PA/530/SW-151.2
IECEMBER 1975
hazardous
re
ports
document no.
2
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An environmental protection publication (SW-151.2) in the solid waste
management series. Mention of commercial products does not constitute
endorsement by the U.S. Government. Editing and technical content of
this report were the responsibilities of the Hazardous Waste Management
Division of the Office of Solid Waste Management Programs.
Single copies of this publication are available from So'id Waste
Information, U.S. Environmental Protection Agency, Cincinnati, Ohio
45268.
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HAZARDOUS WASTE DISPOSAL DAMAGE REPORTS
This publication (SW-151.2), the second in a series of reports
to document incidents of improper land disposal of hazardous wastes,
was prepared by the Office of Solid Waste Management Proqrams
U.S. ENVIRONMENTAL PROTECTION AGENCY
1975
(^K'RA F^
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HAZARDOUS WASTE DISPOSAL DAMAGE REPORTS
On June 30, 1973, the U.S. Environmental Protection Agency (EPA)
submitted a report to the U.S. Congress on the subject of hazardous
waste disposal as Jiad been required by the Solid Waste Disposal Act
Amendment of 1970.' That report concluded that the prevailing methods
of land disposal of hazardous wastes are largely inadequate and cited
numerous case studies pertaining to improper hazardous waste management.
Since the 1973 Report to Congress, EPA has continued to study hazardous
waste disposal. A portion of these st"dies has consisted of more detailed
investigations of improper land disposal practices to determine their
impact on public health and on the environment. Case studies have been
compiled within the framework of these investigations.
The problems associated with improper land disposal of hazardous
wastes--unlike the problems of air and water pollution—have not been
widely recognized by the public, although the damages may be as severe
and difficult to remedy. In addition, the hazardous waste disposal
problem continues to become even more significant, as the progressive
implementation of air and water pollution control programs, ocean
dumping bans, and cancellation of pesticide registrations results
in increased tonnage of land-disposed wastes, with adverse impact on
public health and the environment. The problem is manifested in ground-
water contamination via leachate, surface water contamination via runoff,
air pollution via open burning, evaporation, sublimation and wind
erosion, poisonings via direct contact and through the food chain, and
fires and explosions at land disposal sites.
The objective of publishing these damage reports is to bring about
national awareness of the problem, which is essential to its solution.
These reports will be published from time to time as resources permit.
No systematic effort has been made to concentrate on any one parameter
of interest, be it geographical, industrial, type of disposal site, or
type of damage. Similarly, it is not the purpose of this series of
reports to single out any particular person, firm, or industry. Cases
are investigated as information becomes available. The only criteria
used in the selection of incidents for these reports are:
oseverity of damage
oavailability of supporting information
oavailability of EPA personnel for investigation
The data base for these damage reports varies widely. In some
instances, official public records will be available for documentation;
however, in most cases the reports will have to be based on inspection
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by EPA personnel, interviews with parties involved or having first-
hand knowledge of specific incidents, technical investigations by
consulting firms, newspaper accounts, etc.
The authority for the publication of such reports derives from
Sec. 204 (a)(l) ..id (b)(l) of the Solid Waste Disposal Act of 1965
(P.L. 89-272)—as amended by P.L. 91-512, P.L. 93-14, and P.L. 93-611
CONTENTS
Page
Dioxin Poisoning Caused by Improper Waste Disposal in
Missouri 1
Contamination of Groundwater Beneath the Rocky Mountain
Arsenal and Surrounding Area 5
Dumping into Sand Pit Pollutes Domestic Wells in Texas 9
PREVIOUS DAMAGE REPORTS
EPA Publication No. SW-151
Arsenic Poisoning in Minnesota
Industrial Waste Disposal on Farmland in Illinois
Fatality at a New Jersey Industrial Landfill
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT
January 1976
Pioxin Poisoning
Caused by Improper Waste Disposal in Missouri
1. Personal Damage - Toxic illness of varying degrees affecting ten
persons. The worst illness occurred in a six-year-old girl
who suffered an inflammatory reaction of the kidney and
bladder bleeding, requiring hospitalization and surgery.
