United States
Environmental'Protection
Agency
Region 5
230 South Dearborn Street
Chicago, Illinois 60604
Summer 1985
Region 5
HAZARDOUS WASTE
and
TOXIC SUBSTANCES
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Region 5
HAZARDOUS WASTE
and
TOXIC SUBSTANCES
CONTENTS
HAZARDOUS WASTE 2
EPA and States Use Superfund to Clean Up Hazardous Waste Sites 3
National Dioxin Stategy Targets 150 Midwest Sites 6
Midland Dioxin No Health Threat, Study Shows 8
Region 5 Supports Emergency Team 9
EPA Regulates Hazardous Wastes 10
Siting Hazardous Waste Facilities 12
Alternative Treatments for Hazardous Waste 13
Superfund Isn't Usually "Superfun;"
Community Relations Smoothes the Way 14
TOXIC SUBSTANCES 15
Asbestos in Schools 16
Loans to Help Schools Finanace Asbestos Removal 17
EPA Survey: 20 Percent of U.S. Buildings Might Have Asbestos 18
New Rules to Cover PCS Transformer Fires 18
Risk Assessment 20
Pesticides Regulated by EPA 21
Pesticides Update : 22
Glossary 24
Region 5 HAZARDOUS WASfE and TOXIC SUBSTANCES.is a special
publication prepared by the Office of Public Affairs, U.S. EPA.Region 5,
230 South Dearborn Street, Chicago, Illinois 60604.
Regional Administrator Valdas V. Adamkus
Director, Office of Public Affairs Jon T. Grand
Editor and Writer Kathleen Osborne Clute
Graphic Designer Birute A. Bulota
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Hazardous Waste
Bill Constante/os (center], director. Waste Management Division, EPA Region 5, discusses
the impact of the new RCRA amendments with Lyman W/'b/e (right), administrator. Division
of Environmental Standards, Wisconsin Department of Natural Resources, and Gary
Guenther (left), deputy director, Michigan Department of Natural Resources.
We in the Midwest have our share of hazardous waste
problems. Leaking dump sites are an all-too-familiar
legacy of the heavy industry that has supported our
economy for so long. EPA and many State agencies are
responding to decades of careless and improper disposal
practices in order to protect people and their property
from leaking dumps and contaminated ground water.
EPA's main weapon in the fight
against hazardous wastes is the $1.6
billion "Superfund," created by
Congress in 1 980 to finance the
cleanup of the Nation's worst
chemical dumps. Right now, there are
192 sites in Illinois, Indiana, Michigan,
Minnesota, Ohio and Wisconsin—
Region 5's territory. We have begun
the cleanup process at about 50 of
these and are right now studying
many more.
Several of the cleanups in our
Region are real success stories, and
we're proud of them. But nothing is
accomplished in a vacuum, and we
depend heavily on the input of local
communities to get the job done in the
best and most cost-effective manner
possible.
We at EPA believe it is important for
the public to understand how we are
responding to hazardous waste
emergencies and what we're doing to
make sure similar problems don't
haunt us in the future. The many
articles in this publication should
serve as a primer.
By B. G. Constantelos
One of our biggest efforts right now
involves prevention. Congress has
recently given us new authority under
the Resource Conservation and
Recovery Act to more tightly regulate
current hazardous waste disposal
practices. This Region will be a
national leader in working with waste
generators and handlers to make sure
that the new, more stringent,
regulations accomplish what they're
supposed to.
One of the articles you'll read
concerns alternate treatment
methods—new and different ways that
are being developed to dispose of toxic
wastes in the safest manner possible.
In the meantime, we continue to rely
heavily on land disposal, and another
article deals with the difficult process
of siting hazardous waste treatment
facilities.
Our Region has been actively
involved in the national dioxin
strategy, an effort to determine the
extent of dioxin contamination in the
United States and to evaluate the
health implications of it. About 1 50
locations in our Region are being
sampled, and very encouraging study
results have recently been announced
for the City of Midland, Ml, where the
Dow Chemical Co. plant produced
dioxin as an unwanted byproduct of
pesticide production.
Properly managing hazardous
wastes is a challenge to us all, but I
am convinced this Agency's efforts
will pay tremendous dividends to the
Midwest in the form of a cleaner
environment and fewer threats to
public health. &
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EPA and States Use Superfund to
Clean Up Hazardous Waste Sites
EPA faces no greater challenge than
protecting America from the
consequences of improper hazardous
waste disposal. There are thousands
of abandoned waste sites across the
country; more than 3,900 have been
identified in Region 5 alone.
Because of the threat these sites
pose to human health and the
environment, Congress passed the
Comprehensive Environmental
Response, Compensation and Liability
Act (CERCLA) in 1980. This law is
commonly known as Superfund
because it created a 5-year, $1.6
billion fund to finance the cleanup of
hazardous waste sites throughout the
Nation.
In 1985, CERCLA is expected to be
reauthorized by Congress at an even
higher level of funding. Eighty-seven
percent of Superfund money comes
from taxes on the manufacture or
import of certain chemicals and
petroleum and the remainder comes
from general revenues.
The most important aspect of
Superfund is that it allows EPA to act
immediately when necessary to
protect human health and the
environment. Before Superfund, the
Agency was unable to act swiftly. EPA
is now authorized to clean up a
problem if responsible parties are
unable or unwilling to do so, and to
later recover the cleanup expenses if
possible.
EPA and the States have inspected
584 of the estimated 3,900 waste
sites in Region 5 to determine the
degree of hazard at each. Of the 584
sites inspected, 192 were considered
serious enough environmental threats
to warrant inclusion on the National
Priorities List (NPL), a catalog of 812
sites nationwide which are eligible for
Superfund cleanups. Because of its
heavy industrialization and its
dependence on ground water, the
Midwest has more sites on tha list
than any other area of the country.
When a site is eligible for Superfund
cleanup, either EPA or the State can
take the lead in managing on-site
activities. If EPA takes the lead role in
the cleanup process, it enters into a
contract with the State which
specifies the State role and commits
the State to pay its share of the costs.
If the State takes the lead, the
arrangement is formalized in a
cooperative agreement with EPA. In
this case, the State directly supervises
the cleanup with EPA oversight.
Regardless of which party takes
primary responsibility, the States must
be able to pay 10 percent of the
cleanup costs or 50 percent if the site
was owned by a municipality.
Three Region 5 States—Illinois,
Michigan and Minnesota—often take
the lead at Superfund sites. These
States and Wisconsin also have their
own "Superfund" legislation to help
finance cleanups.
It should be noted that CERCLA
distinguishes between emergency
actions requiring immediate action to
protect human health and sites that
present a longer-range problem. EPA
considers the special demands of each
situation before deciding on the most
appropriate response.
During the past 5 years, Region 5
has responded to emergencies at 84
sites (both on and off the NPL) and has
started the investigation and long-
term cleanup process at 85 NPL sites.
Regional staffers are right now
preparing plans to begin cleaning up
27 sites during Fiscal Year 1985 and
another 25 sites in Fiscal Year 1986.
To date, Region 5 has obligated
approximately $25.3 million for short-
term emergency actions and $49.9
million for long-term measures at
hazardous waste sites in the 6-State
area.
CERCLA also authorizes EPA to
require responsible parties to clean up
their hazardous waste sites when
those sites may be an imminent or
substantial danger.
Region 5 technical staff and
attorneys have been successful in
getting responsible parties at 36 sites
to agree to pay for or conduct cleanup
operations. These agreements are
valued at $112 million, leaving that
much more money for use at sites
where responsible parties cannot be
located. The Region has lawsuits on
31 other sites pending. ^>
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WORK REMAINS AT CHEM-DYNE
The Chem-Dyne Corp. collected and disposed of
chemical wastes at its Hamilton, OH site
between 1 976 and 1 980. During that time, there
were two fires and at least five fish kills due to
operations at the site.
Operations ceased in February 1 980, but more
than 30,000 drums of waste and 300,000
gallons of bulk waste materials were left on site.
In 1 981, Chem-Dyne was added to EPA's
National Priorities List for Superfund cleanup.
Some companies that had shipped wastes to
the site voluntarily removed them between 1 981
and 1 983; in 1 983, the U.S. Army Corps of
Engineers removed the remaining surface
wastes.
Now the remaining contamination in soil,
ground water and on-site buildings will be
addressed. U.S. EPA, U.S. Department of Justice
and State of Ohio reached an agreement in June
1 985 in which 1 60 companies will pay for the
cleanup. The settlement calls for the most
comprehensive groundwater cleanup yet
developed in the Superfund program.
Groundwater will be extracted, treated and
reinjected into the aquifer. In addition, on-site
buildings will demolished, "hotspots" of highly
contaminated soil will be removed, and a 5-foot
cap will be built over the site. The groundwater
treatment system will operate at least ten years,
or as long as necessary to return the water to
acceptable quality. The other measures will occur
within a year.
