JB-02-Uj



                  LISTING  BACKGROUND  DOCUMENT

         Wastes  from  Usage  of  Halogenated  Hydrocarbon
               Solvents  in Degreasing  Operations

The  following  spent halogenated  solvents  used  in  degreasing:
tetrachloroethylene ,  methylene chloride,  trichloroethylene,
1,1,1-trichloroethane ,  carbon  tetrachloride and  the  chlorinated
fluorocarbons; and  sludges  from  the  recovery of  these  solvents
In  degreasing  operations.(T)*,**,***

I.   SUMMARY  OF BASIS  FOR  LISTING

      Solvent  degreasing  operations remove  grease,  wax, dirt,

oil,  and other undesirable  substances  from  various materials.

All  degreasing facilities which  use  the halogenated  hydro-

carbon solvents  listed  above generate  spent solvent  solutions

which are either  discarded  or  processed to  recover the solvent

from  the spent solution.  Spent  solvents include  those which

are  no longer useful without further  processing,  either

because they have outlasted  their shelf life or because they

have  been contaminated, or  so  changed  chemically  or  physically

that  they are no  longer useful as solvents.  The  recovery

operations invariably generate solvent sludges.
*   In December, 1978, the Agency' proposed a generic listing
    for this class of wastes.
**  These solvents are often marketed under various trade
    marks; the listing obviously includes all trade mark
    solvents which have the generic chemical name listed
    above.  Another point of consideration is that different
    naaes nay be used to refer to the same solvent:
         tetrachloroethylene - perchloroethylene
         1,1,1-trichloroethane  methyl chloroform
         carbon tetrachloride  tetrachloromethane
         methylene chloride  dichloromethane
         trichloroethylene * 1,1, 2-trichloroethylene
*** In response to industry comments, it should be noted
    that the Agency is no longer listing these wastes on
    the basis of ignitability or E? toxicity.  However, these
    solvents nay be contaminated with metals (i.e., lead and
    chromium) in the degreasing operations; therefore, the
    generator will be responsible for determining whether the
     asta would also meet the EP toxicity characteristic.

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The Administrator has determined that spent halogenated

solvents from degreasing and the sludges that result  from

associated solvent reclamation operations are solid wastes

which may pose a substantial present or potential  hazard  to

human health or the environment when improperly  transported,

treated, stored, disposed of, or otherwise managed; therefore,

these wastes should be subject to appropriate management

requirements under Subtitle C of RCRA.

     For all of the listed waste solvents, this  conclusion

is based on the following considerations:

     1.  The chlorinated hydrocarbons are toxic  and,  in some
         cases, genetically harmful, while chlorofluorocarbons
         may deplete the ozone layer following environmental
         release.

     2.  Approximately 99,000 metric tons of waste halogenated
         solvents from degreasing operations are generated
         each year(l).  There are approximately  460,000
         facilities dispersed throughout the country  that
         use, halogenated solvents and generate these  wastes(l).
         It is estimated that about 30,000 metric  tons per year
         of halogenated hydrocarbons from these  facilities are
         either disposed of annually in landfills  or  by open-
         ground dumping, either as  crude spent solvents
         or as sludges.  The remainder of these  wastes are
         usually incinerated.  The  large quantity  of  wastes
         generated and the large number of disposal sites
         utilized increases the possibility of waste  mis-
         aanageraent and environmental release of harmful
         cons tituents.

     3.  Since a large majority of  the spent solvents  and
         sludges are in liquid form, the potential for these
         wastes to migrate from land disposal facilities
         is high.   Further, the solubility of these solvents
         is generally high, increasing their migratory
         potential.

     4.  The spent solvent  solution from degreasing operations
         nay contain up to  90 percent  of the original  solvent.
         Depending on the  recovery  technique,  sludges  that  result
         from reclamation  processes  can  contain  up to  50 percent
         of the  original  solvent.   Such  high concentrations

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          of  hazardous  constituents increases the chance of
          waste  constituents  escaping in harmful concentrations.

      5.   Spent  solvents  can  create an air pollution problem
          via  the  volatilization of the solvents from the
          was tas .

For  the  five  chlorinated solvents  (not including chlorofluoro-
carbons)  found  in the  waste  streams, this conclusion is
based  on  the  following  considerations:

      6.   Incomplete  combustion  of  the spent  chlorinated
          hydrocarbon solvents  during incineration can
          cause  emissions of  the solvent and  generate
          toxic  degradation products  (e.g. phosgene).

      7.   These  spent halogenated  solvents can  leach from
          the  waste  to  adversely affect human health and
          the  environment through  the resulting  contamination
          o f  groundwa ter.

      8.   Current  waste  management  practices  have resulted
          in  environmental damage.   These  incidents  serve to
          illustrate  that the mismanagement  of  these wastes
          does occur  and  can  result in substantial  environmental
          and  health  hazards.

      9.   A number of these solvents  are carcinogenic or
          mutagenic,  or  are suspected carcinogens or rautagens,
          and  are  lethally toxic to humans and  animals.

For  the  chlorof1uorocarbons, the  Agency is  basing  the  listing
on the following  consideration:

     10.   Chlorofluorocarbons, after  release  at  the  surface of
          the  earth,  mix  with the  atmosphere  and  rise into
          the  stratosphere where they are  decomposed by  ultra
          violet radiation to release chlorine atoms.   These
          atoms  catalytically deplete the  ozone,  leading to ad-
          verse  effects,  including  skin cancer and  climate  changes

II.   OVERALL  DESCRIPTION OF  INDUSTRY USAGE

      Degreasing operations are  not  industry  specific.   Degreasing

operations are  prevalent in  twelve major  SIC  (Standard  Industrial

Classification) categories, numerous  subcategories ,  and auto-

motive maintenance shops.  The  pertinent  industries  where

halogenated hydrocarbons are used  primarily  are  presented  in

Table 1.   A summary  of the nunber  and  types  of  plants  that

conduct degreasing operations is presented in Table 2.

                             -y-
                             -3-

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                           Table  1




          Industries Using Halogenated  Hydrocarbons




                    in Degreasing  Operations









Source                                   SIC Code




Metal Furniture                             25




Primary Metals                              33




Fabricated Products                        34




Non-electric Machinery                      35




Electric Equipment                          36




Transportation  Equipment                   37




Instruments  and  Clocks                      38




Miscellaneous  Industry                      39




Automotive Repair  Shops                    75




Automotive Dealers                          55




Automotive Maintenance  Shops               




Texitile Plants  (Fabric Scouring)          22




Gasoline Stations                       55

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                            Table 2  -  Solvent Degreasing Source Types*(l)
Source
Material Degreasing
Metal Furniture
Primary Metals
Fabricated Products
Non-electric Machinery
Electric Equipment
Transportation Equipment
Instruments and Clocks
Miscellaneous
Automotive
Auto Repair Shops
Automotive Dealers
Gasoline Stations
Maintenance Shops
Textiles
Textile Plants (Fabric Scouring)
SIC
25
33
34
35
36
37
38
39
75
55
55

22
Estimated Number
Number of of Vapor Degreasing
Plants Operations
9,233 492
6,792 1,547
29,525 5,140
40,792 5,302
12,270 6,302
8,802 1,917
5,983 2,559
15,187 886
127,203
121,369
226,445
320,701
7,201
Estimated Number
of Cold Cleaning
Operations
22,869
17,558
76,329
105,456
31,720
22,756
15,467
39,262
141,977
135,463
277,440
252,735

                           Total
931,513
24,145
1,230,006
*Includes facilities which do not use halogenated solvents

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III.  OVERALL PROCESS DESCRIPTION. WASTE GENERATTOM LEVELS
      AND GEOGRAPHIC DISTRIBUTION OF DEGREASINCT APTT TTTF<;

     1.   Solvents Used in Degreasing Process

          As indicated in Table 3, out of  the  more  than  1,230.000

     non-halogenated and halogenated degreasing  operations

     (see Table 2), approximately 460,000  use  halogenated

     solvents(l).  Table 3 breaks down the  number  of  plants

     which use halogenated solvents to show the  estimated  number

     of  these plants using a particular halogenated  solvent  by

     their type of degreasing operation.   As the table  indicates,

     the largest number of these plants use  cold cleaning  and open

     top vapor degreasing operations (see  next section  for  more

     detailed discussion of specific degreasing  operations).

     In  both of these operations, the largest  number  use trichloro-

     ethylene and trichlorethane.  Of the  industries  with  conveyor-

     ized vapor degreasing operations, the  largest  number  use

     trichloroethylene; fabric scouring operations  use  principally

     tetrachloroethylene (perchloroethylene).  Overall,  trichloro-

     ethylene is the solvent used most prevalently.

     2 .  Process Description

          Degreasing operations may be classified  into

     four basic categories: cold cleaning,  vapor degreasing

     (open top), vapor degreasing (conveyorized),  and fabric

     scouring.

          In cold cleaning operations, the  solvent  is main-

     tained well below its boiling point. The  item  to be

     cleaned is either immersed in the agitated  solvent

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       Table 3 - Estimated Number of Plants  using Halogenated


             Solvents by Type of Degreasing  (1974)  (1)
                    Vapor                       Vapor         Fabric
Solvent
Carbon tetr achloride
Fluorocarbons*
Methylene Chloride
Tetr achloroethylene
Tr ichloroethylene
IT ichloroethane
Total
(open top)

2,130
293
3,121
11,440
4,011
21,000
Cold Cleaning
10,568
66,932
21,136
45,795
149,715
137,386
431,532
Conveyor ized

319
45
467
1,713
601
3,145
Scouring



2,522
693

3,215

Note:  Blanks indicate no use  of specified  solvent in that type
       of degreasing operation.


*This refers to all fluorocarbons,  some  of  which are chlorinated.
                                -X-
                                 -7-

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    or suspended  above  the solvent where it ls systematically




    sprayed in  a  manner  similar to that of an automatic




    dish washer.   Simple cold cleaning operations may




    even consist  of  a  container of solvent in which




    items  are  manually  immersed, as is the case  in  small




    auto repair  shops  and in service stations.




         Simple vapor  degreasing (open top)  is  achieved by




    suspending the item to be cleaned above  the  boiling




    solvent in a vat.   Condensation continues  until the




    temperature of the  object approaches  that  of the solvent




    vapors.  Often the suspended item is  sprayed with liquid




     solvent to facilitate further degreasing.   In order to




     control vapor emissions, a  layer of cold  air is often




     maintained above the open top degreaser.




          The conveyorized vapor degreaser  operates  in much




     the same manner, except  that the objects  to  be  cleaned




     are continuously conveyed  through the  vapor  zone.




     Auxiliary solvent sprays are also used to  improve the




     cleaning efficiency of  the  operations.




          Fabric  scouring operations are slightly more complex.




     Generally, the fabric is conveyed through  the degreasing




     machine, where it is sprayed with solvents.   The solvents




     are then removed with an aqueous solution  of alcohol.






     3 .   Waste Generation Levels and Projected  Levels




          The annual *rowth  rate for the use  of  the  listed




halogenated solvents in degreasing applications  is expected to

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be 4 percent(l).   Growth is expected to be uniform  among




the various  solvents,  except for trichloroethylene,  which




has been banned  in several  states for use in occupational




settings because  it  is  a carcinogen. (1,2,21).  In  Cali-




fornia, the  use  of trichloroethy1ene has been restricted  by




legislation,  but  tetrachloroethylene and 1,1,1-trichloroethane




are exempt(l)  from the  restrictions and are still used  in




degreasing operations.   Rhode Island has completely  banned




the use of trichloroethy 1ene(2).




4.  Geographic Distribution of Degreasing Operations




     The location  of  the vapor degreasing operations has




been determined  by identifying the  industries with  which




the operations are associated.  There are about 24,145'




vapor degreasing  operations in the  United States, which




consume about  52  percent of the  total halogenated solvents




used(l).  More than  63  percent of these operations  are




found in nine  states  (California, Illinois,  Massachusetts,




Michigan, New  Jersey,  New York,  Ohio, Pennsylvania  and




Texas).  Figure  1  and  the associated Table 4 present the




geographic distribution  of  these plants.




     There are about  431,532 operations that perform




cold cleaning  using  about 35 percent of the total




halogenated  solvent  consumption, while approximately




3,125 fabric  scouring  operations consume about 13 percent




of the  total  halogenated solvent(l).  Assuming an equal




distribution  of  halogenated solvent use among cold




cleaning and  fabric  scouring operations, over 59  percent

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     of the  total  halogenated solvent used for  degreasing  occurs

     In ten  states  (California,  Illinois, Massachusetts, Michigan,

     New Jersey, New  York,  Ohio, Pennsylvania,  Texas  and North

     Car olina).

IV.  WASTE STREAM  SOURCES AND DESCRIPTION

     The usefulness of  a  solvent decreases with time  as contami-

nants adulterate and  become concentrated in the solvent.   When the

boiling point  of the  solution (i.e., solvent and contaminants) in-

creases to about 30 C  above that of the pure solvent,  the  solvent

is considered  spent.   Halogenated solvent use pattern  by type  of

degreasing operation  is presented in Table 5.   Approximately

527,520 metric  tons of  halogenated solvents are used  each  year for

degreasing operations(1).

     Spent solvent  solutions include those solvents which  ate  no

longer useful  without  further processing, either because they

have outlasted  their  shelf  life  or because they have  been  con-

taminated, or  so changed  chemically or  physically that they are

no longer useful as solvents.  These spent solvents are either

disposed of, reclaimed  and  recycled by  the waste generator, or

processed by a  contract solvent  reclaiming operator.*  Reclamation

is achieved  via  settling  and/or  batch distillation.   The listed

sludge results  from this  reclamation process.

     The composition  of the spent solvent is dependent on  the

application  of  the  degreasing operation.  The spent solvent
*At this time, applicable  requirements of Parts 262 through
 265 and 122 will  apply  insofar  as the accumulation, storage
 and transportation  of hazardous wastes that are used, reused,
 recycled or reclaimed.  The  Agency believes this regulatory
 coverage is appropriate  for  the subject wastes.  These wastes
 are hazardous insofar as  they  are being accumulated, stored  or
 transported.  These  wastes  may  not pose a substantial hazard
 during their recycling  and,  even though its listed as hazardous,
 this aspect of  their management is not presently being regulated.

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                                              Table 5
                       USE PATEERN OF HALOGENATED SOLVENTS IN DECREASING AND
      Chemical



  Halogenated hydrocarbons:

   Carbon tetrachlorlde

   Fluorocarbons*

   Methylene Chloride

   Perchloroethylene

   TrIchloroethyleue

   Tr ichloroethane


        TOTAL
FABRIC SCOURING
Total U.S.
Consumption
(103 kkg)
*"\ n c 
LMlo 
534.8
428.6
235.4
330.2
173.7
236.3
OPERATIONS IN 1974
U.S. Consumption U.S
for Degreasing for
(103 kkg) (10
Cold
0.72
6
46,2
11.4
43.8
78
Va por
5
11. 1
10
43
112.7
90
                                                                         U.S. Consumption
                                                                         for Fabric Scouring
                                                      54.6

                                                      15
                                                                    Total  U.S.
                                                                    Consumption
                                                                     for  Degreaslng
                                                                    and  Scouring
                                                                    (103 kkg)
1939.0
186.12
                                   271.8
69.6
  5.72

 17.1

 56.2

109

171.5

 168


527.52
*Thls refers to all  fluorocarbons, a  percentage of which are chlorinated.

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solution  contains  up  to  90  percent  of  the original solvent(4).




Depending  on  the  recovery  technique,  sludges which result from




reclamation  processes  contain  from  1  to 50 percent of the




original  hydrocarbon  solvent(S).  However, because of the




economic  considerations  of  the  reclaiming process, the solvent




content of the  sludge  is seldom  reduced below 10 percent.




Heavy metal  fines  and  other  organics  are also present in




these wastes,  in  addition  to the  original solvent(3).






V.   QUANTITIES  OF  THE  WASTE  AND  TYPICAL DISPOSAL PRACTICES




     Disposal  practices  include  overt  open ground dumping,




containerized  landfilling,  and  incineration (3).  Approximately




99,000 metric  tons  of  waste  halogenated solvents frora degreasing




operations are  generated annually(l).   It is estimated that




about 30,000  metric tons of  these are  either landfilled  or




open dumped.-  The  remaining  quantity  of waste halogenated




solvents  from  degreasing operations are incinerated.   The




rationale  and  derivation of  this  estimated quantity  is presented




in Appendix  I.






VI.  HAZARDOUS  PROPERTIES OF THE WASTES
     As indicated earlier,  the  spent halogenated  solvents  and




sludges frora the  reclamation of  these  solvents  contain  very




significant concentrations  of the  solvent  itself  --  the




spent solvent solution contains  up  to  90 percent  of  the  original




solvent and the sludge contains  a  minimum  of  10  percent  of




the original solvent.  The  landfilling  or  open  ground  dumping




of these wastes in an unsecure  land disposal  facility  nay
                                 - 13-

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result in the migration of the toxic halogenated solvents




into the surrounding  environment, thus becoming a potential




contaminant of groundwater.   For example, since a large ma-




jority of these  wastes  are in liquid form --  including  all  of




the  spent solvents  -- these  wastes' physical  form makes  them




amenable to migration from a land disposal  facility.   Addi-




tionally, the  solubility in  water of these  halogenated solvents




is  appreciable  (13):  1,1,1-trichloroethane  -  950  mg/1, tetra-




chloroethylene  150  mg/1, methylene chloride -  20,000  mg/1,




carbon  tetrachloride  800 mg/1, and trichloroethylene  - 1,000




mg/l(14a).  These  relatively high solubilities  demonstrate  a




strong  potential for  migration of these substances  from inade-




quate  land  disposal facilities in substantial  concen tr at io'ns .




Thus,  improperly constructed or managed landfills (for example,




 landfills  located  in  areas with permeable soils,  or  landfills




with inadequate  leachate control practices) could easily




 fail to impede leachata formation and migration.  Haphazard




 dumping of  the wastes is even more likely to result  in migration




 of  waste constituents.




      Once  released  from the  matrix of the waste,  the  halogenated




 solvents could migrate  through the soil to  ground and  surface




waters  utilized  as  drinking  water.  In the  National  Organics




Monitoring  Survey,  the  Agency detected a number of  these  solvents




 in  drinking water  samples tested over the past  several years,  thus




demonstrating  the  propensity of these solvents  to migrate  from the
                              -J/-

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waste disposal  environment  and to persist in drinking  water  follow-

ing migration*  (14a,  14b,  14c, 14e).   In addition,  a number

of actual documented  damage incidents show the potential  for  a

very common halogenated  solvent,  trichloroethylene , to  leach

from disposal  sites  into  groundwater.  (See Damage  Incidents

Resulting from  the Mismanagement  of Halogenated Hydrocarbons ,

p . 16 . )

     These  actual  damage  incidents confirm literature  data points

indicating  the  environmental persistence of these  compounds.   Thus,

1,1,1-trichloroethane,  raethylene  chloride, and carbon  tetrachloride

are all  likely  to  persist  in the  environment long  enough  to reach

environmental  receptors  (1,1,1-trichloroethane is  subject to

hydrolysis, but has  a half-life in groundwater of  6 months)(37).

     Another  problem  which  could  result from improper  landfilling

of these wastes is the  potential  for  the contaminants  to  volatilize

into the surrounding  atmosphere.   All of the listed chlorinated

solvents are  volatile and  thus could  present an air pollution

problem  if  they are  improperly managed (for example, disposed  of

in the open,  or without  adequate  cover), since they are uniformly

toxic via inhalation.

     A special  problem  is  posed by chlorofluorocarbon  solvents.

These solvents  are also  highly volatile, but instead of posing  a

direct toxicity hazard,  they may  be released at the surfa.ce of  the

earth, mix  with the  atmosphere and rise slowly into the stratosphere,


*Xhespecific  solvents  detected in these samples were  methylene
 chloride,  carbon  tetrachloride,  trichloroethylene , and tetra-
 chloroethylene and  trichlor ofluoromethane.

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        Damage Incidents Resulting From The Mismanagement of




                         Trichloroethylene






1.    In one incident  in Michigan,  an automotive parts manu-




     facturing plant  routinely  dumped spent degreasing solu-




     tions on the open ground  at  a rate of about 1000 gallons




     per year from 1968 to  1972.   Trichloroethylene was  one




     of the degreasing solvents present in the spent  solutions.




     Beginning in 1973, trichloroethylene was detected at  levels




     up to 20 mg/1 in neary  residential wells.  The dump site




     was the only apparent  source  of possible contamination  (10)




2.   In a  second  incident,  also in Michigan, an underground




     storage tank leaked  trichloroethylene which was  detected




     in local groundwater  up  to four miles away from  the




     land  (ID.