Le<;s severely affected persons developed diarrhea, headaches,
nausea, polyarthralgias, and persistent skin lesions.
2. Environmental Damage - Contamination of the soil with an extremely
toxic substance in three horse arenas and a farm road. The
death of six dogs and twelve cats, and the destruction of a
large number of birds and insects.
3. Economic Damage - The death of at least 63 Appaloosa and quarter
horses, which resulted in loss of business and subsequent
sale of one of the horse arenas. Also, medical expenses and
cleanup costs. The estimated total financial loss, based on
filed lawsuits (excluding punitive damages), is close to
$500,000.
4. Cause of Problem - Contact with soil containing 2,3,7,8-tetra-
chlorodi benzodi oxi n (TCDD, commonly referred to as dioxin),
a contaminant in the waste oil which was sprayed in three
horse arenas and a farm road as a dust control measure.
5. Type and Quantity of Hazardous Waste - Approximately 4,000 to
5,000' gallons" of waste oil containing about 300 ppm dioxin
was sprayed on the affected areas.
6. Source of Waste - The waste oil was obtained by Bliss Waste Oil
Co. from North Eastern Pharmaceutical and Chemical Co.,
where industrial waste residues from hexachTorophene pro-
duction were kept in a storage tank.
7. Date of Incident - The dioxin-contaminated waste oil was
sprayed on three horse arenas and a farm road in
May and June 1971. Birds died within three days and
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the first horse within four weeks of the spraying.
Horses exposed to the contaminated arena soil in
May and June 1971 continued to die as late as
January 1974.
8. Location - Near the towns of Moscow Mills, Fenton,
New Blcornfield, and St. James, Missouri.
9. Status - Remaining 4,600 gallons of dioxin-contaminated
distillate residues are in an industrial storage tank.
State and Federal officials are actively seeking a
safe disposal method for the material.
10. Remedial Action Taken - The contaminated soil was ex-
cavated during the period from October 1971 to August
1974 and graded under a new concrete highway, dumped
at a sanitary landfill, and in one case (before
the identification of dioxin) used as residential
landfill.
11. Legal Action Taken - Two law suits, for a total of $954,000
in compensatory and punitive damages, have been filed
by the former owners of one of the horse arenas
against Bliss Waste Oil Co., North Eastern Pharma-
ceutical Co., and Independent Petrochemical Corp.
Also, a lawsuit for $60,000 has been filed by several
horse owners against one of the other two horse arenas.
12. Narrative - In August 1971, a six-year-old girl was
admitted to a Missouri children's hospital with
severe bladder pain, urinary urgency, and inability
to pass urine. She was listless, had been bleeding
from the nose, and had diarrhea and a headache.
Over a period of several hours she gradually was
able to void in small amounts, but her urine was
grossly bloody. Her case was diagnosed as acute
hemorrhagic cystitis with signs of focal pyelo-
nephritis.
A significant clue in this case was that the
child lived on a farm where many animals had recently
died. Following the spraying of the farm's horse arena
in late May with waste oil for dust control, numerous
birds, cats, dogs, and horses developed a mysterious
fatal illness. The child was known to have played fre-
quently in the soil of the horse arena during the summer,
as in a sand box.
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Analysis of soil samples taken from the arena initially
identified a complex mixture of organic compounds, including
trichlorophenol and polychlorinated biphenyls. The toxic
agent responsible for the outbreak of poisonings was ultimately
identified as dioxin, one of the most toxic chemicals known.
Based on animal studies, both the oral and the dermal lethal dose
for humans have been established in the range of micrograms per
kilogram body weight.