EPA HELPS RESTORE BATTLE CREEK WATER
Three years ago, EPA and the State of Michigan
discovered that 27 of 30 drinking water wells in
Battle Creek, Ml, were contaminated by varying
amounts of volatile organic compounds (VOC's)—
chemicals commonly used as solvents.
EPA that year declared the area eligible for
Superfund money and began investigating the
nature and extent of the contamination. When it
became apparent that public health could be
endangered by the water, emergency actions
began. Eighty families with severely
contaminated private wells were given bottled
water.
But 36,000 other people still depended on city
wells. As the problem worsened, the city blended
contaminated and uncontaminated water in
order to reduce the concentration of chemicals.
But that wasn't an acceptable long-term solution.
As a result, EPA last year began work on a
barrier system that draws water out of the
contaminated portion of the aquifer and strips it
of the VOC's. The system relies on strategically-
placed "blocking wells" and an air stripping and
carbon adsorption system.
Concurrently, three new wells were dug north
of the blocking wells in the clean portion of the
aquifer.
The contaminated plume has shrunk since EPA
began its efforts, restoring 1 6 of the city's wells
and eliminating the need to blend water. The
stripping and blocking operations are ongoing,
and EPA will remove the major source of the
contamination to prevent any further
environmental or health damage.
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CLEANUP ONGOING AT A&F MATERIALS
Cleanup is underway at the A&F Materials
Superfund site in Greenup, IL. Industrial waste
materials were recycled into fuel oil and fire
retardant chemicals during operations there
between 1977 and 1980.
The facility was abandoned in 1 980, with
waste materials left in storage tanks, lagoons,
and processing equipment. Four waste
generators who stored their materials at the
A&F site agreed in June 1 984 to clean up the
surface of the site at their own expense, and
have removed more than 465 truckloads of
contaminated sludge and soil. About 77,000
gallons of liquid materials were treated onsite or
disposed of, while more than 340,000 gallons
contaminated water were treated to meet State
and Federal standards and were discharged to
the nearby Embarras River.
The Illinois Department of Public Health has
begun a health study to address concerns of
Greenup residents.
The generators will continue the cleanup by
removing contaminated soils, removing all on-
site buildings and grading the site.
BERLIN AND FARRO SURFACE CLEANUP FINISHED
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Following 14 months of negotiations with EPA,
87 private parties paid $14 million last year to
clean up the Berlin and Farro incineration site in
Genesee County, Ml.
Ground water, soil, and on-site surface water
had been contaminated by chemicals during the
10 years the site was used to incinerate and
dispose of liquid and solid wastes. Conditions at
the site prompted the State of Michigan and EPA
to take emergency action beginning in 1 981.
The State of Michigan that year declared the
site a toxic waste emergency and began
removing 1 5,300 cubic yards of contaminated
sludge. EPA Region 5 fenced the site and took
steps to control runoff in 1 982.
The final surface cleanup was completed last
October, ahead of schedule. About 1 million
gallons of liquid wastes and 75,000 tons of solid
wastes were removed from the site by
contractors hired by the 87 responsible parties.
However, significant tasks remain in order to
determine what contamination still exists and
how it might affect public health and the
environment. An ongoing investigation is
examining:
• Hydrology
• Geology
• Soil characteristics
• The way in which the site is affecting area
surface water
• Steps needed to mitigate any problems that
are discovered.
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National Dioxin Strategy
Targets 150 Midwest Sites
About 1 50 locations in Region 5 are
being sampled for dioxin
contamination as part of EPA's two-
year, $7.4 million national dioxin
strategy.
The strategy is designed to
determine the extent of dioxin
contamination in the U.S. and the
associated risks to humans and the
environment, to clean up sites which
threaten public health, to evaluate
ways of preventing future
contamination, and to investigate
methods of destruction or disposal.
Dioxin, specifically 2,3,7,8-
tetrachloro-dibenzo-p-dioxin (2,3,7,8-
TCDD), is a contaminant inadvertently
created during the manufacture of
certain chemicals, including 2,4,5-
TCP, an ingredient in some herbicides.
It is perhaps the most toxic man-made
substance known and poses a threat
at levels that, until recently, were too
minute to measure.
The chemical has become almost a
household word during the past two
years. Dioxin contamination in Times
Beach, MO, prompted a government
buyout in 1 983. Vietnam veterans
reported health problems they
believed were linked to their exposure
to "Agent Orange," a dioxin-tainted
defoliant used by U.S. forces during
the war.
In order to systematically determine
the extent of dioxin contamination in
the U.S., EPA has compiled a list of
more than 1,000 locations for testing.
These sites have been divided into
seven "tiers" according to the
previous uses of the properties.
For the majority of the sites, EPA
investigators will be collecting
samples with no advance expectation
of finding contamination. When
contamination is found, it is expected
to be at very low levels, unlike sites
found earlier in Missouri.
Tiers 1 and 2 are sites where 2,4,5-
TCP was produced or disposed of,
along with sites where 2,4,5-TCP was
used as a precursor to make
pesticides. Dioxin is most likely to be
found at sites such as these. Region 5
has one tier 1 site and no tier 2 sites.
When necessary, EPA will take
remedial action at these sites.
Tiers 3-7 are industrial, commercial
and agricultural sites where pesticidal
products were blended or used. These
include places where 2,4,5-TCP and
its derivatives were formulated into
pesticides (tier 3); incinerators (tier 4);
sites where pesticides derived from
2,4,5-TCP have been and are being
used on a commercial basis (tier 5);
certain organic chemical and pesticide
manufacturing facilities where
2,3,7,8-TCDD could have formed as
the result of faulty or improper quality
control (tier 6); and background
sampling of fish or soils at sites where
dioxin is not expected (tier 7). All but
one of the Region's sampling locations
fall in tiers 3-7. EPA does not expect to
find any significant levels of dioxin at
sites in these tiers.
Sampling may take several forms,
depending on a preliminary analysis of
where dioxin contamination would
most likely occur. Soil and water
samples may be taken at one site,
while fish tissues and stream
sediments may be tested at another.
The dioxin strategy is a
comprehensive effort that is expected
to provide a much clearer picture of
the dimensions of the problem while
allowing the Agency to plan
appropriate measures to protect the
public.
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SOIL SAMPLING SITES FOR MIDLAND, Ml
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As part of the Agency's National Dioxin Strategy,
soil samples were taken in Midland, Ml and other
representative communities to determine whether
dioxin and other toxic chemicals in the soil
presented a public health threat. Through this
multiple testing approach, EPA can best determine
the extent and nature of the contamination
problem and possible solutions to it.
Sites with significant contamination
and those which pose an immediate
public health threat will be referred to
EPA's Superfund waste cleanup
program for action.
Most-of the dioxin strategy's costs
are being financed by a special
appropriation from Congress.
Sampling at tier 1 and 2 sites,
however, is paid for by the
Comprehensive Environmental
Response, Compensation and Liability
Act(CERCLA), more commonly known
as "Superfund."
In cases unrelated to the national
dioxin study, two companies in Region
5 agreed to study their facilities for the
extent of dioxin contamination and to
consult with regional EPA staff on
appropriate action.
Because a very important part of the
dioxin strategy is to determine the
health and environmental risks from
exposure to dioxin, EPA will cooperate
with other Federal agencies to
research the specific effects of
2,3,7,8-TCDD on humans and other
species. The Agency will be especially
interested in developing techniques
to understand actual risks posed by
dioxin under differing conditions.
Although the precise ways in which
dioxin affects the human body are not
known, EPA's cancer assessment
group regards the chemical as an
initiator and promoter of cancer. That
is, it is thought to cause cancer and to
accelerate the formation of cancers
caused by other means. EPA is
working closely with the Centers for
Disease Control in Atlanta on health
issues related to dioxin.
Results from EPA's nationwide
sampling program are expected by the
end of 1985, when a report will be
prepared for Congress. ^
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Midland Dioxin
No Health Threat, Study Shows
A recent EPA study of dioxin
contamination in Midland, Ml, showed
that the compound does not pose an
unacceptable public health risk in that
city.
Concern over dioxin contamination
in Midland began in 1978, when the
Dow Chemical Co. told the Michigan
Department of Public Health it had
found 2,3,7,8-TCDD, the most toxic of
75 related compounds known as
dioxins, in fish caught in the
Tittabawassee River. The public health
department immediately advised
against eating fish caught in the
river—a warning that remains in effect
today.
After a caged-fish study in 1981,
EPA and the Michigan Department of
Natural Resources (MDNR) determined
that Dow's wastewater was the
source of dioxin in the fish. In 1 984,
the State of Michigan ordered the
company to reduce dioxin discharges
by constructing wastewater treatment
systems.
In 1983, the State of Michigan
formally had asked EPA to study
dioxins and other toxic pollutants at
Dow's plant, in the Tittabawassee
River, and in the City of Midland. EPA
agreed, and sampled soil, wastewater,
emissions, brine and river sediments
during 1983 and 1 984. During that
period, EPA also sampled six other
areas in the Midwest for comparative
purposes.