3.   In April of  1974, a  private  water well in Bay City, Michi-




     gan became contaminated  by trichloroethylene.  The  only




     nearby source of this  chemical was the Thomas Company




     (which replaced  the  well  with a new one).  The company




     claimed that, although  it  had discharged trichloroethylene




     into  the ground  in the  past,  it had not done so  since




     1968.  Nethertheless,  in  May  of 1975. two more wells




     were  reported to be  contaminated with trichloroethylene




     at concentrations of  20  mg/1  and 3 tag/1, respectively




     (12).

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     In March,  1978,  EPA banned the use of chlorofluoro-




carbons In  aerosol  propellants.  The primary concern  in  the




enactment of  this  ban was the ozone depletion effects  resulting




from chlorofluorocarbons entering the stratosphere  and reaction




with ozone.   In  the troposphere, chlorofluorocarbons  are  decom-




posed by the  intense  ultra violet radiation to release chlorine




atoms.  The  chlorine  atoms catalytleally remove ozone, thereby




reducing the  total  amount of ozone in the stratosphere,  leading




to an increase  in  skin cancer,  climatic changes and other  adverse




effects.v33,34 )  ^^e  Agency is  therefore concerned  about  chloro-




fluorocarbon  use and  disposal.   Therefore, the Agency  has  proposed




the regulation  of  non-aerosol uses of chlorofluorocarbons.(8)




     The Agency  also  expects to propose regulations controlling




the airborne  emissions of these solvents and other  volatile




organics so  as  to  reduce the air pollution problems presented




when these  solvents are used or disposed.  These proposed




regulations  will apply certain  standards to a number of  the




Volatile Organic Compounds (VOC) which have been demonstrated




to be precursors of or lead to  the formation of ozone  and




other photochemical oxidants in the atmosphere.  Ozone air




pollution endangers the public  health and welfare and  is




thus reflected  in  the Administrator's promulgation  of  a




National Ambient Air  Quality Standard for Ozone (February  8,




1979.  44 FR 8202).  Additionally, 1,1,1-trichloroethane  and

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methylene chloride, which are not  ozone  percursors,  are




being regulated under the proposed  rule  since  under  EPA's




proposed airborne carcinogen policy, a compound  which  shows




evidence of hunan carcinogenic i ty  is a candidate  for regulation




under Section 111 as a pollutant "reasonably anticipated  to




endanger public health and welfare".  Finally, t r i chlor of luoro-




methane, as indicated in the earlier discussion  of chlorof luoro-




carbons in general, has been implicated  in the depletion  of




the  stratospheric ozone layer, a region  of the upper atmosphere




which shields the earth from harmful wavelengths  of  ultra




violet radiation, that would increase skin cancer  risks in



humans .(33,34)




     Additionally, if these wastes  are incinerated,  as a




large percentage are, and the wastes are not subject to




proper incineration conditions (i.e., temperature and  residence




tiaes), pollution of the environment may result from the




airborne disposal of uncombus t ed halogenated organics, partially




combusted organics and newly formed organic compounds.




Phosgene is an example of a partially combusted chlorinated




organic which is produced by the decomposition or combustion




of chlorinated organics  by hea t ( 1 5 , 1 6 , 1 7 ) .   Phosgene has




been used as  a chemical  warfare  agent and is  recognized as




ex t rene ly toxic.




     The  large quantities of the  spent  solvent and sludges re-




sulting from  the recovery of these solvents,  a combined total




of 99,000 metric tons  per /ear,  are another area of concern.
                                -18-

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As previously  indicated, these wastes  are  generated in

substantial  quantities and contain very  high  concentrations

of the original  solvent (the spent solvent  solution contains

up to 90  percent  and the sludges contain up  to  50  percent

of the original  solvent).   The large quantities of  these

contaminants  pose  the danger of polluting  large areas  of

ground or  surface  waters.  Contamination  could  also  occur

for long  periods  of time,  since large  amounts  of  pollutants

are available  for  environmental loading.   All  of  these

considerations  increase the possibility  of  exposure to the

harmful constituents in the wastes.

VII .  HEALTH  AND  ECOLOGICAL EFFECTS ASSOCIATED  WITH THE
      CONSTITUENTS IN THE  WASTES

     The  toxicity  of tetrachloroethylene,  methylene chloride,

1,1,1-trichlorethane, trichloroethylene, carbon tetrachloride

and chlor ofluorocarbons has been well  docum'en ted .   Capsule

descriptions  of  the adverse health and environmental  effects

are summarized  below;  more detail on the adverse  effects of

these solvents  can be found in Appendix  A.

     Tetrachloroethylene has been included  on  EPA's list of

chemicals  which  have demonstrated substantial  evidence of

carcinogenicity.(^1)  Repeated exposure  of  rats and mice

to tetrachloroethylene in  air or in the  diet  has  resulted

in fatty  degeneration of the liver, increased  kidney  weight

and toxic  nephropathy.(18,19,20).  Additionally,  tetrachloro-

ethylene  is  slightly toxic to freshwater fish.(14b22>23)

-------
     Methylene chloride  has  been  shown  to  be  rautagenic  to a




bacterial strain,  S.  typhiraur ium. C 2 4 )   jn  addition,  acute




exposure to methylene  chloride  in  humans  is a central nervous




system depressant  resulting  in  narcosis  in high  concentrations




and  is metabolized  to  carbon monoxide and  causes  an  increase




in ca rboxyheraog lobin ( 2 5 ) .




     Although 1 , 1 , 1-trichloroe thane  (MC) has  been shown in




an NCI bioassay to  induce a  variety of neoplasms ( 26 ), these




data were not conclusive.  A high  incidence of deaths in




test animals has  led  to  retesting  of this  compound by a manu-




facturer and the  NCI(26).  In  vitro studies have  indicated




that MC is slightly  mutagenic  in the Ames  test, and  can cause




mammalian cell transformation.  Human toxic effects  seen




after exposure to  1 , 1 , 1-trichloroe thane include changes in




several central nervous  system  functions,  including  reaction




tine, perceptual  speed,  manual  dexterity and  equilibr iura( 27 ) .




In addition, animal  studies have produced  toxic effects in




the central nervous  system, cardiovascular system, pulmonary




system, and induced  liver and kidney daraage(27).




     Trichloroethylene has been included on EPA's list  of




chemicals which have demonstrated substantial evidence  of




carcinogenici ty . -  21 )  Trichloroethylene has also  been




shown,  both through acute and chronic exposure, to produce




disturbances  of the central nervous system and other  neuro-




logical ef fects( 28, 29, 30) .




     Carbon t e t r achlo r ide has been included on EPA's  list  of




chemicals  which have demonstrated substantial evidence  of
                             -2Q-

-------
care Inogenicity.(21)   in addition, toxicologleal  data for

non-human mammals  are extensive and show carbon  tetrachloride

to cause liver  and  kidney damage, biochemical  changes in

liver  function  and  neurological damage(32).

     The hazards associated with exposure  to the  above  halo-

gen a ted  solvents have been recognized by other regulatory

programs.  Tetrachloroethylene, methylene  chloride,  1,1,1-

trichloroethane, trichloroethylene, and carbon tetrachloride

and the  two  fluorocarbons, trichlorofluoromethane and dichloro-

difluoromethane, are  listed as toxic pollutants  in  accordance

with 307(a)  of  the  Clean Water Act of 1977.*  Under  6 of the

Occupational  Safety  and  Health act of 1970,  final standards

for occupational exposure have been established and  promulgated

in 29  CFR 1910.1000  for  carbon tetrachloride, methylene chlor-

ide and  1,1,1-trichloroethane.  On March 17, 1979,  fully  halo-

genated  f1uorocarbons were banned by the Consumer Products

Safety Commission  as  propellants in the United States,  except

for essential uses  because of their threat to  the ozone.   In

addition, final  or  proposed regulations in the States  of

California, Louisiana,  Maryland, Massachusetts, Minnesota,

Missouri, New Mexico, Oklahoma and Vermont define compounds

containing one  or  more  of the solvents tetrachloroethylene,

methylene chloride,  1,1,1-trichloroethane, trichloroethylene,

carbon tetrachlor ide  and trichlor ofluoromethane as  hazardous

wastes or coaponents  thereof.35
*T'ne Agency has  recently  proposed to remove tr ichloro f luorome thane
 and dichlorodif1uoromethane  from the list of toxic  pollutants
 under 307(a)  of  the  Clean Water Act (45 FR 46103,  July  9,  1980).

-------
                            ATTACHMENT I

     DERIVATION OF THE ESTIMATED QUANTITIES OF THE WASTE

I.   ANNUAL QUANTITIES OF WASTES

     Total amount of spent solvents (Halogenated and non-
     halogenated)C1) = 425,560 kkg

     Total amount of spent solvents from vapor degreasingC1)
     = 54,560 kkg

     Vapor degreasing units only use halogenated solvents so all
     of the 54,560 kkg from this source are halogenated solvents.
     Cold cleaners and fabric scourers use both halogenated and
     non-halogenated solvents.  Assume that the spent solvent
     solutions contain solvents in the same proportion as their
     use.  About 12 percent of solvent use in applications other
     than vapor degreasing is halogenated(1).

     .-.  (425,560 kkg - 54.560 kkg) (0.12)(1)
          44,250 kkg of halogenated solvents contained in wastes
           from sources other than vapor  degreasing

         54,560 kkg + 44,520 kkg = 99,000 kkg of halogenated
         solvents                          yr

II.   DISPOSITION OF WASTE

     The  disposition of about 30 percent  of these  wastes can be
     derived from information which is documented  in the litera-
     ture.   The disposition of the remaining  70 percent is based
     upon extrapolations and economic  consideration of waste
     nanageraent alternatives.

     A.   DISPOSITION OF 30 PERCENT OF THE WASTE

          0    Vapor degreasers only use  halogenated solvents(l)

          0    Virtually all metal finishing  shops  (SIC 35,  36,
               37,  and 39), and by implication vapor degreasing
               operations,  either  reclaim their spent solvents
               or sell them to solvent refiners.(1,3)

          0    Between 50-99 percent of  the solution is recovered(4,5)

               Approximately 37 percent  of the plants which  recover
               these  solvents  on-site  dispose  of  their waste sludges
               in landfills(3).

               (amount  of  waste)  (1-percent recovery)(percent  of
               plants  with  on-site  recovery)  x (percent  of plants
               that  landfill)  = Amount of waste landfilled.

-------
     1.   Assume 50 percent  of  the  solution  is  recovered

          (54,560 kkg)  (0 . 50 ) (0.37)(0.70)  -  7,065 kkg

     -   Assume 99 percent  of  the  solution  is  recovered

          (54,560 kkg)  (0.01)  (0.37)(0.70) -  140  kkg

          140 kkg to 7,065 kkg  of halogenated  solvents
          disposed of In  landfills.

     About 20 percent of  the  solvent  reclaimers  which process
     the remaining 63 percent  of the  solvents  from  this  source
     also landfill their  waste.  The  remaining  80 percent
     of the solvent reclaimers  reportedly  incinerate  their
     sludges(4,5).  Therefore  an additional  109  to  5,456
     kkg of halogenaced solvents are  landfilled  by  solvent
     reclaimers.

3.    DISPOSITION OF THE REMAINING 70  PERCENT  OF  THE WASTE

     The wastes generated by  the plants  in the  SIC  cate-
     gories delineated  above  represent about  60  percent
     of all vapor degreasing  operations  and about  30
     percent of all wastes generated by  all degreasers.
     Reportedly, a facility which generates at  least  350
     gallons of spent halogenated solvents anually has
     economic incentive to implement a recovery strategy(4,9).
     Virtually all vapor  degreasers nee' this criteria.

     The disposition of spent  solutions  from cold cleaning
     and fabric scouring  operations is not as well defined.
     In order to account  for  these wastes, some economic
     factors have been  considered.  In general,  it is expected
     that a plant or industry which has  a high  incidence
     of use of a relatively expansive solvent will probably
     have some kind of  recovery strategy, assuming the scale
     of operations permits an acceptable payback  period.
     In cold cleaning and fabric scouring operations, the
     following factors  are pertinent:

     0     Cold cleaning and fabric scourers use halogenated
          solvents IT conjunction with Inexpensive non-
          halogenaced solvents.  It has  been estimated
          that thes-2 operations must have six to  twelve
          times the solvent throughput of plants  which
          only use h a 1 -3 g e n a t s d solvents  Ln order  to
          economically  justify a recovery strategy.

     0     Cold cleaning and fabric s._juring operations
          represent i b o u r 94.7 percent of all facilities
          that use h .11 33 ena ted solvents  but only  use  about
          43 percent of the total supply of these solvents
                              -23-

-------
          that are  used  for  degreastng.   The implication  is
          that, on  the  average,  the  solvent throughput
          rate is much  lower in  this segment of the
          degreasing  industry than that  of the vapor
          degreasing  segment.

     Although some  cold  cleaning and fabric scouring
     operations probably operate on a scale that would
     make a recovery  strategy economically attractive,
     it is not possible  to estimate the extent of  recovery
     operations in  this  segment  of the industry.   The
     economics seem  to  indicate  that the  incidence of
     recovery from  these operations is probably very  low.

C.   THE GROSS ESTIMATE
     In estimating  the  disposition of all  the  wastes,
     the best and  worst  cases  pertaining to  the  portion
     of the waste  which  cannot be documented  in  the
     literature  are  considered.   The ideal case  is  where
     all of the  wastes  from cold cleaning  and  fabric
     scouring operations are  processed by  contract  re-
     claimer using  maximum efficiency recovery  techniques
     (i.e., 99 percent  recovery).  The worst  case  would
     be where all  of this waste  is simply  disposed  of.
     The following  is  the basis  for the estimate.

     From  Section  A

           249 kkg  Co 12,521 kkg  of h alienated  solvents  are
           land filled.

     Best  Case for  Cold  Cleaning and Fabric  Scouring

           (amount  of waste)(percent recovered)(percent
           landfilled)  =  amount landfilled

           (44,520  kkg)(0.01)(0.2) = 90 kkg of waste  land-
           filled

           Worst  case for cold  cleaning .and fabric  scouring
           is when  all  44,520  kkg of waste  is  landfilled

     The estimated  best  and worst cases for  the  disposition
     of halogendced  solvents  fron all types  of degreasing
     operations  ire  339-57,041 metric tons per year.   It
     is unlikely char  either  the besc or worst case  is
     representative  of  reality.   IT this case, about  half
     of the waste  is generated by vapor degreasers  where
     it is likely  chat  the incidence of recovery  is  high.
     The remaining  half  Is generated in environments  where

-------
the incidence of recovery is  probably  very  low.   A
reasonable inference and prudent estimate based  on
available data would be about 30,000 metric  tons
per year of halogenated solvents disposed of  on  land.

-------
REFERENCES

1.    Hoogheem, T.J.,  et  al.   Source assessment:  Solvent  evaporatlor
     degreasing operations.  U.S.  EPA No. 600/12-79-019f.  NTIS
     ?3 No. 80 128  812.'  August,  1979.

2.    Mansville Chemical  Products.   Chemical products  synopsis:
     trichloroethylene.  Mansville,  New York. September,  1976.

3.    L'.S. EPA.  Hallowell, J.B.,  et al.  Assessment  of  industrial
     hazardous waste  practices:  Electroplating and  metal  finishing
     industries - job  shops".  U.S.  EPA. NTIS PB No.  264  349.  September
     1976.

4.    U.S. EPA.  Organic  solvent  cleaners-background  information for
     proposed standards.  U.S.  EPA  No. 450/2-78-045 a .  October, 1979.

5.    U.S. EPA.  Source assessment:  Reclaiming of waste  solvents.
     State of the art. NTIS  No.  232 934. April,  1978.

6.    No t used in  text.

7.    Not used in  text.

8.    Federal Register, Vol.  43,  Pg. 11301. March 17,  1978.-

9.    U.S. EPA.  Control  of volatile organic emissions  from  solvent
     metal cleaning.  U.S.  EPA  No.  450/2-77-022.  November,  1977.

10.  Michigan Department  of  Natural Resources -  Geological  Survey
     Division. Case history-'* 48.

11.  Shellenbarger, P.   New  charge  hits Air Force.  The Detroit
     News. May 17,  1979.

12.  U.S. EPA.  Open  files.   Hazardous Site Control Branch,  WH-543,
     U.S. EPA, 401 M  St.,  S.W.,  Washington, DC.  20460.
     Contact Hugh Kauffman.  (202)  245-3051.

13.  U.S. EPA.  Section  II of  Appendix B of the  listing background
     document: Fate and  transport  potential of the hazardous
     constituents. U.S.  EPA,  Office of Solid Waste. 1980.

14a. U.S. EPA.  Trichloroethy 1ene:  Ambient water quality  criteria.
     NTIS PB No.  292  443.  1979.

14b. U.S. EPA.  In-depth  studies  on health and environmental
     impacts of selected  water  pollutants. Work  resulting  f r o 3
     Contract No. 63-01-4646.  1973.
                               -2(o-

-------
14c. U.S.  EPA.   Preliminary assessment of  suspected carcinogens  in
     drinking  water,  and appendices. A report  to  Congress.
     Washington,  D.C.  EPA No. 560-4-75-003.  1975.

lid. Not used  in  text.

14e. U.S.  EPA.   The  National organic monitoring  survey.  Technical
     Support Division,  Office of Water Supply, U.S.  EPA.  Washington,
     DC. 20460.  1978.

15.  Edwards,  John  3.   Combustion formation  and  emission  of trace
     species.  Ann Arbor Science . 1977.

16.  NIOSH  criteria  for recommended standard:  Occupational
     exposure  to  phosgene.  HEW, PHS, CDC,  NIOSH.  NT IS  PB  267  514.
     1976.

17.  Chemical  and Process Technology Encyclopedia.  McGraw Hill.
     1974.

18.  National  Cancer  Institute.  Bioassay  of tetrachloroethy1ene
     for possible carcinogenicity.  NTIS P3 No. 272  940.  NCI-CG-
     TR-13. DHEW  Publication No. (NIH) 77-813. 1977.

19.  Rowe,  V.X.,  et  al.  Vapor toxicity of tetrachloroethylene
     for laboratory  animals and human subjects. AMA Ar ch. Ind .
     Hyg. Occu?.  Med.  5:566. 1952.

20.  Klaassen,  C.D.,  and G.L. Plaa.  Relative  effects  of  chlorinated
     hydrocarbons on  liver  and kidney function in dogs. Tox i co1.
     Appl.  Pharmacol.  10:119. 1967.

21.  U.S. EPA.  Carcinogen Assessment Group, Office  of  Research
     and Development.  List  of carcinogens. April  22, 1980.

22.  Alexander,  H.,  et  al.   Toxicity of perchloroethylene,
     trichi oroethy1ene, 1,1,1-trichi oroechane , and  methylene
     chloride  to  fathead minnows.  Bull. Environ. Contam. Toxicol.
     20:344. 1973.

23.  U.S. EPA.   Tetrachloroethylane: Ambient vater  quality criteria.
     NTIS PB No.  292  445. 1979.

24.  Simmon, V.F., et  al.  Mutagenic activity  of  chemicals identified
     in drinking  water.  S.  Scott, et al.,  e d s . In:  Progress in
     genetic toxicology- 1977.

25.  National  Academy  of Sciences.   Chloroform, carbon  tetrachloride
     and other  halo me thanes:  Environmental assessment.  Publication
     Mo. 2763.  1973.
                                -3.7-

-------
26.  National Cancer  Institute.  Bioassay of 1,1,1-trichloroethane
     for possible  carcinogenicity.  NCI-CG-TR-3. NT IS  PB  No.  265 08,"
     1977.

27.  U.S. EPA.   Chlorinated  ethanes: Ambient water  quality criteria.
     NTIS PB No. 297  920.  1979.

28.  N'omiyama, K.,  and  H.  Nomiyama.  Metabolism of  trichloroethylene
     in human sex  differences  in  urinary excretion  of  trichloroacetic
     acid and trichloroethano1. Int. Arch. Arbeitsmed.  28:37.
     1971.

29-  Sardodej, A.,  and J.  Vyskocil.  The problem  of  trichloroethylene
     in occupational  medicine.  AMA  Arch. Ind. Health.  13:581.  1956.

30.  McBirney, B.S.   Trichloroethylene and dichloroethylene  poisoning
     AMA Arch. Ind. Hyg.  10:130.  1954.

31.  No t used in text.

32.  Von Oettingen, W.F.   The  halogenated hydrocarbon  of  industrial
     and toxicological  importance.  In; Elsevier monographs on
     toxic agents.  E.  Browning, ed. Elsevier Publishing  Company.
     New York. 1964.