Dioxin is a by-product from the manufacture of the herbicide
2,4,5-trichlorophenoxyacetic acid (2,4,5-T) and related
compounds. The Hoffman-Taff Company's production of 2,4,5-T in
Verona, Missouri, was terminated in February 1969. The company
was subsequently acquired by Syntex Agribusiness, Inc. The new
owners of the manufacturing facility sold the equipment and
leased the plant space to the North Eastern Pharmaceutical and
Chemical Co. (NEPACCO) which produced trichlorophenol as an
intermediate for the manufacture of hexachlorophene. The toxic
by-product dioxin is also formed in the manufacture of trichloro-
phenol. The residues containing a high concentration of dioxin
were emptied for about 1 1/2 years into a large storage tank
on the site.
Periodically, the residues were hauled away by a disposal
company to Louisiana for incineration. In 1971,
NEPACCO contracted with Indeoendent Petrochemical Corp. (IPC)
of St. Louis for $4,625 to dispose of the residues. Not
actually equipped to handle waste disposal, IPC subcontracted
with the Bliss Waste Oil Co. to remove the material. The
company is owned and operated by Russell Bliss, who
deals in waste oil, lubricants, organic solvents, and
transformer oils generated by automobile service stations
and industrial sources. For many years, Mr. Bliss has been
spraying the nonrefinable grades of waste oils on horse
arenas as a means of dust control.
From February to October 1971, the Bliss Waste Oil Co.
transferred six truckloads (approximately 18,000 gallons) of
industrial residues containing about 300 ppm dioxin from
NEPACCO's storage tank in Verona to its own storage tanks in
eastern Missouri. Mr. Bliss received no payment from IPC but
was paid by the horse arena owners where he sprayed the oil.
Three horse arenas and a farm road on Mr. Bliss1 own property
are known to have received the dioxin-contaminated oil. The
dioxin concentration of the soil in the most seriously affected
horse arena was analyzed at about 30 ppm. The overall toll in the
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four disposal areas can be summarized as follows: ten persons
developed toxic symptoms (two children became seriously ill),
and at least 63 horses died along with 6 dogs, 12 cats, 70
chickens, hundreds of birds, and numerous rodents and insects.
In addition, there were 26 known abortions and 6 birth
abnormalities among the horses. The toxicological as well
as other aspects of this case have been well documented. ^'^
NEPACCO went out of business in December 1971. The
Verona manufacturing facilities reverted to Syntex Agribusiness,
Inc., which disclaims all legal responsibility for the inherited
4,600 gallons of toxic residues in the industrial storage tank.
Syntex has expressed willingness, however, to pay for the safe
disposal of the wastes. Several alternative disposal methods
have been considered, including incineration at sea.
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT
January 1976
Contamination of Groundwater
Beneath the Rocky Mountain Arsenal and"Surrounding Area
1. Personal Damage - None
2. Environmental Damage - Contamination of 30 square miles of a
shallow water table aquifer. Contamination of soil by toxic
substances (aldrin and dieldrin). in the vicinity of a for-
merly used unlined holding pond. Mild earthquakes in the
vicinity of the Arsenal. Occasional waterfowl kills.
3. Economic Damage - Contamination and temporary abandonment of 64
domestic, stock, and irrigation wells. Damage to crops on
6 1/2 square miles of farmland adjacent to the Rocky Mountain
Arsenal. The loss of one million dollars for the construction
of a waste injection well which had to be abandoned when
the deep-well disposal resulted in earthquakes.
4. Cause of Problem - Infiltration of industrial wastes from
unlined holding ponds into a shallow water table aquifer
and subsequent migration of the contaminants through the
groundwater. Deep-well injection of large volumes of
liquid wastes, resulting in earthquakes.
5. Type and Quantity of Hazardous Waste - A complex mixture
of chemical by-products from the manufacture of
pesticides and herbicides, and from the past manufacture and
destruction of some chemical warfare agents. Substances
identified in the groundwater include aldrin, dieldrin,
endrin, diisopropylmethylphosphonate (DIMP), and
dicyclopentadiene (DCPD). Volume of waste infiltration is
unknown due to the unavailability of records of amounts of
wastes discharged into the various holding ponds.
