NEIC
         EPA-33012-90-036
         MULTI-MEDIA COMPLIANCE INVESTIGATION '
         ATLANTIC RESEARCH CORPORATION
         Gainesville, Virginia
         July 1990
                                       i *
       National Enforcement Investigations Center, Denver
O.S. Environmental Protection Agency
                                     Office of Enforcement

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  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
               OFFICE OF ENFORCEMENT
EPA-33012-90-036

MULTI-MEDIA COMPLIANCE INVESTIGATION
ATLANTIC RESEARCH CORPORATION
Gainesville, Virginia

July 1990
Eugene Lubieniecki, Jr.
Joe Funk
   NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
                    Denver, Colorado

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                         CONTENTS


EXECUTIVE SUMMARY

INTRODUCTION	1

     OBJECTIVES	1
     BACKGROUND	3

SUMMARY OF FINDINGS AND CONCLUSIONS	5

     RESOURCE CONSERVATION AND RECOVERY ACT	5

          Generator Standards	5
          General Facility Standards	6
          Contingency Plan and Emergency Procedures	7
          Operating Record	7
          Use and Management of Containers	7
          Permit Application	8
          Land Disposal Restrictions	8
          Underground Storage Tanks	8

     CLEAN AIR ACT	9
     TOXIC SUBSTANCES CONTROL ACT (Polychlorinated
       Biphenyl Handling)	9
     EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-
       KNOW ACT	10


TECHNICAL REPORT

INVESTIGATION METHODS	11

FACILITY DESCRIPTION	13

     PROCESS DESCRIPTION	13
     WASTE GENERATION	14
     WASTE MANAGEMENT/CONTROL	17

          Solid Waste	17
          Air Emissions	19

FINDINGS	20

     RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)	20

          Regulatory Status	20
          Compliance Status	23

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                  CONTENTS (cont.)
CLEAN AIR ACT	34

     Regulatory Status	34
     Compliance Status	35

TOXIC SUBSTANCES CONTROL ACT (Polychlorinated
   Biphenyl Management)	36

     Regulatory Status	36
     Compliance Status	36

EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-
   KNOW ACT	37

     Regulatory Status	37
     Compliance Status	37
                         n

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                         CONTENTS (cont.)
APPENDICES

A     TSCA Inspection Forms
B     Photographs
C     Hazardous Waste Accumulation Areas
D     Consent Agreement and Consent Order (1984)
E     Administrative Order on Consent (1989)
F     ARC Analytical Data - Soil Samples Near Building 201
G     Hazardous Waste Manifests for November 20,  1987  and January 7,
      1988
H     Material Safety Data Sheets, Waste  Material Analyses (by Safety
      Kleen), and Hazardous Waste Shipment Manifests (June 2, 1988,
      August 3, 1988, September 27, 1988, December 19, 1988, April 12, 1989,
      June 15,1989)
I     Thermal Treatment Inspection Reports
J     Facility Safety and Emergency Equipment Inspection  Reports
K     Facility Safety and Emergency Equipment Inspection  Plan
L     Contingency Plan
M    Burn Pit Logs
N     Satellite Storage Area Inspection Report for May 17, 1989
O     RCRA Part A Permit Applications
P     Hazardous Waste Manifest for July 14,  1989
Q     Hazardous Waste Manifest No. CWM 289234
R     Notification for Underground Storage Tanks
S     Notification of UST Closure Sample Results
T     Permit to  Construct and Operate A  beryllium Rocket Propellent
      Laboratory and Test Firing Facility
U     Beryllium Permit Modification
V     Beryllium Facility Operator Training
W    Virginia Air Control Board Registration
X     List of Hazardous Material Exceeding 10,000 pounds
FIGURES

1     Location Map	2
2     Site  Map	15
                                111

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EXECUTIVE SUMMARY

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                          INTRODUCTION

      The EPA National Enforcement Investigations Center (NEIC), at the
request  of EPA  Region  III,  conducted  a multi-media compliance
investigation of the Atlantic Research Corporation (ARC) Pine Ridge Plant
to determine facility compliance with selected Federal and Commonwealth
of Virginia environmental regulations,  permits, consent agreements, and
orders.

      The ARC Pine  Ridge Plant is in Prince William County at 5945
Wellington Road, Gainesville Virginia [Figure  1].  ARC, a subsidiary of the
Sequa Corporation,  researches,  develops,  tests,  and produces solid
propellent rocket motors and gas generators.  Some products manufactured
at this plant include the rocket motor for the Stinger anti-aircraft missile
and launch motors for cruise missiles.  The 422-acre plant has approxi-
mately 135 buildings and 60 associated  structures. About 1,200 people are
employed at the facility, working three shifts, 5 days per week.

OBJECTIVES

      The  specific objectives of the  investigation  were  to  determine
compliance rrith the:

      •      Resource Conservation and Recovery Act (RCRA)/Virginia
            Hazardous Waste Management Regulations and  associated
            consent orders/agreements, approvals, etc.

      •      Clean Air Act  (CAA)/Virginia Air Pollution Control Regula-
            tions and State issued permits

      •      Toxic Substances Control Act (TSCA)

      •      Emergency  Planning and Community  Right-to-Know  Act
            (EPCRA)

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            FIGURE 1
ARC PINE RIDGE PLANT LOCATION MAP

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BACKGROUND

      The  Pine  Ridge  plant originally  owned  by the  Sesquahana
Corporation, began operation in about 1952. ARC purchased the propellent
development,  testing,  and  production  business  from  Sesquahana
Corporation in 1976; the land was sold to the Gainesville Associates. ARC
currently leases the land from the Gainseville Associates.

      ARC routinely generates hazardous wastes regulated under RCRA
including:   (1) propellents and  propellent  components,*  (2) energetic
contaminated materials, (3) spent solvents, (4) spent solvent contaminated
materials,  and (5)  small  quantities of various  laboratory  chemicals.
Periodically, other hazardous wastes,  such as  boiler  descaler and
contaminated soil, are generated.

      Energetic wastes and energetic contaminated waste materials  are
stored for less than 90 days in numerous areas prior to thermal treatment
in three on-site open-burning pits and one burn pad.  ARC reports that non-
energetic waste (spent solvents, laboratory chemicals) are accumulated in
satellite  storage  areas and/or in a 90-day storage area prior to off-site
recycle, treatment, or disposal.

      ARC is a full quantity generator  and currently has interim status
(EPA ID No. VAD023741705) pursuant  to RCRA for open  burning of
hazardous  waste.   The  Virginia  Department of Waste Management
(VDWM) was  delegated RCRA authority and promulgated Virginia
Hazardous  Waste Management Regulations (VHWR) to control hazardous
waste handling.

      The facility notified the Virginia  Water Control Board  (VWCB) on
May 6, 1986, that the facility had underground storage tanks (UST) subject
to UST regulations.
    Propellents and propellent components (which include various explosives) are
    referred to in the propellent manufacturing industry as "energetic" material.  As
    waste, this material is RCRA reactive hazardous waste (EPA waste number D003)
    and is called energetic waste or hot trash.

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      ARC generates  volatile  organic compound  (VOC)  air emissions
during spray painting, cleaning, and degreasing operations.  Additionally,
ARC conducts research, including rocket motor testing, on beryllium-based
propellents.  Therefore, ARC is subject to Virginia Air  Pollution Control
Regulations (the Virginia Air Control Board has been delegated authority to
manage the CAA program).

      The facility reportedly does not  have  any polychlorinated  biphenyl
(PCB) transformers or capacitors.  However, the facility  operates  heat
transfer equipment which historically contained PCBs regulated under
TSCA.  Leakage from  this equipment  contaminated soils outside various
plant buildings. Contaminated soils were excavated and disposed of off-
site.

      ARC  uses   hazardous  chemicals   and  extremely hazardous
substances, regulated  under EPCRA,  during research,  development and
production of propellents.  ARC has notified State and local authorities
regarding this use and has reported environmental release  of:  aluminum
dust, methyl ethyl ketone, and 1,1,1 trichloroethane.

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            SUMMARY OF FINDINGS AND CONCLUSIONS


RESOURCE CONSERVATION AND RECOVERY ACT


      The  NEIC investigation  of ARC  hazardous waste management
procedures identified the following violations:


Generator Standards
    Section 5.04.02(b)*   A unique five-digit number was not assigned to
    40 CFR 262.20(a)**  each hazardous waste shipping manifest.  Two
                       manifests reviewed contained the same manifest
                       document number.

    Section 6.05.05(a)(l) Hazardous waste  was accumulated at an on-site
    40 CFR 262.34(aXD  90-day storage area without placing the waste in a
                       container  or tank.   Two  building air  filters,
                       contaminated with energetic waste  (D003***),
                       were in a storage area without being in bags or
                       drums.
    Section 6.02
    40 CFR 262.11
    Section 6.02.02
    40 CFR 262.11(b)
Residue generated from on-site open burning of
energetic waste was not evaluated to determine if
it is a hazardous waste.

ARC did not determine if a waste generated  on-
site was listed as hazardous. Waste spent solvent
mixtures were  improperly  identified  as a
characteristic hazardous waste (D001) rather than
listed hazardous wastes  F001 and F005.   Also,
rags   contaminated   with   spent   1,1,1-
trichloroethane  and methyl ethyl ketone were
improperly  identified  as characteristic  rather
than listed  (F001 and F005)  hazardous  waste,
respectively.
*   References  1984 Virginia Hazardous  Waste Management Regulations (unless
    otherwise specified)
* *  References Federal Code of Federal Regulations (CFR) parts, subparts and sections,
    as appropriate
* * * References EPA and Commonwealth hazardous waste number

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5.  Section 6.05.057     Hazardous waste was  accumulated  on-site for
    Section 11          more than 90 days without a permit or interim
    40 CFR 262.34(a)/   status. A drum of lead contaminated solids (D008)
    40 CFR Part 270    had been stored for 136 days prior to the NEIC on-
                       site inspection.

6.  Section 6.05.05(a)(3) Hazardous waste was accumulated on-site in less-
    40 CFR 262.34(aX3)  than-90-day storage  areas  without clearly mark-
                       ing each  container with the words "Hazardous
                       Waste." Some drums and bags of energetic waste
                       and  two  energetic-waste-contaminated air filters
                       did not have "Hazardous Waste"  labels.  An addi-
                       tional  drum,  containing small quantities of non-
                       energetic  hazardous waste,  was  improperly
                       labeled as "non-regulated."

7.  Section 6.4.E.l.e*   The VDWM Executive Director was not notified of
                       the exact location for each 90-day hazardous waste
                       accumulation area.   The  April  7,  1987 ARC
                       notification to VDHM did not include five hot trash
                       areas in use during the NEIC inspection.

8.  Section 6.05.05(aX2) Hazardous waste was accumulated on-site in less-
    40 CFR 262.34(aX2)  than-90-day storage areas without each container
                       being clearly marked with the date upon which
                       each period of waste accumulation began.

General Facility Standards

1.  Section 9.02.06(d)   Inspection records for the thermal treatment area
    40 CFR265.15(d)    and  safety and  emergency equipment  did  not
                       include the  name  of  the inspector,   time  of
                       inspection, and date and nature of any required
                       remedial actions.

2.  Section 9.02.06(bXl) The  written schedule for inspecting all facility
    40 CFR265.15(bXl)  monitoring, safety and emergency equipment,
                       and  security  devices  does not include  an
                       inspection  schedule  for the emergency warning
                       siren and phone and two-way radio system.
    References 1988 Virginia Hazardous Waste Management Regulations

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Contingency Plan and Emergency Procedures
    Section 9.04.02(c)
    40 CFR 265.52(c)
    Section 9.04.02(d)
    40 CFR 265.52(d)
    Section 9.04.02(e)
    40 CFR 265.52(e)
    Section 9.04.02(f)
    40 CFR 265.52(f)
The  contingency  plan  does  not  describe
arrangements agreed to by the local police and fire
departments, hospitals, contractors, and state and
local emergency response teams for coordinating
emergency services.

The plan does not list names, addresses,  and
phone numbers of all  persons qualified to  act as
emergency coordinator. The plan does not identify
at least one employee responsible for emergency
response coordination.

The plan  does  not  include  the  location,
description, and capabilities  of  some facility
emergency equipment.  Facility  equipment  not in
the firehouse  or on a  fire truck,  such  as the
emergency siren, and phone and two-way radio
systems are not included.

The plan does not include a complete evacuation
plan for facility personnel for conditions that may
require evacuation.
Operating Record
Section 9.05.02(bXD
40 CFR 265.73(bXD
The  facility  operating record for the  on-site
thermal treatment area does not identify date:1 of
hazardous waste treatment and some quantities of
wastes treated.
Use and Management of Containers
    Section 9.09.02      Hazardous waste  was not  transferred  from
    40 CFR 262.34(aXl)  containers  that were  not in  good condition;
                       hazardous waste was stored in dented and bent
                       drums and drums with rust holes.
    Section 9.09.04(a)
    40 CFR 262.34(aXl)
Containers of hazardous waste were not always
kept closed during storage except when necessary
to add or remove waste. The tops of some drums
were open due to the location of grounding clips.
Other drums had bent lids  preventing complete
closure.  The lid  on a  drum of solvent contami-
nated rags was held open by an over accumulation
of rags.

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                                                                    8
3.   Section 9.09.05     The less-than-90-day hazardous  waste storage
     40CFR262.34(aXD areas  were not  inspected  during the  week  of
                       May 14,1989.

Permit Application

1.   Section 11.02.02    The ARC Part A permit applications  were not
                       signed by both the facility operator (ARC) and the
                       property owner.  ARC leases the Pine Ridge plant
                       property from the Gainesville Associates. Neither
                       the original nor the updated permit application
                       was signed by a representative of the  property
                       owner.

2.   Section 11.04(n)    The original  ARC Part A  permit  application
     40 CFR 270.13(j)    (December 20, 1983) did not include a specification
                       and estimated quantity of some hazardous wastes
                       treated at the facility.

Land Disposal Restrictions

1.   40 CFR 268.7(a)    ARC did not properly determine,  through waste
                       analysis or knowledge  of the waste, that waste
                       generated on-site was  restricted  from  land
                       disposal.   Waste  spent solvent mixtures were
                       improperly identified as D001 rather than F001
                       and F005. Additionally, rags contaminated with
                       spent   methyl   ethyl  ketone   and   1,1,1-
                       trichloroethane  were improperly identified as
                       D001 rather than F005 or F001 waste, respectively.

2.   40 CFR 268.7(aX6)  A copy of the land disposal restriction certification
                       or notification for manifest No. CWM 289234 for
                       the shipment of hazardous waste (including F003
                       spent solvents) was not retained on-site.

Underground Storage Tanks

1.   VR680-13-02        The May 6, 1986 ARC notification to the VWCB did
     Section 2.3*        not include three on-site regulated USTs.
     40 CFR 280.22(a)

2.   VR680-13-02        ARC did not prevent  release from  spilling or
     Section 3.1         overfilling of a regulated UST.
     40 CFR 280.30(a)
    References Virginia Water Control Board Underground Storage Tanks regulations

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CLEAN AIR ACT

      ARC  operates two spray paint booths for rocket  motor and  gas
generator  surface  coating  and two vapor  degreasers  for  small parts
cleaning.  ARC also spot degreases using organic solvents.  According to
the Virginia Emissions Inventory System for point sources, ARC emitted
6 tons of volatile organic carbon in 1988 (the most recent update).  Therefore,
the facility is exempt from Virginia Air Pollution Control Regulations, Rule
4-34 (emission standard for miscellaneous metal parts and  products
coating application systems).  However, ARC is  subject to other Virginia
Air Pollution Control  Regulations.   The NEIC investigation of the air
emissions control  program identified the following violations:
1.  Permit Part II.8*   Training  records for beryllium air pollution
                       control  equipment  operators  did not include  a
                       certification of training (including a statement of
                       the time, place, and nature of completed training).
2.  Part Il.Section     The Air  Quality  Control Board registration
    120-20-31**         (April 25,  1984) does not include some VOC air
                       emission sources (spray  booth, spot degreasing)
                       and has  not been updated  to  show  system
                       modifications (change of solvent in degreasers).