33.  National Academy  of  Sciences,  National  Research Council.
     Halocarbons:  Environmental effects of chloromethane  release.
     Publication No.  2529. 1976.

34.  National Academy  of  Sciences,  National  Research Council.
     Committee on  Impacts  of Stratospheric Change. Stratospheric
     ozone depletion  by halocarbons:  Chemistry  and transport.  1979.

35.  U.S. EPA.   State  Regulations Files.   Hazardous Waste Programs,
     WH-563,  U.S.  EPA., 401 M St.,  S.W.,  Washington, DC.  20460.
     Contact  Sam Morekas.  (202) 755-9145.

36.  Not  used in text.

37.  Dawson,  English and Petty.   Physical  chemical properties  of
     hazardous waste constituents.  1980.

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                                                          SJ-31-06
                 WASTES FROM  USAGE  OF  ORGANIC  SOLVENTS


              t
     I.    LISTING

          The listed wastes are  those  major  streams  which result

     fron usage of organic solvents.   The  listed  solvents include

     both halogenated and non-halogenated  organic  compounds.   The

     specific wastes listed are:


     The following spent halogenated solvents:  tatrachloroe thylene,
     methylene chloride, trichloroethylene,  1,1,1-trichloroe thane,
     chlorobenzene , 1,1,2-trichloro-l,2,2-1rif1uoroethane ,  o-di-
     chlorobenzene , trichlorofluorone thane,  and the  still bottoms
     from the recovery  of these  solvents  (T);

     The following spent non-halogenated  solvents:  xylene,  acetone,
0O3 ec'ayl acetate, ethyl benzene,  ethyl  ether, n-butyl  alcohol,
     eyelohexanone, raethanol, methyl isobutyl  ketone;  and the
     still bottoms frora the recovery of  these  solvents  (I);

    . The following spent non-halogeanted  solvents:  cresola  and
00^ cresylic acid, and nitrobenzene;  and  the  still  bottoms  from
     the recovery  of these solvents  (T);  and

     The following soent non-halogenated  solvents:  toluene,  methyl
     e t hy 1 ketone, carbon disulfide, isobutanol, pyridine;  and the
       ill bottoms frora the recovery of  these  solvents  (I,T).


          Listing  codes for the most widely  used halogenated

     organic solvents are presented  in Table I-1, and  codes  for

     v i d a 1 v - u s e d non-halogenated o r 3 a n i c  solvents are  in  Table 1-2.


     II.   SUMMARY  OF BASIS FOR LISTING

          Wastes resulting from usage  of  organic solvent-; tvoically

     contain significant concentrations  of the  solvent.   Examples

     of  wastes from usage of organic solvents  include  still-bottoms

-------
from solvent recovery and  spent  solvents  from dry cleaning

operations and maintenance  and  repair  shops.

     The Administrator has  determined  that  waste from usage

of the 24 organic solvents  listed  in  Tables  1-1 and 1-2 nay

be a solid waste, and as a  solid waste, may  pose a substantial

present or potential hazard  to  human health  or the environment

when improperly transported,  treated,  stored,  disposed of or

otherwise managed, and therefore should be  subject to appropriate

management requirements under Subtitle  C  of  RCRA.   This

conclusion is based on the  following considerations*:

     1.   Of the list of 24  solvent types presented in Tables
          1-1 and 1-2, each  solvent exhibits  one or more
          properties (i.e.,  ignitability  and/or toxicity)
          which pose a potential hazard.  These solvents
          represent approximately  95' percent  or more  of
          organic solvent usage in the  United  States  (see
          Table II-l)-

     2.   The use of organic  solvents  is  widespread throughout
          the United States, and the quantities  involved  are
          large;  according to Table IT-1  the  total annual
          usage of the listed materials as solvents is  over
          2.8 X 106 '
-------
                           TABLE  1-1
       LISTING  CODES  FOR  HALOGENATED ORGANIC SOLVENTS*
                 (in  order of  usage  as solvent)
Solvents
Listing
 Codes
  Flash
Point (F)
Perchloroethylene

Methylene chloride

Trichloroethylene

1 , 1 , 1 ,-Trichloroethane

Chlorobenzene

1,1,2-Triehloro-1,2,2-

  Tri fluoroe thane

o-Dichlorobenzene

Trichlorofluorome thane
   T

   T

   T

   T
* ^ > 1ja. c a Tn this  table  are  based  on  information contained in
 Reference (1).  Dashes  in  place  of  data  mean either the values
 were not available  or  (in  the  case  of  flash points) not
 applicable.
                              -y-
                              -1.1-

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                          TABLE  1-2

     LISTING CODES FOR NON-HALOGENATED  ORGANIC SOLVENTS*
                (in order of usage as  solvent)
Solvents
Xvle nes
Me thanol
Toluene
Methyl ethyl ketone
Acetone
Methyl isobutyl ketone
Carbon disulfide
Ethyl acetate
Ethyl benzene
Ethyl ether
a -Butyl alcohol
Isobutanol
Cresols and cresyllc acid
Cyc lohexanone
Nitrobenzene
P y r i d i n e
Listing
Codes
x* *
I,**
I,T**
I,T**
X**
I,**
I,T**
x**
I**
I**
I**
I,T**
T
I **
T
1.
I,T**
Flash
Point (F)
84(2)
54
39
22(3)
3
61
-25
45(2)
59
-49(2)
115
82
-
111(3)
-
68
* All -data in this table are based on information  contained in
  Reference ' 1)  e x c e T t as noted.  Hashes  in  place  of  data  -lean
  either that the values v e r e not available  or  (in  the  case of
  flash ooints)  not applicable.
**3ecause  the listed waste typically would contain  a  large
  percentage  of  these solvents, the listed wastes  would  fail
  the iiitability characteristic for liquids--a flash  point
  less  :han 60C (140F).
                             -32-

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                The fifteen solvents  listed  as  either  toxic
           or toxic and ignitable pose a  further  hazard  to
           human health and the environment.   If  improperly
           managed, these solvents could  migrate  from  the
           disposal site into ground  and  surface  waters,
           persist in the environment for extended  periods
           of time, and cause substantial hazard  to  environ-
           mental receptors.

                The two fluoroc-a-rbons, l,l,2-trichloro-l,2,2-
           trifluoroethane and trichlorofluororaethanes present
           a  different type of hazard.  Due  to  their high
           volatility, these two organics can rise  into  the
           stratosphere and deplete the ozone,  leading to
           adverse healch and environmental  effects.

      i.    Damage incidents resulting from the mismanagement of
           waste solvents have been reported.  These damage
           incidents  are of three types:

           (a)   Fire/explosion damage resulting from ignition
                of the solvents;

           (b)   Contamination of wells in the vicinity of in-
                adequate waste storage or disposal (with re-
                sulting illness  in at least one instance); and

           (c)   Direct entry of  solvent  into a waterway,  resulting
                in fish kills.

      5.    These damage incidents  show that  mismanagement
           occurs  and  that  substantial hazard to human health
           and  the environment  may result  there from.
HI. SOURCES OF THE  WASTE  ANTD  TYPICAL DISPOSAL PRACTICES

     A.   Overall  Description  of  Industry Usage*

          The primary  solvent-using  inHustri^s -ind  the quantity

of solvents they use annually  are  as  follows:-^
*Large amounts of chen i .-. a 1 s  listed  in  Table  11 - L  are  used in
 such non-solvent applicitisis  is  zhemical  feedstock  so that
 the total production  of  specific  solvent  chemicals  for all
 applications is often  many  tines  larger  than  the amount
 used specifically as  a

-------
                          Table  II-l

        RANKING AND AMOUNTS OF THE  LISTED  SOLVENTS^)

                                            Amount  Used  As
Chemical Naae	Solvent  (kkg/yr)

Xylenes                                         489,900
Mechanol                                        317,500
Toluene                                         317,500
Parchloroethylene                               255,800
Methylene chloride                              213,200
Methyl ethyl ketone                             202,300
Trichloroethylene                               188,200
1 ,1 ,1-Trichloroethane                           181,400
Acetone                                          86,200
Methyl isobutyl ketone                           78,000
Chlorobenzene                                    77,100
Carbon disulfide                                 77,100
Ethyl acetate                                    69,900
Ethyl benzene                                    54,430
Ethyl ether                                      54.430
n-3utyl alcohol                                  45,360
l,l,2-Trichloro-l,2,2-tri-fluoroethane           24,040
Isobutanol                                       18,600
o-Dichlorobenzene                                11,800
Cresols & cresylic acid(a)                       11,800
Cyclohexanone                                    9,072
Nitrobenzene                                     9,072
Trtchlorofluoronethane                           9,072
Pyridine                                            907
a} Consu^p t ion a-nounts for cresol and cresylic acid were
   combined .

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       Paint  &  Allied  Products  and  Industrial     1,153,500 kkg/yr
         Operations

       Surface  Cleaning                              610,600 kkg/yr

       Pesticide  Production                          266,700 kkg/yr

       Laundry  and Dry Cleaning  Operations           214,550 kkg/yr

       Pharmaceuticals Manufacture                    34,740 kkg/yr

       Solvent  Recovery  Operatic"ns  (Contract  and     499,000 kkg/yr
         in-house)                                   (feedstock)


       Table  III-l summarizes  the use  pattern of  the  10  most

 widely  used solvents in  the  industrial  categories  listed

 above.   These data  illustrate  the  distinct  difference  between

 halogenated and non-halogenated solvents  in industrial usage;

 the chlorinated and  other  halogenated  solvents  in  Table

 III-l are used  almost  exclusively  in  the  surface cleaning,

 laundry  and dry cleaning categories,  whereas  t'le non-halo-

 genated  solvents are used  primarily  in  the  production  cate-

 gories  (paint,  pesticides  and  pharnaceutica1s).  The ten

 specific solvents included in  this table  are  believed  to

 account  for about 80 percent of all organic  solvent usage.(D

       The composition of  the spent  solvent*  is dependent on its

 application, but the spent solvent contains  up  to  90 percent

 of the original solvent**.  Depending on  the  recovery  techniques,
 *Spent solvents include those  solvents which are no  longer
  useful without further processing either because  they have
  outlasted their shelf life or because they have been
  contaminated, or so changed chemically or physically  that
  they are no longer useful as  solvent.
**United States Environmental Protection Agency.  1976.
  Assessment of Industrial Hazardous Waste Practices
  Electroplating and Metal Finishing Industries - Job
  Shops  P3-264-349.

-------
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-------
 sludges  which  result  from reclamation processes contain  from  1

 to  50* of  the  original  solvent.*  However, because of the

 economic  considerations of  the reclaiming process, the solvent

 content  of  the  sludge  is  seldom reduced below 10 percent.**

       3    Solvent  Usage in  Paint & A1 _ . e d Products and

            Industrial  Operations

            The  category  of Dalnt &  Allied Products  and Industrial

 Operations  Is  taken here  to  include the following  solvent-use

 industrial  operations:

       0     Paint  &  Allied  Products  Manufacture

            Roll  Coatings

       0     Paper  Coa t ings

       0     Dye  Manufacture

       0     Ink  Manufacture

       3     Adhesive Manufacture

       '     Printing Operations

       The  Paint  and Allied Products and Industrial  operations

 category  accounts  for about  half  of all  organic  solvent  utili-

 zation by  industry.   The  Paint and Allied  Products  portion

 of  this category is the largest  solvent-use  s ;i be a t ego r y ,  with

 Printing  Operations being the  second  largest  use  subcategory.

       For  the Paint & Allied  Products  Industry,  there  are

 about 1200  paint manufacturing companies  that  operate more
 *'."ni:ed States Environmental  Protection  Agency.   1979.
  Organic Solvent Cleaners-background  Information  for
  Proposed Standards.   -.PA-4 5/1 2-73-04 5a .
**United States Environmental  Protection  Agency.   1978.
  Source Assessment:  ^ecla"iming  of  Waste  Solvents.   State
  of the Art. P3-239-934.

                               -X-
                              -17-

-------
than 1500 plants.   Solvents  are  important  ingredients  in

formulations for solvent-thinned  paints,  lacquers,  and factory-

applied coat ings .

     Solvent containing wastes arise  from  the  use  of  solvents

Co clean equipment, and still bottoms  from  the  recovery of the

solvents used in production*.  It  is  estimated^4'  that approxi-

mately one-third of the solvents  used  for  equipment  cleaning

are reclaimed, and  that 7 x  10 gallons of  solvent  are

disposed of yearly  from this source.

     The total quantity of solvent-containing  wastes  from

the paint industry  is estimated to contain  14,300 kkg/yr of

solvents.(^' These  are primarily  non-halogenated solvents

such as xylenes, methanol, acetone, toluene, MEK, etc.

     The remaining  industrial processes included in  this over-

all category (manufacture of inks, adhesives,  dyes, and

various types  of coatings) utilize organic  solvents  (primarily

non-halogenatad) in much the sane  manner as  the paint  industry;

that is, as  an important component of  formulations and  for

equipment cleaning.(D  Printing  operations  also use sol-

vents  for cleaning  operations and  as dye or  pigment carriers.

The types of waste  generated from  these industries should  be

generally similar to those from the paint industry and  include:

     "quipment cleaning wastes;

     Still  bottoms  from solvent  recover1/.
*Additional waste streams from these industrial categories  (such
 as  off-specification product and spills .of finished product)
 are expected to be c o 7 e r 3 d b v future listings.
                             -Uf-

-------
      Spent  solvents  used  for  equipment cleaning, if not re-




claimed,  are  drummed  and  landf i lied (*).   Most paint companies




contract  for  waste  disposal  services.  Solvent recovery still




bottons are  incinerated,  landfilled,  or  injected into deep




wells.(5)




      C .    Surface  Cleaning




           The  Surface  Cleaning  category  consists of two




important  subcategories:




           0     Industrial  Degreasing




           0     Re pa i r  work




                   Industrial  Maintenance  and  Repair




                   Commercial  Service  and  Repair




                   Consumer-performed  Maintenance and  Repair




     About half  of  the  solvents  used  in  Surface  Cleaning




Operations, as  shown  in Table  III-l,  are  used  in Industrial




Degreasing, (see  the  Listing  Background  Document  for  Solvent




Degreasing Operations)  with  the  other half  being  used  in




various types  of  repair work.(l)   According  to Reference




(6), the  total  number  of degreasing operations in  the  United




States for 1976  was over 1,300,000, of which  nearly half




were associated  with  manufacturing operations  of  various




t v p e s .  The major  solvents used  are trichloroethylene,  1,1,1-




trichloroe thane, and  chlorofluorocarbons.   Most  of  the




solvents used  in surface cleaning  were halogenatei, iue  to




their nonflannable character; this property  is especially




important in high-tanperatura degreasing  operations.
                             -u"-

-------
     Neither surface cleaning nor etcher of its two subcate-




gorles can be classified as industry specific, per se; rather,




these operations are conducted in a number of types of indus-




tries (i.e., primary metals, auto repair shops, textile




plants).



     With respect to the geographic distribution, industrial




degreasing is the most concentrated source of solvent wastes




from the  surface cleaning category since degreasing is asso-




ciated with manufacturing operations that involve metal




finishing (including etching, plating,  priming and painting)




and electronic components manufacture.   The repair




work subcategory is much more diffuse in distribution, with




both commercial service and repair and  consumer-performed




maintenance and repair being generally  distributed in the




same pattern as the population itself.(5)




     The  major types of wastes from solvent usage in the




industrial degreasing subcategory are used (spent) solvent




and solvent recovery still bottoms.  Wastes from the repair




work subcategory would include both halogenated and" non-




halogenated solvents, and would take the form of relatively




small amounts of used solvent (typically up to a few gallons),




plus contaminated rags and other materials.




     D.   Production of Pesticides, Pharmaceuticals and




          Other Organic Chemicals




          Solvent qp?li:ations in the production of pesticides,




Pharmaceuticals and other organic chemicals include usage as

-------
a reaction  (synthesis)  medium,  and  usage  in  equipment  cleaning.(


The solvents used  are  primarily non-halogenated  and  are

typically selected  for  compatibility  with the  production


process.  Toluene  is  the  most  widely  used solvent  in pharma-


ceuticals manufacture,  methanol is  used as the  reaction

solvent in  Nylon  66  production, and acetone  is  used  as  the


solvent in  the  production of cellulose acetate.(*)


     Wastes frora  solvent  usage  in these industries take the


form of off-specification product material,  equipment  cleaning


wastes, and solvent  recovery still  cottons.  The destination


of all solid wastes  is  not  known, but a large percentage  is

reclaimed either  in-house  or by contract  recovery ope rat ions.(5)


     Solvent-containing wastes  in these industries are  not as'


geographically  distributed  as  in the  other categories  discussed

herein, but would be expected  to follow the  general  geographical


pattern of  the  organic  chemical  industry.


     E.   Laundry and Dry  Cleaning

          There are  about  25,000 retail dry  cleaning plants


in the United States, 18,000 of  which use between 167,000


k'
-------
solvents are used Co remove dirt, grease and other materials.

It is believed that 8 percent^7' -of the amount  of perchloro-

ethylene used in dry cleaning is disposed of along with  still-

botton and cooker residues, so that the amount  of perchloro-

ethylene discarded is between 13.4 and 16.6  thousand  kkg/yr.

     The distribution of dry cleaning plants is  uniform  with

respect to population and is especially associated with  popu-

lation in large urban areas.(7)

     Still bottoms from retail dry cleaning  consist of about

60 percent solvent and 40 percent oily residue.(7)  "Cooker"*

residues are 25 percent solvent and 75 percent  spent  filter

(mostly diatoraaceous earth).(7)

     F.   Solvent Recovery Operations

          Still bottoms from solvent recovery operations are

Che regaining waste streams included in this Listing.  Each

of Che solvent use industry cacegories discussed above generates

feedstocks for solvent recovery operations.   Recovery nay be

accomplished either in-house or by conCracC  Co  a recovery firm.

     With regard to contract solvent recovery operaCions,

there are between 30 and 100 contract solvent recovery

operations in the 'J.S.(^)  The surface cleaning  caCegory,

and particularly industrial degreasing operations is  one of che

largest sources of spent solvents sent Co concract reclaimers.
*A "cooker" is a type of still in which so 1vant-contaminated
 diatonaceous filter powder is heated to drive off the solvent
 fraction of the total liquid residue contained in the filter
 po wde r-

                             -X-
                             --J2-

-------
Other  important  sources of spent solvents are  the  paint,  ink,




and coatings  manufacturers and manufacturing processes  where




very pure  solvents are used in organic synthesis  (e.g.,  the




organic  chemical  and Pharmaceuticals industries).*^8)   Some




contract  reclaiming of solvents is also carried out on  sol-




vents  from  commercial and industrial dry cleaning  operations.




The geographic  distribution,  by state, of contract solvent




recovery  operations is presented in Table III-2.




     The  volume  of feedstock  sent to the contract  solvent




recovery  industry is approximately 287,000 kkg/yr; of  this




volume,  about  27  percent  are  halogenated.(^)




     Although  there are approximately 100 contract solvent




recovery  companies, the total  number of solvent recovery




operations  is  much larger due  to on-site recovery.  Of  the




total number  of  plants involved in "cleaning oDerations",




97.39 percent  perform on-premises solvent re:)very.(8)




     Excluding  the dry cleaning plants, which are distributed




geographically  in the same pattern as population,  the geographic




distribution  of  all solvent  recovery operations is as shown




in Table  III-3.