6. Source of Waste - Chemical manufacturing operations at the
Rocky Mountain Arsenal, carried on by the U.S. Army Chemical
Corps and the Shell Chemical Company.
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7. Date of Incident - Disposal of chemical wastes in unlined
ponds took place between 1943 and 1957. The first
reported damage to grain crops dates back to 1951.
8. Location - Rocky Mountain Arsenal and surrounding area,
between Denver and Brighton, Colorado.
9- Status - Although wastes have not been stored in unlined
holding ponds since 1957, groundwater contamination
of significant areal extent is still evident.
10. Remedial Action Taken - Construction of an injection well and a
96-acre asphalt-lined reservoir with a holding capacity of
240 million gallons. Extension of the influent pipe to the
reservoir and replacement of 800 feet of chemical sewer line.
11. Legal Action Taken - Suits filed by landowners against the Rocky
Mountain Arsenal for well water contamination and crop
losses have resulted in payment of over $165,000 in
damages by the Federal Government. A recent suit brought
by Larry Land, a farm owner to the north of the Arsenal,
is still pending. He alleges that contaminants originating
from the Arsenal have polluted his well water, causing
crop arid livestock losses.
12. Narrative*- The Rocky Mountain Arsenal was established in 1943
and for several years was operated by the U.S. Army
Chemical Corps for the production of chemical warfare agents.
In the late 1950's, most of the industrial facilities
were leased to the Shell Chemical Company, which has
utilized them for the manufacture of pesticides and some
herbicides. The Arsenal occupies 27 square miles of the
South Platte River Valley between Denver and Brighton,
Colorado. From 1943 to 1957, canals and ditches were
used to convey liquid chemical wastes from various chemical
processes to unlined holding ponds for storage. Since
the river valley is underlain by alluvial deposits which
act as a shallow water table aquifer, waste liquids
infiltrating into the soil moved directly into the
groundwater.
First indications that contamination of the groundwater
had taken place were in 1951. At that time, damage to
crops irrigated with water from shallow wells in an
area to the northwest of the Arsenal property became evident.
*For further details, see References 4 to 9.
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During subsequent years, the crop damage extended
to several farms in the area. The crops that had become
affected included sugar beets, pasture grasses, alfalfa,
corn, and barley. Those crops irrigated with contaminated
well water exhibited yellow foliage, retarded growth,
and consequently low yields. Complaints and damage claims
against the Arsenal prompted the U.S. Army Chemical Corps
to engage a firm of consulting engineers to investigate
the problem in 1954. Subsequent investigations were
performed by the U.S. Geological Survey, the Colorado
State Department of Health, and the U.S. Public Health
Service. By means of a well sampling program, the holding
ponds employed at the Arsenal were identified as the
source of contamination.
After having defined the problem, technical studies
resulted in remedial action in 1957, six years after the
initial indications of groundwater damage. A 96-acre
asphalt reservoir with a capacity of 240 million gallons was
constructed, into which the industrial wastes have been
conveyed by pipeline and by tank trucks. In addition,
a 12,045-foot deep-injection well was constructed in
1961 for the purpose of waste disposal. However, correlation of
the injection of large volumes of liquid into the well with
earthquakes in the Denver area caused this operation to
cease in 1966.
Wells sampled in a 1965 study conducted by the U.S.
Public Health Service (USPHS) in the vicinity of the
Arsenal showed severe contamination of the aquifer below
an area of at least 12 square miles. Contaminants
observed included chloride, sodium, fluoride, arsenic,
chlorate, the herbicide 2,4-D, and the insecticides
aldrin and dieldrin. Chloride concentrations greater than
200 parts per million (ppm) were used as a contamination
indicator. However, concentrations in the contaminated zone
ranged as high as 3,000 to 4,000 ppm. The USPHS study also
found that the saline water from the shallow contaminated
zone in the vicinity of the Arsenal had probably entered an
underlying bedrock aquifer through at least three defective
wells in the vicinity of a previously used unlined holding
pond. Extent of damage to that aquifer was not established.