TOXIC SUBSTANCES  CONTROL ACT (Polvchlorinated Biphenvl
Handling)

      Based on information  provided by ARC during the NEIC inspection,
ARC no longer has any TSCA-regulated PCB equipment. ARC documents
indicate that soil contaminated from PCB  heat  transfer fluid has been
excavated and disposed of off-site. The last shipment of PCB contaminated
material was on August 8, 1988.  The ARC  1989  annual document shows
that no PCB material was handled.

      Heat  exchange equipment, previously PCB-contaminated, remains
in use in building 105.  ARC  analytical data for heat transfer fluid currently
*   References the June 27, 1986, ARC permit to construct and operate the beryllium
    rocket propellent laboratory and test firing facility.
* *  References Virginia Air Pollution Control Regulations

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                                                                 10
      Heat exchange equipment, previously PCB-contaminated, remains
in use in building 105. ARC analytical data for heat transfer fluid currently
used in this equipment shows PCB concentrations less than 50 parts per
million.


EMERGENCY PLANNING AND COMMUNITY RIGHT-TQ-KNOW ACT


      The NEIC investigation of ARC EPCRA reporting  requirements
identified the following problem:

40 CFR 370.21(b)        The materials on the list of hazardous chemicals/
                      extremely  hazardous substances submitted  by
                      ARC to the Virginia Emergency Council and the
                      local fire  and rescue  departments were  not
                      grouped by hazard class.

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TECHNICAL REPORT

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                                                                  11

                    INVESTIGATION METHODS

      The NEIC investigation of ARC consisted of:

      •    Compilation and review of background information from State
           and Federal files

      •    Discussions with State and  Federal  regulatory  personnel
           regarding facility activities

      •    An on-site inspection

      Collection and review of background information and discussions
with EPA Region III personnel began in February 1990. Virginia State
personnel were subsequently contacted  regarding the investigation and
facility conditions/records were discussed.

      The on-site inspection was conducted April 16 through 20, 1990 and
involved:

      •    Discussions  with  facility  personnel,  predominantly the
           Environmental Coordinator, regarding plant operations and
           waste management

      •    Review and copying of facility documents including operating
           plans and records

      •    Visual inspection of plant facilities, including process areas,
           waste storage areas,  thermal treatment area, beryllium air
           emission control  equipment, and underground  storage tank
           areas

      NEIC document  control procedures  were  followed during the
investigation.  Uniquely numbered TSCA inspection forms were discussed
with the ARC  Environmental Coordinator  and  completed prior to the on-
site TSCA inspection [Appendix AJ. Documents  obtained from the company

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                                                                  12
during the on-site inspection were uniquely numbered  and listed in a
document log.  A copy of the document log was provided to ARC personnel
after  completion  of  the on-site inspection. Photographs were taken  of
selected inspection items.

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                                                                   13

                      FACILITY DESCRIPTION

PROCESS DESCRIPTION

      ARC researches, develops, produces, and tests solid propellent rocket
motors and gas generators at the Pine Ridge plant. Solid propellent motors
are the propulsion mechanism for rockets  and normally consist of solid
propellent inside an exterior case with an exhaust nozzle and propellent
initiator.  Gas generators are basically canisters of solid propellent which
produce pressurized gas that can be piped/valved to more than one exhaust
nozzle.  Rocket motors are used to propel a payload, such as a warhead; gas
generators have uses including maneuvering rockets on spacecraft.  Rocket
propellent motors and gas generators are  produced in batch quantities
dictated by contract commitments.

      Propellent motor and  gas generator manufacturing generally
involves:  (1) propellent component preparation (sizing and  weighing);
(2) component mixing; (3) grain* casting; (4) grain curing (using heat and
time); (5) grain finishing (machining); and (6) motor assembly (putting
grain in casing, assembling  various motor components, painting motor
casing,  and motor  packaging).  When complete, solid propellent rocket
motors  are shipped  off-site  for final  rocket  assembly  (warhead  and
guidance system application).

      A  "typical" propellent  consists mainly of an  oxidizer (usually
ammonium perchlorate) and an organic polymer binder (such  as carboxy
terminated polybutadiene or  polyvinyl chloride).   Cyclotetramethylene
tetranitramine (HMX) may also be used as a deflagration agent. Burning
rate  catalysts  (such  as iron oxide), curing  agents (epoxies,  maleic
anhydride, triphenyl bismuth) and catalyzers (such as chromium octoate)
are added in  relatively small quantities as necessary.  Aluminum  powder
is often used to enhance heat generation.
    A grain is a mass of solid propellent formed from a number of smaller pieces

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                                                                  14

      Rocket motor and gas generator components,  such as propellent
ingredients  (ammonium  perchlorate,  HMX, etc.) and motor  casings are
supplied by off-site sources.

      Rocket motor and gas generator research, development, production
and production support at ARC occurs in approximately 135 buildings and
60 associated structures [Figure 2] generally divided into the following
areas:

      •     Storage magazines  - raw material and finished product
            storage
      •     Technology - research and development
      •     Propellent  mixing  - propellent preparation, mixing,  and
            curing
      •     Grain finishing - propellent machining, wrapping, etc.
      •     Motor assembly - final motor assembly/painting/packaging
      •     Thermal treatment - open burning of waste  energetics and
            energetic contaminated material
      •     Administrative - facility operations support
      •     Material storage - miscellaneous storage
      •     Propulsion testing - motor/generator testing
      •     Engineering - facility engineering support

WASTE GENERATION

      Hazardous waste  (as defined in 40 CFR  Part 260/Virginia HWMR
Part 1) generation and air emission sources controlled by Federal or State
regulations  addressed  during  this  NEIC  investigation are  generally
associated with the above areas except for material storage, propulsion
testing (beryllium  rocket motor testing is conducted for research and
development and is associated with the technology area) and  engineering
offices.   Most  hazardous waste generated  at  ARC  are energetic and
energetic  contaminated  waste  (propellent/propellent components) and

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                                                 STORAGEjj MAGAZINES
                             MOTOR ASSEMBLY
PROPULSION T
                       MINISTRATIVE AREA
 NGINEERINQ
  FFICE  BUILDING
                           FIGURE 2
          ARC PINE RIDGE PLANT GENERAL SITE PLAN

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                                                                  16
various  halogenated  and  nonhalogenated  cleaning solvents.    More
specifically, waste streams generated at ARC include:

      •    Energetic solids (propellent or propellent component scraps,
           off-specification energetics and energetic contaminated  solids
           such as rags from  equipment  cleaning, and  contaminated
           building air filters - D003)

      •    Energetic liquids [spent  solvents that contain energetics from
           cleaning operations  - D001, D003, F002 (methylene chloride,
           1,1,1-trichloroethane), F005 (methyl ethyl ketone)]

      •    Spent  solvent contaminated  solids   [mostly  rags  from
           degreasing/cleaning -  F001  (methylene  chloride,   1,1,1-
           trichloroethane), F005 (toluene, methyl ethyl ketone), D001)]

      •    Bulk spent solvent  liquid [from degreasing/cleaning -  F001
           (methylene chloride, 1,1,1-trichloroethane), F005 (toluene,
           methyl ethyl ketone), U123 (formic acid), D001]

      •    Small quantities (usually less than 1 gallon) of miscellaneous
           materials that have  exceeded shelf-life  requirements or are
           otherwise unusable (maleic  anhydride  -  U147, sodium
           dichromate and copper chromate - D007)

      •    Paint waste (D001)

      •    Corrosive liquid (boiler descaling - D002)

      •    Air  emissions  potentially  contaminated  with  beryllium
           (processing and rocket motor testing  of beryllium  based
           propellents)

      •    Participates  (aluminum dust from component grinding and
           mixing)

      •    Volatile  organic  compound  air   emissions (ultrasonic
           degreasing,  soaking,  spot  degreasing/cleaning, and   spray
           painting)

      •    Sulfur dioxide air emissions (fuel oil burning)

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                                                                   17

WASTE MANAGEMENT/CONTROL

Solid Waste

      ARC  generally  segregates solid  waste  (as  defined in 40  CFR
261.2/HWMR Part  1) into three  major handling categories: (a) energetic
waste,* (b) nonenergetic hazardous waste, and (c) nonhazardous waste.
Process knowledge and information from product certifications supplied by
product manufacturers are used to identify  and segregate the various
wastes. A description of ARC waste management procedures for the three
general solid waste types follows.

      a.    Energetic Waste

            Propellents, propellent components, or material contaminated
            with these materials  are referred to as energetic waste or "hot
            trash."  Hot trash is normally contained in red (30-gallon) steel
            drums  or in the original product container (for outdated/off-
            specification material).  This waste is stored in less than
            90-day  accumulation  areas near the point of generation. ARC,
            in an April 7,  1989 letter to the Virginia Department of Waste
            Management (VDWM), stated that the facility hod a total of 28
            less-than-90-day hot  trash accumulation areas [Appendix C].
            The number of hot trash accumulation areas in use at any
            time fluctuates as a function of the particular type of work in
            progress.

            Hot trash is periodically removed from storage and placed in
            the  thermal treatment area for open burning.  The thermal
            treatment  area consists of three unlined, bermed excavations
            (burn pits) and an unbermed "burn pad" located between pits 1
            and 2 [Appendix B-l  and 2].  Waste energetics are segregated
            by waste type and spread out in one of the three burn pits or the
            burn pad:
    All energetic waste is hazardous waste.

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                                                              18
            Pit  1  is used for "1.1 type material,"  energetics more
            likely  to detonate than burn.
            Pit 2 is used for "1.3 type material," material more likely
            to burn than detonate.
            Pit  3  is for energetic  material  from  research and
            development activities.
            The burn pad, referred to as the D-5 burn area, is used to
            burn  energetic material, such as D-5 rocket  motors,
            which may go ballistic.  The motors are partially buried,
            nose down, prior to ignition.
      All energetic material is ignited remotely.  Ash and partially
      burned material (rags, gloves, etc.) are sometimes ejected from
      the  pits due to thermal convection during burning.  The pits
      are inspected for thermal (infrared) activity no sooner than 24
      hours after each burn  and before anyone is allowed to enter
      them.

b.    Nonenergetic Hazardous Waste

      This waste, mostly spent solvents, spent solvent contaminated
      solids, and small quantities of unusable laboratory material, is
      normally  stored in  silver drums in satellite accumulation
      areas near the point of waste generation.  Periodically (i.e.,
      when a drum of waste is full) this hazardous waste is moved to
      the  facility less-than-90-day "chemical waste"  accumulation
      area (near building 107). Periodically, other hazardous waste,
      such as  boiler descaler waste (D002) and contaminated soil is
      generated.  This  waste is stored  in  the  less-than-90-day
      chemical waste accumulation area.

      ARC, in a March 1, 1988, letter to the VDWM, stated that the
      facility  has a  total of 41  hazardous  waste  accumulation/
      satellite storage areas [this includes both hot trash and solvent
      waste satellite storage areas (Appendix C)].

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                                                                    19

            Spent bulk solvent is sent off-site for either recycling or for use
            as supplemental  fuel.  Solvent-contaminated solid  material
            and small quantities  of miscellaneous hazardous waste from
            the technology area is currently incinerated off-site.  Other
            miscellaneous waste is also disposed of off-site.

      c.     Nonhazardous Waste

            Nonhazardous  solid  waste,  normally  referred  to  as "cold
            trash" is stored in blue drums or dumpsters and is disposed of
            at the Prince William County  Sanitary Landfill.

Air Emissions

      VOC  air emissions  from  two  freon  ultrasonic  degreasers  are
controlled by cold coils when in use and closed tops when not in operation.
VOC  air emissions from soaking  of motor parts and casting tooling  are
controlled by  keeping  the soaking containers closed.  Air emissions from
spot cleaning or degreasing and spray painting are not controlled.

      Air emissions from  the beryllium  laboratory (used for producing
sample quantities of beryllium based propellents) and test tank (used for
propellent test firing)  are  treated in separate treatment systems.  Each
system consists of a venturi  scrubber, demister, and HEPA filter.   Air
emissions are  sampled for beryllium content.

      Particulate  emissions  from several plant  operations, including
propellent sizing, mixing, and machining are  controlled with building air
filters.   Contaminated filters are  handled according  to  the  type of
contamination (as previously described).

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                                                                20

                            FINDINGS

RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)

Regulatory Status

      ARC  generates hazardous waste regulated by RCRA and currently
has interim status (EPA ID No. VAD023741705) pursuant to RCRA for
thermal treatment (open burning) of hazardous waste.

      ARC  notified EPA as a hazardous waste generator in August 1980.
However, ARC  did not submit a RCRA Part A permit application until
January 19, 1984, reportedly because they believed that they were an exempt
small quantity generator.  A June 1984 Consent Agreement and Consent
Order with EPA addressed this late filing of the Part A permit application
[Appendix D].

      This agreement and order also waived 40 CFR 265.382 requirements
for open burning at  ARC  provided ARC conformed to  Army Regulation
AR385-64.   This  Army regulation,  superseded  by DOD 4145.26-M,
establishes protocol for open burning of waste explosives/propellents.  The
waiver essentially allows ARC to use the historic on-site thermal treatment
area even though this area does not meet the location requirements of 40
CFR 265.382 (which require a minimum of 670 feet between any open burn
area and the property of others; the ARC burn area is less than 500 feet
from the property line).

      In November 1988, ARC submitted a RCRA Part B permit application
for thermal treatment of hazardous waste.  The application, revised in
June 1989, was in  review by EPA and VDWM during the NEIC
investigation.

      A 3008(h) Administrative Order on Consent between ARC and  EPA
became effective in May 1989.  The order required ARC to investigate
hazardous  constituent releases to  the environment  (RCRA  facility
investigation) and undertake specified interim measures to mitigate off-site

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                                                                  21
contaminant migration [Appendix E].  A draft RCRA facility investigation
(RFI) report was submitted to EPA in February 1990.  According to ARC
personnel, the final  RFI was about  90%  complete during the  NEIC
inspection. Three of the five interim measures required by the order had
not been completed at the time of the NEIC inspection.  These were:

      1.    Reduction of all VOCs  in  surface  streams leaving  ARC
           property to maximum contaminant levels (MCLs)

      2.    Improvement of on-site satellite chemical storage facilities

      3.    Disposal or treatment of contaminated soils that are a factor in
           possible  off-site  migration of  organic  hazardous waste
           constituents

      ARC's initial attempt to reduce VOC levels in plant  surface streams
by  riprapping  channel segments  was   only  partially  successful.
Perchloroethylene levels in the stream remain  above  the MCL.  ARC is
studying the use of an air stripper to further reduce VOC levels.

      ARC has purchased two types of steel vaults  to  improve on-site
satellite accumulation areas.  Several  of these vaults remain to be installed
but ARC expects to have all vaults in use by the end of June 1990.

      Some contaminated soil that may be contributing to off-site migration
of organic hazardous waste constituents have not been treated or disposed
of.  Soil in the building 40 area, a source of surface water VOC contamina-
tion, has not been treated or disposed of. ARC  personnel stated that the
building 40 soil contamination problem will be addressed based on the
outcome of discussions  with  the Commonwealth regarding  material
handling.

      Soil contaminated with chlorobenzene from the building 201 area was
being treated on-site by bioaugmented soil venting as an interim measure
required by the 1989 Order on Consent. According to ARC analytical data,

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                                                                     22

the soil also contains up to 199 parts per million chromium [Appendix F].
Region III approved the on-site treatment process.

      ARC  operates  satellite  accumulation  areas  for  nonenergetic
hazardous  waste, mostly spent  solvent  and spent solvent contaminated
waste.  ARC personnel claim safety considerations require that satellite
accumulation  areas be located outside the buildings where the waste is
generated.  On November 30, 1987, ARC requested clarification from EPA of
the satellite accumulation area rule.   In  an undated letter,  Marcia  E.
Williams, EPA Director, Office of Solid Waste, Washington, DC, answered
that "The storage areas you describe appear to  be satellite accumulation
areas" [Appendix C].