The goal of the study was to
determine if dioxin or other toxic
pollutants in Midland soil could pose
unacceptable public health risks. EPA
wanted to identify the likely source or
sources of dioxin in Midland; to
determine if levels in Midland are
comparable to other areas with
combustion sources and process
operations different from Dow's; and
to see if levels at Midland were
significantly different from background
levels generally found in the
environment.
The findings:
• Current dioxin levels in surface
soils away from the Dow Chemical
plant are well below 1 part per
billion (ppb}, the level at which the
Centers for Disease Control feels
some action must be considered to
prevent human exposure.
• Dioxin was found inside the Dow
Chemical property in quantities as
high as 36 ppb in surface soils. Dow
has agreed to cover two areas that
have high dioxin concentrations.
• Concentrations of dioxin in Midland
but outside the plant property are
significantly higher than the trace
levels found in a few samples taken
in other cities. No detectable levels
of dioxin were found in most
samples from comparison sites, and
in all samples from natural areas.
• Air emissions from Dow Chemical
are the likely source of dioxin
contamination in Midland.
• A warning against eating fish from
the Tittabawassee River should be
continued.
• Current levels of toxic organic
pollutants in Midland soils are
equivalent to those found
elsewhere in the environment and
do pose an unacceptable public
health risk.
In order to interpret the Midland
findings, EPA sampled four natural
areas in Minnesota and the cities of
Henry, IL, and Middletown, OH. These
cities have manufacturing processes
with wastes similar to those produced
at Dow.
No detectable levels of dioxin were
found in any of the pristine areas,
suggesting that it is not present in all
parts of the environment. Samples
taken in Henry and Middletown also
generally showed no detectable
contamination. However, a few
samples taken in those towns showed
dioxin in amounts ranging up to .005
PPb.
EPA also compared the Midland
dioxin levels to data from other
chemical manufacturing and disposal
sites where dioxin has been found. For
the most part, levels of 2,3,7,8-TCDD
at Dow Chemical are in the range of,
or lower than, levels at eight other
similar sites.
Because of continuing concern over
relatively high levels of dioxin in game
fish in the Tittabawassee River, people
should not eat fish from that river.
Dow Chemical, in a 1984 consent
decree with EPA, has agreed to
analyze fish from the river for dioxin
levels' every two years between 1985
and 1991. This program will help
determine if wastewater treatment
systems at Dow result in lower dioxin
levels in fish. &
8
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Region 5 Supports
Emergency Team
Oil or chemical emergencies are rarely
convenient and almost always
dangerous. That's why each of EPA's
10 regional offices has a staff of
emergency response professionals on
call 24 hours a day.
The 1 6 engineers and scientists in
Region 5's Emergency Response
Section are based in Chicago and
Grosse Me, Ml. They supervise
immediate removals at uncontrolled
hazardous waste sites and coordinate
on-scene activities at major oil or
hazardous substances spills. A multi-
agency regional response team is
available to support these efforts.
Most of the Emergency Response
Section's work involves immediate
removals at hazardous waste sites on
and off the National Priorities List
(NPL). The NPL is a catalog of 81 2
sites across the Nation that are
eligible for Superfund-financed
cleanups.
Immediate removals usually involve
neutralizing, isolating or removing
chemicals to prevent fires, explosions
or public health risks. When an NPL
site is involved, long-term cleanup
plans are developed after the
immediate hazards have been taken
care of.
In at least three recent cases,
emergency response activities
involved supplying bottled water to
some residents of NilesTownship, Ml;
Byron, IL; and Elkhart, IN; after their
wells were contaminated by leaking
chemicals. In Wausau, Wl, an
emergency response involved
installing carbon filters on a city
drinking water well serving 3,500
people.
At the Saginaw Paint Co. in
Michigan, an immediate removal in
1 984 meant removing the contents of
1,000 drums, 200 yards of pigments
and solids, and several thousand
gallons of liquids from abandoned
underground tanks. At the Midco II
Superfund site in Gary, IN, EPA is
supervising a surface cleanup that
includes draining, sorting, and
shredding thousands of contaminated
drums.
EPA's national emergency response
budget for Fiscal Year 1 985 is $54
million, with $8.5 allocated for Region
5. Last year the Region spent $4.6
million on spill response and
immediate removals, according to
Gerald F. Regan, chief of the
Emergency Response Section. S»
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EPA Regulates Hazardous Wastes
If it's an ignitable, reactive, corrosive,
or toxic waste, it's probably also a
hazardous waste. And if you generate,
treat, store, transport, or dispose of
enough of it, you may have to follow
EPA guidelines under the Resource
Conservation and Recovery Act (RCRA).
RCRA, passed by Congress in 1 976
and amended in 1984, was designed
to improve the way industry handles
hazardous wastes. The focus of the
law is on industrial wastes which
weren't traditionally regulated under
EPA's other environmental programs.
RCRA actively involves EPA in
managing hazardous wastes from the
time they are created until their
disposal or destruction. Through the
use of "cradle to grave" waste
tracking and a permit system, EPA and
the States can ensure that wastes are
being handled and disposed of
properly.
The RCRA process starts with the
generators of hazardous wastes. It is
their duty to evaluate their waste
streams and determine whether the
wastes meet RCRA's definition of a
hazardous waste. EPA currently lists
more than 450 chemicals and other
wastes that are automatically
considered hazardous; the generator
can use EPA's guidelines to evaluate
other waste streams.
Is it ignitable? Is it corrosive? Is it
reactive? Is it toxic? If more than 2,200
pounds (1,000 kg) of wastes are
generated each month, they are
regulated under RCRA. Certain highly
toxic compounds, such as arsenic and
some discarded pesticides, are
regulated in quantities as small as 2.2
pounds (1 kilogram). In addition, the
new RCRA amendments tighten the
control over hazardous wastes by
bringing small quantity generators—
those who create between 220
pounds (100 kilograms) and 2,200
pounds (1,000 kilograms) of wastes in
a month—under the purview of the
law.
RCRA allows generators to store
their own wastes onsite for as many
as 90 days without a permit. Some
facilities have chosen to limit the
amount of time they store hazardous
wastes in order to avoid having to get
a RCRA permit.
When wastes are to be shipped
offsite, the generator must prepare a
manifest which describes the wastes
and identifies the transporter and the
facility to which the wastes will be
shipped. Wastes may only be sent to
facilities with RCRA permits or with
interim status. (RCRA permits may be
issued by those States authorized by
EPA to do so.)
Hazardous waste transporters also
have responsibilities under RCRA.
Transporters are required to carry
manifests prepared by the generator
and must follow all applicable U.S.
Department of Transportation safety
regulations.
Treatment, storage and disposal
facilities (TSD's) are subject to RCRA's
most stringent provisions. The law
requires EPA to issue permits for these
facilities so they will make the
minimum impact on the environment.
RCRA regulations for land disposal
facilities are primarily concerned with
protecting ground water. These
facilities, including landfills, must
install monitoring wells and check
them quarterly or semi-annually for
any evidence of leakage from the site.
If contaminants are found in the
monitoring wells, the facility must stop
the leak and remove or treat the
contaminants.
The recent amendments to RCRA
significantly strengthen EPA's ability
to protect ground water. For instance,
the law now requires EPA to regulate
underground storage tanks—thought
to be the biggest threat to ground
water—by developing standards for
the design, construction, and
installation of new tanks.
In addition, EPA will develop
standards to protect human health and
the environment from the dangers
posed by existing leaking underground
storage tanks. The Agency will require
leak detection or inventory systems,
recordkeeping and reporting by tank
owners, and closure procedures when
a tank is to be taken out of
commission.
RCRA regulations also specify
certain controls to limit the creation or
escape of leachate, liquid that forms
as wastes decompose in a landfill.
Safeguards such as synthetic liners,
leachate collection systems and runoff
controls are specified for landfills.
Even more important, EPA will prohibit
the land disposal of bulk or non-
containerized liquid hazardous wastes
as of May 7, 1 985. RCRA permits for
landfills will be reviewed every 5
years.
TSD's must also develop
contingency plans for protecting
health and the environment, provide
closure and post-closure plans and
provide proof of financial
responsibility.
There are about 1,240 TSD's in
Region 5, according to Edith Ardiente,
chief of the regional RCRA Technical
Programs Section. Most of these
facilities have what EPA calls "interim
status" until a decision is made on
whether they qualify for a RCRA
permit. Facilities must comply with
10
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TREATMENT
TRANSPORTATION
DISPOSAL
A HAZARDOUS WASTE WILL BE TRACKED FROM 'CRADLE-TO-GRAVE'
EPA's interim status standards, which
specify how hazardous wastes must
be managed.
Part A permit applications tell the
Agency who owns the facility, where it
is located, any other environmental
permits held, and a written description
of operating procedures, quantities
and types of wastes involved, and
photographs of the operation.
Interim status enables existing
facilities to operate until they can be
evaluated for complete, or Part B,
permits. So far, the Region has
determined that six facilities cannot
meet RCRA standards. Because EPA
denied permits for those operations,
they must be closed down.