As of 1975, groundwater contamination in the Rocky Mountain
Arsenal area is still evident. A 1974-75 investigation
conducted by the Colorado Department of Health detected aldrin
(S30 ppb), endrin (*40 ppb), dieldrin (*40 ppb), and DCPD
(fS4 ppm) in the groundwater, migrating from the perimeter
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of the 96-acre asphalt reservoir. The study defined the
extent of groundwater contamination (based primarily on the
distribution of DIMP) as approximately 30 square miles, of
which 25 are outside the Arsenal property. The northernmost
well indicating trace contamination from the Arsenal is located
approximately one mile south of the public water supply well
field of the City of Brighton.
In April 1975, the Colorado Department of Health issued
a cease and desist order against the U.S. Army and Shell
Chemical Company to stop polluting the surface- and ground-
waters of the area. Since that time, the Army has entered into
an extensive joint monitoring program with the Department of
Health. In an effort to eliminate leakage from the perimeter
of the asphalt-lined reservoir, the influent pipe has been
extended to its center. Also, water which has surfaced in
a slew area located 1.3 miles northeast of the reservoir has been
pumped back to prevent its reaching the aquifer. Aerial photo-
graphy is now being employed as an aid in determining the
present extent and potential sources of contamination.
NOTE: Subsequent to the first printing of this report, it was
learned that the Department of Defense is proposing to fund a
comprehensive project, to study the feasibility of decontaminating
the Rocky Mountain Arsenal property. The project could cost as
much as 78 million dollars over the next seven years. Based on
the study's recommendations, a program will be initiated to
restore the site.
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HAZARDOUS WASTE DISPOSAL
DAMAGE REPORT
January 1976
Dumping into Sand Pit Pollutes Domestic Wells in Texas
1. Personal Damage - Offensive and irritating odors to nearby
residents and motorists which according to witnesses
caused nausea, sore throats, and headaches.
2. Environmental Damage - Contamination of ground- and surface-
waters. Air pollution from occasional fires. Destruction
of local vegetation.
3. Economic Damage - Discontinued use of about 26 wells for drinking
water purposes for at least 1 1/2 years. Devaluation of
property. Unknown amount spent by French Limited of Houston,
Inc., on correction of pollution problem. Forced closure of
nearby sand pit operation because waste seepage contaminated
sand. Fires which occasionally caused closure of a highway.
4. Cause of Problem - Disposal of acidic and oily wastes into an
unlined, abandoned sand pit.
5. Type and Quantity of Hazardous Waste - Approximately 70,000,000
gallons of solid, semi-solid, and liquid industrial wastes
with a pH as low as 1.5 (highly acidic).
6. Source of Waste - Various oil refineries, petrochemical, chemical,
and other industrial plants in the Houston metropolitan area.
7. Date of Incident - Waste disposal at the pit occurred from the
mid-1960's to 1971. First complaints date back to 1966.
8. Location - Crosby (near Houston), Texas.
9. Status - The affected wells are again providing drinking water,
and the disposal area no longer has odor problems. The
Texas Highway Department is utilizing the site for disposal
of excess dirt from a freeway project.
10. Remedial Action Taken - Prior to the summer of 1973, the company
responsible for the disposal neutralized the acid wastes
and skimmed the surficial oils. It pumped air into the
waste pond and introduced bacteria cultures which lowered
the COD. It also stabilized and rebuilt earthen dikes to
prevent overflows.
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11. Legal Action Taken - Litigation against French Limited of Houston,
Inc., began on January 16, 1968, and was completed on
October 31, 1973 (see Narrative).
12. Narrative*- The disposal of industrial wastes in an unlined
sand pit in Crosby, Texas, resulted in the contamination of
groundwater, surface waters, and the atmosphere. Disposal
operations at the site began in the mid-1960's when the pit
was owned and operated commercially by B.G. Burton.