      The only controls that operators of ARC hazardous waste  generation
activities have over most* of these satellite  accumulation areas  are facility
standard operating procedures (SOPs) that address how the areas are to  be
used.  According to ARC  personnel, some of the satellite accumulation
areas, such as the area referred to as building 255, contain waste generated
at several different buildings by several different operators.  Most satellite
accumulation  areas are out-of-sight of the process operators.   Buildings
near the hazardous waste accumulation areas are not  always occupied and
operators are not  always  near  the accumulation areas.  Additionally,
personnel not associated with hazardous waste  generation have physical
access to most of these areas.

      ARC was operating  four  underground storage  tanks during the
NEIC on-site inspection:

      •     One 6,000-gallon unleaded gasoline tank installed in  1985
      •     One 2,000-gallon leaded gasoline tank installed in 1978
      •     One 1,000-gallon waste oil tank installed in 1982
      •     One 1,000-gallon kerosene tank installed in 1982
    A few areas, such as storage areas associated with buildings 200 and 253, are locked
    and totally controlled.

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                                                                   23
ARC notified the VWCB on May 6, 1986 that the Pine Ridge facility had two
underground storage tanks subject to UST regulations. ARC removed one
1,000-gallon underground gasoline storage tank (installed prior to 1965) in
January 1990. The facility is investigating soil contamination attributed to
leakage of this tank.

Compliance Status

      Generator Standards

1.    ARC did not assign a unique five-digit number to each hazardous
waste  shipping manifest.  Manifests  describing shipments of hazardous
waste from ARC to Safety Kleen Envirosystems, New Castle, Kentucky on
November 20, 1987, and January 7, 1988, both had the same "State Manifest
Document Number," 01001 [Appendix G].

2.    ARC accumulated hazardous waste at an on-site 90-day storage area
without placing the waste in a container or tank.  Two building air filters
were at the building 116 hot trash storage area without being in bags  or
drums. The filters were placed directly on the covered concrete pad.  This
locked, energetic hazardous waste storage area services building 116,  a
building that mixes propellent [Appendix B-3].

3.    ARC did not determine if waste generated on-site is a hazardous
waste.  Residue generated in the three on-site thermal treatment pits from
open burning of reactive hazardous waste (energetic waste) has not been
analyzed or knowledge not used to  determine if it is hazardous waste.
Heavy metal compounds present in the energetic material treated, such as
chromium octoate, may concentrate in the residue making the material EP
toxic.   Also, listed hazardous waste may be generated during waste
oxidation.

      ARC personnel stated that the residue has never been removed from
the pits. Rather, the material is periodically pushed into a pile at the north
end of each pit [Appendix B-4 and 5]. Some partially burned waste (rubber

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                                                                   24
gloves,  rags) is ejected from  the  pits during burning  and was  present
around the thermal treatment area [Appendix B-6].

4.     ARC did not determine  if a waste generated  on-site  is listed as
hazardous.   ARC combines several spent solvent waste  streams in 55-
gallon drums.  While specific  constituents and/or concentrations of each
constituent will vary between 55-gallon drums  (each mixture is dependent
on the particular batch operation in progress  when each drum is filled), the
mixtures contain solvents such as methyl ethyl  ketone, methylene chloride,
tetrahydrofuran,  toluene,   perchloroethylene,  and  ethyl   alcohol
[Appendix G].

      According to ARC material safety data sheets,  the solvents, before
use, compose 99 to  100%  of the solution [Appendix G].   Spent solvent
mixtures containing methyl   ethyl ketone and/or  toluene  are listed
hazardous wastes, F005 and mixtures containing methylene chloride are
F001 listed hazardous waste.   However, ARC manifested this waste as
characteristic ("RQ Flammable  Liquid N.O.S.,"  "D001") rather than listed,
F005 and F001 waste [Appendix H],

      Additionally, rags contaminated with spent methyl ethyl ketone
(F005),  1,1,1-trichloroethane (FOOD, and methylene chloride (FOOD,  listed
hazardous wastes, were improperly manifested as  characteristic waste
("Waste Flammable Solid NOS," "D001" [Appendix H].

5.     ARC accumulated hazardous waste on-site for more than 90  days
without  interim  status or a  RCRA permit for container storage.   On
April 18,  1990,  a drum containing lead-contaminated  solids (D008) at
storage  area  107 had a beginning accumulation date of December 1, 1989,
indicating it had been stored for 136 days [Appendix B-7].  This area is used
to store  nonenergetic hazardous waste prior to off-site removal.

6.     ARC accumulated hazardous waste on-site in 90-day storage  areas
without  clearly marking  each container with the  words  "Hazardous
Waste."   This included:

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                                                                   25

      •     Five drums at hot trash storage area 105 [Appendix B-8]

      •     Four plastic bags in the locked, fenced, hot trash storage area
            85 [Appendix B-9]

      •     Two  HMX fiber drums  at hot  trash storage  area  116
            [Appendix B-3]
      •     Two  building air filters at  the hot trash storage area  116
            [Appendix B-3]

      •     One drum in storage area 107 (this drum was actually marked
            as "non-regulated" but  was found  to  contain numerous
            1-gallon  and smaller containers  of waste including  one
            container each of mercuric cyanide and silver permanganate)

      •     A 5-gallon pail containing a 1-quart jar of urea nitrate and two
            1-quart cans of sodium naphthalene (reactive  hazardous waste
            according to ARC personnel)  located on the burn pad between
            thermal treatment pits 1 and 2 (observed on both April 17  and
            19,1990)

7.    ARC did not notify the VDWM Executive Director of the exact location
of each 90-day hazardous waste accumulation area.  ARC notified VDHM of
the location of 28 "hot trash" accumulation areas in an April 7, 1989 letter
[Appendix C].  However, the list of hot trash storage  areas  (90-day
accumulation areas for D003 waste) presented in the letter was incomplete.
The list did not include accumulation areas at buildings 46, 222, 223,  and
235 and at the burn pad between burn pits 1 and 2 (a 1-quart jar of urea
nitrate and two 1-quart  cans of sodium  naphthalene were in a 5-gallon
plastic container located  on the burn pad  on  both April 17, 1990,  and
April 19, 1990; ARC personnel said the waste was stored awaiting  special
burning).  ARC should have notified the State at least 15 days prior to use of
these additional 90-day accumulation areas.

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                                                                  26
8.    ARC accumulated hazardous waste  on-site in 90-day storage areas
without clearly marking each container with the  date upon which each
period of waste accumulation began. This included:

      •      Fourteen drums,  some  red metal and fiber, at hot trash
            storage area 105 [Appendix B-8]

      •      Two  HMX fiber  drums at  hot trash  storage area  116
            [Appendix B-3]
      •      Four plastic bags in locked, fenced, hot trash storage area 85
            [Appendix B-9]

      •      One red drum at hot trash storage area 28

      •      One drum in storage area 107  (this drum was actually marked
            as "non-regulated" but was found to contain mercuric cyanide
            and silver permanganate)

      •      One 5-gallon bucket containing a 1-quart jar of urea nitrate
            and two 1-quart cans of sodium naphthalene located on the
            burn pad

      Additionally, numerous  drums at  hot trash storage  areas  had
several dates listed and/or dates that were upside down [Appendix B-10].

      General Facility Standards

1.    Inspection records for the thermal treatment area, and safety and
emergency equipment were incomplete.  None of the inspection reports
reviewed included the time of the inspection.  These included:

      •      Fifteen thermal treatment area inspection reports (January 2,
            1990, to April 13, 1990 - Appendix I)

      •      Twenty-eight general facility safety and emergency equipment
            inspection reports  (February 12, 1990 through April 16, 1990,

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                                                                   27
            for fire truck W-30, and January 5, 1990, through April 16,
            1990, for fire truck B-30).

      Many of the inspection reports reviewed included only the initials of
the inspector rather than the name.  These included:

      •     Five  general  facility   safety  and emergency equipment
            inspection reports (the February 12, 1990 report for fire truck
            W-30; and February 14, 1990  report for fire truck  B-30)
            [Appendix J].

      Inspection  reports identifying required remedial actions did not
include the date  and nature of remedial  actions taken.  These included
thermal treatment area inspection reports (hot trash logs) for:

      •     April 3, 1989 (pit 1 overloaded)

      •     July 12, 1989 (holes in pit 1)

      •     September 5, 1989 (hot trash pan) [Appendix I]

2.    The written schedule for inspecting all facility monitoring, safety and
emergency  equipment, security devices,  and operating and structural
equipment that are important to preventing, detecting, or  responding to
environmental or human health hazards was not complete.  According to
the  ARC  Environmental  Coordinator,  ARC is  currently  using the
inspection plan described in the November 7, 1988, RCRA Part B permit
application  (revised June 30, 1989).  Attachment IV of the plan lists the
equipment to be inspected weekly but only includes firehouse and fire truck
equipment.  The plan does not include inspections conducted for the facility
emergency warning siren and the phone and two-way radio system (the
latter of which is used during each burn) [Appendix  K].

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                                                                 28

      Contingency Plan

1.     The  current  ARC contingency plan (the plan contained in the
June 30, 1989, revision of the ARC RCRA Part B permit  application)
[Appendix L] does not describe arrangements agreed to by the local police
departments, fire departments, hospitals, contractors, and Virginia and
local  emergency response  teams for coordinating  emergency  services.
Item 13 of the plan states that copies of the contingency plan are available to
and have been discussed with the local police and fire departments and the
hospital. Pages six and seven of the plan's Attachment A state that, if the
hazard  is deemed  to be beyond the  remedial capabilities  of ARC's  spill
response team, the incident commander may call for additional outside
assistance.  Pages 43 and 44 of Attachment A describe ARC's policy on
requesting outside assistance from Prince William County Fire and Rescue
units.  However, the applicable agreements with the local services are not
described.

2.     The  contingency plan does not list names, addresses, and phone
numbers (office and home) of all persons qualified  to act as emergency
coordinator.  Page  one of the  plan provides only emergency coordinator
responsibility information.   Pages  14 and  15  provide names,  phone
numbers, and cities of numerous emergency per&onnel but do not identify
the emergency coordinator. Page 40  provides the name of the emergency
coordinator but does not include phone numbers or addresses.  Attachment
II  of the plan's Attachment A provides four pages of names, cities, states,
and home phone numbers but does not identify the emergency coordinator.
Although the plan identifies C. G. Lawrence as the emergency coordinator
in  one place (page 40) and provides his phone numbers, city,  and state in
another (Attachment  II of Attachment A), the  plan does not list  this
information, nor does it  contain C. G.  Lawrence's  complete address
[Appendix L].

      Additionally, the plan  separates  responsibility  between  the
emergency operations director and the officer in charge.  Page one of the
plan's Attachment A  states that the  senior member  of management
present  at  the plant is, in times of emergency, ultimately responsible for

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                                                                   29
control activities. This senior member of management is referred to as the
emergency operations director.  Page 39 Attachment A states that the
officer in charge of the first response team  will serve as the incident
commander for the duration of an emergency operation.  Page 40 of the
plan's Attachment A further titles the officer in charge as the chief officer,
titles the  chief officer as the emergency coordinator, and names  the
emergency coordinator as C. G. Lawrence.

3.    The plan does not include the location, description, and capabilities of
some facility emergency equipment  (such as  communication equipment,
and alarm systems  observed on-site).  Attachment 1 of the  plan's
Attachment A lists  the  emergency equipment  used  for  chemical
emergencies, including all hazardous waste material responses, but this
listing only includes the equipment stored on the two fire trucks  (wagon 30
and brush 30) and in the firehouse (building 36).  The  facility has an
emergency phone procedure, two-way radios  and an emergency  siren that
are not listed in the contingency plan [Appendix L].

4.    The  plan does  not describe a  complete  evacuation plan,  including
signals, routes, and alternate routes for facility personnel for  conditions
where there is  a possibility that evacuation could be necessary.  Pages 21
through 23 of Attachment A only describe storm condition,; requiring ARC
to evacuate the facility, and pages 27 and 28 only identify assembly locations
for  bomb threats. Neither of these conditions is addressed completely nor
are explosion or fire evacuation measures related to the thermal  treatment
area addressed [Appendix L].

      Operating Record

      The  facility operating record for the  thermal treatment area is
incomplete.  The record  does not  identify dates of hazardous waste
treatment and  the quantities of some hazardous waste burned.  ARC has
two records relating to quantity and  dates of energetic waste burning; hot
trash log and burn pit log [Appendix I and M],

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                                                                   30

      None of the logs reviewed (hot trash logs from April 1989, to April 13,
1990, and burn pit logs from January 1989 to April 13, 1990) identify each
treatment (burn) date. Although the burn pit log identifies the weight of
most material taken to the pits, the quantity for each burn is not provided.
Also, the weight of individual loads of waste taken to the pits is not always
recorded.  According to the burn pit logs, the following wastes were loaded
into the thermal treatment pits without weights recorded [Appendix Mj:

      •    Ammonium perchlorate loaded in pits 1, 2, and 3 on March 14,
           1989
      •    "Hot waste" loaded on January 2, 1990
      •    "Propellent + ignition material" loaded on January 12, 1990
      •    "Aluminum dust collector  pipe" and  "propellent + ignition
           material" loaded on January 13, 1990
      •    "Hot waste material" loaded in pits  1, 2, and 3 on March 12,
           1990
      •    "Hot Waste Material" loaded into pit 1 on March 23, 1990

      Use and Management of Containers

1.    ARC did not transfer hazardous waste from containers not iu good
condition. Hazardous waste was stored in drums that had rust holes and
were bent.  These included:

      •    Red drums containing energetic waste in storage areas 41 and
           46 (one in each)  which had several small rust holes near the
           bottom [Appendix B-ll]

      •    A red drum containing energetic waste at  storage area 46
           which had a bent lid [Appendix B-12]

      •    A red  drum of energetic waste in storage area 100 that was
           dented.

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                                                                   31

2.    Containers of hazardous waste were not always kept closed during
storage except when necessary to add or remove waste. These included:

      •     Red drums of energetic waste at storage areas 41 and 222 that
            could not be completely closed because of grounding clips
            attached to  the drum lip  preventing the lid  from  closing
            completely (the 1-  to 2-inch drum/lid opening caused  by
            grounding clips attached to the lip of the drum is a reoccurring
            problem at many of the storage areas) [Appendix B-ll]

      •     A silver drum of solvent contaminated rags at storage area 46
            that could not be closed due to an over accumulation  of rags
            [Appendix B-12]

      •     A red drum containing energetic waste at storage area  46
            which had a bent lid that could not  be  completely closed
            [Appendix B-12]

      •     An open bag of energetic waste inside an open drum at storage
            area 105.

3.    ARC personnel did not inspect less-than-90-day storage areas during
1 week in 1989.  No inspection was conducted during the week of May 14,
1989.  This is evident from  a notation on a blank inspection sheet dated
May 17, 1989 stating that "had a 40 hour class; didn't have time to inspect"
[Appendix N].  There is  no  completed inspection record for  the week of
May 14,  1989 (the facility has maintained inspection records for other
weeks).

      Permit application

1.    The ARC RCRA Part A permit applications were not signed by both
the facility operator (ARC) and the property owner.  ARC leases the Pine
Ridge plant property from the Gainesville Associates. Neither the original
(December 20, 1983) nor the updated (June 29, 1989) permit application was

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                                                                  32
signed by a representative of the property owner.  The applications were
only signed by an ARC representative [Appendix 0].

2.     The ARC original RCRA Part A permit application (December 20,
1983) was not complete. The application did not include the specifications
and estimated quantity of some hazardous waste  treated at the facility.
Only "D001" and "waste explosives" were identified in the application. ARC
thermally treats reactive hazardous  waste  (D003) and  reactive waste
contaminated with solvents (F002, F003, F005).   Solvent wastes were
included in  an amended Part A  permit application (June 29, 1989)
submitted with the facility RCRA Part B permit application.

      Land Disposal Restrictions

1.     ARC did not determine, through waste analysis or knowledge of the
waste, that waste generated on-site was restricted from land disposal. ARC
combines several spent solvent waste streams in 55-gallon drums.  While
specific constituents and/or concentrations of each constituent will vary
between 55-gallon drums (each mixture is dependent on the particular
batch  operation in progress when each  drum is filled), the mixtures
usually contain solvents such as methyl ethyl ketone, methylene chloride,
tetrahydrofuran,   toluene,  perchloroethylene,  and  ethyl   alcohol
[Appendix G].