     Solvent  recovery still  bottoms  (sludges) from contract




reclaiming  operations amount  to about 7 3 , 9 " 0 -;kg/yr,  of which




between  5 and  50  percent  i >  solvent,  or an average solvent




content of  about  25 pe r c e n ~ . ' 4 }  Voo-.it  2~  o-ercent  of  the




solvents in still-bottom  slices  are  halogenated. ( ' )   Thus,




the total still bottom -a-te  from contract reclaiming consists




of the  following  components:

-------
                Table  III-2

GEOGRAPHIC DISTRIBUTION  OF CONTRACT SOLVENT

           RECOVERY OPERATIONS^4)
 \T e w J e r s e y            9

 California            9

 Ohio                  8

 Illinois              3

 Michigan              7

 Mew York              5

 Indiana               4

 Massachusetts         3

 Rhode Island          2

 Maryland              2

 South Carolina        2

 Georgia               2

 Kentucky              2

 Tennessee             2

 Missouri              2

 Texas                 2

 Connec t icuc            1

 North Carolina        1

 Florida               1

 Kansas                1

 \rizona                I
                      TT
                    --N-

-------
                    Table  IZZ-3
n DisT?;H-jTia; c? SCIV--ST .-^L^IXTG

C'-s-a
x T - ' - 	 
Arize -a
Cal i f o r.i a
Colorado
-.^i 	 	 a
C o-c; a

'.'_J  < - C
r. e."^^ V C-*. ^
I-O u i s i .= ~a
V s i' ->a
v - - - = <--   c s. - - ~
u~cr. igar.
. : 	 =S- -i

v.- c=c.._:
>'c.~."ar.a
^va^a
N'ev r.=r~^ shire
Nev Mexico
>^ev York
^^'*>~-'"~-l  3. ^' 1 1. 7^. -H.
Ohio
C!-t
cf Tcral
: s
0.94
0.59
 0 .
C.15
i 
0 *5
W . _ J
3.5
* j
E-l
2.2
1.7
2.0
0.5
2.0
j ^
-. .3
- ^
i W

2.3
0.77
.1 ~ Q
0.33
 * /
0.57
3. 9
2.5
=!i'
1.3
i . i
5.9
0.57
1.3

-------

"Jtah
           .r.ia
21
5
C "7
72
41
90

0.36
0.24
2.3
1.7
O.SS
2.2
r\ * A

-------
     13,250 kkg/yr  solvent,  including  13,320 kkg/yr non-

        halogenated  and  4,930  kkg/yr  halogenated;

     54,750 kkg/yr  non-solvent  contaminant,  including oils,  waxes,

        metals and  chlorinated  and  nonchlorinated  organics.

     The estimate of  25  percent  average  solvent  content,  as

presented above, can  probably  be  applied  to  solvent recovery

still bottoms for all  of  the  industries  discussed  herein,

since the technology  used  to  reclaim  solvents  is  roughlv

similar throughout  U.S.  industry.^3^

Waste Management Practices*

     The nost widely  used  management  practices for spent

solvents is either  recovery/reclamation  (either  on-site

or by contract recovery  operations),  land  disposal (which

nay include anything  froo  open  ground  dumping  to  landfi111ng),

or incineration.  For  still  bottoms,  about  3 "^ 3)  to 36^)

percent of these bottoms  from  contract solvent  reclaimers
*The Agency has concluded  that  it  does  have  jurisdiction
 under Subtitle C of RCRA  to  regulate  waste  materials  that
 are used, reused, recycled or  reclaimed.   "urthernore,  it
 has reasoned that such materials  do  not  become  less  hazard-
 ous to human health or the environment  because  they  are
 Intended to be used, reused,  recycled  or  reclaimed  in  lieu
 of being discarded.  Therefore, at  this  time, applicable
 requirements of Parts 2o2  through  265  and  122 will  apply
 to the accumulation, storage  and  transportation  of  hazardous
 wastes that are used, reused,  recycled  or  reclaimed.   The
 Agency believes this regulatory coverage  is  appropriate  to
 the subject wastes.  These spent  solvents  and still  bottoms
 from the recovery of these solvents  are  hazardous  in  so  far
 is they are being accumulated  or  stored  in  drums  or  tanks
 prior to recycling.  Therefore, these  wastes  will  be  con-
 sidered as hazardous whether  recycled  or  disposed.   However,
 at the present time, the  management  of  these  wastes  during
 recycling operations will  not  be  regulated.
                              .-17-

-------
are incinerated.   Still bottom sludges from both contract




reclaimers and from solvent recovery operations performed




by solvent-using  industries, if not incinerated, are either




Ian.drilled or injected into deep vells.f ,5)  Land disposal




of still bottom sludges from contract reclaimers is mostly




in landfills that are covered d ;i i 1 y . V ^ )  A snail amount




of sludge is used as asphalt ex:ender (about 0.1 percent).(
                            -vf-

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IV.   References  to  Section  III

1.   Lee, B.B.,  G.E.  Wilkins  and E.M. Nichols.  Organic
     solvent use  study.  Final Report. EPA No. 560/12-790-
     002. NTIS PB No.  301  342.  1979.

2.   Wildholz, M. (ed.).   The Merck Index. 9th ed.  Merck
     and Company. Rahway,  New Jersey. 1976.

3.   Sax, N. I.   Dangerous  Properties of Industrial Materials.
     Van Nostrand Reinhold  Publishing Company, New York. 1963.

4.   Scofield, F.,  J.  Levin,  G.  Beeland and T. Laird.  Assess-
     ment of industrial  hazardous  waste practices, paint &
     allied products  industry,  contract solvent reclaiming
     operations,  and  factory  application of coatings. EPA
     No. 530/SW-119c.  NTIS  PB No.  251 669. September, 1975.

5.   Levin, J.,  G.  Beeland, J.  Greenberg, and G. Peters.
     Assessment  of  industrial hazardous waste practices:
     Special machinery manufacturing  industries. NTIS PB No.
     262 981. March,  1977.

6.   Goodwin, D.  R.,  and D. G.  Hawkins.  Organic solvent
     cleaners -  Background  information for proposed standards.
     EPA No. 450/2-78-045a. NTIS PB No. 137 912. October, 1979.

7.   International  Fabricare  Institute. Silver Spring, Maryland
     Personal communication with B. Fisher. December, 1979.

8.   Tierney, D.R.,  and  T.W.  Hughes.   Source assessment
     reclaiming  of  waste  solvents.  State of the Art. EPA
     No. 600/2-7S-004f.  NTIS  PB  No. 282 934. April, 1978.

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IV.  HAZARDS POSED BY THE WASTES




     A,   Hazardous Properties  of  the  Solvents




     The major halogenated  solvents  exhibit  organic toxic




properties which make them  potentially  hazardous  to human




health and the environment.   Tn particular,  the  two halo-




jenated solvents, perchloroethylene  and  trichloroethylene




are on CAG's List of Carcinogens and 1 ,1,1-trichloroethane




is a suspect carcinogen.  All of the listed  halogenated




organic solvents, except 1 ,1,2-trichloro-l,2,2-trif 1uoro-




ethane, are priority pollutants under Section 307(a)  of  the




CWA.




     A number of the non-halogenated organic  solvents  also




exhibit toxicity properties.  For  example, nitrobenzene  has




been identified as a suspect  carcinogen.  These compounds




are toxic via one or more of  the exposure routes  inhalation,




ingestion and/or through the  skin.   Short tern human exposure




to these compounds can have numerous adverse effects.  (For




more information on the adverse health effects of these




halogenated and non-halogenated solvents, see Health and




Environmental Effects,  pp'.   38-45.   In addition,  almost all




of the  non-halogenated  solvents also present  an ignitahility




hazard.




     In  light of  the  health  hazards associated with the  waste

-------
solvents  particularly  those  which  are  genetically active--




and the high concentrations  of  hazardous  solvents  contained




in the waste,  the  Agency  believes a decision  not  to list




these waste solvents  as hazardous would  be  warranted  only if




the Administrator  were  convinced  that  waste  solvents  could  not




migrate and persist,  reaching 'human or  environmental  receptors




(if improperly managed).   Such  assurance  does  not  appear possi-




ble.   Not only do  all of  the  waste  solvents  invarying  degrees,




have significant potential for  migration, mobility, and  persist-




ence, but many have been  implicated in  actual  damage  incidents as




well.  The Administrator  thus believes  the hazardous  waste




listing to be  warranted.




     In addition,  almost  all  non-halogenated  solvents  also




present an ignitability hazard.  According to  Table 1-2,




the fourteen most-used  non-halogenated  organic  solvents  exhi-




bit flash points of 115F  or  below,  and are  thus well  below




the limit set  for  defining an ignitable waste  under RCRA




261.21 (flash point  below 140F);  therefore,  these spent




solvents and the still  bottoms  from the recovery of these




solvents are defined  as hazardous.




     Based on  the  information in Section  III,  nost  of  the




wastes from usage  of  organic  solvents are landfilled  or  incin-




erated.   Smaller amounts  of  these solvent wastes are  either




placed on open land (or rtunps), into storm sewers,  and into




deep  wells.   Misnanagenent and  improper disposal of these

-------
wastes by any of these methods could  result  in  a  substantial




health and environmental hazard.




     Actual damage incidents  (see pp.  32-35)  involving"certain




of these listed wastes confirm the dangers of  ignitability,




and of leaching of waste constituents  from landfills  to




groundwater.  Improper waste  incineration could also  lead  to




substantial hazard.  Thus, inadequate  incineration  conditions




(temperature and residence time) can  result  in  emission of




solvents or toxic degradation products.  Where  a  chlorinated




solvent is involved, emissions could  be more dangerous  than




the waste itself.  For example, phosgene is  a partially




combusted chlorinated organic (halogenated solvent) which is




produced by the decomposition or combustion  of  chlorinated




organics by heat. ^a  ^^ ^-c '   Phosgene has been




used as a chemical warfare agent and  is recognized  as extremely




toxic.




3.   Migratory Potential and  Persistence of  Halogenated And




     Non-Halogenated Solvents




     The following section discusses  the migratory  potential,




nobility, and persistence of  the individual  waste solvents.




In general, a_l of these solvents appear capable  of sufficient




migration, mobility and persistence  to create a substantial




hazard should waste mismanagement occur.




     Environmental fate d * t a  showing  the ootential  for  release




of the individual haloenat*i and non-haloge  na t = d solvents is

-------
                                                       SJ-34-01
described  below  and  summarized in Table IV-1 and Table IV-2.




Perchloroethylene




     Perchloroethylene,  if  not properly disposed of, may




migrate  from  the  waste  into  the environment via both air and




.ground water exposure  pathways.




     Having been  detected  in several  sites  away from the




disposal area  (i.e.,  found  in  varying  amounts  in school




basement air,  in  basement  sumps,  and  on solid  surface samples




at the Love Canal  site),  perchloroethy1ene  has  indeed been




demonstrated  to  be quite  mobile and persistent.1'




Methylene  Chloride




     Hethylene chloride,  if  not properly managed,  may migrate




from the waste into  the  environment.   It is very water-




soluble  (20,000 ng/1),  thus  could leach into groundwater




and persist there  due  to  its stability.1^  It  is also very




volatile (350  mm  Hg  at  20C) and  could present  an  air pollu-




tion problem  because  of  its  high  evaporation rate  (1.8 times




the rate of ether) and  its  stability  in air and light.10




Trichloroethylene




     Trichloroethylene ,  if  not properly managed, may migrate




from the disposal  site  into  the environnent via air  and




groundwater pathways.   First,  it  is volatile (77 mg  Hg at




20"C,  141.04 mm Hg at 40C'S),  so  it nay be  released  from




the waste  into the air;  it  has been detected in school and




basement air at the Love Canal site.*5

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                                       TABLE IV-1

                                  Halogenated Solvents*
Compound
Perch lor oe thy lene
Methylene chloride
Trichloroe thy lene
1, 1,1-Trichloroethane
Chlorobenzene
1
1,1,2-Trichloro-
1,2, 2-Tr if luor oe thane
1
1 , 2-D ichlor obenzene
Trichlorof luor ome thane
Vapor Pressure
(mm Hg)
19 at 25 C5
350 at 20C
77 at 25C5
100 at 20 C
10 at 22 C
270 at 20C
1.56 at 25C5
687 at 20CU
Solubility in
Water (mg/1)
150 at 25 C5
20,000 at 25 C5
1,000 at 20C5
950 at 25 C
488 at 25 C
10 at 25C
145 at 25 C
1,100 at 25 o11
Octanol/Water
Partition
Coefficient
3392
20
1952
158
690
100
24002
'
3392
* Table compiled from data given in "Physical  Chemical  Properties of Hazardous Waste
  Constituents"  (U.S. EPA, 1980) unless  otherwise  specified by superscript.
                                          -54-

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                                    Table  IV-2

                            Non-Halogenated  Solvents*
Compound
Me t ha no 1
Toluene
Methyl ethyl ketone
Methyl isobutyl ketone
Carbon disulfide
Isobutanol
Cresols and cresylic
acid ortho (1,2)
aeta (1,3)
para (1,4)
itrobenzene
Pyridine
Vapor Pressure
(mm Hg)
100 at 21.2C
28.4 at 25C
100 at 25C
16 at 20C
260 at 20C
10 at 25C
0.24 at 25C1-1

0.04 at 20C^
0.11 at 25CH
1 at 44.4C
20 at 25C
Solubility
in Water
Miscible
470 at 25'C
100,000 at 25C
10,000 at 25C
2,200 at 25C
95,000 at 18C
31,000 at 40C11

23,500 at 20C11
24,000 at 40CL1
1,900 at 25C
Miscible
Octanol/Water
Partition Coefficient
5
117
1
1
100
8
HO2

1022
982
62
5
*Table compiled from data given in  "Physical Chemical Properties of Hazardous
 'Jaste Constituents" (U.S. EPA, 1980) unless otherwise specified by superscript.

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     Ic is also relatively water-soluble  (1,000  mg/1),  so




that it may leach into groundwaters  if  not  adequately  contained.




Trichloroethylene has been detected  in  a  number  of  wells  and




residue ponds near groundwater contaminated  by a chemical




company dump, as well as in basement  sumps  at  the Love Canal




site, confirming its moblity and  persistence  in  groundwater.9




l,l,l-Trichloroet'-ine




     1,1,1-Trichloroethane is a highly  mobile  compound,  and




if not properly managed, could migrate  from  wastes  into




the environment.  It is highly volatile (100 mm  Hg  at  20C;




approximately 210 mm Hg at 40C), so  that it may be  released




from waste sites into the air.  Once  in the  air,  it  will




only decompose at elevated temperatures.  Because of this,




and the fact that 1,1 ,1-trichloroethane is reactive  to  sunlight




at high altitudes, while stable at low  altitudes, it nay




create air-pollution problems if  disposed of inadequately.^-^




It has been detected in school and basement  air  at  the Love




Canal s i te . 9




     1,1,1-trichloroethane is also relatively water-soluble




(950 mg/1) and mobile, particularly where soils  are  low  in




inorganic content.10  Tt is also  relatively  persistent in




groundwater where it reacts slowly, releasing hydrochloric  acid.10




Chlorobenzene




     Chlorobenzene may migrate from the disposal  site  into  the




en/ironment if  inadequately disposed of.  Its water  solubility is




fairly high (488 mg/1)  to enable  its leaching into groundwater




where it  would  persist,  since it  is not amenable  to hydrolys is . -[~>

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Chlorobenzene  is  also volatile so it could be released from




wastes  into  the  alr-10   It has been detected in school




and basement  air,  basement sumps, and solid surface samples




at  the  Love  Canal  site.9  Because it does not biodegrade




well,  Chlorobenzene  is very persistent in the environment.10




l>12~Trichloro-l>2>2-trifluoroethane/Trlchlorofluoromethane




     These  two  solvents, if improperly managed,  can migrate from




the disposal  site  into the environment.   They are extremely




volatile  (1,1,2-trichloro-l,2,2-trifluoroethane-270 mm Hg at




20C,  to  over  500  mm Hg at 40C;10 trichlorf1uoronethane-




687 ma  Hg at  20C7)  and very  persistent  in the environment




due to  resistance  to biodegradation, photodecomposition,  and




chemical  degradation.7  Because of their  high volatility  and




persistence,  after release at  the surface of  the earth,




these  solvents  rise  to the stratosphere  where they  nay release




chlorine  atoms  and deplete the  ozone.  This can  lead to




various adverse health and environmental  effects resulting




from an increase  in  the amount  of ultraviolet radiation




reaching  the  earth,  as well as  possible  changes  in  the earth's




climate induced by the "greenhouse effect".3'14




o - PiChlorobenzene




     o - Dichlorobenzene,  if  disposed of  improperly, may




migrate from  the disposal  site  into the  environment by both




air and water pathways.   Having been detected at several




sites away from the  disposal  area (found  in school  and base-




nent air, in basement  sumps,  and  in solid surface samples at







                              -vf-

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the Love Canal site), o-dichlorobenzene has  been  demonstrated




to he mobile and persistent.




     o-Dichlorobenzenes has a very high octanoI/water  par-




tition coefficient of 2,400, indicating a  high bioaccuraulation




potential.  Thus, migration, even in small concentrations,




could lead to a chronic toxicity hazard (Appendix  A).




Toluene




     Toluene, if improperly managed, may migrate  from  the




the disposal site into the environment.  Tt  is relatively




volatile (vapor pressure 23 mm Hg at 20C) and so  can  migrate




via and air pathway.  Tt can re-enter the  hydrosphere  in




rain.^-2  Toluene is also capable of migration via a groundwater




pathway since it is relatively soluble (470  mg/1), and  persistent




in abiotic environments (such as most aquifers).




     Toluene has been detected in school and basement  air,




basement sumps, and solid surface samples  at the Love  Canal




site, demonstrating its mobility and persistence in both air




and groundwater."




Methyl Ethyl Ketone




     Methyl ethyl ketone, if disposed of inadequately  may




migrate from the disposal site into the environment.   It is




extremely soluble in water (100,000 mg/1), and therefore could




leach into groundwater.   Tt is also very volatile  (185.4 mm




'-Ig at 40C^),  and could present  an air pollution problem




if improperly  contained.   because of its high solubility

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it could  be  re-entrained  from  air  into  the  hydroshpere via




rain.




     Methyl  ethyl  ketone  has been  detected  at  several  sites




near groundwater contaminated  by an  old  chemical  company




dump, as  well  as in  school  and basement  air at  the  Love  Canal




site, demonstrating  both  its mo-bility and  persistence.9




Carbon Disulfide




     Carbon  disulfide,  if  improperly managed,  may migrate




from the  disposal  site  into  the environment.   It  is  extremely




volatile  (260  mm Hg  at  ?. 0  C) and althouth  subject to photo-




lysis, could present  an  air  pollution problem  if  inadequately




contained.   It  is  also  quite soluble in  water  (2200  mg/1),




and is not known to  attenuate  in soils;  therefore it could




leach into the  groundwater,  where, being unamenable  to hydro-




lysis, it is likely  to  persist for an extended  time  period.1 ^




Isobutanol




     Isobutanol, if  improperly managed,  may migrate  from




the disposal site  into  the  environment.  It is  extremely




water-soluble  (95,000 mg/1); thus, if inadequately  contained,




it may contaminate surface  water and adversely  affect  its  self-




purification ability.10   jn  addition, isobutanol  could leach




into groundwater if  disposal is inadequate.




Cresols (and cresylic acid)




     Cresols,  if improperly  managed, may migrate  from  the




disposal site  into the environment.  Cresols are  highly




soluble (23,500 to 31,000 mg/1) and  are  not known to attenuate

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significantly in soils; thus, they could leach  into  groundwater




if disposal is inadequate.  Once in water,  cresols rapidly




form chlorinated compounds, which are more  environmentally




objectionable.10  Cresols are not known  to  hydrolyze and  so




would be likely to persist in groundwater.11




Nitrobenzene




     Nitrobenzene, if disposed of inadequately, may  migrate




from the disposal site into the environment.  It is  water-




soluble (1900 mg/1) and would be mobile where soil organic




content is low,10 and thus could leach into groundwater if




disposal is not adequate.  It is likely to  be highly per-




sistent in groundwater since it is not amenable to hydrolysis




and does not biodegrade well.^0




Pyridine




     Pyridine, if disposed of inadequately, may migrate from




the disposal site.  Because pyridine is miscible with water,




it has high migratory potential.  It would  be mobile  as well,




unless soil has high clay content.10  Pyridine also  would be




likely to persist in the abiotic environment of most  ground-




waters .




C.   Mismanagement of Wastes Destined for Land Disposal




     Documented damage incidents resulting  from the  mis-




management of these wastes from usage of organic solvents




are presented below:
                             -yt-

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Damage Resulting  from  Ignitability of  Wastes


(1)  A load  of  used  pesticide  containers delivered to a

     disposal site  in  Fresno  County,  California,  also con-

     tained  several  drums  of  an  acetone-raethano1  solvent

     mixture.   When  the  load  was  compacted  by a bulldozer,

     the waste  ignited,  engulfing  the  bulldozer in flames

     and dispersed  pesticide  wastes.(13)

(2)  A large number  of drums  containing  organic solvent wastes

     were deposited  in a  landfill  at  Contra  Costa,  California.