The Region 5 RCRA staff is now
reviewing 142 Part B applications and
have so far issued 54 RCRA permits.
Applications for incineration and land
disposal facilities are given top priority
in the review process.
Once EPA has evaluated a Part B
permit application, it advertises in
local media its intent to issue or deny
the permit. There is a 45-day comment
period and, if requested, a public
hearing in the community where the
facility is located.
As with many environmental laws,
RCRA provides for the States to take
over the day-to-day running of the
program. Minnesota has already
received authorization to do that, and
four other States—Illinois, Indiana,
Ohio, and Wisconsin—have been
authorized to regulate interim status
generators, transporters andTSD's. In
order to be authorized to run the RCRA
program, States must demonstrate
that their laws and regulations are at
least equivalent to and consistent with
Federal regulations. States must
continually update their programs to
keep them consistent with Federal
requirements.
EPA and the States inspect TSD's to
make sure they are complying with
their interim status requirements or
their RCRA permits. When violations
are found, EPA or the State issues a
warning letter or a compliance order,
which specifies what the permit
holder must do to remedy a violation
and may also assess a fine. In very
serious cases, the Agency can
suspend or revoke a permit.
Region 5 issued 84 compliance
orders and 688 warning letters during
Fiscal Year 1984. The Region assessed
more than $2.3 million in fines in its
compliance orders during that year,
according to Bill Miner, chief of the
regional Hazardous Waste
Enforcement Branch. The States of
Indiana and Minnesota, the only ones
in Region 5 with the authority to issue
RCRA compliance orders that assess
penalties, issued 28 orders during
Fiscal '84. Altogether, Region 5 States
issued 879 warning letters during the
same period.
RCRA provides for fines of up to
$50,000 per day of non-compliance
and criminal prosecution in some
cases. The act makes it illegal to
knowingly transport hazardous wastes
to a TSD without interim status or a
RCRA permit or to cause wastes to be
transported in that manner; to treat,
store or dispose of hazardous wastes
without interim status or a permit; or
to falsify any RCRA-related
documents.
A 1 980 amendment to the law
created a new felony offense called
"knowing endangerment"—putting
another person in imminent danger of
death or serious bodily injury. A
conviction under this provision can
result in a fine of up to $1 million for a
corporation and up to $250,000 for an
individual. It can also result in
imprisonment.
A particularly significant addition to
the law was included in the 1984
amendments to RCRA—it allows
citizens to file suit when a waste site
poses an imminent or substantial
hazard. A
11
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Siting Hazardous
Waste Facilities
Siting commercial hazardous waste
facilities is a critical aspect of waste
management, but it's very hard to do.
Love Canal and other highly
publicized incidents have contributed
to a phenomenon known as the "not-
in-my-backyard" syndrome, or NIMBY.
This syndrome makes it difficult to find
places where even well-run and
properly safeguarded facilities can
function.
The location of a hazardous waste
treatment, storage or disposal facility
is a tremendously important
consideration in the overall success of
the operation. Hydrology and geology,
for example, are two critical
parameters to be considered when
locating land disposal operations such
as landfills and deep injection wells.
The impact of any waste facility will
depend on its design, purpose, and
proximity to people, transportation
routes, water supplies and important
ecological systems. The operator's
past record is also important, and
many States consider it during the
permit evaluation.
Although Federal regulations
developed under the Resource
Conservation and Recovery Act (RCRA)
affect siting decisions, choices about
where to build treatment, storage, and
disposal facilities are largely left to
State and local governments.
Concerns about health risks,
potential ground-water contamination,
and equity must be addressed, and
many States have hazardous waste
facility siting laws to provide a
structured decision-making process.
Five of this Region's six States, for
example, have such laws.
THE SITING PROCESS
The Siting Process should:
• Be well thought out by site developers, facility operators, and
government agencies;
* Provide for early and full public information and participation;
• Be understandable to the public;
• Provide the public with accurate information concerning the benefits,
risks, and alternatives to a proposed facility;
• Address the legitimate concerns of all parties;
• Be a shared consultative process among site developers, facility
operators, communities, government agencies, and other affected
parties; and
• Provide opportunities for all concerned parties to negotiate areas of
dispute.
Furthermore, an evaluation of a proposed facility should include an
assessment of:
• The need for a facility of some sort;
• Whether the proposed facility represents the most appropriate
technology for handling the particular wastes; and
• Whether the location proposed for such a facility is suitable given
environmental, social, and economic concerns.
Reprinted with permission from Siting Hazardous Waste Management Facilities, A
Handbook. Published by the Conservation Foundation, Chemical Manufacturers
Association, National Audubon Society, 1983.
Siting laws generally create a State
board to identify and evaluate
potential hazardous waste facility
sites. Sometimes these boards actively
seek out such sites and are involved in
statewide hazardous waste planning;
in other cases the boards review
permit applications and make the final
decisions on where a proposed facility
will be located. The State boards
usually can override local objections,
but often will include local ordinances
as permit conditions.
Several States in Region 5 require
deed covenants to restrict the future
use of the land on which a facility has
operated. Bonds or other sureties are
frequently required to guarantee the
financing of closure and post-closure
monitoring.
One of the main problems
confronting State governments and
the people involved in building
hazardous waste facilities is public
distrust. Citizens perceive site
selection processes to be inequitable.
State siting laws help remedy that by
requiring that environmental factors
be considered and that the community
is protected.
EPA feels that citizens are more
inclined to make siting decisions on
merit, rather than emotion, if they
have complete answers to questions
such as these: Will the facility cause
health problems? How will compliance
with environmental laws be
monitored? What plans have been
developed for emergency situations? Is
the facility needed?
In the event that well-thought out
proposals aren't enough, some States
actually provide communities with
financial incentives to allow hazardous
waste facilities within their borders. In
Indiana, for example, the host county
receives 50 cents for each ton of
waste disposed of in or on the land.
EPA encourages States to use fee
systems and other means to help
finance their hazardous waste
programs.
Changing waste disposal practices,
State planning and siting policies, and
increasingly tough EPA regulations are
expected to result in less wastes and
more responsible disposal in the
future. The recent RCRA amendments
require EPA to develop criteria for the
location of hazardous waste facilities
as necessary to protect human health
and the environment. An EPA task
force has been established to address
those concerns.
12
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Alternative Treatments for Hazardous Waste
Editor's Note: This article was adapted
from an October, 1984, EPA Journal
article by Donald White and Bob Burke
entitled "Choices in the Disposal of
Hazardous Waste."
EPA's regulations under the Resource
Conservation and Recovery Act (RCRA)
are designed to make land disposal of
hazardous wastes safer, but even the
toughest regulations don't come with
guarantees.
In view of the drawbacks inherent in
land disposal, there is a growing
consensus that the Nation should
move as rapidly as possible toward
treatment and recovery as the
preferred means of managing
hazardous wastes.
As a consequence, Congress
recently amended RCRA to include an
explicit provision against the land
disposal of particular wastes unless it
can be demonstrated that human
health and the environment would be
protected during the full life of their
disposal.
[There is evidence that industry is
moving away from its reliance on
landfills in favor of treatment and
incineration. In Illinois alone, 81.7
percent of all RCRA manifest wastes
were landfilled in 1980. But by 1983,
that figure had dropped to 42.6
percent, according to a 1983 report by
the Illinois Hazardous Waste Task
Force.]
EPA wants to encourage this trend
by discovering, testing and promoting
feasible technologies for treating and
recovering those kinds of hazardous
waste that will ultimately be banned
from land disposal.
EPA's treatment, recycling and
reduction program is examining the
following technology:
• Biological treatment processes
that employ living organisms to feed
on and decompose certain wastes.
• Dechlorination that detoxifies
chlorinated substances by adding
nontoxic products such as
hydrogen.
• Carbon adsorption involving the
use of specially-treated carbon to
retain wastes, a technique that has
proven particularly useful for
removing organic compounds from
wastewater.
• High temperature incineration
leading to thermal destruction of
wastes—an effective way to destroy
many organic compounds.
• Neutralization of wastes that are
either too acidic or alkaline.
Neutralization involves combining
proper concentrations of acid
substances or wastes with alkaline
substances or wastes.
• Oxidation of primarily organic
materials, including cyanides,
phenols and organic sulfur
compounds, essentially involving a
chemical reaction that transforms
these wastes into harmless carbon
dioxide and water.
• Precipitation technologies that
transfer certain soluble constituents
of liquid wastes into solids suitable
for sedimentation. This is a
particularly useful means of
removing metals from water.
• Recovery/reuse/recycle
processes that not only remove
hazardous wastes from the
environment but provide for their
productive reuse. Solvents, acids
and metals are among the products
frequently recovered.
• Solidification and stabilization
processes that ultimately turn
wastes into a solid mass. The
wastes cannot then be easily
transported by water or other
liquids into the environment.
EPA's existing research suggests
that many of these alternative
technologies can be used or are
already being used to treat and
recover various hazardous wastes.
Many solvents, for example, are
already being recycled or incinerated.