      According to ARC material safety data sheets, the solvents, before
use, compose 99 to 100% of the  solution [Appendix G].   Spent solvent
mixtures  containing  methyl  ethyl ketone  and/or toluene  are listed
hazardous wastes, F005,  restricted from  land  disposal.   Mixtures
containing methylene chloride are  listed F001 hazardous wastes,  also
restricted from  land disposal.  ARC sent such spent solvent mixtures to
Safety Kleen Envirosystems as bulk "RQ Flammable Liquid N.O.S.," "D001"
[Appendix G].

      Additionally,  rags contaminated with  spent methyl ethyl ketone,
1,1,1-trichloroethane,  and  methylene chloride from  degreasing were

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                                                                  33
improperly identified as D001 rather than F005 or F001 waste. These rags
were manifested as "Waste Flammable Solid, NOS," "D001" [Appendix P].

2.     ARC did not retain, on-site, a copy of the land disposal restriction
certification or notification with manifest No. CWM 289234 for the off-site
shipment of hazardous  waste.   Hazardous waste  shipped under this
manifest included "Waste Paint (RQXF003)"  a land disposal restricted
hazardous waste [Appendix Q]. The ARC file did not contain a notification
or certification for this waste shipment.

      Underground Storage Tanks

1.     The May 6, 1986,  ARC notification to the VWCB,  identifying the
regulated USTs brought into use after May 8, 1986, did not identify three of
the five regulated tanks.  The notification only included the 6,000-gallon
unleaded gasoline tank and the 2,000-gallon leaded gasoline  tank but not
the 1,000-gallon waste oil tank, 1,000-gallon kerosene  tank, or 1,000-gallon
flammable liquid tank [Appendix R]. All five tanks were in service prior to
May 8, 1986. Four regulated tanks (the 1,000-gallon flammable liquid tank
was removed from ARC in January 1990) were in service during the NEIC
inspection.

2.     ARC did not prevent release from spilling or overfilling of a regulated
UST.  The soil in about a 2-foot-diameter area surrounding the used oil tank
fill apparatus was discolored, indicating oil release [Appendix B-13],

3.     ARC did not revise the May 6, 1986, UST notification after removing a
UST.  On January 2, 1990, Groundwater Technology, Incorporated (GTI),
an ARC contractor, removed the 1,000-gallon flammable liquid UST from
ARC's premises. On March 8, 1990, GTI sent tank closure information to
the VWCB, but did not include a revised notification [Appendix S].

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                                                                   34

CLEAN AIR ACT

Regulatory Status

      ARC generates VOC air emissions during painting, cleaning and
degreasing operations.  ARC conducts research, including motor testing,
on beryllium based propellents and operates facility boilers for space and
process heat.  Therefore, ARC is  subject to some Virginia Air Pollution
Control Regulations [the Virginia Air  Control Board (VACB) has been
delegated authority to manage the CAA program].  Virginia  regulations
incorporate, by reference, Federal hazardous air pollutant requirements.

      ARC received a permit to construct and operate a beryllium rocket
propellent laboratory, and test firing facility in June 1986 [Appendix T].
The permit was modified on October 31, 1988 to delete the beryllium ambient
monitoring requirement  (stack sampling is still required - Appendix U).
The facility does not have any other air emission control permits. However,
other ARC point air emission sources have been registered with the VACB.
The current (April 25, 1984) ARC registration (number 70033) identifies one
spray paint booth (building 28), two vapor degreasers and rocket motor
cleaning  (with methyl ethyl ketone) as plant VOC emission  sources.
Facility boilers are also registered.

      According to the Virginia Emissions Inventory System for Point
Sources, ARC emitted 6 tons of volatile organic compounds in 1988 (the
most recent update).  The  ARC registration identified VOC sources to
include:  one paint both (2 tons per year VOC), two vapor degreasers (.15
tons per year  VOC each, and spot degreasing (no value given).  A second
spray paint booth, not registered, was estimated to emit less than 2 tons per
year. Based on the Emission Inventory, the facility is exempt from Virginia
State Rule 4-34  (emission standard for miscellaneous  metal parts  and
products coating application systems).

      According to ARC personnel, facility boilers normally use natural
gas fuel. Periodically, ARC switches to fuel oil at the request of the natural
gas supplier.  The largest ARC boiler, rated at 34 million British thermal

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                                                                  35
units (Btus) per hour, burning fuel oil with 0.25 percent sulfur and 140,000
Btus per gallon fuel content, emits less than the maximum allowed (by
regulation) sulfur dioxide emissions of 36 pounds per hour.

Compliance Status

1.     The ARC training records for operators of the beryllium air pollution
control  equipment  did not include  the name(s)  of the operators  or a
certification of training (including a statement of the  time,  place, and
nature of completed training).  The only records ARC provided that were
associated with training of beryllium facility operators were a July 14, 1987,
one-page memo regarding unspecified training and an announcement and
agenda  of  available training [Appendix V].   ARC claimed all applicable
personnel were trained but the specific records were not provided.
2.     The current VACB registration (dated April 25, 1984) is not complete
or accurate and has  not been updated to reflect facility modifications to VOC
emission sources. The registration does not include all VOC air emission
sources  and  has  not been updated to show  system  modifications
[Appendix W]. Registration deficiencies include:

      •      No listing of the spray paint booth in building 40 (in operation
            since before 1983 - the year  the registration was prepared for)

      •      No listing for spot  degreasing of  mechanical parts at various
            facility locations (using various solvents  including 1,1,1,
            trichloroethane);  degreasing is used during equipment
            maintenance and  has  been  used since  facility  operations
            began.

      •      An  inaccurate statement claiming that  the building 74
            degreaser "is not in use at this time" when, in fact, the unit
            was in operation during the NEIC inspection

      •      Improper  identification of degreasing solvent in the two
            operating vapor degreasers.  The registration has  not been

-------
                                                                 36
           updated to show a change from perchloroethylene to freon in
           the building 40 and 74 vapor degreasers.

TOXIC SUBSTANCES CONTROL ACT (Polvchlorinated Biphenyl
Management)

Regulatory Status

      According to ARC personnel, the facility does not have any PCB
transformers  or capacitors.  However, the facility operates heat transfer
equipment which historically contained PCBs regulated under  TSCA.
Leakage from PCB equipment contaminated soils outside various plant
buildings.  According to ARC soil sampling analytical  results, PCB-
contaminated soil has been excavated and contaminated soil, heat transfer
fluid, and heat transfer equipment were disposed of off-site  in the late
1970s/early 1980s and again in 1987/1988 (some material from the early
cleanup was buried on-site and required removal). The last shipment of
PCB-contaminated material was on August 8, 1988.  The 1989 PCB  annual
document showed that no PCB material was handled.

      Heat exchange  equipment that  previously contained PCB fluid
remains in use in building 105.  The system was originally flushed in  the
early 1980s.  The fluid was sampled and analyzed in February 1983 and
found to contain 138 parts per million (ppm) PCBs (ARC believes that an
extrusion die, inadvertently not flushed in the early 1980s, recontaminated
the heat exchange equipment). Following further flushing, the PCB
concentration was reduced to 1.9 ppm.

Compliance Status

      Based on information provided during the NEIC inspection, ARC no
longer has any PCB equipment at the facility that is regulated under TSCA
(the PCB content of the building 105 heat transfer fluid was last determined
to be less than 50 ppm in 1983, following flushing).

-------
                                                                 37

EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT

Regulatory Status

      ARC notified the Virginia Emergency Council and the local fire and
rescue departments of the names of hazardous chemicals and extremely
hazardous substances used at the facility in quantities above the minimum
threshold levels in October 16, 1987 (EPCRA Section 311/312 reporting). The
latest Tier One chemical inventory update was dated March 1, 1990.

      ARC also reported environmental release of three toxic chemicals
(EPCRA Section 313 reporting).  The three chemicals were methyl  ethyl
ketone, aluminum (dust), and 1,1,1-trichloroethane.

Compliance Status

      The list of hazardous chemicals/extremely hazardous  substances,
submitted on October 16, 1987, was not complete.  Rather than submitting
material safety data sheets for each  regulated  substance, ARC elected the
alternate reporting method of listing the common chemical name of each
substance.  Although ARC listed each chemical name as well as  the CAS
number, the cheuiicals were not grouped by hazard class [Appendix X].

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                      APPENDICES

A    TSCA INSPECTION FORMS
B    PHOTOGRAPHS
C    HAZARDOUS WASTE ACCUMULATION AREAS
D    CONSENT AGREEMENT AND CONSENT ORDER (1984)
E    ADMINISTRATIVE ORDER ON CONSENT (1989)
F    ARC ANALYTICAL DATA - SOIL SAMPLES NEAR BUILDING 20
G    HAZARDOUS WASTE MANIFESTS FOR NOVEMBER 20, 1987, AND
     JANUARY 7, 1988
H    MATERIAL SAFETY DATA SHEETS, WASTE MATERIAL ANAL
     YSES (BY SAFETY KLEEN) AND HAZARDOUS WASTE SHIP-
     MENT MANIFESTS (JUNE 2,1988, AUGUST 3,1988, SPETEM
     BER 27,1988, DECEMBER 19,1988, APRIL 12,1989, JUNE 15,1989)
I    THERMAL TREATMENT INSPECTION REPORTS
J    FACILITY SAFETY AND EMERGENCY EQUIPMENT
     INSPECTION REPORTS
K    FACILITY SAFETY AND EMERGENCY EQUIPMENT
     INSPECTION PLAN
L    CONTINGENCY PLAN
M    BURN PIT LOGS
N    SATELLITE STORAGE AREA INSPECTION REPORT FOR MAY 17,
     1989
O    RCRA PART A PERMIT APPLICATIONS
P    HAZARDOUS WASTE MANIFEST FOR JULY 14,1989
Q    HAZARDOUS WASTE MANIFEST NO. CWM 289234
R    NOTIFICATION FOR UNDERGROUND STORAGE TANKS
S    NOTIFICATION OF UST CLOSURE SAMPLE RESULTS
T    PERMIT TO CONSTRUCT AND OPERATE A BERYLLIUM
     ROCKET PROPELLENT LABORATORY AND TEST FIRING
     FACILITY
U    BERYLLIUM PERMIT MODIFICATION
V    BERYLLIUM FACILITY OPERATOR TRAINING
W    VIRGINIA AIR CONTROL BOARD REGISTRATION
X    LIST OF HAZARDOUS MATERIALS EXCEEDING 10,000 POUNDS

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     APPENDIX A



TSCA INSPECTION FORMS

-------
                      US ENVIRONMENTAL'PROTECTION AGENCY
                                WASHINGTON, DC 20440

                          TOXIC SUBSTANCES CONTROL ACT

      DECLARATION OF CONFIDENTIAL BUSINESS INFORMATION
                                                                                                             Form Approved
                                                                                                             OMB No. 2070-0007
                                                                                                             Expirts 3-31-88
                1. INVESTIGATION IDENTIFICATION
,3ATE.
INSPECTOR NO.
  INSPECTOR ADDRESS
   frO.   & yx  is-
                                          DAILVSEQ. NO.
                                            2. FIRM NAME
                                                                                                    7-0
                                INFORMATION DESIGNATED AS CONFIDENTIAL BUSINESS INFORMATION
        NO.
                                                                     DESCRIPTION
       N
                                                                      P     e-.* *.-/
                                              ACKNOWLEDGEMENT BY CLAIMANT

     The undmignfld Kknowiedgw that thi information dacrilxd abovi ii dniputid as Confidant*! Buttnatt Information undar Saction U(c) of tha
     Toxic SubttincM Control Act Tha undareignad furthar acknowHadgat that ha/tfta i* authorizad to maka tuch claims for his/har firm.

     The undareignad undarstands that challangas to confidantiality daims may ba mada, and that claims va not likaty to ba upheld unless tha infor-
     mation meats tha following gukWinaa: (1) Tha company has taken measures to protact tha confidentiality of tha information and it intends to
     continue to take such  measures;  (2)  Tha information is not,  and has not bean reasonably attainable without tha company's consent by other
     persons (other than governmental bodies) by  use of legitimate means (other than discovery based on a showing of special need in a judicial or
     quasi-judicial proceeding); (3) The information is not publidy  available elsewhere; and (4)  Disclosure of tha information would causa substantial
     harm to the company's competitive position.
               ATUR6
                           ^_-
                                                                 CLAIMANT SIGNATURE
 AM 6
                                                                 NAME
                                          OAfESIGNEb
                                             VltLE
                                                                                                           DATE SIGNED

:PA Form 774O-2 (12-8ZJ
                                                                                                                  INSPECTION FILE

-------
US ENVIRONMENTAL PROTECTION AGENCY
A ^r%JL WASHINGTON. DC 204«o Form Approved.
^^*^.^^^Jf\ TOXIC SUBSTANCES CONTROL ACT // 3 V- * ^ OMB No. 2070-0007
v^^VB^B^MM //--// <-J / Approval expires 3-31 -88
^^••l f\ RECEIPT FOR SAMPLES AND DOCUMENTS '
1. INVESTIGATION IDENTIFICATION 2. FIRM NAME
DATE / /
y//7/*^
INSPECTOR NO. OAILYSEQ.NO. -**-/ ^y ' "^ ' ^- <- &. t^ ± tr sr^e^-J-s <- GcX-/^
/^/^f '2~
INSPESTTJR SIGNATUf
55g^:
NAMS— -^ ("~ "
tf<-'{*e+-4f
M ^^7 RECIPIENT SIGNATURED
^—^^/^ ^? £23r//&<*7 ^^^^
"T^^O^ <^C />%" ^ j/—-^^
^^c^-.^^^^^^^^ ^ >^ ^^
-^c^/^,^^, v< NAMe /7/j^; ^ ^w
"^f^/ut,g~n.e-~7* DATE SIGNED TITLE DATE SIGNED
^^tix^^^>e E,V/*H>hiM">^/ ^TT3t
-------
US ENVIRONMENTAL PROTECTION AGENCY
AMIJIIBIJJk m* WASHINGTON, DC 20460 , Form Approved
• • B^% jj y// SI -3 OMB Ho. 2070-0007
^•BUMBiHM^^ TOXIC SUBSTANCES CONTROL ACT ffJj~~U-J Expires 3-31 -88
^^~" ^» TSCA INSPECTION CONFIDENTIALITY NOTICE
1. INVESTIGATION IDENTIFICATION
DATE . , INSPECTOR NO. DAILY SEQ. NO.
V/'7/*o
3. INSPECTOR NAME
tP<~>£tT+^e~ i- ._,/«, / & *-* j t-c^t^L J/2.
5, INSPECTOR ADDRESS
/* o. &** ±^H7 J £,^c ^ &U06 ^3
Oc'^t-'c*; c~ ^ ^ °*2. 2-J"

1. FIRM NAME
.4-/^/T7<^7T. c ft- 1~ s f s^-/z- <, rr c (j(^/o
/V/u-^~ £-t<& 6**!- py^sr^T
4. FIRM ADDRESS
5" ? y j- c-^
-------
US ENVIRONMENTAL PROTECTION AGENCY
^•k •MV^J& WASHINGTON, 00 20400
^K^ir^F^Gk TOXIC SUBSTANCES CONTROL ACT
^^••i ** NOTICE OF INSPECTION /-/ 3^" 0 /
1 INVESTIGATION IDENTIFICATION 2. TIME 3. FIRM NAME
DATE / , INSPECTOR NO. DAILY SEQ. NO. ,/ ,f A ' <-*• ~ TL^ /«_£"-. £- rf r£~*-
eY//7/'^0 P/^tr /2/^^sr £>£ sji
4 INSPECTOR ADDRESS 5. F IRM ADDRESS
P,O, /5^x^ ZJ~2-2-7y 6> L ,j & ,5""-? 0 ^^ IT-«,,_~ -
St^^^^^i C, ^ S-O^-g G+fSSis/n. E- , u/i
REASON FOR INSPECTION
Under the authority of Section 1 1 of the Toxic Substances Control Act :
Form Approved
OMB No. 2070-0007
Expires 3- 3^-55
/71 CO £-fi -
" T~
t<3



j2- For the purpose of inspecting (including taking samples, photographs, statements, and other inspection activities) an establish-
ment, facility, or other premises in which chemical substances or mixtures or articles containing same
essed or stored, or held before or after their distribution in commerce (including records, files, papers,
are manufactured, proc-
processes, controls, and
facilities) and any conveyance being used to transport chemical substances, mixtures, or articles containing same in connection
with their distribution in commerce (including records, files, papers, processes, controls, and facilities]
bearing on whether the
requirements of the Act applicable to the chemical substances, mixtures, or articles within or associated with such premises or
conveyance have been complied with.
L~H In addition, this inspection extends to (Check appropriate blocks):
d A. Financial data d D. Personnel data
D B. Sales data D E. Research data
DC. Pricing data
The nature and extent of inspection of such data specified in A through E above is as follows;
iNSPEC^rmsiGNVryjiE ^^ ^- RECIPIENT SIGNATURE^-) ,
J^-^^<^-^^ . <::3~j/)%?^L/
——-7 -^ X*r-*^>'*-*-"2-«^ — S^S* / I' / ' —- 	
•^^~ i* s.£&*^*^ ^^ xvO^V"-r / ^ 	 «?^
lisCCTf' k^T'
TITLE_ BATESlGN§b ' 	 TITLE 	 ' J —
e-x^v^/^c/-^ *^r (g^^T-^c / /o/Y
e^t.^r-eT*. ///7/^ £*^>*^t °*h'c«'







, — • 	 •

DATE SIGNED
INSPECTION FILE

-------
 APPENDIX B



PHOTOGRAPHS

-------
 Original pictures forwarded to
        EPA Region III
Environmental Services Division
   Victor Guide, Acting Chief

-------
           B-l
Thermal treatment burn pit 2

-------
                                       B-2
                 Thermal treatment burn area between pits 1 and 2
^ygS^gqaMrr*,-      —  "" ~" ' ' ' ^


-------
        B-3

Satellite storage area 116
                             x\
  \x-xx
  '\,X

-------
                                     B-4
                         Thermal treatment burn pit 2
                                «^?^^^@K
                                '  7»-7srvnr n  *• TV ->i/V- AV-^-A
•V,

-------
           B-5
Thermal treatment burn pit 2

-------
                 B-6
Outslope of thermal treatment burn pit 1

-------
           B-7
Satellite storage area 107

-------
           B-8
Satellite storage area 105

-------
          B-9
Satellite storage area 85
                   V*.

