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