But it is going to take an impressive
amount of research, field work and
cooperation with the private sector to
make sure these alternatives are
available when needed. &
13
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Superfund Isn't Usually "Superfun;"
Community Relations Smoothes the Way
Anywhere there's a Superfund site,
there are people with questions. Is the
drinking water safe? Will EPA protect
the community from hazards? When
will the problem be taken care of?
The people who answer these
questions and provide a direct link
between EPA and the communities at
Region 5's 187 Superfund sites are
project managers and community
relations coordinators.
Project managers are professionals
who typically have degrees in
engineering or earth sciences.
Community relations coordinators are
public affairs specialists with in-depth
environmental backgrounds.
The two professionals work as a
team to provide citizens, elected
officials, State agencies and the media
with accurate and up-to-date
information about the work going on
at a given site.
"We want to tell people what's
going on and we feel an obligation to
do that," said John Perrecone, the
lead community relations coordinator
in Region 5. "The people appreciate
the fact that we talk to them in their
homes and communities."
With the exception of sites where
EPA takes emergency action because
of immediate health or environmental
threats, most Superfund cleanups are
multimillion dollar undertakings that
require substantial planning and
engineering work.
The first step in any cleanup is what
EPA calls a remedial investigation. EPA
or its consultants carefully study the
site to assess the type and extent of
contamination and the possible risks
to people living nearby. These
investigations can take as long as two
years, but usually average 14 months.
The Agency's commitment to
keeping people informed begins right
after a Superfund site is scheduled for
EPA action. Community relations plans
are individually tailored to provide EPA
professionals with essential
background on the site and the
community in which it is located. The
plans also outline a schedule of
community relations activities and
opportunities for public participation.
Once a remedial investigation is
scheduled, the project manager and
community relations coordinator for
that site will hold a public meeting in
the community. The meeting is to
acquaint citizens with the Superfund
cleanup process and the employees
involved.
Citizens frequently take this
opportunity to make comments that
help EPA with the investigation. For
instance, residents of Gary, IN pointed
out that the Lake Sandy Jo Superfund
site floods at certain times of the year,
washing onto private property. They
also noted that it might be a good idea
to test a local spring where many
people get their drinking water. As a
result, EPA altered its remedial
investigation to include those
concerns.
Citizens are urged to keep in touch
with EPA between meetings by calling
a toll-free number when they have
questions or want to check on the
progress being made. In addition,
documents related to the cleanup are
kept in a notebook "repository" at a
local library or the village hall.
After the remedial investigation is
finished, a feasibility study is
prepared. This study examines various
ways of solving the problems at the
site. Once the feasibility study is
completed, usually after 4-6 months,
another public meeting is held to
solicit comment on the alternatives
presented in it.
The Federal law that created
Superfund, the Comprehensive
Environmental Response,
Compensation and Liability Act
(CERCLA), does not specifically require
this degree of public input. But the
Agency itself has made this a priority
at all sites—"a good sign of the
Agency's commitment," said
Community Relations Coordinator
Margaret McCue.
Perrecone, McCue and three other
community relations coordinators in
Region 5 have devised many ways of
keeping in touch with communities
scattered around the 6-state Midwest
area. They periodically mail fact sheets
to citizens, elected officials and
reporters. Press releases announce
timely and important developments;
trips and frequent phone calls keep
channels of communication open.
This communication is often
positive, said Community Relations
Coordinator Judy Beck. Cities with
Superfund sites are usually eager to
have them cleaned up, and "for many
little towns, any Federal money
coming in is positive."
Even when tensions are high and
disputes are raging over the
particulars of a given cleanup, citizens
seem to appreciate having personal
contact with EPA. "People, no matter
how annoyed or concerned, always
say at every single meeting I've been
to that they appreciated us being there
and talking to them," said McCue. &
14
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Toxic Substances
Bill Sanders (right), director. Environmental Services Division, EPA Regions, attendsa
briefing with Valdas Adamkus (left), regional administrator, EPA Region 5.
Chemicals play an important role in protecting,
prolonging and enhancing our lives. But in the past few
years, we have discovered that some common and
widely-used chemicals, such as PCB's, have created
significant health and environmental dangers. Part of
the Agency's mandate is to eliminate or minimize those
dangers, and we do so underthe authority of two laws —
the Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA) and the Toxic Substances Control Act (TSCA).
FIFRA and TSCA differ from other
environmental laws such as the Clean
Water. Act because they focus
primarily on the marketing, use and
distribution of specific chemicals—not
the disposal of them.
The Agency uses the authority of
FIFRA and TSCA to control chemical
manufacturing and use by establishing
standards, issuing permits, inspecting
facilities, and taking enforcement
action when necessary. The statutes
also provide the foundation for the
Agency's decisions on the continued
marketing of pesticides and other toxic
chemicals. EPA is committed to
assessing the risks and benefits of
chemicals in the marketplace and to
controlling those that may threaten
health or the environment.
EPA has been using risk assessment
as a management tool for some time,
even though the process is not
thoroughly understood. The Agency is
devoting considerable effort to risk
management, and in cooperation with
other agencies, has refined the
process significantly. Risk assessment
By William H. Sanders,
guidelines for mutagenicity, cancer,
reproductive disorders, systemic
effects and chemical mixtures are now
available to help EPA set priorities.
Asbestos, and particularly asbestos
in schools, is emerging as a priority
regional activity. The program requires
local education agencies to assess and
document whether their schools
contain friable (easily crumbled)
asbestos. We in Region 5 have so far
inspected more than 1,000 of our
23,000 schools to see if they are
meeting the requirements of our
asbestos-in-schools rule. Nationally,
60 percent of school districts are not
doing so. To help needy school districts
finance asbestos removal, EPA has
recently begun a no-interest loan and
grants program which will actively
involve Region 5's asbestos staff.
Protecting health and the
environment from toxic chemicals is
not the exclusive responsibility of EPA.
Congress has directed the Agency to
establish active partnerships with the
States, where possible, in
environmental protection efforts. As a
result, all six States in Region 5 are
primarily responsible for enforcing
pesticide regulations. Two States,
Michigan, and Ohio, have the
authority to perform PCB inspections
under TSCA.
We have made significant progress
in controlling toxic chemicals since
TSCA and FIFRA were enacted, but we
still have a long way to go. I hope you
will find this publication a useful tool
in gauging our progress so far. <>
15
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Asbestos
In Schools
EPA will inspect more than 500 school
districts in Region 5 this year to see if
they are complying with the Agency's
asbestos-in-schools rule, which
required all elementary and secondary
schools to be inspected for friable
(easily crumbled) asbestos by June,
1983.
The rule is designed to limit the
exposure of students, teachers, and
staff to microscopic asbestos fibers
released into the air from deteriorating
ceiling tiles or sprayed-on insulation.
Asbestos is a common name for
several silicates—natural minerals
that easily separate into thin fibers of
exceptional strength. Chemically inert,
heat resistant and stable, asbestos is,
or recently has been, used in the U.S.
as a fire retardant or insulator in some
3,000 different products.
Unless it is sealed or encased,
asbestos can break into a dust of
microscopic fibers that are easily
inhaled or swallowed. The presence of
the fibers in the body, usually the
lungs, can lead to lung cancer,
asbestosis, and mesothelioma.
Asbestosis is a disease that makes
breathing increasingly difficult and, in
severe cases, can cause death.
Mesothelioma is a cancer of the
linings in the chest and intestinal
tract. All of these diseases can take 20
to 40 years to develop.
School districts are required to post
notices and inform parents, students,
teachers, and school employees when
friable asbestos is found in schools.
Although EPA's rule does not require
asbestos abatement measures,
districts typically choose to seal,
encase or remove it.
EPA estimates that approximately 1 5
million students and 1.4 million
teachers and school employees use
buildings that contain some friable
asbestos material. However, this does
not mean that these children and
employees are breathing asbestos. It is
only when friable materials are
damaged or degraded that they can
release the asbestos fibers into the air.
If friable materials are properly
encapsulated or enclosed, there is no
threat to human health.
Preliminary surveys show that two-
thirds of the school districts in the
country with asbestos problems are
correcting them.
EPA inspections of 339 school
districts in Region 5 during Fiscal Year
1984 showed that 116 were
complying with the asbestos-in-
schools rule. Tony Restaino, Region 5
Asbestos Coordinator, said he uses a
neutral inspection scheme to
determine which districts to inspect.
Factors considered are size,
complaints, or lack of records on
district compliance with the asbestos-
in-schools rule.
Restaino said citizens often call him
complaining that they cannot get
information from their districts or that
asbestos has been found but the
district doesn't want to take any
action. Complaints can often be
resolved over the phone, he said.
To help school districts finance
asbestos abatement projects,
Congress recently appropriated $50
million for EPA to disburse in the form
of no-interest loans and grants. The
schools that will receive the money
will be selected by the States and EPA,
and will be announced in June, 1 985.