-------
           B-10

    Satellite storage area 5
HAZARDOUS WASTE
FEOEML LAI

-------
         B-ll
Satellite storage area 41

-------
         B-12
Satellite storage area 46

-------
         B-13
Spillage at used oil UST

-------
             APPENDIX C



HAZARDOUS WASTE ACCUMULATION AREAS

-------
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                        WASHINGTON, D.C. 20460
                                                       OFFICE OF

                                              SOLID WASTE AND EMERGENCY RESPONSE
Michael E. Young
Environmental Compliance Officer
Atlantic Research Corporation
Propulsion Division
7511 Wellington Road
Gainesville, VA  22065-1699

Dear Mr. Young:

    This is in response to your November 30, 1987 letter to
Michael Petruska concerning your hazardous waste container storage
areas.

    The storage areas you describe appear to be satellite accumula-
tion areas.  A satellite accumulation area must be at or near any
point of generation where wastes initially accumulate.  The satel-
lite accumulation area should also be under the control of the
person operating the waste generation process, and your operation
appears to meet these criteria.

    If ARC accumulates no more than 55 gallons of hazardous waste
or one quart of acutely hazardous wastes at each satellite area and
follows the other requirements of 40 CFR 262.34(c), the areas would
not be subject to permitting, interim status, or the requirements
for generator storage at Section 262.34(a).

    If you have further questions in this area, please continue to
communicate with Michael Petruska of my staff at (202) 475-8551.

                                       Sincerely,
                                          V
                                       Marcia E. Williams
                                       Director
                                       Office of Solid Waste

-------
                                          ci:
                        ATLANTIC  RESEARCH CORPORATION
"3OPULSION DIVISION 75 *1 VX E'_'_ NG^C^ RD  GAiNE5V!l_,_E. V iRGilMlA 22065-1693


                                            Nove-T.ber 30, 1987
       Mr. Michael Petruska
       Environmental Protection Agency
1
        401 M Street, SW
        Washington, DC  20460

        Dear Mr. Petruska:

            Atlantic Research Corporation  (ARC) requests a formal clarification
        of CFR 40 Section 262. 34 (c) (1) as it pertains to cur facility at
        5945 Wellington Road in Gainesville, Virginia.  The plant, which
        is 420 acres and comprised of approximately 150 snail buildings,
        manufactures solid rocket propellant.  In it's operations, ARC
        generates waste chemicals which are accumulated in containers located
        in storage sheds outside of the buildings generating the materials.
        The waste chemicals are accumulated outside of the buildings for
        safety reasons due to the explosive nature of the work conducted.
        The waste chemical containers are moved from the storage shed once
        they are filled and taken to our waste chemical storage facility
        where the start accumulation begins and arrangements for off-site
        disposal at a TSD facility are made.

           ARC believes that the storage sheds described above satisfy
        the requirements for satellite storage as descibed in CFR 40
        Section 262. 34 (c) (1) .  ARC's storage sheds are located as close as
        safety permits 'to the operation generating the waste chemicals and
        no more than one container per material is located in any single
        shed.  ARC consulted EPA's Industry Assistance Group about our
        storage facilities.  The Industry Assictance personnel stated our
        facilities do fall under the definition of CTR 40 Section 262. 34 (c) (1)
        and referred us to you for a written confirmation of their
        interpretation .

           If you have any questions or need additional information, contact
       me at (703) 642-6411.
                                            Michael 6K Young
                                            Environmental Compliance Officer
       MY/as

-------
Mtfantlc Research Corporation

Virginia Propulsion Division
                                                    5945 Wellington Road
                                                 Gainesville, Virg'ma 22065
                                                       (703) 642 6000
                                        April  1,  1989
   Patrick Grover
   Department of Waste  Management
   Commonwealth of  Virginia
   Eleventh Floor Monroe  Building
   101 North  14th Street
   Richmond, Virginia   23219

   Dear Mr. Grover:

        The holding pads,  where  waste  explosives  and propellants are
   held until the weekly  thermal treatment operations are conducted,
   were redefined as accumulation  areas  during the recent inspection.
   This interpretation  has never been  proposed until now.  ARC has
   taken the actions discussed below to  comply with this new
   interpretation.

        The following sites,  identified  by the building number the
   pads are associated  with,  are now designated accumulation areas
   for the storing  of waste explosive  and propellants:
   5-6
   41
   76
   90
   1 16
          Hot Trash  Pads

      10         15         28
      42         48         70
      78         85         86
      97         100a       103
      117        225        255
35
73
87
105
40
74
88
106
        The containers  for  this  waste are now labeled as shown on the
   attached label. The  label  will  be  replaced each v/eek, as necessary
   to maintain ledgibility, as  the waste is collected to be moved to
   the thermal treatment  units.  The  accumulation start date will
   placed on each label after each collection.   The previous v/eek 's
   date will be crossed out as  the new date is entered.  Waterproof
   labels are being ordered which  will not need to be replaced as
   frequently. This new system  will bring the waste explosives
   accumulation activities  in line with the new interpretation.

        If you have any questions  or  comments please call me at
   703-642-6411 .
                                 Sincerely,

                                 ATLANTIC RESEARCH CORPORATION
                                  Mike 'Young
                                  Environmental Officer
ARC
a subsidiary of Sfquo Corporation

-------
            EXAMPLE OF LACEL  TO  "!. USED
                   .••'..L.i,-;11. 'Jo s  ,.i i t
       FEDERAL L'V.i1  : '•";:•! I'; [ i 5  {"' '  "i'l UISi'CSAL
IF FOUND CONTACT  ri'E  NCWLSl  'LMICE, PUBLIC  STU
AUTMU;:ITY OR TII^  i:  s.  .':-.. i ;-"Y!: •: (-•!  r;;uiiCTiu:i
AGENCY

WASTE  EXPLOSIVES   :UU03)
GENERATOR:   ATLANTIC  RESEARCH  LCI'.I'll'.ATIUfi
     5945 WELLINGTON  RUA'J,  GAKir.SVILLE, VA 220G5
EPA  I.D.  t:   VAD02:7417C5
ACCUMULATION START  DATE:

-------
                       ATLANTIC RESEARCH  CORPORATION
OPULSION DIVISION -7511 WELLINGTON RD. GAINESVILLE. VIRGINIA 32065-1899  7C3-S^2-SCOQ

                                               March 1,  1988


    Cynthia  Bailey
    Executive  Director
    Virginia Department  of Waste Management
    llth  Floor Monroe  Building
    101 North  14th Street
    Richmond,  VA  23219

    Dear  Ms. Bailey:

           Pursuant to  §6.4.E.2.e. of the Ccmonwealth of Virginia's
    Hazardous  Waste Management Regulations, Atlantic Research Corporation
     (ARC)  is notifying the Virginia Department of Waste- Management  (VC&M)
    of ARC's accumulation areas for hazardous waste at the Gainesville, VA
    facility (VAD023741705) .

           The Gainesville facility has three types of hazardous waste
    accumulation areas:  1)  hot trash area; 2) satellite storage area; and
    3) chemical  waste  handling area.  At the hot trash area, hot trash is
    accumulated  in drums and  then is taken to the thermal treatment facility—
    on site  for  disposal.   These drums are emptied approximately once a
    week.  The satellite storage areas are used to accumulate waste materials
    which are  to be disposed  of off-site.  Once the containers are filled,
    they  are taken to  the their disposal within the  ninety day limit.  A
    list  of  the  location of these areas and a reference map are attached.

           If  you have any questions, please contact me at  (703)642-6448.

                                               Sincerely,

                                               ATLANTIC RESEARCH CORPORATION
                                               Melisa T. Cohen
                                               Environmental Engineer
    MTC:mh
    cc:    Susan Young  (VDW1)
    Attachments  (2)

-------
PROPULSION DIVISION
Accunulation Area Associated with The
5
15
28
29
35
40
41
42
46
48
70
73
74
76
78
81
84
85
86
87
88
90
100
103
105
106
107
116
117
175
191 253
200
201
202
203
206
222
235
236
240

-------
               GAINESVILLE FACILITY    ATLANTIC  RESEARCH CORPORATION
        *^Mi«tr«ic  ••'
ATLANTIC  RESEARCH COftPOHATON
         ftlMC  PLAHT
                                               X

-------
X - DESIGNATES APPROXIMATE SITE OF ACCUMULATION AREAS (ALL TYPES)

-------
               APPENDIX D



CONSENT AGREEMENT AND CONSENT ORDER (1984)

-------
  ER,  KALER. GRIMES  &  SHRIVER
            ATTORNEYS AT  LAW
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
j PAUL 9 RIGHT JR »
P*UL OANiEL
THOMAS 0 WASH8URNE *
LEWIS C STR'jOwiC* *
^*^PENCE 0 ~OLc,MAN
CARL'LE C RING jH
THOMAS 8 EASTMAN •
FREDERICK S HIRO jfl
GEORGE T TYLER
WILLIAM L BALFOUR '
SHERWOOD S SMITH JH
WILLIAM A SNYOER. JR
P.ICHARQ R JACKSON jR
DAVID W CHOSLANO. Ill
JESALD J OPPEL *
PAUL M VINCENT
JOHN M WEST. Ill *
ROBERT v BARTON. JR
ALAN j MOGOL
JOHN C BALDWIN * *
WARREN 8 QALV, -R **
-•AMES B WiELAND
ROBERT L ASH

COUNSEL
EMORT r NUNNELEY

r^A.N^ a OSES
(1889-19811
WILLIAM A GRIMES
(I9O* -19771
11912-1977)
LINDA DALLAS HEiOER
DEBORAH A RANDALL
PA M£ LA J WH'TE
CARLA G KATZEN8EHG *
JOHN M KINSEr *
ROBERT E MAZER •
THOMAS S. SPENCER '
JONATHAN A CHASE '
GUY W WARTIELO

KEVIN A OU NNE *
JAMES E EDWARDS. JH *
JOHN N. ROOOCK
MICHAEL F SCHATf '
ROBERT L.EHRLICH. JH '
JOSEPH A GUZINSKI *
HOANN NICHOLS •
*NQT ADMITTED IN O. t.

   710 RING BUILDING

iaoo EIGHTEENTH STREET N w

 WASHINGTON. 0. C. 20036

     I2O2I 331 • 9iOO
                                                       AND NATIONAL BANK BUILDING

                                                       IO LIGHT STREET

                                                       MORE MARYLAND 21202

                                                        I30M 685-1120

                                                        CAQLE PITNEY1

                                                        TELEX 8-7774
                 ONE EXCHANGE PLAZA

                  AT 55 3P.OAOWAT

               NEW VQRK, NEW "OP* OOC6
                   1 2 ! 21  f *2 i*OO

                  CABLE  PI'-NE-' N*«
                                                                35 WEST PINC STREET
                                                               ORLANDO. PLOOIOA 32301
                                                                  (3OSI 641 • 2SI2
                                                                  CABLE 'RlTNEV
                                                                  TELEX 6-7774
                                       June 1, 1984
       Mr.  Ralph W. Siskind
       Assistant Regional Counsel
       United States Environmental
         Protection Agency
       Region III
       6th & Walnut Streets
       Philadelphia, PA  19106

       Dear Mr. Siskind:

            In accordance with your  letter,  I  am  enclosing  the  original  copy
       of the Consent Agreement and  Consent  Order which was signed by William
       Kreitz on June 1, 1984.

            We are very grateful for the extension  and cooperation of your office
       in resolving this matter.

                                                Sincerely,
                                               Carlyle  C.  Ring,  Jr.
       Enclosures
       cc:   Mr.  William Kreitz
          yMr.  Michael Young

-------
   BEFORE THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          REGION III
In Re

Atlantic Research Corporation
7511 Wellington Road
Gainesville, Virginia
                  Respondent
Docket No. RCRA-III-098

Consent Agreement and
Consent Order
                    Preliminary Statement
1.  This administrative proceeding requiring certain actions
    and assessing a civil penalty was initiated pursuant to
    Section 3008(a) of the Resource Conservation and Recovery
    Act, 42 U.S.C. § 6928 (the Act).  The United States En-
    vironmental Protection Agency (EPA)  issued a Complaint,
    Compliance Order and Notice of Opportunity for Hearing on
    March 16,  1984 against Respondent.  The Complaint alleged
    that Respondent, in violation of the Act, operated a
    hazardous  waste management facility without a permit.

2.  For the purposes of this proceeding, Respondent admits
    the jurisdictional allegations of the Complaint.

3.  For the purposes of this proceeding, Respondent neither
    admits nor denies the facts contained in the Complaint and
    in the Findings of Fact in this Consent Agreement.

4.  Respondent hereby expressly waives its right to request a
    hearing on any issue of fact or law set forth in the
    Complaint  or herein.

5.  Respondent consents to the issuance of this Consent
    Agreement  and Consent Order and agrees to comply with its
    terms.

6.  In mitigation of the penalty proposed in the Complaint,
    Respondent states:

    a.  Respondent has been operating its "Hot Trash Pit" for
        approximately 20 years without any inadvertant detonation,
        fragmentation or mishap.  It is used to burn waste from
        Respondent's solid propellant operations.

    b.  Respondent has been and continues to operate this pit
        under  the requirements of the Department of Defense (DOD).

    c.  The DOD requirements for this type of operation were used
        by EPA as the basis for regulation 40 C.F.R. S 265.382 -
        Open Burning.  EPA did not, however, incorporate the
        DOD requirements in full in its regulation.

-------
                            - 2 -
    d.  Respondent was informed by a representative of the
        Commonwealth of Virginia Department of Health that it
        was a small quantity generator and did not have to
        submit a Part A Permit Application in order to qxialify
        for interim status and continue its operation of the
        pit.

    e.  DOD regulations prohibit the long term accumulation of
        the material being burned in the pit and Department
        of Transportation regulations prohibit its transportation
        off-site .