     In the  immediate  area  were  leaking  containers  of concen-

     trated  mineral  acids  and  several  bags  of beryllium wastes

     in dust forra.   The  operators  failed to  cover  the wastes

     at the  end of  the day.   The  combination of wastes  ignited

     during  the night, starting  a  large  chemical  fire which

     possibly dispersed  toxic  beryllium  oxide.(13)

(3)  Two serious  fires at  the  Merl-Milara Landfill,  St.  Clare

     County, Illinois  (August, 1973 and  April,  1974)  were

     attributed to  the presence  of solvent  wastes  from  plastics

     manufacture.(13 )

Contamination of  Groundwaters

(1)  In two  separate instances in  Michigan,  trichloroethylene

     was dumped on the ground  and  later  found  to have migrated

     into groundwater.   In  one case, trichloroethylene  dumped

     at a rate of 1000 gallons per year  over  a  four-year

     period was detected in residential  wells  as much as

     1100 feet from  the  site of dumping.  Concentrations


     ranged as high  as 28 ppn.'13)



                             -vf-
                              -(0\-

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          In the other case, the Air Force at a base near




     Oscoda, Michigan, had problems with contaminated  ground-




     water because of a leaking tank which use to hold




     trichloroethylene.  The problem was compounded  when




     a waste hauler apparently mismanaged the trichloro-




     ethylene that was hauled from the leaking tank, and




     groundwater contamination up to four miles away was




     considered one of the results. (H)




(2)   A sump overflow in 1971 at the Superior Tube Company




     allowed trichloroethylene wastes to leak into a cooling




     pond.  Seepage from this pond was found to contaminate




     a private well 75 yards distant and a company well at




     the site.(13>




(3)   Open dumping of wastes, including solvent wastes, from




     a chemical packing plant by U.S.  Aviex Company  resulted




     in entry of organic solvents into the water table and




     contamination of several nearby water wells in  1973.




     One family reported illness resulting from use  of the




     contaminated well water.(13)




(4)   [Mono ] c'nlorobenzenes , at concentrations of 5 mg/1 and




     30 mg/1 has been detected in the  water from 2 of  21 ob-




     servation wells, installed at depths up to 50 feet at




     varying distances from an industrial manufacturing com-




     plex devoted to the development  and manufacture of en-




     gineering plastics.(14)

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     The damage Incidents presented above  illustrate  the




following potential hazards associated  with  wastes  from  usage




of organic solvents:




(1)  Ignitability hazard during mismanagement;




(2)  Potential  toxicity hazard  to humans  via  groundwater




     exposure  pathways.

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IV .   References to Section IV  (A,  B  and C)

1-   Jacobs, S.  The handbook  of  solvents. D.  Van
     Nostrand Company, Inc.  New York.  1957.

la.   Edwards, J.B.  Combustion  formulation and emission of trace
     species. Ann Arbor Science.  1977.

Ib.   NIOSH.  Criteria  for a  recommended standard: Occupational
     exposure to phosgene. HEW, PHS,  CDC,  NIOSH.  NTIS PB No.
     267 514. 1976.

Ic.   Chemical and Process Technology  Encyclopedia. McGraw
     Hill. 1974.

2.   Leo, A., C. Hansch and  D. Elkins.   Partition coefficients
     and their uses. Chem. Rev. 71:525-616.  1971  (Updated 1977).

3.   National Academy  of Sciences, National  Research Council.
     Halocarbons:  Environmental effects of chloro me thane
     release. Publication No.  2529.  1976.

4.   National Academy  of Sciences, National  Research Council.
     Committee on Impacts of Stratospheric Change. Stratospheric
     ozone depletion by halocarbons:  Chemistry and transport.
     1979.

5.   Patty, F.A.,  ed.  Industrial  hygiene  and  toxicology.
     Interscience  Publishers,  New  York. 1963.

6.   Sax, N. I.  Dangerous properties  of  industrial  materials,
     5th ed. Van Nostrand Reinhold Company,  New York.
     1979.

7.   U.S. EPA.  Environmental  hazard  assessment of one- and
     two-carbon f luor ocar bons . EPA No.  560/2-75-003. NTIS
     P3 No. 246 419. 1975.

3.   U.S. EPA.  Evaluation of  treatment,  storage, and disposal
     techniques for ignitable, volatile,  and reactive wastes.
     Contract Number 68-01-5160.  (Draft final  report).  1980.

9.   "Love Canal Public Health Bomb",  A Special Report  to the
     Governor and  Legislature, New York State  Department of
     Health. 1973.

10.   U.S. EPA.  Physical chemical  properties of hazardous
     waste constituents. (Prepared by  Southeast Environmental
     Research Laboratory; Jim  Falco,  Project Officer).  1980.

11.   Verschueren,  K.   Handbook of  environmental data on
     organic chemicals. Van  Nostrand  Reinhold  Company,  New
     York. 1977.
                             -44-

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12.  Walker, P.   Air  pollution assessment  of  toluene.
     NTIS PB No.  256  735.  May, 1976.

13.  U.S. EPA.   Open  Files.  Hazardous  Site  Control Branch,
     WH-548, U.S.  EPA.  401 M St., S-W.,  Washington, D.C. 20460
     Contact Hugh Kauffman. (202) 245-3051.

14.  TSCA Section 8(e)  notice from General  Electric Company to
     U.S. EPA,  Region I Permits Branch,  January  23, 1980.
                               -(,*>--

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D.   Health and Environmental  Effects*

Perchloroethylene  (Tetrachloroethylene)

     Perchloroethylene  (PCE) was  reported  carcinogenic  to

mice.(^)  It has  also  been  identified  by  the  Agency as a

chemical which has demonstrated  substantial  evidence of being

carcinogenic.  PCE is chronically  toxic  to  rats  and  mice, causing

kidney and liver damage;(l^>^21-)  and  to  humans,  causing impaired

liver function.(2)   Subjective central  nervous  system complaints

were noted in workers occupationally  exposed  to  PCE.(^'   PCE

exposure is reported to cause  alcohol intolerance  to humans.

     PCE is a priority  pollutant  under  Section  307(a) of  the

Clean Water Act.

Methylene Chloride (Dichloromethane )

     EPA has found "suggestive" evidence of  the  carcinogenicity

of methylene chloride,  therefore, methylene  chloride is

considered a "suspect carcinogen"  (Appendix  A^;  methylene

chloride was also  reported as  being mutagenic to a bacterial

strain, _S_. typhimurium. (24) -jt was  reported  to be  feto- or

embryo-toxic to rats and mice.(23)  Female workers had

gynecological problems  after prolonged exposure  to methylene

chloride.(36)  Methylene chloride also causes central

nervous system depression and  elevation of carboxyhemoglobin

levels.(1)  Severe contamination of  food or water can

causa irreversible renal and hepatic  injury.(30)   Acute

toxicity values range from 147,000  to 310,000 ug/1 for  aquatic


*Euhyl benzene, which is only being listed for its ignitability
hazard,  is also considered a priority pollutant  under Section
307(a) of the Clean Water Act.

                             -3X-

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organises  (Appendix  A)




Trtchloroethylene




     Trichloroethylene  (TCE)  has  been reported Co be carcino-




genic  to mice.(15)   It  has  also  been identified by the Agency




as a chemical  which  has  demonstrated substantial evidence of




being  carcinogenic.H8)  industrial  exposure to TCE caused




some cases  of  central  nervous  system disturbances (headaches,




insomnia,  tremors)  as  well  as  peripheral  nervous system




impairment  (neuritis,  temporary  loss of  tactile sense, finger




pa ra lys is ) . ' *- > 1 3 )   Rare  cases  of  hepatic  damage have been re-




ported  following  repeated  abuse  of  TCE.(6)




     TCE was  found  to  be  toxic  in varying  degrees to several




freshwater  organisms. (< 8)   There  was also  a 50% decrease




noted  in l^C  uptake  by  a  saltwater  algae  at a  concentration




of 3,000 ng/1.(2)(Appendix A)




1,1,1-Trichloroethane  (Methyl  Chloroform)




     Data  regarding  the  careinogenicity of  1,1,1-trichloroe th-




ane is  inconclusive. (1?)   it  is mutagenic  in  the Ames  test,




and in  a mamallian cell  transformation  system  (See  Appendix




A).   Chronic  exposure,  albeit  is  greter than  ambient levels,




can cause  central nervous  system  disorders  in  humans.   Animal




studies showed  toxic effects on the  central nervous  system,




cardiovascular  system,  oulmonary  system,  and  induced liver




and  kidney damage.^34)   1, 1 ,1-Trichloroethane  is  a  priority




pollutant  under Section  307(a) of the  Clean Water Act.
                             -yf-

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Chlorobenzene  (Monochlorobenzene,  MCB)




     Chlorobenzene has been  found  to  produce  htstopathological




changes In the lungs, liver,  and kidneys  following  its  inhalation




by rats, rabbits and guinea  pigs. (7)  Oral  administration of




^onochlorobenzene to rats  was  reported  to cause  growth  retar-




dation  in males .( H)  MCB  also -appears  to increase  the  activity




of some microsomal enzyme  systems,  wh-ich  enhances  the metabolism




of many drugs, pesticides, and other  xenobiotics.(29)(Appendix ^ )




     MCB was reported to be  toxic  to  varying  degrees  to




several fresh- and salt-water  organisms,  including  algae, (28)




has a high biomagnification  factor  (Appendix  B),  is resistant




to biodegradation and hydrolysis and  is,  therefore, persistent.




     MCB is a  priority pollutant under  Section 307(a) of  the




Clean Water Act, is a subject  of TSCA section 4  Test Rule,  and




has been selected for bioassay by  NCI.  These regulatory  actions




point to concern regarding its toxicity.




1,1,2 Trichloro-1,2,2 trifluoroethane




     The Agency's primary  concern  in  listing  this solvent  is




the air pollution hazard resulting  from its release at the




surface of the earth.  This  can have many adverse health  and




environmental effects including increased incidence of skin




cancer, reduced productivity in several important agricultural




crops,  and increased mortality in  the larvae  forms of several




important  seafood species  resulting from the  depletion of




the ozone.(39,40)  Because of these effects,  EPA is currently




considering regulation of  CFG production and  use.

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1,2-Dichlorobenzene  (ortho  isomer)

     Ortho  1,2-dichlorobenzene  exhibits  moderate toxicity via

inhalation  and  oral  routes.   The  major toxicologica1 effect

is  injury  to  the  liver  and  kidneys;  it is  also  a central ner-

vous system  depressant  after  short  periods of exposure(1922)

(Appendix  A) .

     1,2-dichlorobenzene  is  designated a priority pollutant

under  section  307(a)  of  the  Clean Water  Act.

Trichlorofluorome thane

     The Agency's  primary concern in  listing  this solvent is

the air pollution  hazard  resulting  from  its release at  the

surface of  the  earth.   This  can have  many  adverse health and

environmental  effects including skin  cancer resulting from

the depletion  of  the  ozone  (Vide  Sufora). ( 394)   However,

additional  adverse health effects have been found and are

presented below.

     Exposure  of  rabbits  to  trichlorofluoromethane  was  re-

ported  to cause cardiac arrhythmias.^-"^   It  induced

cardiac arrhythmias,  sensitized the heart  to  epinephrine-

induced arrhythmias,  and  caused tachycardia (increased

heart rate) myocardial depression, and hypertension in  the

monkey, dog, rat  and  mo use.(26)

     Trichlorofluoromethane  is a  priority  pollutant under

Section 307(a)  of  the Clean Water Act.*


*The Agency has recently  proposed to  remove trichlorofluoro-
 -ie thane from the  list of toxic pollutants  under  307(a)  of
 the Clean Water  Act  (45  FR 46103, July  9,  1980).

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Toluene




     Toluene is a toxic chemical absorbed  into  the  body  by




inhalation, ingestion, and through  the  skin.  Data  on  its




tnutagenicity and carcinogenicity are  inconclusive,  but it




has been reported to cause chromosomal  change;  teratogenic




problems were also recently reported.'4''   The  acute




toxic effect is central nervous system  depression,  (+5;




and irritation of eye and throat.   These effects  occur at




low concentrations [200 ppm].(^)   Chronic occupational




exposure to toluene has led to the  development  of neuro-rauscular




disorders.  Occupational exposure to  female workers to toluene




reported to cause several reproductive  problems,  both  to the




wonan and the offspring.(25)  Chronic toluene exposure can




cause dermatitis, affect the immune system, and cause  permanent




damage to the central nervous system.(4 " '




     Since toluene is metabolized in  the body by  a  protective




enzyme system which is also involved  in the elimination of




other toxins, it appears that over-loading the metabolic




pathways with toluene -nay greatly reduce the clearance of




other more toxic chemicals.   Additionally, the high affinity




of toluene for fatty tissue can assist  in the absorption of




other toxic chemicals into the body-  Thus, synergistic




effects of toluene on the toxicities  of other contaminants




may render the waste stream nore hazardous (Appendix A).




     Toluene is a priority pollutant  under Section  307(a) of



the Clean Water Act.
                             -70-

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Methyl Ethyl Ketone




     Methyl ethyl ketone  Is  a  highly  volatile  ignitable liquid




of moderate toxicity  via  ingestion  which  can affect  the




peripheral nervous  system and  is  an experimental  teratogen




(Appendix  A ) .   It is  also a  strong  irritant  of the mucous




membranes  of the  eyes and nose..  A  lethal dose in animals




(LC5Q ~ 700 ppra)  has  caused  marked  congestion  of  the internal




organs and slight congestion of the br.iii.   Lungs also showed




emphysema  (Appendix  A).




Carbon Disulfide




      Short term human exposure to low atmospheric concentrations




of carbon  disulfide  nay  result in central nervous system de-




pression,  headaches,  breathing difficulty and  gastrointestinal




disturbances.   Exposure  to short  term b-ut high atmospheric




concentrations  can  lead  to narcosis and death.  The  symptoms




of humans  subjected  to repeated exposure  to  high  concentrations




or prolonged exposure to  low concentrations  include  insomnia,




fatigue,  loss  of  memory,  headache,  melancholia, vertigo and




loss  of appetite.   Visual impairment, loss  of  reflexes, and




lung  irritation has  been  r epo r t ed . ( *9  2 2 >  Kats and  mice exposed




3 hours per day  for  20 weeks to an  average  concentration of 37 ppra




carbon disulfide  showed  evidence  of toxic e f fee t s . < 19 )( Appendix A)





Isobutanol



      Rats  receiving  isobutyl alcohol, either  orally or subcu-




taneously, one  to two tines  a  week  for 495 to 643 days showed




liver carcinomas  and sarcomas, spleen sarcomas and myeloid





leukemia. (43)
                               -71-

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     Ingestion of one molar solution  of  Isobutyl  alcohol  in




water by rats for 4 months did not  produce  any  inflammatory




reaction of the liver.  However, rats  ingesting a two  molar




solution for two months developed Mallory's  alcoholic  hyaline




bodies in the liver and were observed  to have  decreases  in




fat, glycogen, and R N A in the liver. (43)




     Acute exposure to isobutyl alcohol  causes  narcotic  effects,




and irritation to the eyes and throat  in humans exposed  to




100 ppm for repeated 3 hour periods.   Formation of  facuoles




in the superficial layers of the cornea  and  loss  of  appetite




and weight were reported among workers subjected  to  an undeter-




mined but apparently high concentration, of  isobutyl alcohol.(44)




(Appendix A)




Pyridine




     Pyridine exhibits moderate toxicity when absorbed into




the human body through oral, dermal, and inhalation  routes.(22)




Liver and kidney damage has been produced in animals and  man




after oral adrainistration.(3)   in small doses, conjunctivitis,




dizziness, vomiting, diarrhea  and jaundice may appear; tremors




and ataxia, irritation of the  respiratory tract with asthmatic




breathing, paralysis of eye muscles, vocal cords  and bladder




also have been reported.(22)




     Adverse taste in fish (carp, rudd) has  been  reported  at




5  ppm.   Pyridine  causes inhibition of  cell multiplication  in




algae and bacteria at 23  and 340 ppm respectively.(35^(Appendix A)
                             -72-

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Nitrobenzene




     Nitrobenzene Is a suspected  carcinogen.(4) When




administered to pregnant  rats,  it caused  abnorna1ities  in




some of the fetuses exanined.(^)  Changes  were observed




in the chorionic and placental  tissues  of  pregnant  workers




exposed to nitrobenzene,^) and menstrual  disturbances




after chronic exposure have been  reported.   Chronic exposure




to nitrobenzene has been  found  to cause a  variety  of  blood-




variety disorders.




     Nitrobenzene is toxic  in varying degrees to several




salt- and fresh-water organises.(31)  (Appendix A), and nitro




benzene is a priority pollutant under Section 307(a)  of the




Clean Water Act.




Cresols (Cresylic Acid)




     Cresol is highly toxic if  orally administered, and




moderately toxic if inhaled.  Absorption  may result in danage




to kidney and liver as well as  the  central nervous  system.(22




Exposure to cresol can cause severe skin  burns and  derma-




titis .(l922>(Appendix A)
                              -73-

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VII. References to Section IV, D

1.   Bardodej, A., and J. Vyskocil.  The  problem of trichloro-
     ethylene in occcupational medicine.  AMA Arch. Ind. Health.
     13:581. 1956.

2.   Coler, H.R., and H.  R.  Rossmiller.   Tetrachloroethylene
     exposure in a small  industry.  Ind.  Hyg. Occup. Med.
     3:227. 1953.

3.   Deichmann, W.R.  Toxicology  of  drugs  and chemicals.
     Academic Press Inc., New York.  1969.

4.   Dorigan, J. and J. Hushon.   Air  pollution assessment
     of nitrobenzene. NT IS PB No. 257  776. May,  1976.

5.   Gosselin, R.E., et.  al.  Clinical  toxicology of
     commercial products, 4th ed.  The Williams  and
     Vilkin Company, Baltimore. 1976.

6.   Huff, J.E.  New evidence on  the  old  problems of  trichloro-
     ethylene. Ind. Med.  40:25. 1971.

7.   Irish, D.D.  Halogenated. hydrocarbons:II.  Cyclic.
     In Industrial hygiene and toxicology, V.II,  2nd  ed.
     F. A. Patty, ed .  Interscience,  New  York.
     p. 1333. 1963.

8.   Kazanina, S.S.  Morphology and  histochemistry of
     hemochorial placentas of white  rats  during  poisoning of
     the maternal organisms  by nitrobenzene.  Bull. Exp. Biol.
     Med.(USSR) 65:93. 1968.

9.   Not used in text.

10.   Klaassen, C.D., and G.L. Plaa.   Relative effects of
     chlorinated hydrocarbons on  liver and kidney function  in
     dogs. Toxicol. Appl. Pharmacol.  1967.

11.   Knapp, W.  K-,  Jr., et al.  Subacute  oral toxicity  of
     monochlorobenzene in dogs and rats.  Toxicol. Appl.
     Pharmacol. 19:393. 1971.

12.   Not used in text.

13.   McBirney,  B.S.  Trichloroethylene and dichloroethylene
     poisoning. AMA Arch. Ind . Hyg .  10:130.  1954.

-------
 14.   Medek,  V., and J. Kovarik.   The  effects of perchloro-
      ethylene on the health  of  workers.  Pracovni Lekarstvi
      25:339. 1973.                       	

 15.   National Cancer Institute.-   Car c inogene s i s bioassay
      of  trichloroethylene. NCI-CG-TR-2.  NTIS PB No. 264 122.
      1976.

 16.   National Cancer Institute.   Bioassay of tetrachloro-
      ethylene for possible carcinogenicity.   NCI-CG-TR-13.
      NTIS  PB No. 272 940. 1977.

 17.   National Cancer Institute.   Bioassay of 1,1,1-trichloro-
      ethane  for possible  carcinogenicity-  NCI-CG-TR-3.
      NTIS  PB No. 265 082. 1977.

 18.   National Institute  for  Occupational  Safety and Health.
      Criteria for a recommended  standard:  Occupational
      exposure to methylene chloride.  HEW  Pub.  No.  76-138.
      U.S.  DHEW. Cincinnati,  Ohio.  1976.

 19.   Patty,  F.A., ed.  Industrial  hygiene and  toxicology.
      Volume  II. Interscience Publishers,  New York.  1963.

 20.   Pearson, C.R., and G. McConnell.  Chlorinated  C^  and  C2
      hydrocarbons in the  marine  environment.  P roc .  R.  Soc .
      London  B  189:302. 1975.

 21.   -Rowe , V. K., et al .  Vapor  toxicity  of  te tr achlor oe thyl ene
      for  laboratory animal and human  subjects.  AMA   Ar ch.  Ind.
      Hyg.  Occup. Med. 5:566. 1952.

 22.   Sax,  N.  I.   Dangerous properties of  industrial materials,
      5th  ed.  Van Nostrand Reinhold Company,  New  York.  1979.

 23.   Schwetz,  B. A., et al.   The effects  of  maternally inhaled
      trichloroethylene , perchloroethylene, methyl  chloroform,
      and methylene chloride on embryonal  and  fetal  development
      in mice and rats.  Toxicol. Appl. Pharmacol. 32:84.  1975.