16
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Loans to Help Schools
Finance Asbestos Removal
EPA this June will distribute $45
million in grants and no-interest loans
to the country's neediest schools for
asbestos encapsulation and removal
projects. The money, available under
the Asbestos School Hazard
Abatement Act of 1984, is meant to
protect school staff and students from
serious asbestos hazards.
Asbestos is the common name for
several silicates—natural minerals
that easily separate into thin fibers of
exceptional strength. Chemically inert,
heat resistant and stable, asbestos
was widely used between 1940 and
1979 in fireproofing, insulation and
acoustical materials.
When asbestos fibers are tightly
bound into a product, they pose no
danger—it is only when asbestos
materials deteriorate and crumble that
they can release asbestos fibers into
the air to be inhaled by people.
Exposure to asbestos can cause lung
cancer; mesothelioma, a serious lung
disease; and other cancers.
EPA for several years has
administered an asbestos-in-schools
program that requires school districts
to inspect their buildings and to notify
parents and school employees when
friable (easily crumbled) asbestos is
found. It is the Agency's policy to
provide school districts with technical
expertise and other assistance to
reduce human exposure to asbestos.
The new loan and grants program
marks "the first time in its history that
EPA has ever made grants to schools,"
said Dr. John A. Moore, EPA's
assistant administrator for pesticides
and toxic substances. Moore stressed,
however, that this money will be made
available only to the Nation's neediest
school districts on a site-by-site basis.
Number of Public
Schools
Documentation
Of Inspections
Number of
Schools Requiring
Corrective Action
Schools Where
Corrective Action
HasBeenTaken
Number of
Non-Public
Schools
Documentation
Of Inspections
Number or
Schools Requiring
Corrective Action
Schools Where
Corrective Action
HasBeenTaken
Projects completed before January 1,
1984, are not eligible.
Application packages for the loans
and grants were mailed last December
to all public school districts and private
school organizations. Designated State
agencies were to receive the
completed applications by mid-
February and rank them according to
degree of hazard. The hazard ranking
process considers the condition of the
asbestos in question, whether it's
exposed, if it's in an air flow, and if it's
friable.
The hazard rankings were to be
submitted to EPA in Washington by
mid-March for the final hazard ranking
and financial need assessment. No-
interest loans with a 20-year payback
period will be the most common form
of financial help, but poorer schools
are eligible for grants to cover as
much as 50 percent of the asbestos
removal's cost.
Grants and loans are to be
announced June 6 so that removals
and encapsulations can be done
during the summer, while students are
away from school.
School districts with questions
about the asbestos assistance
program may call EPA's toxic
substances toll-free number at 800-
424-9065, the appropriate state
agency, or EPA's regional asbestos
professionals at (31 2) 886-0769. &
17
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EPA Survey:
20 Percent of U.S. Buildings
Might Have Asbestos
New Rules
To Cover PCB
Transformer Fires
As many as 700,000 commercial,
residential (apartment) and Federal
Government buildings in the U.S.
could contain friable asbestos, a
recent EPA survey shows.
Extrapolating from a sample of 231
buildings, the Agency estimates that:
• About 20 percent of all buildings
(700,000) in the U.S. contain some
type of friable asbestos material.
• Five percent of all buildings
(200,000) have sprayed-on or
trowelled-on asbestos materials
containing an average of 14 percent
asbestos.
• Sixteen percent of all buildings
(550,000) have asbestos-containing
pipe and boiler insulation with an
asbestos content of 70 percent.
• About 2,000 buildings, or .1 percent
of all buildings, have asbestos-
containing ceiling tile with an
average asbestos content of three
percent.
Asbestos, valued for its heat and fire
resistant qualities, was widely used in
construction between 1940 and 1973,
when most uses of it were banned.
Often, city building codes specified
that asbestos be used for insulating or
fire retardant purposes.
While EPA is concerned about the
number of buildings that contain
asbestos, the mere presence of
asbestos does not necessarily mean
there's any health risk. Asbestos only
poses a threat when friable material
degrades or is damaged, Agency
officials stress.
EPA recently surveyed 220 of its
273 buildings to see if any of them
contained asbestos. Lab results
confirmed sprayed or trowelled-on
asbestos in occupied areas of 1 2 of
these buildings, with asbestos found
in pipe wrap, ceiling tiles or remote
locations of 31 others. Fifty-three
warehouses and other buildings only
occasionally occupied by EPA
employees are still being surveyed.
The 42 buildings with asbestos were
immediately surveyed by EPA health
hazard teams consisting of one
technical expert, one asbestos
coordinator and one industrial
hygienist. The teams determined that
employee health could be at risk in the
12 buildings where asbestos had been
discovered in occupied areas.
Forty employees at a building in
Research Triangle Park, N.C., were
evacuated because of asbestos dust
found in various office furnishings.
EPA office workers in Denver were
permanently transferred to another
building because asbestos above the
dropped ceilings was being disrupted
by remodeling work. Operation and
maintenance plans were immediately
developed to eliminate the hazard in
the other buildings. £
EPA is expanding its asbestos program to include a contractor certification
program and to establish asbestos information centers in Georgia. Kansas
and Massachusetts,
The Agency will also extend Its technical assistance program to cover potential
hazards in public and commercial buildings, consider establishing Regulations to
protect workers who remove or encapsulate asbestos, and educate custodians and
others about how they can minimize their exposure to asbestos during normal
maintenance work.
These actions were announced by the Agency last December in response to a
petition by the Service Employees International Union (SEIU).
When electrical transformers catch
fire there is often more to worry about
than extinguishing the blaze. If the
transformer contains polychlorinated
biphenyls (PCB's) then the smoke and
soot from the fire could blanket
firefighters and innocent bystanders
with toxic compounds.
In order to minimize this exposure,
EPA recently proposed regulations that
will require certain controls on
transformers containing PCB fluid. The
new regulations will require:
• Immediate registration of all PCB
transformers with the appropriate
local fire department.
• Immediate marking of PCB
transformer locations with PCB
identification labels.
• Immediate removal of stored
combustibles from PCB transformer
locations.
• Immediate registration with
building owners of all PCB
transformers located in or near
buildings.
• The installation of additional
electrical protective devices on
certain voltage systems located in
or near buildings.
• The isolation of all PCB
transformers near or in buildings
from ventilation equipment and
ductwork that could spread toxic
smoke from the fire throughout the
building.
EPA banned the manufacture and
distribution of PCB's in 1979, citing
toxicity to humans and animals and
the persistence of the compound in
the environment.
However, the Agency allowed
continued use of PCB fluids in
electrical transformers as dielectric, or
insulating, fluid. The heavy, oil-like
18
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fluids are known for their stability, low
flammability, high heat capacity, and
low electrical conductivity. A typical
PCB transformer holds about 200
gallons of fluid with a PCB
concentration of about 50 to 60
percent. Some transformers can hold
as many as 1,000 gallons of PCB
liquid.
In the rare cases when these
transformers catch fire and incomplete
combustion occurs, relatively large
amounts of toxic products can form.
If the transformers are near building
ventilation equipment and ductwork,
these compounds can spread
throughout a building, exposing
hundreds or thousands of people to
substances that have produced
unusually toxic effects in laboratory
animals.
The substances of most concern to
EPA are 2,3,7,8-tetrachloro-dibenzo-p-
dioxin (2,3,7,8-TCDD, or dioxin) and
2,3,7,8-tetrachloro-dibenzofuran
(2,3,7,8-TCDF). Other potentially
dangerous compounds may also be
produced and released during PCB
transformer fires.
EPA believes that firefighters, when
responding to a transformer fire, need
to know if PCB's are present so they
can wear the proper respiratory
devices and protective clothing to
guard against the combustion
products. Bystanders should be
evacuated, as should building
occupants if the smoke and soot have
gotten into the ventilation system.
The relative risk posed by PCB
transformer fires will depend on the
concentration of PCB's in the dielectric
fluid. Transformers containing 50 to 60
percent PCB's will pose much greater
" ".-• Polyehoforinated biphenyls {PCB'sh a once-popular insulating fluid in
eliectrteal transformers and capacitors, are carefully regulated by EPA
JSeeaws© of their toxicity and persistence in tfif=environment
••";/; -/ERA regulations prohibit the manyfaeturiejof PCB's, require the phase- '
, @uti>f existing uses, and specify disposal rrt^thods. There are penalties as
- hiigh as $25,000 a day for not complying witrt .the" rules.