    EPA has determined, as set forth in the Complaint, that
    the date for submission of a Part A for this facility
    will be extended to January 19, 1984 pursuant to regulation
    40 C.F.R. §  270.10(a)(3).  Respondent then, is, considered
    to qualify for interim status and is subject to the
    applicable requirements and regulations.

    EPA and Respondent agree that the facility will, for
    enforcement  purposes, be considered in compliance with
    regulation 40 C.F.R.  § 265.382 if its open burning
    activities conform to Chapter 5 of Army Regulation
    AR385-64.  (See Attachment 1)
                       Findings of Fact
1.  Respondent is the owner and operator of a business in
    Gainesville, Virginia which includes a facility for open
    burning of hazardous waste listed or identified under
    Section 3001 of the Act, 42 U.S.C. S 6921.

2.  Respondent's facility was in operation prior to and has
    been in operation since August 18, 1980.

3.  Respondent submitted to EPA a Notification of Hazardous
    Waste Activity for this facility on August 18, 1980.

4.  Respondent submitted to EPA a Part A Permit Application for
    this facility on January 19, 1984.


                      Conclusions of Law


1.  Section 3005(a) of Subtitle C of the Act, 42 U.S.C.
    S 6925(a), prohibits the treatment, storage or disposal
    of hazardous waste listed or identified under Subtitle C
    except in accordance with regulations requiring a permit
    for such activity.

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2.   Section 3005(e)  of the Act and regulations 40 C.F.R.
    §§  270.70 through .73 provide that an owner or operator
    shall be treated as having been issued a permit pending
    final administrative disposition of the permit application
    if  the following requirements for attaining interim status
    are met:  (1)  compliance with the notification provision
    in  Section 3010(a) of the Act, 42 U.S.C. § 6930(a), if
    applicable,  (2)  submission of a Part A Permit Application
    by  November  19,  1980 and (3)  facility in existence on
    November 19,  1980.

3.   Respondent's  facility is an "existing hazardous waste
    management facility" as defined in regulation 40 C.F.R.
    § 260.10.

4.   Respondent's  facility did not qualify for interim status
    due to its failure to submit  a timely Part A Permit
    Application  except by virtue  of the extension provided by
    the Complaint  and paragraph 7 of the Preliminary Statement.

5.   By  reason of  the facts set forth in the Complaint and
    Findings of  Fact, it is concluded that Respondent has
    operated a hazardous waste management facility without a
    permit, in violation of regulations promulgated under
    Section 3005  of  the Act and Section 3005 of the Act,
    which are requirements of Subtitle C of the Act.

For Respondent:
 June 1,  1984
Date                             William £.Kraitz
                                 Director, Contracts and Material
For Complainant
Date                             Ralph W. Siskind
                                 Assistant Regional Counsel

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   BEFORE THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          REGION III
In Re

Atlantic Research Corporation
7511 Wellington Road
Gainesville, Virginia
                  Respondent
    Docket No. RCRA-III-098

    Consent Order
This Consent Agreement and Consent Order is hereby adopted
and issued pursuant to Sections 3008(a), (c) and (g) of the
Act, 42 U.S.C. §§ 6928(a), (c) and (g), and the consolidated
Rules of Practice Governing the Administrative Assessment of
Civil Penalties, 40 C.F.R. Part 22.  Respondent is hereby
ordered to pay a civil penalty in the amount of $1,800
to the United States no later than 60 days from receipt of
this Consent Order by Respondent.

Payment shall be made by cashier's or certified check, payable
to the Treasurer, United States of America.  Remittance shall
be sent to the Regional Hearing Clerk, EPA Region III, Curtis
Building, 6th & Walnut Streets, Philadelphia, Pennsylvania
19106.

Failure to make timely payment shall result in referral of
the matter to the United States Attorney for recovery of the
amount by action in the appropriate United States District Court
Date
Thomas P. Eichler
Regional Administrator
EPA Region III

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             APPENDIX E



ADMINISTRATIVE ORDER ON CONSENT (1989)

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                                              P . Q 2
                                             UNITED STATES

                                    ENVIRONMENTAL PROTECTION AGENCY

                                               REGION III
                     IN TH£ MATTER OFi

                     Atlantic Research Corporation
                     5945  Wellington Road
                     Gainesville,  Virginia
                     VAD 02 374 1705
                   ADMINISTRATIVE ORDEK ON CONSENT
                      .  EPA Docket N'O.
                        RCRA-riI-024-rA
                                RHSPOMOENT.
                                                         Proceeding undac Section
                                                         3008(n) of th« Resource
                                                         Conservation and Recyvary
                                                         Act, as amended, 42 u.S.C.
                                                         5 6928(h).
                          This  Wminlstrativt Order on Consent ("Conocnt Order"
                   «r  *0rd«r")  is ifl.«u«d pursuant tn th* authority vested in tho
                   Administrator"of th« united States Environmental Protection
                   Agency ("EPA")  by Section 300fl(n) of th* Solid Wasto Disposal
                   Act,  cotwaonly referred to as tha R«»ourc-« Conservation and
                   Recovery Act of 1576, aa amended by the Hazardous and Solid
                   Wasto Amendments of 1984 (collectively referred to hereinafter
                   aa  "RCRA"),  42 U.S.C. ! 693101)»  Th« authority veatad in the
                   Administrator has been delegated to the Regional Administrators
                   by  EPA delegation Noa. 3-31 and 8-32 dated Match fl, 1986.

                          On December 14, 19U4, th* EPA granted the Commonwealth
                   of  Virginia  (the "State") authorization to operate a hazardous
                   vasta program in lieu of the Federal program pursuant to
                   Section 3006(b) of RCRA, 42 U.S.C. $ $926(b).  The 3tat»,
                   however,  do*s not have authority to enforce Section 5 3008(h)
                   of  RCRA.

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                          This Consent OrOr Is  l3ai.ie
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                                                                P . 0-4
                              .1-
IV.
                                  OF
       A,   -Respondent is a corporation doing business in the
Commonwealth af Virginia' and U a pcrann as defined in section
1004(15) of RCRA, 42 U.S.C. S 690.1(15).

       S.   Respondent in * qenoratar of hazardous waste and
an owner and/Or operator of a hazardous waste management fa-
cility located at 5945 Wellinrjf.ori Road, Gainesville, Virginia.
Respondent angagvd in treatment, storage and/or disposal of haz-
ardous wast* at the facility,  specifically, ARC manufactures
rocket engines producinq hazardous waste oy-nroducts that are
burn«d in open pits.

       C.   Respondent owned and op«r4t«d tha Facility as a
hazardous waste management facility on and after November 19.
1980, tha applicable date which renders facilities subject to
interim status requirements or th« requirement to have a per-
mit undar SS 3004 and 3005 of RCRA, 42 u.s.C. }$ 6924 and
692!.

       D,   Pursuant to S 3010 of RCRA, 42 U.S.C. 5 «930, Re-
spondent notified EPA of its hazardous wastw activity.  In
its notification, dated Auqust 18, 1930, Respondent identified
itself as a generator of hazardous waste and as 
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(=, p R,—  2 — 9> 0  MON  11:09
                                   — HWMD  P H I 1_ f
                                                         P . 03
liSmisss^ff^ s;a
                               :?.'K.L" «.«"s.;:"u?!«
                                         a nanvfae,  sconce,  and testing
                          Decora and yao gurerator*.   Ohwr operations include
                 administration and  laboratory  re.«*arch.  The Facility includse
                 three RCRA^perrM tted thermal tr*»dcnenc unica where spent  ener-
                 getic materials  ar« treated.  Solv^nca .have been 'j?»
                 3it«  aa degreasl.icj agants, and ooNe
                at several location
                     -,. ..auorator

      ..,ie« xcxA^perml tted  thermal  . ._^,icnc unica whete spent «ner
      cetic materials are treated.  Solvents .have been used at the
      sin as c'egrsastfls acants,  and solvent releases have occurred
      at several locattonOi


            H,   After  initiation of testing by ARC, ARC talephoned
     SPA on  February  5, 1937 and  informed SI»A that ground water
     production wells 72A and  72B located oneifre ware sampled~*nd
     found to contain organic hazardous waste constituents.  Ad-
     ditional wells were sampled  on-site which  also showed organic
     hazardous  waste constituents  present  In the ground  water.   A
     surface  water sample,  taken from Pin«»y  Srancn  CrecK which
     runs through the  Site/  showed organic hazardous  waste con-
    stituents.  Soil  sample* taken on-site  in an area whare
    solvents w»re allegedly  disposed, also showed high levels of
    organic hazardous waste  constituents.   Five domestic well*
    in the immediate vicinity of  the ARC facility were  sampled.
    Of those,  one domestic well showed te.trachloroethene at
    levels below EPA'a Maximum Contaminant Laval (MCL)»  Subse-
   cuent testing did  not validate t.hos« results and  indicated
   that  contamination in that  well did not originate from ARC.

         I.    «^11 samples  were  also tjken  from a 20'X40' araa
   on-site believed to be a  farmer solvent disposal are*.  Up
   Co  130 ppb 1/1,1  trichloroethane was  found in the  area.


         J,   Hazardous wastes and/or hazardous constituents may
  migrate  from the  Facility  into the environment via the path-
  ways f>f surface water/ and/or ground water.


        K.   The hazardous  wastes and/«r  hazardous constituents
  identified  in paragraph-* » through r above may poa« a  threat
  to human health and  the environment.   Human health  impacts  for
  each of these conatituenta  are described in the Administrative
  Record.



        L.   Respondent's Facility is located upgradiont of
 several private residential well  supplies/  however/  there
 are  no puftJfa wtee- supply systems within several  miles of
 the Site-. Sotwral  Intermittent streams flow through the Site
 to Bread Rurr> which feod
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            ARC has
 a Plan of AC-'.O.-. (
:o deiine and develop
                                  .-H  jr.c^rtcak  ptaLi.tir.ar/
5j:e         n  an    eveop  ".u  aporspriec*  PC A.   £PA
approved the POA on Ju.is  24, :;>S3. "The  POA ir.ciud*g  *ab-
stantial cornponantc of  both  the  PPI-arid  IM.
           V . Cg;jCLtJ3 IONS. CF' ^AW A-HD  QSYS
       aaacd on the finding^ of  fact  s«t  out  JDOV«,  ind after
conaideration of  the Administrative  Record,  EPA,  haa made
the following canclusior.a  of law and  determinations :

       A.   ?.«soondent  is  4  "ocraon"  wichin  th* mii*ni.ig of
Section 1004(15)  of RCRA,  42 U.S.C.  § 0903d1;).

       B.   Respondent  i3/w*»  the owner ^nd/or  operator of
a facility authorized to operate under  §  JCO'(«)  o£  W
42 y.S.C. §
       C.   Certain wastes  founrf  at  the  facility are  "nazardou*
       or hazardous constituents  thereof a^  dsfinca by §  1004(5)
of SCRA, 42 U-S.C. § 6903(5).  These Are also hazardous wastes
or h«?ardou8 const xtuenta within  LJi9 meaning of  § 3001 of RCRA,
42 C.S.i.. $ 6^21 4nd 40 C.T.R. Part  261.

       D-   Then is yr haa  bean  a  caleaaa of hazardous wa*t*s
nnd/or hasardftus constituents  into  the environment teon
Respondent's Facility wM-.hin the  meaning of  § 300fl(h) of  RCRA
42 II.S.C. 5 6928 (h) .

       E.   Tht  actions rsquircd  by f->iis Consent Order arc
        y to protect human  health yr chc envi ronment .
                       VI.  WORK  TO  BE  PERFORMED
       SPA AOknowltdgas  th«t  Rtapondent.  li«a  prepared and iub-
mitt«d the POA itr cooparation with  SPA and that EPA approved
and authorirad implamentation of  chae  POA by l»tt«r dated
June 24, 1988.  In particular,  tho  PDA m*«ts the IM provisions
of thia Order afl a«t out  in paragraph  B  below;  and tht RFI work-
plan requiremanta *» act  out  in paragraph P  and 5.  Therefore,
EPA considura tha POA  to  bw equivalent to an RTl Workplan
with ihe oxccptions citad under paragraph B.

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                            -6-
      Pursuant to S 300fl(h) y£ P.CRA, 42 'J.S.C. J «923(h), Re-
 spondent agrees to ar.d is hereby ordered to perform the fol-
 lowing acts in the manner and by the dates specified herein.
 All work undertaken pursuant to this Consent Order shall
 be developed and performed in « mano#r consistent-, with,
 at a minimum:  the Scope of Work for Interim M«aaure(0) sat
 forth in Attachment A; th* Scope of Work for a SCRA Facility
 Investigation sat forth in Attachment 8; the Scop* of Work
 for a Corrtctiva Measures Study sat forth In Attachment C;
 RCRA and its implementing rsgulations; and relevant EPA
 guidance documents.  All Scopes of Work and othar Att«ch-
 nento to this Consent Order are incorporated herein &y
 reference.  Relevant o«id«nce jnay include, but is not
 limited to, taa "P.CRA facility Investigation (Pfl) Guidance"
 (EPA S30/SW-87-001), "RCSA GrounU Water Monitoring Technical
 Enforcement Guidance Document" (OSWt'R Directive 9950.1,
 September  1986), "T«»t Methods For Evaluating Soiid Wastw"
 (SW-846, November 1986) and "Construction Oualit-y Assurance
 far Hazardous Waste Land Disposal Faciliti*?" (EPA 330/SW-
 85-031, July 19B6).
-is"
                   INTERIM MEASURES (IH)

      A.  The Interim M*«»ur«» to be undertaken by Respondent
 at the facility shall include?

          1,  Installation of an air otripper and <,-*rbon
              treatment units to provide potable drinking
              w»ter from the Facility's ground water produc-
              tion wells.  The »«id unit haa been installed
              with EPA approval.

          2.  Removal of all Volatile Organic Compound!
              (VOCs) to KCL levels through the placement
              of rip rap/stone or other measures from
              ill stream* leaving the property.

          3.  Diipo«»l or treatment it) accordance with RCRA
              of fluids in floor drain tanks where level*
              of organic hazardous waste constituent* are
              a factor in possible off-site miqrationi

          4.  improvement of on-aita  satellite chemical
              storage facilities.

          5.  Disposal or treatment  in  accordance with RCRA,
              of soils where  lev*I* of organic hazardous
              waste constituents  are  a  factor  in possible
              off-site migration.

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                                                             p . ea
     8.  Tha POA submitted  to  arr!  *pproct  to
approval by £PA and shall b« dsveloped to include tha
      desorib«d in paragraph Q,  abAv<>.
     n.  Upon receipt of SPA 
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                            -8-
             PfJBLIC COMMFMT ,».VO ?.» ".rr-
     I.  ypon approval ey TPA of •; Correct iv* Measure Study
     t/^EPA ah-ill ;r. a** byth the R"RA facility Investigation
Report (or summary o-f report-.) and che Corrective Measure
study Rupert (or summary of report) and a summary ot EPA's
proposed corrective m^aajre And EPA 'a justification for pro-
posing election of chat corrective m^aaura available to
she public for review and comment tor at least 21 calendar
days.

     J.  following the public review ^nd comment period,
SPA shall notify K«3ponJ«nt ot ch* final eorrtctive 
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            MON  11:11  EPl=i — HUIMD   P H I
                                                                             P .  1 0
                       on
              vithin.  10 calendar days of  r*cajpt of  SPA's  com-
        „.» on the workpJan, report or other submission , Scspon-
     dant shall submit to EPA for approval a revisad wcrkplan,
     report, 'or other submission,  which  respond* to and/or
     remedies any  def iy  th# t«nth day of  th« foilowino month.
   Th«  birnonthly pro*i-e- --- •*
            «h*" -
                                                ,...^««  pursu
                            	.~rn.ui<,"  below,

      P.  All work porformarf pursuant  ho this Consent Ordar
 shall fie under tho direction and supervision of « profes-
 sional  »rigln««r or gaologiat with exp«rtis* in hazardous
 waate site  cleanup.   Before the commoncwaient of work for
 this  Consent  Order,  Respondent  shall  submit to EPA,  in
 writing, the  narso, title,  and qualifications of the  engineer
or geologist  and of any contractor* or subcontractors  to
be u»ed in carrvi**     th« terms of this Consent Order.
m»                      *w of any pro/a«B<^	'
                                                 	«»c co EPA, in
                               -^.^.B, ana qualification* of the engl
            -.  y
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                                                               1 1
     0.  SPA -nay dut-sr.ninw trial csrtair. t.iska and deliver-
ablca including, but net limited tut investigatory work or
enc;ine«ring evaluation nay tequue additional work.  These
ia.sks and deliveraftles may or nuy not have- been in the IM
or RPI Wd"rl or oth«r aubmlaaion* in tho #v»nt that
R»spanc'»nc do«» not perform such additional work.
                  vri.
     Throughout all sample colir«eion* and analysis activi-
tieg> Rtspondwnt shall us» EPA-«pprov«d quality assurance/
quality control, and chain-of-custody procedures as specified
in the approved vorkplans.  Tha'RFI Workplan submitted to and
approved by EPA included tha abovo statad r«quir#ments.