 24.   Simmon,  V.  F., et  al.  Mutagenic activity  of  chemicals
      identified in drinking water. S. Scott,  et  al.  eds.
      In: Progress in genetic toxicology.  1977.

 25.   Syrovadko,  0.  N.   Working conditions  and  health status
      of women handling  organosiliceous varnishes containing
      toluene.  Gig.  Tr .  Prof.  Zabol. 12:15. 1977.

 26.   U.S. EPA.   Environmental hazard  assessment  report:
      Major one-  and two-carbon saturated  f1uorocarbons;
      review  data.   EPA  No. 560/8-76-003.   NTIS  PB  No.
      257 371.  August,  1976.

27.   Not used  in text.
                         -7.5"-

-------
28.  U.S. EPA.  In-depth  studies  on health and environmental
     impacts of selected  water  pollutants. Contract No. 68-01-4646.
     1978.

29.  U.S. EPA.  Chlorinated  benzenes:  Ambient water quality criteria
     NTIS PB Mo. 297 919.  1979.

30.  U.S. EPA.  Halomethanes: Ambient  water quality criteria.
     NTTIS PB No. 296 797.  1-979.

31.  U.S. EPA.  Nitrobenzenes:  Ambient water quality criteria.
     NTIS PB No. 296 801.  1979.

32.  U.S. EPA.  Tetrachloroethylene: Ambient water quality
     criteria. NTIS PB No. 292  445.  1979.

33.  Not used in text.

34.  U.S. EPA.  Chlorinated  ethanes: Ambient water quality
     criteria. NTIS PB No. 297  920.  1979.

35.  Verschueren K.  Handbook of  environmental data on organic
     chemicals. Van Nostrand Reinhold  Company, New York, 1977.

36.  Vozovaya, M.A.  Gynecological  illnesses in workers of
     major industrial rubber products  plants occupations.
     Gig. Tr. Sostoyanie  Spetsificheskikh  Funkts.  Tab.
     Neftekhim. Khim. Prom-Sti. (Russ.)  56.  (Abstract). 1974.

37.  Not used in text.

38.  U.S. EPA.  Office of  Research  and Development. Carcinogen
     Assessment Group. List  of  Carcinogens.  April  22,  1980.

39.  National Academy of  Sciences,  National  Research Council.
     Halocarbons:  Environmental effects  of chloromethane release.
     PB No.  2529.  1976.

40.  National Academy of  Sciences,  National  Research Council.
     Committee on  Impacts  of Stratospheric Change.   Strato-
     spheric ozone depletion by halocarbons:  Chemistry
     and transport. 1979.

41.  Linari, F., G. Perreli, and  D. Varese.  Clinical observa-
     tions and blood chemistry  tests among workers  exposed
     to the  effect of a complex ketone--methyl isobutyl ketone.
     Arch. Sci. Med. 226-237. 1964.  (Ital).

42.  Specht, H., J.W. Miller, P.J.  Valaer, and R.R. Sayers.
     Acute response of guinea pigs  to  the  inhalation of
     ketone  vapors.  NIH  Bulletin No.  76.  Federal  Security
     Agency. Public Health Service, National Institute of
     Health, p.  66.
                           -74-

-------
43.  Gibel, et  al.   Exp.  Chir.  Forsch.  1:235. 1974.

44.  Smith et al .   Arch.  Ind.  Hyg.  Occup. Med.  10:61. 1954.

45.  U.S. EPA.   Toluene:  Ambient water  quality  criteria.
     MTIS PB No.  296  805.  1979.

46.  NIOSH.  Registry of  toxic effects  of chemical substances
     Toluene. 197 3.

47.  Nawrot, P.  S.,  and  R.  E.  Stapler.   Embryofetal  toxicity
     and  teratogenicity  of  benzene  and  toluene  in the mouse
     (abstract).  Teratology.  19:41a.

48.  Cohr, K. H.,  and J.  Stockholm.  Toluene-a  toxicologic
     review. Scand.  J. Environ,  and Health. 5:71-90. 1979.
                               -77-

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 Response to Comments (Proposed Listings  (December  18,  1978))


0    One commenter objected to the listing  "Waste non-

     halogenated solvent (such as methanol,  acetone,  iso-

     propyl alcohol, polyvinyl alcohol, stoddard  solvent

     and methyl ethyl ketone) and solvent sludges from

     cleaning, compounding milling and other  processes."*

     The commenter argued that without indicating the  con-

     centration or quantity of the solvent  in  the waste,

     the Agency would be listing wastes as  hazardous  even

     if the solvent were present in small concentrations and

     quant it ies.


     In the listing promulgated today for waste solvents,

     the Agency is only listing those spent solvents or

     still bottoms from the recovery of these  solvents

     which wo'uld contain substantial quantities and con-

     centrations of the solvent.   ^ o r example, spent solvents

     can contain up to 90% of the original  solvent  while

     the still bottoms may contain up to  50% of the spent

     solvent.


     A number  of comnenters objected to the listing of poly-

     vinyl alcohol (PVA) as a solvent.   These  commenters

     argued that PVA is  not a solvent but is a solid and

     can only  be used  as a  solute.   Therefore, they recommended

     that  PVA  be removed from the list.
*This specific listing will not be included in the final
 regulation;  however,  it  will be covered under the generic
 listing "The Spent  non-halogenatad solvents

-------
The Agency agrees  with  Che  comnenters  and  therefore,




has removed PVA  from  the  listing.







A number of comnenters  objected  to  the  listing  of waste




halogensted/non-halogenated  solvents.   They felt that




the listing was  too vague  and  ambiguous.







In the listings  promulgated  today,  the  Agency has




specifically listed only  those  solvents  for which data




or information are available  which  indicates  a  present




or potential hazard could  be  posed  to  human health and




the environment  if improperly  managed.   Therefore, the




listing description promulgated  today  should  respond




to the comraenters1 objection.

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Response to Comnents -  Spent  Halogenated  and  Non-Halogenated




Solvents and the Still  Bottoms/SJudges  From the Recovery of




These Solvents









A number of comments were  received  with respect to wastes




F001 to F005 (Spent halogenated  and  non-halogenated solvents




and the still bottoms/sludges  from  the  recovery of these




solvents).






1.   One commenter  requested  that  the  Agency  clarify or




     define what it means  by  the  term  "spent".   For example,




     the commenter  questioned  whether  "spent"  refers to the




     state of the chemical  which  was pure  initially but




     now appears in the  waste  stream after  being used,  or




     whether it refers  to  the  altered  or  decomposed state of




     a chemical which has  outlasted  its shelf  life.




          The Agency agrees with  the commenter  and has




     thus included  the  following  definition for "spent




     solvents" in the listing  background  documents:




               "Spent solvents  include  those  solvents  which




               are  no longer  useful  as  solvents without




               further  processing  (i.e.,  solvent reclamation),




               either because  the  solvents  have outlasted




               their shelf  life,  or  because the solvents
                                 -30-

-------
           have  been contaminated or chemically or




           physically changed.




      It  should  be  clear from this discussion that the




wastes encompassed  by this listing do not include waste




streams  where  the  solvent is a contaninant, such tnat




the  waste  stream  is not a spent solvent, as defined




above.   Thus,  wastes which contain as constituents




solvents which  are  used in the industrial process




are  not  included  within the  scope of this listing.




Mor  are  these  waste streams  hazardous by virtue of the




mixing rule  ( 261. 3(a)(2)(ii)), since a spent solvent is




not  being  mixed  with another solid waste.




      The Agency,  however, does not believe it appropriate




to define  the  term  "spent solvent" by using a quantity/




volume cut-off  (i.e., spent  solvents include those




solvents wh ich  contain  x  percent or more of solvent).




As we have indicated in other  support documents (see e.g.,




Background Document on  EP toxicity), the Agency does not




presently  believe  sufficient information exists to




establish  minimum  waste concentration levels for  toxic




constituents, except for  those regulated by the Interim




Primary Drinking Water  Standards.   Ue intend to make




case-by-case determinations  via the delisting raechanisn




to remove  those  wastes  containing  Tiniial concentrations




of "spent  solvent".

-------
     Another commenter argued  that  the  scope  of  the  listing

     of both spent solvents  and  still  bottons/sludges from

     the recovery of solvents,  is  overinclusive  because it

     do35 not recognize  that certain  solvent  recovery opera-

     tions produce non-hazardous  still  bottoms.* For  example,

     the comnenter stated  that  it  is  possible to produce a

     nonleaching, non-ignitable  fused  waste  solid containing

     as low as 5 percent solvent.   Therefore, the commenter

     recommends  that solvent recovery  still  bottoms  be defined

     as fo11ows:

          "Solvent recovery  still  bottoms: residue from

          the disti1lation/evaporation  process  of re-

          covered solvent  which  has more  than 10% of

          the original solvent  (excluding water)  re-

          maining"


          The Agency disagrees with the comnenter.   In the

     first place, the commenter has not correlated  the

     recommended concentration of solvent with a  showing that

     exposure to these levels of contaminant  will not cause

     substantial hazard.    Nor is there  documentation  for the

     claim that still bottoms containing 5% of the  listed

     solvent would be incapable of  posing substantial harm if

     mismanaged.   Furthermore,  the  Agency believes  that
*It should be noted that this comment was directed  to  waste
 F004 (the following spent non-halogenated  solvents: cresols
 and crasylic acid, and nitrobenzene; and the  still  bottoms
 from the recovery of these solvents).  However,  EPA's  res-
 ponse is also applicable to wastes F001, FOG2  and  F005.

-------
     still  bottoms  containing 5% of the listed solvent

     nay  indeed  pose  a  substantial hazard to human health

     and  the  environment  if  improperly managed.*  This premise

     is based  on  the  following factors:

     (1)  The  recommended  cut-off  level  (50,000 ppa)  is at least

          an  order  of magnitude above  that  needed to  cause

          acute  effects,  and  in most  case orders of magnitude

          higher  (see Appendix A to the  listing background

          document).  Thus,  still  bottoms with 5% concentration

          of  a  listed solvent would only have  to leach a

          snail  percentage  of the  contained  solvent to cause

          substantial hazard.

     (2)  Cresols,  cresylic  acid and  nitrobenzene are  all

          toxic  chemicals:  nitrobenzene  is  a suspect  carcino-

          gen  and has been  found to cause a  variety of blood

          disorders from  chronic exposure.   Cresols and

          cresylic  acid are  highly toxic if  administered

          orally and  moderately toxic  if inhaled.   In  addition,

          cresol and  cresylic acid may  result  in damage to the

          kidney and  liver as well as  to the central  nervous

          system.

     (3)  Because of  the  toxicity  of  these  solvents,  the

          concentration of  solvent in  the  still bottoms

          (five percent)  is  considered  significant  by  the

          Agency.
*At a 5 percent level of  solvent,  the  waste  streams  may no
 longer he ignitable as defined  in  S261.21.

-------
     (4)  All of  these  solvents  have  high or appreciable

          water solubilities  (nitrobenzene:  water solubility

          1^00 rag/1  (Appendix  B);  cresols and cresylic acid:

          water solubilities  23,500  and  31,000 rag/I (Appendix

          3) and  therefore, could  leach  into groundwater under

          improper disposal conditions.

     (5)  All of  these  solvents  are  likely to persist in

          groundwater;  cresols,  cresylic  acid and nitrobenzene

          are not known to hydrolyze  while nitrobenzene also

          does not biode grade  well.j^/

     The Agency therefore, believes  that  still bottoms from

     the recovery of cresols and cresylic acid,  and nitro-

     benzene may  pose a substantial hazard to human health

     and the environment even  when five  percent  of  solvent

     is in the waste.   If an individual  generator believes

     his still bottoms  are non-hazardous,  the generator

     should petition the Agency  to de-list his wa s t e (see

     5260.20 and 260.22).

3.   One coramenter criticized  EPA's generic  designation of

     ill spent chlorinated fluorocarbons  as  hazardous.

     Therefore,  the coramenter  bel laves that  the  broad  category

     (chlorinated fluorocarbons) should be replaced by specific

     compounds for which documented evidence  of  hazard is

     iv a 1 lab le .    The comnenter also -argued more  specifically
* These data are all taken from Appendix  R  to  the  listing
 background document.
                              --3H-

-------
      that trichlorofluoromethane and  dich1orodifluoromethane

      are not hazardous constituents^/ and  that  EPA's  reason

      for regulating these materialsthat  they  can  rise  into

      the stratosphere and deplete the ozone leading  to adverse

      health and environmental effectshas not yet  been

      proven.  The comnenter pointed out that the most sophisticated

      statistical analyses of actual ozone measurements taken

      at  various places around the world have consistently

      failed to  detect the depletion calculated to have

      occured to date,  despite the fact that the most recent

      analyses  should detect this  depletion even if it were

      only half  the  calculated amount.   The conraenter also

      argued that there have been  growing  indications that

      the  current ozone depletion  theory as it  applies to

      chlorofluorocarbon  depletion does not accurately describe

      the  present-day atmosphere,  or  fails  to  consider aspects

      of  atmospheric chemistry  which  are  both  significant  and

      important.   Cited in support is  the  study  Chlorofluoro-

      carbons and  Their Effects on Stratospheric  Ozone (2nd Rpt.)

      Pollution  Paper  No.  15,  Department of  Environment,  Central

      Directorate  on Environmental Pollution, October 1979.
VThe coramenter cited several  reasons  for  this  statement:
 (1) the Health and Environmental  Effects  Profile  (Appendix
 A)  indicates that both  trlchlorofluoromethane  and  dichloro-
 'luoroaethane are non-toxic,  (2)  EPA's  proposed action  to  remove
 these two compounds from  the  Clean Water  Act  toxic  pollutant
 list indicates EPA's admission as  to  the  innocuous  nature
 of  these two compounds  in  the aquatic environment,  and  (3)
 EPA's limited discussion  of the various factors under
 261 . ll(a)(3) of RCRA indicates that  wastes  containing  these
 two compounds pose no hazard  during storage,  transportation,
 treatment or disposal.

-------
Therefore, the coramenter requested  that  all  chlorinated




fluorocarbons be deleted from  the  F001  and  F002  'generic




waste list.




     The Agency disagrees with  the  commenter on  both




points.   With respect to their  concern  regarding the




generic  designation of all spent chlorinated fluorocarbons




as hazardous, the Agency believes  that  all  chlorinated




fluorocarbons share the same physiological  and  photo-




chemical attributes of concern, namely  depletion of




the ozone.  Therefore, the Agency  feels  justified




in listing the broad category  of chlorinated fluorocarbons




as hazardous, rather than its  individual  -nenbers.




     As  to the hazardous nature of  the  listed chloro-




fluororaethanes, the Agency agrees "that  they  pose a  low




potential for adverse acute effects at  anbient air




concentrations, although there  is some  indication that




long terra exposure to very low  levels (<400  p?t)  will




have chronic effects (Health Assessment Document, ^PA,




October, 1980).  In the present instance, however, the




Agency's overriding concern relates to  the fact  that




chlorinated fluorocarbons nay  indirectly  cause skin




cancer due to the depletion of  stratospheric  ozone.




Such depletion leads to increased intensity  of damaging




ultraviolet light at the earth's surface.  This,  in  turn,




leads to increased skin cancers, reduced  productivity of




several  important agricultural  crops and  increased

-------
mortality  in  the  larval forms of several important seafood




species.   The  fact  that these compounds are proposed to




be deleted  from  the  list of  toxic pollutants under




Section  307(a) of  the  Clean  Water Act does  not affect




our conclusion,  since  Section 307 does not  address




adverse  effects  arising from air exposure pathways.




     The Agency  has  analyzed the British Ministry of




the Environment  report  and has  concluded that  there are




few differences  in  regards  to the science of CFC transport




into the stratosphere  and  the reactions involving ozone




destruction between  this report and  a recent National




Academy  of  Sciences  report which provides the  basis for.




EPA's regulatory  action banning the  manufacturing,




processing and distribution  of  chlorinated  fluorocarbons




for those  non-essential aerosol propellant  uses  which




are subject to TSCA  authority (43 FR 11301,  March 17, 1978).




While the  British Ministry of the Environmental  report




concluded  that ample cause for  regulating CFCs  does




not presently  exist, the Agency strongly believes that




their is sufficient  evidence  to regulate and limit




chlorinated flurocarbon emissions.   In the  judgment of




SPA,  chlorinated  fluorocarbons  can be a significant




component of a solvent  waste  stream,  can migrate into




the environment (stratosphere)  if improperly managed,




are persistent (remaining intact  long enough to  migrate




tr> the stratosphere), and may pose a  substantial hazard

-------
   to human health and  the  environment.   They  thus  should

   be regulated as hazardous  wastes.V   We  also  note  that

   the Food and Drug Administration  (FDA) has  promulgated

   regulations which prohibit  the  use  of  chlorinated  fluro-

   carbons as propellants in  containers  for products  subject

   to the Federal Food, Drug,  and  Cosmetic  Act.

   One comraenter argued that  the  "T"  (toxic)  designation

   assigned to several  of the  waste  solvents  listed under

   F005, is ill-conceived in  light of  the information

   presented in the regulations and  in the  background

   documents; specifically, methanol,  toluene, methyl

   ethyl ketone, methyl isobutyl ketone,  pyriderie and

   carbon disulfide.  More  specifically  the commenter

   noted:

        Methanol -      this compound  is  not found to  be

                        carcinogenic, nutagenic or tera-

                        togenic

        Toluene -       this compound  is  shown not to  be

                        carcinogenic, mutagenlc nor  teratogenic

        Methyl Ethyl -  this compound  is  shown to have
          Ke tone
                        no chronic  toxicity

     Methyl Isobutyl -  this compound is shown to have
        Ketone
                        no chronic  toxicttv
It should be noted that the Office of Toxic Substances/
'J.S.  Environmental Protection Agency is currently considering
further regulation of chlorinated fluorocarbon production
and use.

-------
     Pyridine  -          this  compound is not carcinogenic




                         or  mutagenic  and the determination




                         of  teratogenicity is questionable




     Carbon  disulfide  -  this  compound is shown to have




                         no  chronic  toxicity




Therefore, the commenter  recommends  that these compounds




no longer be designated  as  toxic  wastes.




     The Agency  continues  to  believe  that all  of  these




spent solvents,  with  the  exception  of aethanol and methyl




isobutyl ketone  should continue  to  be listed as  toxic.




In reviewing the  data  available  in  the  record, the




Agency believes  that  there  is  sufficient evidence to




continue to  list  these solvents  as  "toxic"  wastes




(except for  methanol  and  methyl  isobutyl ketone).   As




explained in the  health  and environmental effects section




of the listing background document, "Waste  from usage  of




organic solvents" as  well as  the  respective  Appendix A




health profiles  for these compounds,  it  has  been  reported




that chronic low  level exposure  to  toluene  has caused




chromosome damage in humans and has led  to  the development




of neuro-rauscular disorders.   Toluene has  also been




reported to cause reproductive problems  to  female workers




during occupational exposure.




     Methyl ethyl ketone  (MEK), although only  moderately




toxic via ingestion, can  affect  the peripheral nervous




system and is an  experimental  teratogen.   In addition,




lethal doses  in animals caused narked congestion  of




the internal  organs and slight congestion of the  brain.

-------
       Chronic  exposure  to  pyridine  has  produced liver

  and kidney  damage  in both  animals  and  humans.,   In

  addition, small  doses  of  pyridine  have produced tremors

  and ataxia, irritation  of  the  respiratory  tract with

  asthmatic breathing and paralysis  of  the  eye  muscles,

  vocal cords and  bladder.

       Chronic  exposure  to  carbon  disulfide  can  affect the

  cardiovascular and central nervous  system,  causing

  personality changes.   In  addition,  exposure  to short

  terra, but high atmospheric concentrations  can  lead  to

  narcosis and  death.  Carbon disulfide  is also  suspected

  of being teratogenic.   Therefore,  these solvents  will

  continue to be listed as  toxic.

       The Agency, however, agrees with  the  comnenter  that

  both spent aethanol and methyl isobutyl ketone were  im-

  properly listed as toxic wastes.   Methanol's oral toxicity

  is rated as low_^/ and in  fact  is permitted  in  foods  for

  human consumption as an additive.   Methyl  isobutyl ketone's

  principal toxic effects appears  to  be  irritation  of  the

  eyes and mucous membranes, and gastrointestinal upset.

  Under these circumstances, we  do not be Have a toxicity

  listing for these solvents is  appropriate,  thus,  the

  Agency will no longer list spent aethanol  and  methyl

  isobutyl ketone as toxic wastes.   However,  both -nethanol

  and methyl isobutyl ketone are ignitable (flash points


Sax, V.  Irving.   Dangerous Properties of  Industrial
Materials.  5th  ed.  Van \ostrand  Reinhold Co.
New York.   1979

-------
of  54F  and  618F, respectively).  Thus  spent  methanol and




methyl  isobutyl ketone will continue  to  he  listed  as




ignltable  hazardous wastes.