French Limited of Houston, Inc., a waste disposal company,
purchased the pit from Mr. Burton in June 1967. Both
Mr. Burton and French Limited accepted all types of
industrial wastes from the Houston area. Approximately
70,000,000 gallons were poured into the sand pit.
Leachate from the pit, which was located above a
40-foot-thick sand aquifer, polluted the groundwater causing
contamination of about 26 private wells in the area. Well
water contaminants included abnormally high concentrations
of Mn, Zn, Fe, and Cd, which originated from the dumping
of steel mill pickling wastes into the pit. Failure of a
dike permitted contamination to reach the San Jacinto River
on several occasions.
Residents first complained of the pit operations to
State government agencies in the summer of 1966. Seven
years later, after numerous court actions, the site was
closed. The highlights of these actions are:
°January 16, 1968--Courts temporarily enjoined French Limited
frofn open burning and the disposal of liquid and oily wastes
in an open pit. Operations continued.
°May 27, 1970--Violations of court order resulted in $2,000
fine. Operations continued.
"February 2, 1971-- Court judgment for five acts of contempt
resulted in $500 fine. Operations continued.
°March 26, 1971--Court order cancelled the waste control permit
of French Limited and ordered it to cease all discharges
of waste and to remedy all problems existing at the site.
Operations continued.
*The documentation for this Damage Report was obtained
from the official records of Harris County and the Texas
Water Ouality Board.
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°May 3, 1971--Temporary restraining order issued which
prohibited further disposal of wastes. Operations ceased.
°May 3, 1971 - April 16, 1973--Series of eight court orders
followed which outlined procedures to be taken in eliminating
the pollution problems.
°June 15, 1973--Heavy flood flushed disposal site, removing
most wastes into the San Jacinto River.
°0ctober 31, 1973--Final court order issued which required
French Limited to pay $5,000 to the County of Harris. In lieu
of an additional cash payment, French Limited was to deed
its 22-acre disposal site to the State of Texas.
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REFERENCES
1. U.S. Environmental Protection Agency, Office of Solid Waste
Management Programs. Disposal of hazardous wastes; report
to Congress. Environmental Protection Publications SW-115.
Washington, U.S. Government Printing Office, 1974. 110 p.
2. Carter, C.D., R.D. Kimbrough, et al. Tetrachlorodibenzodioxin:
an accidental poisoning episode in horse arenas. Science,
188:738-740, May 16, 1975.
3. Shea, K.P., and B. Lindler. Pandora and the storage tank.
Environment, 17(6):12-15, Sept. 1975.
4. Groundwater pollution in the South Platte River Valley
between Denver and Brighton, Colorado. Denver, U.S.
Public Health Service, Division of Water Supply and
Pollution Control, Dec. 1965. 53 p.
5. Shukle, R.J. 1974-75 Groundwater study of the Rocky
Mountain Arsenal and some surrounding areas. Denver,
Colorado Department of Health, Water Control Division,
1975. 21 p. (Unpublished report.)
6. Hoover, D.B., and J.A. Dietrich. Seismic activity during the
1968 test pumping at the Rocky Mountain Arsenal disposal
well. U.S. Geological Survey Circular No. 613.
Washington, U.S. Government Printing Office, 1969. 35 p.
7. Petri, L.R. The movement of saline groundwater in the
vicinity of Derby, Colorado, ^n_ Proceedings; 1961
Symposium on Groundwater Contamination. Technical
Report W 61-5. Cincinnati, U.S. Department of Health,
Education, and Welfare, Robert A. Taft Sanitary Engineering
Center, 1961. p. 119-120.
8. Walton, G. Public health aspects of the contamination
of groundwater in the vicinity of Derby, Colorado. IJT_
•Proceedings; 1961 Symposium on Groundwater Contamination.
p. 121-125 (see Reference 7).
9. Gahr, W.N. Contamination of groundwater--vicinity of
Denver. Presented at 128th Meeting, American Association
for the Advancement of Science, Denver, Dec. 26-30, 1961.
p. 9-20.
ycrll 83bR
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