     To #neure continuing compHanoo with approved quality
assurance/Quality cyntrol programs/ EPA may rcqu«»t Respond-
ent '§ laboratory to parform analyx«« of saniplts provided by
EPA to demonstrate th« quality of the analytical data.
       VIII..  PUBLIC HgVIEK OF AnMrN.ISTHATiyg  RgCORP

     The Administrative Record lupportlng tho  isauane*  of
this Consent Order will b« available  for public  review  on
Mondays through Fridays, from 9:00 a.m. to  5)00  p.m.  by
contacting*.

             Richard J. Dulcey   (3HW11)
             0.S. Environmental  Protection  Agency
             841 Chestnut Building
             Philadelphia/ Pennsylvania   1910?
             Telephone  (213)  597-9377

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—  2 — 9 0  MOM
                   1 1  : 1 2  EPft — HUIMD  PHIUPi
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                             IX.  CM-5.ITE AND OFF-SITE ACCF53

                   A.  &PA and/or its authorized t^preservatives shall have
               the- authority to wnter and ^reely TOVC aa«ut all property *i
               the Facility during th* effective dates of cMs Consent
               Order Cor the- purnosai of, inter alia!  interviewing Facility
               personnel and =onnractoro! inspect:ing records, operating
               logs, and contracts related to the Facility; reviewing the
               progress of the Respondent in carrying out the terms of this
               Consent Order; conducting such tests, sampling or monitoring
               A3 EPA or its Project Coordinator deom necessary; using a
               camera, sound recording, or other documentary typo equipment)
               and verifying the reports and data submitted to SPA by the
               Respondent.  The Respondent shall permit such persons to
               inspect and copy all r*cocds, files, photographs, documents,
               and nther writings, including ail sampling and monitoring
               data, that pertain to worK undertaken"pursuant to thio Con-
               sent Order,  while on Respondent's property, EPA, Respondent
               and their authorized representatives shall comply with all
               approved health and safety plans.  SPA alae agrees to comply
               with security measures required by the Department of Defense
               regaling Mational d«fer.s« related sensitive information
               or areas of the Facility.

                   B.  To the extent that worx required by this Consent Or-
               der, or £>y any approved Scopes) gf Work or Wotkplan prepared
               pursuant hereto, must b« dotiw on property not owned or con-
               trailed by Respondent, Respondent shall use its bast efforts
               to obtain gita acc«»» agreement* Crom the present own*r(s)
               of ouch property within 14 calendar days of. receipt of ?PA
               approval of any Scop* o£ Worh or Workplan pursuant to this
               Order which requires work on property which 
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                                                              P . 1 3
        X._ SAMPLING A_NC 3ATA/C CCl'MZMT AVAI LA 1=11L IT y

    A.  Tils Respondent shall submit-, to rPA the results of
all sampling and/or tests or fltrh«r data Generated by, or on
behalf of the Raspondcnt, •> ° accordance with the requirements
of this Consent Order and attachments hereto.

    B.  Respondent throuoh its Bimonthly Reports ahall
keep ~?A fully advised o£ its schedule for all rieJd activi-
ties, including scheduled dates of initiation and duration,
E?A may request idvanco notice of specified fiwld activities
and unon such request Respondent shall notify EPA at least
14 calendar days In advance  of engaging in any such field
activities.  At the request  of GPA, Respondent shall provide
or allow EPA or its authorized representatives to take
split <*nd/or duplicate s^-nplea of all samples collected by
Respondent pursuant to thi3  Consent Ordwr,  EPA shall uie
its Sest «f£ort5 to promptly notify Respondent of th«
results of any aueh sampling.  Similarly, it the request
of Respondent, PPA shall allow Respondent or its authorized
representatives to take split or duplicate samples of all
samplss collected by EPA under this Consent Order.  EPA
will notify Respondent at least 14 calendar days before
conducting any sampling under this Consent Order.

     C.  Respondent may assert n business confidentiality
claim in the manner described in 40 C.F.R, S 2.203(b> cover-
ing all or part of any information submitted to SPA pursuant
to thio Consent Ordvr.  Any  assertion of confidentiality
snail Se adequately substantiated by Respondent wh«n the
assertion is made in accordance with 40 C.F.F. $ 2,204(e) (4).
Information determined to be confidential by SPA shall be
disclosed only to the extent ywrmittcd by 40 C.F.R. Part  2,
Subpart 8.  If no such confidentiality claim accompanies
the information when it is. submitted t« EPA, it may be
mado available to the public by EPA without further notice
to th« Respondent.  Respondent agrees nofc to assert any
confidentiality clai* with regard to any phyiical, sampling,
monitoring or analytical data.
                  XI,  RECORD PRESERVATION

     Respondent agree* that it ahall preserve, during tha
pendency of thi» Conaont order and for a minimum of at
least 6 years after its termination, all data, record* and
documents in its po«s«*aion or in the possession of its
divisions, officttr», directors, employ we»( agents, contrac-
torsr successors, and assigns which relate in any way to
this Consont Order or to haiardous va*fce management and/or
disposal at the Facility.  Respondent shall  notify EPA at

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                              PHIL-A
                                                              R . 1 4
                            -13-
      30 calendar days pr:ot ;o sh« desUuction of any
sue!-! records, and shall provide £?A with tho opportunity
to inspect, copy «*nd/o,r take possession of any 3uch records,
                 XII. _ i'RO.7FCT COORDINATOR

         EPA designate* the following Project Coordinator:
         _   _ . rtf-*r-a\Ocey  (3HW11)  --
         U.S. Environmental Protection
         841 Chestnut Building
         Philadelphia, TA  19107
         (215)  597-9377

         Respondent designate* the following Project Coordinator:

         Michael Ifoung
         Atlantic Research Corporation
         5945 Wellington Poad
         Gainesville, Virginia  22C63
         (703)  642-6411

     Each Project Coordinator shall bw responsible for
           the implementation o£ thia Consent Order.  Thw
EPA Project Coordinator will be KFA'* primary designated
representative  at the facility.  To the maximum extent
possible* all communications between Respondent and EPA,
and all documents, reports, approvals, and other correspon-
dence concerning the activities performed pursuant to the
terms and conditions Of this Consent Order, shall bo directed
through the Project Coordinator.

     3.   The parties agree to provide at least 7 calendar
days written notice prior to changing Project Coordinator*.

     C.   If EPA determines that activities in compliance or
nonoompliance with this Consent Order* have caused or may
cause a release or threatened release, of hazardous wastes,
hazardous constituents, hazardous substances, pollutants or
conta&ttfatnts; which threaten or may pooe a threat to the
public health or welfare or to the environment, SPA may
direct Respondent to stop further implementation of this
Consent Order for such period of time as may be needed to
abate any such release or threatened release and/or to un-
dertake any action which EPA determines is necessary to
abate such release or threatened release*  A written direc-
tive from EPA to Respondent to stop work when Respondent
is in compliance with this Consent Order shall toll the
assessment of stipulated penalties in Section XIV, bolow,
a) for the specific matter or matters impacted by the etop

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                            -14-


work order, b)   for the time that the stop work order
remains in place and c)  while Respondent maintains compli-
ance with"~all other provisions of this Order.

     0,   The absence of the EPA Project Coordinator from
the Facility shall not be cause for the stoppage of work.


                    XIII.  NOTIFICATION

     Unless otherwise specified, reports, correspondence,
approvals, disapprovals, notices, or other submissions
relating to or required under this Consent Order shall be
in writing*  Four copies of all such documents shall be
submitted to the EPA Project Coordinator and documents to
be submitted to the Respondent shall be sent to its
Project Coordinator.  One copy of those documents shall be
sent tos  Pat Grover, Virginia Department of Waste Manage-
ment, llth Floor, Monroe Building, 101 N. 14th Street,
Richmond, Virginia  23219.


      XIV.  DELAY IN PERFORMANCE/STIPULATED PENALTIES

     A.  Unless there has been" a written modification of a
compliance date by EPA, or excusable delay as defined below
in Section XVI, "FORCE MAJEURB AND EXCUSABLE DELAY," in
the event Respondent fails to meet any requirement set
forth in this Consent Order, Respondent shall pay stipulated
penalties, as set forth below upon written demand by EPA.
Compliance by Respondent shall include commencement or com-
pletion of an activity under this Consent Order or a plan
approved under this Consent Order or any matter under this
Consent Order in an acceptable manner and within the speci-
fied time schedules in and approved under this Consent Order*

1.   For failure to commence or complete work as prescribed
     in this consent Order:  $2,000 per day  for one to four-
     teen days or p*rt  thereof of delay, and $5,000 per  day
     for each day of delay/ or part thereof/ thereafter;

2«   For failure* to submit any draft or final reports at the
     time required pursuant to this Consent  Order:  $1/000 per
     day for on* to  fourteen days or part thereof of delay/
     and  $4,000 per day  for each  day of delay» or part
     thereof/ thereafter;

-------
3,    For failure to submit bimonthly progress reports at the
     time required pursuant to this Consent Order:   S500 =er
     day for one to fourteen days or part thereof of delay,
     and $2,000 per day for each day of delay, or part
     thereof, thereafter;

4.    For failure to submit other deliverables required by .
     this Consent Order.-  $500 per day for the first one
     to fourteen days or part thereof of delay,  and 52,000
     per day for each day of delay, or part thereof, there-
     after;

5.    Tor other failure to comply with provisions of this
     Consent Order after notice of non-compliance by EPA:
     $3,000 per day for the first one to fourteen days or
     part thereof of delay, and $5,000 per day for each
     day of delay, or part thereof, thereafter.

     B.  All penalties shall begin to accrue on the date
that complete performance is due or a violation occurs,
and shall continue to accrue through the final day or
correction of the noncorapliance.  Nothing herein shall
prevent the simultaneous accrual of separate stipulated
penalties for separate violations of this Consent order.

     C.  All penalties owed to EPA under this section (XIV)
shall be due within 30 calendar days of receipt of a notifi-
cation of noncompliance.  Such notification shall describe
the noncompliance and shall j.ndicate the amount of penalties
due.  Interest shall begin to accrue on the unpaid balance
at the end of the 30 calendar day period and shall accrue
at the United States Treasury Tax and Loan rate.

     D.  All penalty payments shall be made by certified or
cashier's check payable to the Treasurer of the United States
of America and shall be remitted to:

           Regional Hearing Clerk
           U. S. Environmental Protection Agency* Region III
     ••     P.O. Box 360515M
       '    Pittsburgh, Pennsylvania  15251

All payments shall reference the name of the Facility,
Respondent's nan* and address1, and the EPA docket number of
this Order.  Copies of the tranemittal of payment shall be
sent simultaneously to the EPA Project Coordinator and the
Regional Hearing Clerk  (3RCOO), U.S. Environmental  Protection
Agency, Region III, 841 Chestnut Building, Philadelphia,. Penn-
sylvania   19107-

-------
                            -16-
     S.  Respondent may dispute EPA's right to the stated
amount of penalties by invoking the dispute resolution pro-
cedures be-low under Section XV, "DISPUTE RESOLUTION."  To the
extent that Respondent does not prevail upon resolution of
the dispute, Respondent shall remit to EPA within seven (7)
calendar days of receipt of such resolution any outstanding
penalty payment, including any accrued interest, in the man-
ner described above in Paragraph D of this section.  To the
extent Respondent prevails upon resolution of the dispute,
no penalties shall be payable.

     F.  Neither the filing of a petition to resolve a dis-
pute nor the payment of penalties shall alter in any way
Respondent's obligation to comply with requirements of this
Consent Order.  This Consent Order shall be interpreted
and implemented in a manner consistent with the resolution
of any dispute resolved pursuant to Section XV.

     0.  Tht stipulated penalties set forth in this section
(XIV) do not preclude EPA from pursuing any other remedies
or sanctions which may be available to EPA by reason of
Respondent's failure to comply with any of the requirements
of this Consent Order.
                  XV.  DISPUTE RESOLUTION

     A.   If Respondent disagrees, in whole or in part, with
any EPA disapproval, modification or other decision or
directive made by EPA pursuant to this Consent Order, Respon«
dent shall notify EPA in writing of its objections, and the
basis therefor, within 14 calendar days of receipt of EPA's
disapproval, modification, decision, or directive.  Said
notice shall set forth the specific points of the dispute,
the position which Respondent asserts should be adopted as
consistent with the requirements of this Consent Order, the
basis for Respondent's position, and any matters which it
considers necessary for EPA's determination.  EPA and Re-
spondent shall have an additional 14 calendar days from the
receipt by EPA of the, notification of objection, during
which tIM< representatives of EPA and Respondent may confer
in person or by telephone to resolve any disagreement.  If
an agreement is reached, the resolution shall be written
and signed by representatives of each party and the Consent
Order will thenceforth be interpreted in accordance with
that resolution*  In the event that resolution is  not
reached within this  14 calendar day period, EPA shall
provide Respondent  its decision on  the pending dispute.
Thereafter, Respondent and EPA may pursue whatever remedies
they may have under  law.

-------
                            -17-


      B.   The existence of a dispute, as defined in this
section (XV), and EPA's consideration of matters placed into
dispute shall not excuse,  toll or suspend any compliance
obligation or deadline required pursuant to this Consent
Order firing the pendency of the dispute resolution process.
Respondent may request and EPA may,  in its discretion,  modify
any deadlines for matters which are  or have been the subject
of a dispute under this Section*

      C.   Notwithstanding any other provisions of this Con-
sent Order, no action or decision by EPA, including, but
without limitation to, decisions of  the Regional Administrator,
Region III, pursuant to this Consent Order, shall constitute
final agency action giving rise to any rights to judicial
review prior to EPA's initiation of  judicial action to compel
Respondent's compliance with this Consent Order.


          XVI.  FORCE MAJEURE AND EXCUSABLE DELAY

     A.  Respondent shall perform the requirements of this
Consent Order within th« time limits sat forth herein,  unless
the performance is prevented or delayed by events which
constitute a force majeure.  Respondent shall have the burden
of proving such a force majeure.  A force majeure is defined
as any event arising from causes not reasonably foreseeable
and beyond the control of Respondent, which cannot ba over-
coma by dua diligence and which delays or prevents perfor-
manca by a date required by this Consent Ordar.  Such events
do not includa increased costs of performance, changed
economic circumstances, reasonably foreseeable weather
conditions or weather conditions which could have baan
overcome by due diligence, or failure to obtain Federal,
State, or local permits.  If Respondent seasonably applies
for Federal, State, or local permits or actions, and the
Federal, State, or local authority fails to act upon such
application within a reasonable time, the delay thereby
caused shall ba deemed, for the purposes of this Consent
Order, to be a force majeura event.