Gprtgress directed EPA in t976 to ?egula*f .PCB's because it believed
that the compound posed a significant risfc to public health and the
•renWortment. In 1979, EPA banned the manufacture of PCB's and
twttowed most uses, _ ..:';.-'•'"'. ; ' '
"•' .-;'. This .current PCB regulations pertato Jarg^Jy; to those who use, .store or ": ,:
! .-.(jisjpofe cat electrical equipment that ritain"ftC6's. The major provisions of
'
.-,S£:
MAR KING
'
PCB transformers fcorttaining fluids, with more '•
than 500 parts per mtjilbn PCfi's) must be --...',
inspected every tljir^Ki^onths for signs of
leakage; 'Inspection tejSords mvstbe maintained;
and leaks must be promptly cleaned up. •' -
PCS transfo'riir»ers,.;la'r^e;highivoltage PCS' .'':
capacitors'ln service, .-targe low- voltage PCi "• ••
transformers at.thftiJrtf of removal for disposal, y
PCB containers' In sttrfarge'for -disposal, and;P£B ,
-storage areas .mus^Wmarked;WitK, the _Mt-fe'tK5tr.
specified in the regulations. ''. • .-• •
A concise aniiual suoimary document must be
prepared to account fjBr aHPCB activity during
each calendar year, fhis document applies to in-
service PCB fquipmertt, stored PCB equipment
and disposed PCB's: -'•".' , '
-Storage areas. for P<3B's~and PCB items must' -
meet certain-coridif ons fuch as adequate roof .-•
and floors and s6ntwi*ou$ curbing to contain
. spills. • . : ':-'",- /• ', '•' •
Transformer fluids (ftorftairiing more than 500
ppm PC8?s) must. be;. destroyed on/y by high-
temperature ihcineraiion in an EPA-approved
incinerator. btfterPipl'a in. cjmcentrations '
between 50 wid. ftfiQ 'pjpm m,ust be disposed of in
Wgh-efficiency bolfifsi approved chemical waste
'landf ills or hfgrVt0m'petatureincit>e.pators. Fluids.'-
with less'than 60 ppWrPC.B's cannot be-usedas'-a
sealant coating, or dust'pontrol agent but, may
b© disposed of in a.-*ciranical. waste .landfill;,
Regulations a|so apply to the disposal of PCB
solids and.
,'f-or wore information about the'fCB r^tmft^a^,- ca'H::|PA"s Toxic-
.-Substances Control Act assistance aumb:er'cW.';SOO-42:4-9Q65.
risks of significant exposures than
transformers containing a smaller
concentration.
The Agency feels that the additional
transformer control measures in the
proposed rule will avert about 38
serious PCB transformer incidents
during the remaining useful life of
PCB-containing equipment.
The proposed transformer fire rule is
scheduled to be issued July 1. &
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Risk Assessment
EDITOR'S NOTE: This article was adapted
from EPA Journal and an EPA report
entitled Risk Assessment and Risk
Management: Framework for Decission
Making.
The goal of the EPA is to improve the
condition of the environment—to
reduce risks to human health, and to
protect and enhance the quality of
natural ecosystems. This much has
always been clear, but the more
recently understood threat of toxic
chemicals has greatly increased the
difficulty of carrying out that
assignment.
To develop priorities and to act
constructively in a highly uncertain
environment, the Agency is relying
heavily on the techniques of risk
assessment and risk management.
Risk assessment is the process used
to estimate risks to the public health.
Because of the uncertainties in
currently available scientific
information, the Agency estimates risk
conservatively. Risk management
looks at the economic and social
implications of varying levels of
protection against certain compounds.
EPA's objective is not to join risk
assessment and risk management, but
to separate the two clearly so that
scientific judgments (risk assessment)
can be made independently and then
balanced against economic, social and
community considerations (risk
management). EPA's risk assessment
logic basically asks four questions.
• How hazardous is the substance?
• How much is harmful?
• What is the nature of exposure?
• What are the risks in a particular
situation?
In order to improve this process, EPA
has proposed new guidelines to
improve consistency and credibility.
Specifically, the Agency considers the
following health risks:
• Cancer.
• Mutagenicity.
• Reproductive effects.
• Systemic effects (effects on other
body systems).
• The effects of chemical mixtures.
The Agency feels that since risk
management involves statements
about values, the public has a right to
know what values EPA is applying. It is
essential that we address the worst
and most-controllable risks first and
the risk assessment/management
process is helping us do that. Despite
its uncertainties, it's the only tool we
have right now for discriminating
among environmental health
problems. ^>
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Pesticides Regulated by EPA
Herbicides, fungicides, and
insecticides all are chemicals that fall
under the general heading of
"pesticide." Whether they're designed
to kill weeds, fungus, or crop-eating
bugs, they are toxic compounds whose
manufacture, distribution and use is
controlled by EPA.
EPA requires all pesticides used in
the United States to be registered with
the Agency before they are marketed
for use. In order to obtain a
registration, a manufacturer must
provide EPA with information about
the pesticide's contents, toxicity,
persistence in the environment, short-
and long-term environmental effects,
safety and use, and effects on humans
and the environment.
Once this information is available,
EPA specialists determine if the
product can perform its intended
function without causing
"unreasonable adverse effects" on
human health or the environment.
If so, the Agency registers the
product and specifies the language
that must be used on the label. It is
illegal to use a pesticide for purposes,
or in a manner, other than specifically
directed on the label.
For instance, a label might specify
that the product in question can be
used only for killing rodents and that
children and pets should not be
allowed to come into contact with the
compound. If someone hired a pest
control service that used the product
to kill bats in the attic and then
allowed the family dog to eat some of
the poison, the pest control service
could be prosecuted by EPA.
EPA and the States routinely collect
and analyze pesticides to ensure that
they are labeled according to their EPA
registration. In very serious cases of
mislabeling, such as when antidote
instructions are incorrect, EPA issues
"stop sale" orders to avert serious
i nj u ry.
The Region 5 Pesticides Section is
responsible for seeing that pesticides
are used safely and properly in the six-
State Midwestern region and that
manufacturers comply with their
responsibilities under the Federal
Insecticide, Fungicide and Rodenticide
Act(FIFRA).
In order to do this, the pesticides
section:
• Monitors pesticide use by
professional pest control operators,
aerial applicators, homeowners,
industry officials, and farmers.
• Protects the public by ordering
manufacturers to stop sales when
their products violate the terms of
the law.
• Assesses fines for major violations
of FIFRA.
• Supervises State inspections of the
3,600 pesticide manufacturers in
the Region.
• Oversees State-administered
pesticide compliance programs.
Most of the day-to-day aspects of
the pesticides program are handled by
the six States in Region 5: Illinois,
Indiana, Michigan, Minnesota, Ohio
and Wisconsin. EPA, through its
grants program, provides much of the
money needed by the States to run an
effective pesticides program.
Pesticide programs are usually run
by State agriculture departments.
Pesticides specialists in these
departments train and certify
applicators to work with certain highly
toxic, restricted-use chemicals. As of
September 30, 1984, there were
89,000 certified private and 26,000
commercial applicators in Region 5.
The States, in cooperation with EPA,
also are auditing laboratories to
ensure the accuracy of data submitted
to EPA by manufacturers, monitoring
pesticide importers and exporters, and
enforcing the law. «»
The following pesticides specialists
work in Region 5 States and are
available to answer your questions.
ILLINOIS
Tom Walker
Department of Agriculture
(217)785-8462
Harvey Dominick
Department of Public Health
(217)782-4674
INDIANA
L 0. Nelson
State Chemist's Office
(317)494-1587
MICHIGAN
Robert Mesecher
Department of Agriculture
(513)373-1087
MINNESOTA
William Bulger
Department of Agriculture
(612)296-1161
OHIO
Oren Spilker
Department of Agriculture
(614)866-6361
WISCONSIN
William Simmons
Department of Agriculture,
Trade and Consumer Protection
(608)266-7135
U.S. EPA, CHICAGO
Phyllis Reed, Chief
Pesticides Section
(312)353-2192
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Pesticides Update
EDITOR'S NOTE:
About 50,000 pesticide products,
composed of 600 basic chemical
active ingredients, have been
registered for use in the United States
since 1 947. Since many of them were
approved when knowledge of health
and environmental effects was far
more limited, EPA is reregistering
these compound's using current
scientific standards.
If data show that a product can be
used without unreasonably affecting
public health or the environment, EPA
will reregister the product for use. If at
any time after the pesticide is
registered by EPA there is new
evidence that casts doubt on its safety,
EPA must conduct further risk/benefit
evaluations to see if new regulatory
action should be taken.
If data indicate a possible
unacceptable risk, the Agency begins
the special review process. This
process considers acute toxicity,
chronic toxicity (including cancer, birth
defects and sterility), significant
reductions in wildlife species, or the
lack of an antidote for emergency
treatment.
The special review may result in a
determination to cancel the
registration or restrict use of the
chemical.
ALACHLOR
EPA recently placed additional
restrictions on alachlor, the largest-
volume herbicide sold in the United
States. Alachlor, known by the trade
name Lasso, is widely used to control
weeds in corn and soybean crops.
Use of alachlor on potato crops is
now prohibited, as are applications of
the herbicide from crop dusting
planes.
The Agency has determined that
alachlor could pose a substantial
cancer risk to persons working with
the compound and is therefore
subjecting it to a special review
process in which EPA will assess all
the risks and benefits of alachlor
before deciding if it should be allowed
to remain on the market.
Monsanto Co., the manufacturer of
alachlor, has agreed to make special
training programs available to all
potential users of the herbicide before
the 1 985 planting season. The training
will outline safeguards to be followed
when using the product and will be
held in all parts of the country.