One conmenter  criticized the Agency's determination




that  chlorobenzene, o-dichlorobenzene, methanol,  toluene,




methyl  ethyl  ketone,  nethyl isobutyl  ketone,  isobutanol




and ethyl  benzene are persistent and  do  not degrade




well.   The commenter  argued that this inclusion  is




contrary  to  the published literature, including  this




Agency's  own  studies, which shows that biodegradation is




the preferred  method  of treatment for these compounds




in  aqueous solutions.  The commenter  therefore,  believes




that  the  degradation  data within the  listing  background




document  should be  reviewed and properly assessed  In




listing.




     We note  initially that the comnenter's claims  are




largely unsubstantiated.   We note further that bio-




degradation plays a limited role in the  environmental




persistence of  the  waste  constituents because groundwater,




the exposure  pathway  of paramount concern,  is abiotic.




As  pointed out  In the listing  background document  (pp.




57-61), a number  of these solvents  have  migrated via




air and groundwater pathways,  and persisted for  long




oeriods of time,  and  caused substantial  hazard in  the




course of actual  waste management practice.   Thus,
                          -II-

-------
      chlorobenzene,  o-dichlorobenzene,  toluene and methyl

      ethyl  ketone have  all  been  detected in basement air,

      sump pumps  and/or  in  solid  surface samples in the Love

      Canal  area._*_/   All  of  these  solvents  (chlorobenzene,

      o-dichlorobenzene,  toluene  and  methyl  ethyl ketone) are

      thus deraonstrably  persistent  enough to have migrated

      from a disposal  site  and  contaminate  adjacent areas to

      create a substantial  hazard.

          In addition,  the  following  properties/character-

      istics of these  compounds indicate further the persis-

      tence  of these  solvents:**/

          chlorobenzene  -  this solvent  is  not  amenable to

               hydrolysis  nor  does it biodegrade very well

               and therefore is  expected to persist in the

               e nvironment.

            toluene -  this  solvent  is  persistent in abiotic

               environments  (such  as  most aquifers) and

               therefore is  expected  to persist in ground water.

               Toluene also  is relatively  soluble  (water

               solubility  470  mg/1 at 25C), and thus would

               be expected  to  migrate into  grovindwater.

          methyl ethyl ketone  -  this  solvent,  in addition to

               being  reported  at Love Canal, has been de-

               tected at several sites  near ground water
^*7Since methanol and methyl isobutyl ketone  are  no  longer  being
   considered toxic, a discussion on their  persistence  is  no
   longer appropriate.
*_*_/These data are all taken from the listing  background  document,
   "Waste from usage of orsanic solvents".

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                contaminated by an old chemical company dump,

                again showing migratory potential and per-

                sistence ._*/


           With  respect to isobutanol, the Agency has not

      made  any claim as to the 'persistenee of this compound;

      however, due  to its  toxicity and extremely high water

      solubility (water solubility 95.000 mg/1 at 18C), the

      Agency  believes that this solvent may pose a substantial

      hazard  to  human health and the  environment if  improperly

      managed.

           Finally,  ethyl  benzene  is  being listed because of

      its ignitability hazard, not toxicity.   As is  indicated

      in  the  regulations (261.21, 45 FR 33121-33122,  May 19,

      1980),  a liquid waste is considered ignitrable,  and

      therefore  hazardous, if it has  a flash  point less  than

      140F.  Consequently, the persistence of ethyl  benzene

      is  not  at  all  relevant.

           Therefore,  absent any information  provided  by the

      comraenter  on  the persistence and degradabi1ity  of  these

      solvents,  the  Agency finds no reason to c'iaage  its

      original conclusions.
*/Listing background  Document,  "Wastes  from  usage  of  organic
~ solvents", Section  IV.  B.  (Migratory  potential and  per-
  sistence of halogenated  and  non-halogenated  solvents)
  pg. 31.

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 6.    One  commanter  criticized  the  Agency's  conclusion,  as stated

      in the  listing  background  document,  that  "the  solubility of

      these  solvents  is  uniformly high  "  (LBD  pg.  3)  and "the

      solubility  in  water  of  these  halogenated  solvents  is

      quite  high"  (LRD pg.  14)  when in  fact, as  the  comnenter

      points  out,  their  solubilities  vary  from  10  to  20,000 mg/1

      (LBD pg.  55).   The comnenter  went on  to  argue  that the

      Agency's  determination  that "these high  solubilities

      demonstrate  a  strong  propensisty  to migrate  from inade-

      quate  land  disposal  facilities  in substantial concentrations'

      (LBD pg.  15) and "all of  these  waste solvents have sig-

      nificant  potential for  migration, nobility and  persistence..,

      (LBD pg.  52) is overstated when in fact, as  the commenter

      indicates,  migration, nobility  and persistence  differ  sig-

      nificantly  with respect to both routes of  transport  and

      rates  of  degredation.   Therefore, the commenter believes

      that the  Agency needs to reassess these listings.

          The  Agency agrees  with the commenter  that  the water

      solubilities of the chlorinated hydrocarbons do vary

      considerably.  However, in re-evaluating the data, the

      Agency believes that  the solubilities oc all of these

      solvents  except 1 ,1,2-1richloro-l,2,2-trifluoroe thane

      are generally high and  do  indeed  indicate  a  potential

      for migration from inadequate land disposal  facilities.*/
^/Although the water solubility for trichlorofluoromethane
  is high, the principal concern with this solvent  is  its
  potential to rise to the stratosphere where it may release
  chlorine atoms and deplete the ozone.

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The Agency  recognizes  that  solubility is  not  the sole




parameter which  determines  the  potential  of  a  substance




to migrate  into  the  environment,  i.e.,  mobility  and




persistence  also  play  a  role.   However,  it  is  a  key




parameter in  evaluating  how likely  these  substances




are to migrate from  land  disposal  facilities.   Indeed,




this potential to  migrate has been  demonstrated  for all




of these solvents, except methylene  chloride,  in actual




damage cases, i.e.,  tetrachloroethylene,  trichloroethylene,




1i11-trichloroethane ,  chlorobenzene  and  o-dichlorobenzene




have all been detected  to migrate  at  Love  Canal  or  other




disposal facilities.   Methylene  chloride,  although  not




detected at  any  disposal  facilities,  is highly soluble




with a water  solubility  of  20,000 mg/1 at  25C,  and thus




has the potential  to migrate  from disposal sites and  create




a problem.    However, the  Agency has modified the  listing




background documents as  to  the  solubilities of these




solvents to better reflect  the  Agency's conclusions.




     With respect  to the  solvent 1,1 , 2-trichloro-l,7,2-




trifluoroethane,  the Agency has indicated clearly  that




the potential to migrate  and  contaminate  groundwater  is




not of concern.   The primary hazard posed by the mis-




management  of this solvent, as  with all chlorinated




fluorocarbons, is  the  potential to  rise to the stratos-




phere  and indirectly cause  skin cancer due to the

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     depletion of  stratospheric  ozone^/  (see  Response to

     Comments No.  3  of  this  document  for  a  more  detailed

     discussion) .

          The Agency  also  agrees  that  its conclusions regarding

     migration,  nobility aid  persistence  are  overstated.

     Therefore,  the  listing  background documents  have been

     changed to  reflect the  Agency's  determination  that,

     while the various  chlorinated  solvents do differ in

     their migratory  potential, nobility  and  persistence,

     they all may  pose  a substantial  present  or  potential

     hazard to human  health  and the environment,  if  improperly

     managed, when considering the  routes and rates  of  transport

     and degrees and  rates of degradation.

7.   One cominenter believed  that  the  Agency's decision  to

     include trichloroethylene on the list of chemicals which

     have demonstrated  substantial  evidence of carcinogenicity

     was inaccurate.   The comraenter indicated that according

     to Elizabeth Weisberger of the National  Institute  of

     Health,  whose organization did the original  studies which

     classified trichloroethylene as a "merely suspicious

     carcinogen", indicated that  "trichloroethylene  seens

     not to be a carcinogen."  The  comnenter  also argued

     that nore extensive and recent researc'-i  indicates  that
*yi,l,2-'trichloro-l,2,2-trifluoroethane is considered  to be
  extreraently volatile (vapor pressure - 270 mm of Hg  at 208C),
  and thus is likely to rise into the atmosphere.

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     trichloroethylene may  not  be  carcinogenic  after  all.

          The Agency disagreees with  the commenter.   Trichloro-

     ethylene has been designated  carcinogenic  by EPA's  Cancer

     Assessment Group (CAG) after  reviewing the available data

     in the literature.   In fact,  before a chemical compound

     is deemed carcinogenic by  CAG, it is subject to  ex-

     haustive literature  study  and evaluation.  In light of

     CAG's determination, EPA will continue to  include tri-

     chloroethylene as a  chemical  which has demonstrated

     substantial evidence of carcinogenicity.

8.    One commenter questioned the  Agency's characterization

     of 1,1,1-trichloroe thane as a suspect carcinogen.  The

     comnenter argued that  1 , 1,1-trichloroethane has  not been

     found to be a carcinogen.  They quote the  MCI Bioassay

     of 1,1,1-Trichloroethane for  Possible Carcinogenicity

     (January 1977),  which states:

          "A  variety of neoplasms  were represented in both
          1,1,1-trichloroethane treated and matched-control
          rats  or mice.  However,  each type of neoplasm has
          been  encountered previously as  a lesion in untreated
          rats  or mice.  The neoplasms observed are not be-
          lieved attributable to 1 , 1 ,1-trichloroe thane expo-
          sure,  since no relationship was established between
          the dosage  groups, the species, sex, type of neoplasm
          or  the site of occurence.  Even if  such a relation-
          ship  were  infered, it would  be  inappropriate to
          make  an assessment of careinogenicity on the basis
          of  this test,  because the abbreviated life spans
          of  the rats and the nice."


     The  commenter also argued that EPA's own  Office of Drinking

     Water, in  their  appendices to Planning Workshops to
                               -97-

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Development Recommendations for  a  Groundwater  Protection




Strategy, state that methyl chloroform  (1,1,1-trichloro-




ethane)  Is not considered  to be  a  carcinogen  (June  1980).




Therefore, the comraenter believes  chat  there  is  no  support




for the  carcinogenicity of 1,1,I-trichloroethane  and




argues that it be deleted  from all lists  of hazardous




was tes .




     The Agency disagrees  with the commenter's claim.




Although the MCI Bioassay  Study  on the carcinogenicity




of 1 ,1 , 1-trichloroethane referred  to in  the listing




background document (pg. 464) and an unpublished  study




are inconclusive, positive responses in  two in vitro




systems  (a rat embryo cell transformation assay (Price




et. al.  1978, Transforming Activities of Trichloroethane




and Proposed Industrial Alternatives.  In .vitro.  14:290.)




and a bacterial mutation assay (Simmon et. al. 1977.




Mutagenic activity of chemicals  identified in drinking




water, In t Progress in Genetic Toxicology, ed. I.D. Scott,




B. A.  Bridges and F.  H. Sobels,  pp. 249-253; McCann, J.




and B. Ames, 1976.  Detection of  carcinogens as mutagens




in the Salmonella raicrosome test: Assay of 300 chemicals.




Proc.  Nat. Acad.  Sci. 78:950.))  currently used to detect




chemical  carcinogens, indicate that 1,1,1-trichloroethane




has the potential for carcinogenicity in animals  (App.  A).




Additionally, a two year carcinogenesis animal bioassay

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      is  being repeated at the National Cancer Institute.

      Therefore,  the Agency believes that there is ample

      evidence to consider 1,1,1-trichloroethane as a suspect

      carcinogen*/,  and thus  will continue to include

      1,1,1-trichloroethane as a constituent of concern.

 9.    One  comraenter  also argued that the statements in the

      background  document that "methylene chloride is reported

      as  being nutagenic to a bacterial strain, S. typhimurium",

      and  "methylene chloride...  is highly mutagenic" are

      inaccurate.   The  commenter  pointed out that  a variety

      of  more  detailed  tests  performed  subsequently and  not

      cited  in the  listing background  document  prove  otherwise.

      For  example, a definitive cell transformation test for

      methylene chloride was  found  negative.   Additionally,

      many other  tests  have been  run for carcinogenicity of

      methylene chloride with negative  results.

          The Agency agrees.  The  current  assessment  on the

      carcinogenicity of raethylene  chloride  is  only based  on

      animal experiments which  are  so  far  incomplete.  How-

      ever, methylene chloride  is the subject  of an NCT  spon-

      sored bioassay.   In  addition,  EPA has  found  "suggestive"

      evidence of the carcinogenicity of  nethylene  chloride
*/It should be noted  that  the  Agency  recently  determined  to
~ retain the listing  of  1,1,1-trichloroethane  as  a  toxic  pollu-
  tant under 307(a)  of  the  Clean Water Act.   The reasons  for
  that action are incorporated  by reference herein.

-------
     (App.  A).  The Agency cannot ignore this  information.




     Therefore, the listing background document  will  be




     revised to indicate that aethylene chloride  is only  a




     "suspect" carcinogen.




10.   One commenter questioned the Agency's characterization




     of tetrachloroethylene, m-ethylene chloride,  trichloro-




     ethylene and 1,1,1-trichloroe thane as aquatically  toxic.




     The comnenter indicated that statements relative to




     methylene chloride li'ce ''acute toxicity values range




     from 147,000 to  310,000 mg/1 (correct units  are  ug./l)




     for aquatic organisms" are meaningless until put into




     relative significance.  When compared with most  common




     nonhalogenatad solvents,  the commenter argues, the halo-




     genated solvents were less toxic  to the tested fish specie's.




     In addition, the commenter pointed out that  EPA,  in fact,




     concurs with this  viewpoint  by  stating,  "aquatic  organisms




     tend to be fairly  resistent  to  dichlororne thane (methylene




     chloride),  with  acute values ranging  from 193,000 to 331,000




     ug/1 (EPA BD 38  at 389).   Therefore,  the commenter believes




     that EPA has not properly  assessed the relatively low




     aquatic toxicities of these  halogenated  solvents.




          In re-evaluating the  aquatic toxicity of tetrachloro-




     ethylene,  nethylane  chloride,  trichloroethylene ani .1,1,1-




     trichloroethane,  the  Agency  agrees with  the  commenter that




     all  four of  these  halogenated  solvents are not of regu-




     latory  concern under  the hazardous waste program  to
                                - IQO-

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     warrant characterization  as  "aquatically  toxic."   In




     the Registry of Toxic  Effects  (1975  Edition),  a  widely




     used reference book  which  is  published  by  the  National




     Institute  for Occupational  Safety  and Health  (NIOSH>,




     a rating of the aquatic  toxicity or  non-toxicity  of




     chetnical substances  if  provided.   In this  rating,




     substances with an LC50  value  of between  10,000 ug/1




     to 100.000 ug/1 is considered  slightly  toxic  while




     substances with an LC5Q  value  above  100,000 ug/1  is




     practically non-toxic.   Based  upon this rating, raethylene




     chloride is practically  non-toxic  while the other halo-




     genated solvents are slightly  toxic.  Therefore,  the




     Agency will modify the  listing background  document to




     reflect this change.   However, it  should be noted that




     toxic wastes are not so  designated solely  on  the  basis




     of their aquatic toxicity.   \s discussed earlier, all




     of these halogenated solvents  exhibit other toxic effects




     i.e., carcinogenicity,  chronic toxicity, etc.  which




     are sufficient to warrant designation of these solvents




     as toxic.




11.   One comnenter also argued that the Agency  has misinter-




     preted and overstated  the bioaccumulation  potential for




     both the halogenated and  non-halogenated solvents.




     arguing that most of these  solvents have a low bioaccunu-




     lation potential.  In  particular,  the connenter believes




     that the Agency has  shown a lack of perspective by

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concluding that,  " . . .methanol  could  bioaccumulate




causing numerous  adverse health  effects  from  prolonged




ind/or repeated exposure"  (EPA 3D-11  at  59),  despite




its reported very  low Kow  of 5 and  readily biodegradable.




Therefore, the comnenter believes  that  the bioaccumulation




data should be reviewed a'nd properly  assessed in  listing.




     As discussed  in the preamble  to  Part  261 of  the




hazardous waste regulations (45  FR  33105-33107),  the




Agency in listing  wastes for which  a  characteristic




has not been developed has adopted a  flexible, multiple




factor approach to be better able  to  accommodate  itself




to the complex determinations  of hazard.   These multiple




factors include the type of toxic  threat posed, the




concentrations of  the toxic constituents in the waste,




the migratory potential, persistence  and degradation




of the toxic constituents,  the degree to which the




toxic constituents bioaccumulate in ecosystems, the




plausible types of improper management to  whic'h the




waste could be subjected,  the  quantities of waste




generated, and other factors not explicitly designated




by the Act.  Thus, if a substance exhibits one or




more of these properties,  the  Agency may list the waste




as hazardous.  The bioaccumulation potential  of a sub-




stance is not considered by the Agency as  a necessary




factor before a waste can be listed.  Therefore, just




because a chemical substances  is not bioaccuraulativa
                           -/oa-

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     is  no  reason not to list a waste.




          With respect to the comraenter's claim for methanol,




     the  Agency is no longer listing this solvent for toxicity,




     but  for ignitability.  Bioaccumulative propensity of




     this compound thus is no longer relevant.




12.   One  commenter cited some inconsistencies/errors in the




     listing background documents and suggested that the




     Agency make the appropriate revisions.




          The Agency agrees.  There were some typographical




     and  transcription errors, e.g., in the methylene chloride




     background document, as well as sone judgmental errors.




     Therefore, within the limits of its resources,  the




     Agency has made every effort to correct such errors.




13.   One  comraenter criticized the Agency's conclusion as




     stated in the listing background document that, "the




     chlorinated waste hydrocarbons are toxic" (EPA BD-11




     at  3)  when in fact, as the commenter points out, that




     the  oral-rat LC5Q values vary by several orders of




     magnitude.  Therefore, the comraenter believes that the




     listing of these halogenated solvents are not fully




     warranted in all cases.



          The Agency strongly disagrees with the commenters




     unsubstantiated claim.  As discussed in the preamble




     to  the May 19,  1980 hazardous waste regulations (45




     FR  33107), the  Agency listed a number of toxic wastes

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     as  those "which have been shown  inreputable  scientific

     studies  to have toxic, carcinogenic,  mutagenic  or

     teratogenic effects on humans  or  other  life  forms."

     Toxicity is defined to include systemic  effects of

     chronic  low level exposure, acutely  toxic^/,  aquatic

     toxicity,  phytotoxicity or the potential (as  with chlori-

     nated fluorocarbons) for indirectly  causing  harm to

     human health or other life forms.  Therefore,  a substance

     with a high LC^Q value is not  necessarily  non-toxic.

          In  reviewing the data available  in  the  r ecord**/ ,

     the Agency is convinced that these substances  are properly

     designated as toxic, and that  improper  management and

     disposal of these waste solvents  may  pose  a  substantial

     present  or potential hazard to human  health  and the

     environment.  Since the comrnenter failed  to  provide

     additional toxicity data except as discussed  in other

     parts to this section, the Agency finds  no reason to

     change its original conclusion to list  these  solvents

     as  toxic wastes.
 ^/Acutely toxic does not include  those wastes  which  are defined
   in 251 . 11(a)(2) as acutely hazardous.

^/Appendix  A (Health and Environmental Effects  Profiles)  out-
   lines  the health and environmental effects exhibited  by
   each of these compounds.

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             ADDENDUM TO SOLVENTS BACKGROUND DOCUMENT


I.  Responses To Public Comments On Proposed Solvent Mixture
    Rule

A.  Renumbering of the F001 through F005 Spent Solvent Listings

     Several comments have been received regarding the proposal

to renumber the list of solvents by deleting F002, F003, F004,

and F005 and modifying F001 to include all the solvents formerly

listed in F001 through F005.  Some commenters requested that the

Agency, if renumbering the listings, should distinguish between

halogenated and non-halogenated solvents.  The reasons for the

distinction were that non-halogenated solvents usually are burned

as fuel, incinerated, or reclaimed on-site, while halogenated

solvents primarily are reclaimed on-site and then reused by the

generator.  In addition, the environmental impacts posed by

halogenated and non-halogenated solvents are somewhat different

(for example, biodegradation).  These commenters suggested that

we assign two new waste codes to distinguish halogenated from

non-halogenated solvents.  Alternatively, one commenter suggested

that the Agency renumber the solvents listings into three codes:

halogenated, non-halogenated, and ignitable non-halogenated

solvents.   This commenter believed that using the three codes

will facilitate source separation by generators and, therefore,

lead to environmentally sound treatment, disposal, and recycling

of solvent wastes.

     Other commenters requested that the F001 through F005

waste codes remain as originally listed, but with the addition

of solvent mixtures at 10% or greater to each code.  These

commenters believed that the five categories should be retained

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because the solvent groups require different treatment,  recycling



and handling processes and procedures, and one single classification



number would make the differentiation between the solvents



difficult.




     The following are other specific concerns mentioned by the



various commenters on the issue of renumbering:




       One commenter stated that renumbering would increase the



       cost of compliance for recyclers,  transporters,  etc.,



       due to the cost of re-labeling containers, retraining



       hazardous waste workers, and revising hazardous  waste



       management plans.



     " Three commenters stated that the renumbering would cause



       confusion in future paperwork (i.e.,  annual reporting



       data manifests, transportation and storage logs),  when



       evaluated and compared with past documents.  In  particular,



       one commenter stated that there may be possible



       inconsistancies with the new single waste code and the



       DOT manifest requirements and the manner in which solvents



       are segregated for recycling (i.e., halogenated,  non-



       halogenated, and ignitable solvents are managed




       differently).



      One commenter stated that renumbering would require



       facilities to perform massive waste characterization



       analyses when undergoing delisting and closure procedures.



       The comraenter noted an example where this might  occur.

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  In some instances,  generators are being required  to
  perform analyses for every constituent in a waste code
  reported at their facility.  Under the single  combined
  waste code, F001, the facility would have to test for
  all 27 solvents, whereas before they may have  only tested
  for five.
0 Three commenters were concerned that the distinction of
  the solvent's hazards would be lost if all the solvents
  were combined into a single waste code,  rendering the
  reporting, handling, etc., of the ignitables and  toxic
  solvents undifferentiated.  For example,  in handling
  these chemicals, the workers would not know if a  particular
  waste was toxic (i.e., carbon disulfide is harmful to
  human skin) or ignitable (i.e., acetone).
 One commenter requested that the F004 solvents be
  separated from the single F001 waste code because of
  their corrosivity to human skin.  These solvents  require
  careful handling and worker training.
 A few comraenters stated that the single combined  F001
  code would cause confusion due to past use of  the F001
  number. The new F001 code, which would list all 27 spent
  solvents, might be confused with the present F001 code,
  which lists only six solvents.  Computer data  systems of
  hazardous waste manifests is an instance where confusion
  between the two definitions of the F001 code may  appear.

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       One commenter stated that many TSDs are "permitted" only



       for chlorinated solvents (F001 and F002).   If all 27



       solvents were grouped into a single waste code, these



       facilities would be forced either to become properly



       equipped to store and to handle ignitable solvents or to



       upgrade their waste anaylsis plans and laboratory capabi-



       lities to determine whether incoming wastes may be



       accepted at their facility.



     * One commenter requested that if ignitable solvents are



       to remain in the hazardous waste listing as spent solvent



       wastes, they should be categorized under a separate



       hazardous waste number.  "Toxic" solvents  then could be



       easily distinguished from ignitable solvents.





Agency Response:



     In considering the renumbering of the solvent listings,



the Agency has concluded that renumbering may, in fact, increase



compliance costs and cause confusion (i.e., re-labeling of



containers, confusion for transporters and others handling the



wastes, different management and handling practices for



halogenated solvents, and confusion in record keeping because



of past F001-F005 designation).  Therefore, we are retaining the



existing hazardous waste numbers.





B.  Process Wastes Containing Solvents



     Two comraenters requested that the Agency delete the term



"spent solvents" from the proposed rule.  These ccmmenters felt

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that by limiting the mixture rule to the F001 through F005 spent



solvent wastes, the Agency would be excluding a large universe



of wastes, such as process wastes containing significant quantities



of solvents.  The commenters asserted that the exclusion of



process wastes leads to enforcement difficulties.  They pointed



out that there is little difference in toxicity between solvent



wastes which are spent or discarded after use, and process wastes



containing solvents.




     * The coramenters stated that from an enforcement standpoint,



       it may not be possible to determine if a mixed solvent waste



       originally was generated as a spent solvent or as a process



       waste.  A generator claiming that their spent solvent mixture



       is a manufacturing process waste could avoid regulation.



       One of the comraenters asserted that industry has used



       this reasoning in past land disposal practices.



     * On the other hand, several commenters requested that the



       proposed rule not apply to waste products in which solvents



       were used as carriers for active ingredients.  The commenters



       stated that these waste quantities per container are usually



       small and are equivalent to household wastes.  Therefore,



       the comraenters requested that these wastes not be included




       in the rule.




Agency Response:



     The intent of the proposed solvent mixture rule is to close



a regulatory loophole in the 261.31 spent solvent  listings, in

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which spent solvent mjxtures currently are unregulated as hazardous
wastes.  The Agency agrees with the first commenters that many
process wastes, including those containing solvents and solvent
mixtures, are erroneously unregulated.  However, there are also
some process wastes which should be excluded from the regulations
because of the low concentration of hazardous chemicals or their
low toxicity.
     The Agency has not developed health-based standards or
regulatory thesholds for all of the listed solvents.  The level
set by today's rule is an interim measure, and may be modified
or superceded when work on the Toxicity Characteristic is
completed.
C.  Applicability of the Ten Percent Threshold Level for
    Solvent Mixtures
     Several comments have been received concerning the 10%
threshold level for solvent mixtures.  Comments are as follows:
      One commenter suggested that the threshold level should
       be lowered to 1% to place tighter controls on these
       wastes.  This commenter stated that the lower threshold
       level would be more protective in prohibiting these
       solvent mixtures from sanitary landfills, because they
       now would be considered hazardous wastes.  At 1%, the
       solvent mixtures would be less likely to mobilize other
       wastes from land disposal facilities.  The 1% level is
       based on the 1979 EPA Draft Ambient Water Criteria.  The

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  commenter further stated that the original  background



  document for listing solvents and the  Drinking  Water



  Criteria promulgated in November 1980,  provide  data  for



  establishing health-based thresholds  for  solvent  mixtures.



  One commenter similarily stated that  the  level  should  be



  5000 ppm since this is more  protective  of human health



  and the environment.  The 5000 ppm level  coincides with



  the State of Connecticut's proposed waste oil regulations



  for hazardous constituents added to waste oil.  The 5000



  ppm level is said to be protective of human health and



  the environment for burning  waste oil  containing  solvents.



*  Three commmenters expressed  concern that  the 10%  threshold



  level will not adequately protect human health  and the



  environment.  One stated that the Agency  should not



  exclude mixtures which are at concentrations below 10%,



  because their toxicities are still orders of magnitude



  higher than the levels considered safe  for  human  health



  and the environment.  Another commenter mentioned that the



  10% level is adequate for an interim  measure, but not



  for a final one.  The commenter requested that  the new



  hazardous waste characteristic be based on  toxicity and



  that it set levels which will preempt  the 10% level if



  necessary to protect human health and  the environment.

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       The third commenter was concerned that many of the wastes



       impacting the environment contain solvents at concentrations



       much lower than the 10% level.



       One commenter stated that many persons in the regulated



       community, the EPA, and the States interprete the F001-F005



       solvent listings to include solvent mixtures at all con-



       centrations.  The  commenter was concerned that by specifying



       a threshold level  for solvent mixtures, the effect will



       be a relaxation of the regulations.



      One commenter stated that the 10% threshold level may



       bring into regulation wastes containing de minimis



       concentrations of  solvents.  The commenter recommended



       that the 10% level apply to only the concentration of



       an individual solvent in a solvent mixture, rather



       than the total concentration of all the solvents in



       the mixture.





     Agency Response:



     In establishing the  threshold for solvents, the Agency was



unable to define the concentrations at which solvent mixtures



are considered hazardous  waste.  At this time, the Agency has not



developed health-based thresholds for all of the 27 listed solvents.



Nor does the listing background document identify levels at



which solvent mixtures would be considered hazardous waste.  The



Agency, therefore, expanded the universe of wastes considered



"spent solvents" to include those solvent mixtures commonly used





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as industrial solvents.  The ten percent threshold level will



bring the majority of these wastes into the hazardous waste



management system.  This threshold level is not intended to define



the concentration at which these mixtures are considered hazardous,



rather, it defines the concentration at which these wastes are



considered spent solvents.  The level applies to the total concent-



ration of listed solvents  (before use) in the mixture,  and not



simply the concentration of a single solvent in the mixture.



The Agency is concerned with the total solvent effect of the



mixture.  Whereas a single solvent at low concentrations may not



be hazardous, the Agency is concerned with possible hazardous



additive effects the solvent might exhibit when in combination



with other solvents in a mixture.  The Agency is expanding the



EP Toxicity Characteristic to establish maximum permissible



concentrations for solvents.  These thresholds will override



the 10% level for solvent mixtures, in part, and bring  many



wastes containing solvents (including process wastes) into the



hazardous waste management system.



     The Agency believes that the proposed rule will not result



in a relaxation of regulation because solvent mixtures  used in



commerce generally contain greater than ten percent solvent.



The rule will cover many of these mixtures.  Data show that



solvent mixtures often contain greater than fifty percent solvent.



Specifically, the Agency believes that solvent formulators cannot



successfully reformulate below the ten percent level and retain



the desired characteristics of solvent mixtures.

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The EPA believes if the regulation is extended down below the


10% level, dilute mixtures or office type cleaning products will


be brought into the system.  This is not the intent of the Agency.


D.  Clarification of Scope and the Definition of the Rule


     Several comraenters requested clarification of the scope of


the rule and definitions of certain phrases used in the rule.


     ' One conunenter stated that the new F001 spent solvent


       listing is confusing and should be reworded.  As currently


       written, the rule may be interpreted such that the 10%


       threshold applies to both the individual spent solvents


       and the spent solvent mixtures.  The commenter recommends


       that a comma be inserted after the first use of the term


       "spent solvents."


Agency Response:


     The Agency agrees with the commenter and will redraft the


rule to clarify the scope of the listing.
 \


     * Another commenter requested that the 10% threshold also


       should apply to still bottoms from the recovery of solvents


       and solvent mixtures.  The commenter stated that still


       bottoms containing less than 10% solvent should not be


       considered hazardous if the individual solvents and solvent


       mixtures are not hazardous below 10%.


Agency Response:

     The commenter has misinterpreted the proposed rule.  As


discussed in the preamble to the final rule, the regulation will



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list as hazardous wastes certain spent solvent mixtures  which
contained, before use, ten percent or more of the solvents listed
for toxicity.  The ten percent threshold does not define the
concentration at which these wastes are hazardous.  (Agency data
show that solvents maybe hazardous at concentrations  below ten
percent).  Rather, it specifies a concentration low enough to
bring the majority of commonly used toxic solvents into  the
hazardous waste management system.  The preamble states  that
these mixtures typically and frequently contain 50 percent or
greater total listed solvents.  In many cases, solvent mixtures
contain 100 percent total solvent.  Since Agency data show that
still bottoms from the recovery of these solvents may contain up
to 15 percent solvents, we are including these wastes under the
listing.
     0 One commenter requested clarification of the terms
       "non-solvent constituents" and "any other combination
       that includes a listed solvent."
Agency Response:
     In defining solvent mixtures, the Agency intended the
listing to cover mixtures that are considered solvents but
contain non-solvent constituents such as pigments (which impart
desired product color), preservatives (to enhance shelf  life), or
any other additives.  Thus, the Agency included the terms "non-
solvent constituents" and "any other combination that includes
a listed solvents."
      One commenter requested that the phrase "used  in  degreasing"
       not be deleted from the F001 listing.  The commenter felt
       that the deletion was unnecessary and unsubstantiated.
                             11

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       In addition, the commenter felt that the deletion would



       add confusion to waste characterization.  The commenter



       contended that a paint waste containing a solvent mixture



       at or above 10% would be wrongly classified as a  listed



       F001 waste.



Agency Response:




     In the proposed rule, the Agency deleted the phrase "used



in degreasing" as part of the renumbering issue.  Thus,  the



qualifying phrase of each waste code had to be deleted in order



for the single F001 code to apply to all the listed solvents.



Since the Agency has retained the existing solvent listings,



the phrase "used in degreasing" will remain in the F001  solvent



listing.



E. Effective Date



     Several comments were received regarding the "effective



immediately" provision of the rule.  One commenter stated that



the provision was appropriate, however the majority stated



that industry needs time to comply with the new rule.  The



reasons cited for allowing lead time were:






      Some companies will need time to determine whether their



       waste will be a newly-regulated hazardous waste under  the




       solvent mixture rule.



      Companies who were generating solvent mixtures, but were



       not previously regulating them as hazardous will need



       time to come into compliance.  For example, these companies



       may need to design and build hazardous waste storage and






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        processing  equipment.   In addition,  company  personnel
        need to be  trained in  hazardous  waste management.
        The  proposed  effective date would  severly  stress smaller
        companies.
      0  EPA's  justification that  few generators will be newly
        regulated does  not justify an immediate date.  These
        generators  should be given the necessary time to implement
        proper waste  management as a  result  of this rule.
      *  The  Agency  has  not  presented  a convincing argument for the
        immediate effective date.
      *  One  conunenter suggested that  a 60  day period after promul-
        gation would  be sufficient time  for  the generators to
        come into compliance.  Two commenters suggested that the
        usual  six month advance notice be  applied to the solvent
        mixture rule.
Agency  Response:
     On January 11,  1985,  the Agency  proposed to regulate hazardous
waste and used oil burned  for energy  recovery in boilers and
industrial  furnaces  (see  50 PR at 1684).  These rules, signed
November 8, 1985,  prohibit burning in non-industrial boilers of
hazardous waste, including used  oils  adulterated by mixing with
spent chlorinated  solvents.   The  Agency believes a substantial
loophole will  be created  if mixtures  containing chlorinated
solvents remain unregulated when  these new  rules become effective.
Generators  may continue to  commingle  these  solvents with waste
oils destined  for  energy recovery.  Based on the toxicity of

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chlorinated compounds, the Agency is concerned with possible



adverse health effects posed by the burning of these wastes.  In



view of these concerns, we believe it imperative to bring these



wastes into the hazardous waste management system before the



annual demands for heating oil peak.



F.  Volume vs. Weight



       One comment was received concerning EPA's decision to use



       volume rather than weight as the determining parameter for



       solvent amounts.  The commenter was concerned that Material



       Safety Data Sheet information is expressed in terms of weight



       percentage and that laboratory analysis results are often



       reported in terms of weight per volume or weight per



       weight.  They recommended changing the parameter from



       "volume" to "weight".



Agency Response:



     The majority of the commenters did not dispute the use of



volume rather than weight in the proposed rule.  The spent



solvent wastes are primarily liquids or watery sludges (slurries).



Thus, the Agency felt that it would be easier to determine the



spent solvent concentration by volume.  In addition, the Agency



has contacted chemical companies to determine how the constituents



of mixtures are reported on the Material Safety Data Sheet  (by volume



or weight).  The answers received indicated that both systems



are used.  However, since most commercial solvent products are
                             14

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 expressed in terms of  volume, the Agency is  expressing solvent



 mixtures  in terms  of volume.






 G.   Regulation of  Ignitable Solvents - F003



      In the proposed rule, the Agency requested comments



 concerning the ignitability listing for solvents.  The majority



 of  the  comments were in  favor of eliminating the list of ignitable



 solvents  (F003) for the  following reasons:






        the listing is  duplicative and unnecessary



        ignitables  are  considered "hazardous waste" under the



        "characteristic of ignitability"



      0  the F001-F005 numbers should be reserved for solvents



        that are toxic



      *  One commenter favored maintaining the ignitability listing.



        This commenter  felt that small facilities would be less



        likely to have  access to flash-point testing.  These



        facilities  needed the ignitability listing maintained for



        waste classification reasons.




Agency  Response:



     The  Agency has  decided to retain the ignitable solvents in



the  list  of hazardous  wastes.  Although the commenters are correct



that these  spent solvents would be caught by the ignitability



characteristic,  these  solvents are likely to contain other



toxic contaminants.  In  fact, spent solvents become spent when



they have been  contaminated with other materials (i. e. , toxic




heavy metals, toxic  organic compounds) and must be disposed,



reprocessed, or reclaimed.  If we were to remove these solvents




                              15

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from the list of hazardous wastes, we believe such action would
conflict with the spirit of one of the new requirements under the
Hazardous and Solid Waste Amendments of 1984.  In particular,
under Section 222 of HSWA, the Administrator is required, in
evaluating delisting petitions to consider factors (including
additional constituents) other than those for which the waste
was originally listedif there is a reasonable basis to believe
that the waste may still be hazardous.  (See 50 FR 28742, July
15, 1985.)  Although this provision discusses site-specific
delisting petitions, we believe that it is consistent with this
provision to make the same finding for generic delisting as
well, since such action ordinarily has far more potential impacts
on the environment than a site specific listing.  Thus, since the
spent solvents are likely to contain other toxicants at levels
of regulatory concern, and since we have not evaluated those
wastes for these other toxicants, we believe it is inapprop-
riate to remove these solvents from the hazardous waste list.
Rather, persons who wish to delist those wastes will need to
submit a delisting petition, pursuant to 40 CFR  260.20 and
 260.22, to exclude the waste from the hazardous waste category.
     One commenter also asked whether the ten percent used to
define solvent mixtures includes  solvents listed for ignitability
only (F003).
Agency Response:
     Since we have not evaluated  these (F003) solvents  for their

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toxicity, then  ten percent threshold does  not apply.  The  final
rule  reflects this.

H.  Affect  of Solvents  on Liners
        One  comment concerned the statement in the preamble whdch
        said "since solvents are known to degrade synthetic and
        clay landfill  liners, these toxic constituents, once
        mobilized may  readily migrate to ground water."  The
        commenter requested that the Agency mention other studies
        which indicate that dilute solvents and solvent mixtures
        do not degrade clay liners.
Agency  Response:
      The adverse effects of concentrated solvents on synthetic
and natural liners generally is accepted (Haxo e_t al. 1985;
Lord  et al.  1985; Van Schaik,  1974; Schram, 1981; Anderson and
Jones,  1983.).  The adverse effect of dilute solvents and their
mixtures is less widely accepted.  The effect of solvents on
synthetic liners was  shown in  a study where toluene at 5000 ppm
was mixed in water and  exposed to a high density polyethylene
liner.  The toluene mixture permeated through the liner at 2
gm/m2/day-   (Surprenant et al., 1984.)  The Agency acknowledges
that  several studies  indicate  little or no effect on natural
liners.  But, these studies were conducted over a short-term
period  (i.e., Daniel  and Liljestrand, 1984).  The Agency is
concerned that  in the long-term (years) exposure to dilute solvent
mixtures may degrade  natural liners.  Some studies indicate
mechanisms  by which dilute solvents could  form into concentrated

solvents so that adverse effects occur (Artiola et_ a_l. , 1985;
                               17

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Anderson and Brown, 1983).  The Agency acknowledges that there



is not sufficient information available to predict the effect on



soil liners from long-term exposure to dilute solutions and that



additional research is needed.



I.  Human Health Effects



     * One commenter stated that the rule indicates that all



       spent solvents pose carcinogenic,  mutagenic, terato-



       genic, and neurotoxic health risks.  The commenter



       asserts that at least two of the solvents, trichloroethylene



       and tetrachloroethylene, have been re-evaluated such that



       they are not probable human carcinogens. The commenter



       felt that the revisions should be incorporated into the



       development of health-based thresholds.






Agency Response:



     The rule does not specify that all of the 27 listed solvents



pose these health risks.  The preamble clearly states that "many



(solvents) are known carcinogens, teratogens, mutagens, or neuro-



toxins.  Others are associated with acute and chronic adverse



health effects."  Data from a recent NTP bioassay, however,



indicate that tetrachlorethylene is carcinogenic  (National Toxicology



Program, August 1985).  Trichloroethylene is also a known human




carcinogen.
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J.  PCB-containing Wastes


     One comraenter requested that EPA exempt from regulation


electrical equipment fluids which contain PCBs and any of the


the listed solvents.


Agency response:

                             IT")
     The commenter has misintapreted the proposed rule and the


spent solvent  listings.  PCB transformer fluids (i.e., dielectric


fluids containing PCBs and tetrachlorobenzene) are not covered


under the current hazardous waste regulations.  Tetrachlorobenzene


is not a listed hazardous waste.  (Monochlorobenzene is covered


under the listing.)  Furthermore, dilectric fluids are not considered


"spent solvents" and, as such, are not regulated under RCRA.  At


this time, PCBs are regulated under the Toxic Substances Control


Act.
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