EPA has required Monsanto to
revise alachlor labels to include the
following information:
—A statement that alachlor causes
tumors in laboratory animals.
—Handling instructions designed to
reduce worker exposure to the
product.
—A statement that the compound
has been found in limited ground-
water testing and could run off
into rivers and streams.
—Instructions for wearing goggles,
rubber gloves, boots, trousers and
long-sleeved shirts during mixing
and loading operations and during
cleaning and repair.
AMITROLE
EPA began a special review of amitrole
in May, 1984, based on evidence that
it causes tumors in laboratory animals.
Amitrole is a herbicide used to control
grasses and broadleaf weeds, mainly
along highways. Large-scale use of
the compound has been restricted
during the review process.
DAMINOZIDE
EPA has undertaken a special review
of all pesticides containing the active
ingredient daminozide. This
compound, which is used primarily on
peanut and apple crops, causes cancer
in laboratory animals and has been
detected in raw agricultural products
as well as processed food.
A hydroloysis product of daminozide
also causes cancer and mutagenic
effects in laboratory animals. This
compound is unsymmetrical 1,1 -
demethylhydrazine (UDMH) and is of
special concern because UDMH is
formed when apples are processed or
cooked. The compound has been
detected in apple juice and sauce.
Daminozide is used in apple
orchards to delay the fruit ripening
process, thereby extending the
harvesting period. It also improves the
color of apples and makes them firmer,
increasing storage life and preventing
bruising and rotting during transport.
In peanuts, daminozide stimulates
upright growth of the plant, allowing
increased air circulation and light
penetration. It also reduces disease
and insect problems and increases
harvesting efficiency.
Daminozide is most often sold under
the trade name Alar.
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DICOFOL
EPA has proposed cancelling the
pesticide dicofol because it may
contain DDT and other impurities that
are hazardous to fish and the birds
that feed on fish.
Approximately 2.5 million pounds of
dicofol are used in the U.S. each year,
primarily in Arizona, California, Florida
and Texas to control mites on cotton
and citrus.
Of concern to EPA is the 10 percent
of the product that contains DDT and
related compounds DDE, ODD and
tetrachloro-DDT. These compounds,
collectively known as DDTr, can affect
the reproductive abilities of fish and
birds.
DDT, once widely used to control
insects, was banned by EPA in 1972
because of its persistence in the
environment and its harmful effects
on wildlife.
Dicofol was the subject of a special
review required by the Federal
Insecticide, Fungicide and Rodenticide
Act (FIFRA). After evaluating the risks
and benefits of dicofol, EPA
determined that its risks to the
environment outweigh any benefits.
Dicofol was first registered in 1 957.
It is known by the trade names Acarin,
Kelthane and Mitigan.
ETHYLENE DIBROMIDE
EPA has suspended the use of
ethylene dibromide as a fumigant on
grain, soil, citrus and tropical fruits
after EDB residues were detected in
raw and cooked foods and in ground
water.
The Agency took this action last
spring based on evidence that EDB
could induce cancer in laboratory
animals, as well as posing the threat
of tumors, genetic mutations, and
birth defects.
Because EDB residues were found
in food, EPA has proposed lowering
the allowable levels of these residues
in products ranging from raw grain to
flour and ready-to-eat products.
LARVADEX (cyromazine)
EPA is still determining if the pesticide
larvadex should be registered for use
as a chicken-feed additive to help
combat the avian flu. Although the
Agency allowed the emergency use of
larvadex in four States during 1 983
and 1 984, it will wait for adequate
health data before making a final
decision on the compound's use.
LINURON
The Agency initiated a special review
of linuron in September, 1984, after
determining that it causes cancer in
rats and mice. The herbicide, widely
used on soybeans, other foods and
non-agricultural sites, will continue to
be available on a restricted use basis
during the review process.
PENTACHLOROPHENOL
EPA has proposed cancelling most
non-wood uses of pentachlorophenol
(PCP) after determining that continued
use may pose unreasonable public
health risks.
This action is based on data
showing that PCP causes birth defects
in the offspring of laboratory animals.
It contains dibenzo-p-dioxin (HxCDD)
and hexachlorobenzene (HCB), both of
which cause cancer in laboratory
animals.
PCP, in addition to its function as a
wood preservative, is used as a
herbicide, disinfectant, defoliant, for
moss control, and as an anti-microbial
agent.
EPA has decided that continued use
of PCP for other than wood
preservative functions would pose an
unreasonable risk to human health
and the environment. In most cases,
acceptable substitutes are available.
However, PCP will still be registered
as an anti-fungal agent in oil well
flood waters and in pulp and paper
mill solution. EPA has decided that the
benefits of continued use in these
circumstances outweigh the risks. <>
EPA distributes many informative
brochures and booklets on a wide
variety of environmental topics.
You can obtain publications
by contacting:
EPA PUBLIC INFORMATION CENTER
820 QUINCY ST. N.W.
WASHINGTON, D.C. 20011
Phone: (202)829-3535
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GLOSSARY
Asbestos
A building and insulating material widely used for
years because of its strength and heat-resistant
qualities. When not completely sealed in a product, it
can break into microscopic fibers that can float almost
indefinitely in air. If inhaled, the fibers can cause
asbestosis—a severe lung ailment, certain types of
cancer, and other respiratory problems.
Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA)
Also known as Superfund, this law authorizes the
Federal government to respond directly to releases of
hazardous substances that may endanger public
health, welfare or the environment. It ahso provides
money, through a tax on chemicals, for cleaning up
abandoned hazardous waste dumps.
Dioxin
A generic term for a group of 75 related compounds
known as polychlorinated dibenzo-p-dioxins. However,
the term usually refers to the most toxic and widely
known of the group—2,3,7,8-TCDD. Dioxin is not
produced intentionally; it is an undesired byproduct in
the manufacture of several commercial substances,
chiefly the pesticide 2,4,5-TCP. Dioxin was a
contaminant in Agent Orange, the defoliant used
during the Viet Nam War. Dioxin is a suspected human
carcinogen and can produce a painful skin rash known
as chloracne. EPA is performing a nationwide study to
determine the extent of dioxin in the environment.
Federal Insecticide, Rodenticide and Fungicide Act (FIFR A)
Regulates the 50,000 pesticides in use in the United
States. Provides for: premarket clearance (registration)
of pesticides to prevent unreasonable hazards to
humans or the environment; classification of
pesticides for specific uses; certification of pesticide
applicators; informative and accurate labeling of
pesticides; and enforcement to ensure proper
pesticide practices. The Agency is now reregistering
the 600 active ingredients found in U.S. pesticide
products to ensure that they pose no unreasonable
risks in light of currently available scientific
information.
National Priorities List (NPL)
A list of 812 sites in the U.S. now eligible for
Superfund-financed cleanups. One hundred and
ninety-two of these sites are in Region 5. The NPL is
expected to include as many as 2,000 sites by the year
2000; Region 5's share may be 440.
Polychlorinated biphenyls (PCB's)
PCB's are a family of organic compounds used since
1926 as an insulating and dielectric fluid in electrical
transformers and capacitors and in hydraulic systems.
EPA banned the manufacture of PCB's in 1979
because of their persistence in the environment, but
PCB's still are allowed in electrical transformers and
capacitors. PCB's are not as toxic in acute doses as
other chemicals, but can cause a painful skin rash.
Ubiquitous in the environment, the compounds,
accumulate in the fatty tissues of humans and
animals.
Resource Conservation and Recovery Act (RCRA)
Enacted in 1976 and amended by Congress last year,
RCRA regulates hazardous waste management
practices by licensing hazardous waste treatment,
storage, and disposal facilities and by tracking wastes,
via a manifest system, from their creation until their
disposal. The law provides for criminal penalties in
certain cases.
Remedial Investigation/Feasibility Study (RI/FS)
The RI/FS is a two-part study completed before long-
term work at a Superfund site can begin. The
Remedial Investigation (Rl) is a study of the nature and
extent of the problem at the site. The Feasibility Study
(FS) is an evaluation of different methods of dealing
with the problem and a recommendation of the one
that will most effectively protect public health and the
environment.
Toxic Substances Control Act (TSCA)
Passed in 1976, this law gives EPA the authority to
gather certain basic information from chemical
manufacturers regarding health risks. The law also
requires manufacturers to notify EPA 90 days before
making a new chemical substance. TSCA allows EPA
to regulate unreasonable risks at any stage in a
chemical's life—manufacturing, processing,
distribution, use or disposal. PCB regulations and the
Agency's asbestos-in-schools rule were promulgated
under the authority of TSCA.
24
*U.S. GOVERNMENT PRINTING OFFICE: 1985-557-OO6
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•TF
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United States
Environmental Protecion
Agency
Region 5
230 S. Dearborn St.
Chicago, IL 60604
Official Business
Penalty for Private Use
$300.00
THIRD CLASS
BULK RATE
Postage and Fees Paid
EPA
Permit No. G-35
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