     B.  Respondent shall notify EPA, in writing, within 7
calendar days after it becomes aware of any event which
causes* or say cause a delay in complying with any require-
ment of thi« Consent Order and any event which Respondent
claim* constitutes a force majeura.   Such notice shall
estimata tha anticipated  length of delay, including neces-
sary demobilization and remobilization,  its cause, measures
taken or to be taken to prevent or minimize the delay, and
an estimated timetable for implementation of  these  measures.
Failure to comply with tha notice provision of  this section

-------
                            -18-
(XVI) shall constitute a waiver of Respondent's right to as-
sert a force ma_jeur_e claim with respect to such event,

     C.  If EPA determines that the delay has been or win
be caused by circumstances not reasonably foreseeable and
beyond the control of Respondent, which cannot be overcome
by due diligence, the time for performance for that require-
ment of this Consent Order may be extended, upon EPA approval,
for a period equal to the delay resulting from such circum-
stances,  This shall be accomplished through an amendment
to this Consent Order pursuant to Section XXI, "SUBSEQUENT
MODIFICATION."  Such as extension does not alter the schedule
for performance or completion of any other tasks required
by this Consent Order, unless these tasks are also specif-
ically altered by amendment of the Consent Order.  In the
event that EPA and Respondent cannot agree that any delay
or failure has been or will be caused by circumstances not
reasonably foreseeable and beyond the control of Respondent,
which cannot be overcome by due diligence, or if there is
no agreement on the length of the extension, the dispute
shall be resolved in accordance with Section XV, "DISPUTE
RESOLUTION."
                XVII.  RESERVATION OF RIGHTS

     A.  EPA expressly reserves all rights and defenses that
it may have, including the right both to disapprove of work
performed by Respondent pursuant to this Order and to request
that Respondent perform ta^-.s in addition to those stated in
the Scope(s) of Work.

     B.  EPA hereby reserves all of its statutory and regula-
tory powers, authorities, rights, remedies, both legal and
equitable, which may pertain to Respondent's failure to com-
ply with any of the requirements of this Consent Order,
including, without limitation, the assessment of penalties
under  S 3008(h)(2> of RCRA, 42 U.S.C. $ 6928(h)(2).  This
Consent..Order shall not be construed as a covenant not to
sue, or as a relene, vaivtr or limitation of any rights,
remediety power• and/or authorities, civil or criminal,
which  Efft ha* under RCRA, CERCLA, or any other statutory,
regulatory or eonaon  law enforcement authority of the
united Statea.

     C.  Compliance by Respondent with  the terms of  this
Consent Order shall not relieve Respondent of  it* obliga-
tions  to comply with  RCRA or any other  applicable  local,
state, or Federal  lawa and  regulations*

-------
                            -19-


     D.  The signing of this Consent Order and Respondent's
consent to comply shall not limit or otherwise preclude the
EPA from taking additional enforcement action pursuant to
Section 3008(h) of RCRA, 42 U.S.C. $ 6928(h), should the EPA
determine that such actions are warranted.

     E.  This Consent Order is not intended to be/  nor shall
it be construed as, a permit.  This Consent Order does not
relieve Respondent of any obligation to obtain and  comply
with any local, State, or Federal permits.

     F.  EPA reserves the right to perform any portion of
the work consented to herein or any additional site charac-
terization, feasibility study, and response/corrective
actions as it deems necessary to protect public health or
welfare or the environment.  EPA may exercise its authority
under $ 7003 of RCRA and CERCLA to undertake removal actions
or remedial actions at any time,  in any event, EPA reserves
its right to seek reimbursement from Respondent for such
additional costs incurred by the United States.  Notwith-
standing compliance with the terms of this Consent  Order,
Respondent is not released from liability, if any,  for the
costs of any response actions taken by EPA.


                    XVIII.  OTHER CLAIMS

     Nothing in this Consent Order shall constitute or be
construed as a release from any claim/ cause of action or
demand in law or equity against any person, firm/ partner-
ship, or corporation for any liability it may have  arising
out of or relating in any way to the generation/ storage,
treatment/ handling/ transportation/ release, or disposal
of any hazardous constituents, hazardous substances/ hazar-
dous wastes, pollutants/ or contaminants found at,  taken
to/ or taken from the Facility*
                XIX*  OTHER APPLICABLE LAWS
         >   '
     Alt action* required to be taken pursuant to this Con-
sent Order snail be undertaken in accordance with the
requirements of all applicable local/ State/ and Federal
laws and regulations.  Respondent shall obtain or cause its
representatives to obtain all permits and approvals neces-
sary under such laws and regulations.

-------
                            -20-
    XX.  INDEMNIFICATION OF THE UNITED STATES GOVERNMENT

     Respondent agrees to indemnify and save and hold harm-
less the United States Government/ its agencies, departments,
agents, and employees, from any and all claims or causes of
action arising from or on account of acts or omissions of
Respondent or its agents, independent contractors, receivers,
trustees, and assigns in carrying out activities required by
this Consent Order.  This indemnification shall not be con-
strued in any way as affecting or limiting the rights or
obligations of Respondent or the United States under their
various contracts.
                XXI. SUBSEQUENT MODIFICATION

     A.  This Consent Order may only be amended by mutual
agreement of EPA and Respondent.  Any amendment shall be in
writing, shall be signed by both parties, shall have as theiri
effective date the date on which they are signed by EPA, and
shall be incorporated into this Consent Order.  EPA agrees
to use its best efforts to respond in a timely manner to
any request by Respondent to modify this Consent Order.

     a.  Any reports, plans, specifications, schedules, and
attachments required by this Consent Order are, upon written
approval by EPA, incorporated into this Consent Order.  Any
noncompliance with such EPA-approved reports, plans, speci-
fications, schedules, and attachments shall be considered a
violation of this Consent Order and shall subject Respondent
to the stipulated penalty provisions included in Section XIV,
above, "DELAY IN PERFORMANCE/STIPULATED PENALTIES."

     C.  No informal advice, guidance, suggestions, or com-
ments by EPA regarding reports, plans, specifications, sched-
ules, and any other writing submitted by Respondent will be
construed as relieving Respondent of its obligation to obtain
written approval, if and when required by this Consent Order.


              V'i  . XXII.  SEVERABILITY

     If any provision or authority of  this Consent Order or
the  application of this Consent Order  to any  party or  circum-
stances is held by any judicial or administrative authority
to be  invalid, the application  of such provisions to  other
parties or circumstances and the remainder of this Consent
Order  shall not be affected thereby  and  shall remain  in full
force.

-------
                             -21-
             XXIII.  TERMINATION AND SATISFACTION

       The provisions of this Consent Order shall be decreed
satisfied upon Respondent's receipt of written notice from
EPA that Respondent has demonstrated, to the satisfaction of
EPA, that the terms of this Consent Order,  including any
additional tasks determined by EPA to be required pursuant
to this Consent Order, have been satisfactorily completed.
This notice shall not, however, terminate Respondent's obli-
gation to comply with Sections XI  ('RECORD PRESERVATION"),
XVII ('RESERVATION OF RIGHTS"), XIX  ("OTHER APPLICABLE LAWS,'
EPA shall use its best efforts to provide timely responses
to Respondent's written notice to  EPA that Respondent has
completed its obligations, including any additional work,
pursuant to this Consent Order.
                    XXIV,  EFFECTIVE OATS

       The effective date of this Consent Order shall be the
date on which it  is signed by  EPA.  Because this Order was
entered with the  consent of both parties. Respondent waives
its right to request a public  hearing pursuant to Section
3008(b) of RCRA,  42 U.S.C. $ 6928(b).
IT IS SO AGREED  AND ORDERED:
Date:
                       BY:
                          Altantie
                                      President and General Counsel
                                     esearch Corporation
 Dates
                           Edvin B. Erickson
                           Regional Administrator
                           United States Environmental
                           Protection Agency, Region IXZ

-------
                   APPENDIX F
ARC ANALYTICAL DATA - SOIL SAMPLES NEAR BUILDING 20

-------
            From ARC  Interim RFI  Report
TABLE 4-54  BUILDING 201 LABORATORY METALS ANALYTICAL RESULTS
REFERENCE
SAMPLE DEPTH (FT)
SAMPLE NUMBER
DATE
QAQC

•METALS*
(Aluminum
| Antimony
Arsenic
Bar i un
(Beryllium
Cadmium
(Calcium
(Chromium
(Cobalt
(Copper
Iron
Lead
(Magnesium
(Manganese
(Mercury
(Nickel
(Potassium
(Selenium
(Silver
| Sodium
(Thallium
(Vanadium
Zinc
SS33333333333333333!
[COMMENTS
FD-201
0.0-3.0
02923
8/04/89

(PPB)

20100
41.2 S
11.1
1780
943
12.9
221000
96.8
25.7 3
415
107000
80.5
18500
1480
132
37.8 B
3320 B

13.3
6430

53.4
622
z
TB201-08
0.0-2.0
02925
8/04/89

(PPM)

35400

2.8
94.9
1.7

4820
171
38.9
39.4
51600
7.2
5710
802

47.1
705

1.7
315

173
40.4
z
•••• JJT**^***^
TB201-09
0.0-2.0
02926
8/04/89

(PPM)

24900

B
55.9
0.87

7700
55.2
12
36.7
22000
1.5
4830
176
0.14
28.9
B 441

B
B 1220

56.6
21.2
z
^33333333=33333
TB201-10
0.0-2.0
02927
8/04/89

(PPM)

40400

1.1
72.9
B 1.3
1.5
8410
123
B 29.3
53.2
43800
2.3
10300
755

52.6
B 504

1
B 1070

109
43.8
z
3333S3V3333X3ZX
TB201-12
0.0-2.0
02930
8/07/89

(PPM)

28100

B 0.99
96.4
1.7

3390
147
39.6
32
43700
B 6.9
5740
1190

44.7
B 412 B

B 1.1 B
B 440 B

141
33.1
z
TB201-14
0.0-2.0
02932
8/07/89

(PPM)

20900
9.3 B
5.1
78.9
2.1

1430
199
68.2
21.9
63500
21.9
3060
2070

27.5
496 B

1.6 B
176 B

238
40.2
z
                                                1-239

-------
FIGURE 4-33
ARC BUILDING 201
SAMPLING LOCATIONS
METALS-FEB. 1,1990
             LEGEND
O  SOIL BORING LOCATION
   (FIELD OVA SCREENING)
A  SOIL BORING LOCATION (FIELD OVA
   SCREENING,  LAB ANALYSIS - SOIL)
A  SOIL BORING LOCATION,  COMPLETED AS
A  A WELL  (FIELD OVA  SCREENING,  LAB
   ANALYSIS - SOIL  8 WATER)
•   SEPTIC TANK  LOCATION
   SOIL a WATER
           50
 IOO
_J
                    FT
^UH! GROUNDWATER
          TECHNOLOGY, INC.

-------
                   APPENDIX G

HAZARDOUS WASTE MANIFESTS FOR NOVEMBER 20,1987, AND
                  JANUARY 7, 1988

-------
                      I tar uaa or
                                  {12
                                                                                                     io&o-ooas.
 UNIFORM HAZARDOUS
    WASTE MANIFEST
                               1. Generator's US EPA 10 No.
                                                               Manrtest Document No.

                                                                01 Cfcl
                         2. Pagei
Information m me inaded areas
« not required by F«deru law
3.  Generator's Name and Mailing Address
                                                                                  A. SUM MwiifMt Docurn«fn NumMr
                                                                                           O t OO I
                                                                                  8. St*M Qcrwroofi 10
5.  Transporter 1 Company Nan*
                                                          US EPA ID Numb*
                        C. 8MttTfan«pofW»iD
                                                                                                                    9 9*.
7. Transpomr 2 Company Name
                                                          US EPA 10 Nurnbar
                        6. Stata Tranaponcft 10
                                                                                  F. Tfin
9.  0««gnat«d Facility Nam* and Sit* Address
                                                   10.
US EPA ID Number
                                                                                  Q. State Fsctftty-s 1O
                                                                                  H. FaoUtysPhooe
11. US DOT Description'(Tnc/udtnc Proper S/Hpp*ny A/ame, Hazard Oest and /O Mumper)
                                                                          12. Containers
                                 13.
                                Total  '
                               Quantity
                                                                                                     14.
                                                                                                     Unit
                                                                                                    Wt/Vol
               Waste No.
b.
J. Addtton^r^eacrlptiom for UateriaisUeted Above
                                                                                 K. Henttng Code* tor Wastes UstedAoove
15.  Special Handling Instructions and Additional Information
   oiMUUTON'* cwmnomoN:
   proper Mppng name and •>•
                                 d*eur* uwi tn*
                                                raa olttm eonaignmani ara (uHy and accmaialy daacriMd atto»« by
                                            and labatad. and ara m a» taaaaets In prepar conoHen tar tranapen by Mel>»a>
   if I wnat
                           , I eertty Met I «••»• • program M puc* to r*due«
            IB human hiUMi ane the om»onB>em; OH. M I MI a i
                                                              th« *e
                              tot Mectipi o< Materials
    Prtn»»d/TypedN«ne
                                                         Signature
                                              Month 0«y  '
                                              I     I     i
19.

20. FeciltyOwntf or Operator Certlflc»<>ono« receipt o«rmardouem«ter^
               Nam*
                                                                                                        Month  oey  >»•
                   Oto. at Ainenean UMmerk Co. inc. KM44
                                                                              CM tam (TOO^a (Me« KM) r^rneut •dban* an
                                        OfttOtNAt-ACTUflM TO OCNUUTOft

-------
                              '  jit tx* H- -e  'C-nnc" 'vnew"e<-
                                                                                         Forni
                                                                                               OMB No  2050-0039 Eiuires 930-88
          IFORM HAZARDOUS
          WASTE MANIFEST
                               i Generators US EPA lO No
                               VAD023741705
                                                                     Maniles: Document No
                                                                   Q1QQ.1
2 Page i
  ol  i
                                                                                                 Information in the shaded areas
                                                                                                 is not required Oy Federal law
3  Generators Name and Mailing Address
    ..ulantic  research  Corporstio
    ji-^j '..'el 1 i lie ton Roau,  Gci
4  Generaior s Pnore i  703   '  n$.?-c.
                                                                                         A  State Manifest Document Numoer
                                                                                            0100]	
                                                      ',  Virginia   220S5
          'ansponer ' Con^oanv Name
          l-.'azmat  Env. Group
                                                   6        US EPA ID NumDer
                                                   I   NYD980769947
                                                                                     C  State Transporter's IDNYD9r.n7fiQQ/n
                                                                                   D  Transporter's Phone (7] fi ^
          •anspone' 2 Ccmsany Name
                                                                 US EPA ID Numoer
                                                                                   E. Slate Transporters ID
                                                                                         F  Transporter's Phone
I ,9  Designated Facility Name and Site Address
      Safety  Kleen  Envirosysterns
      State  Hwy  146
      :;ew  Castle, Kentucky   40050
                                                         10
                                                                 US EPA ID NumDer
                                                                                   G. Slate Facility's ID
                                                                                      KYD053348103
                                                                                         H. Facility's Phone
                                                                                              (502) 345-2453
11  US DOT Description (including Proper Shipping Name. Hazard Class and ID Number)
                                                                                 12. Containers

                                                                                  No    Type
                                                                                             13.
                                                                                            Total
                                                                                           Quantity
                                                                                                        14.
                                                                                                        Unit
                                                                                                       VWVol
                          Waste No.
           *Q  i-'aste  Flammable Liquid  N.O.S,
            Flammable Liquid  UN  1993
                                                                                        DfJ
     -ysoo
                                                                                                             D001
               |aste   1,1,1-Trichloroethaiie
                ORM-A   UN  2831
                                                                                   DM
                                                                                                               F001
      d.
      J. Additional Descriptions tor Materials LJsttd A5ov«
                                                                                   K. Handling Codas for W«s»s Listed Above

                                                                                   T63
       15. Special Handing instructions and Additional Information
                                                                                          6K
       16  GENERATOR'S CERTIFICATION i h«r«Cy Otciart tn«t in* contcmt at inn eontignm««ii arc fully and accurately dticribM afiov* By
          progtr snioomg njmt tna art classified, packed, markad. and labeled, and are in all respect) in proper condition for transport by highway
          according to appiicaDie international and national government regulation*.

          If I am a large quantity generator. I certify that I nave a program m place to reduce tne volume and toiicily of waate generated to Ine degree I have determined to t»
          •conomicaliy practicable ana mat I nave selected tne practicable met nod of treatment, storage, or diapoaaJ currently availabM 10 me wfticn mmimues ine present and
          future threat to human nealtn and ine environment OR if I am a small quantity generator, t nave made a good faith eHort to minimize my wute generation and Mlact
       	the oest waste management metnod tnat is available to me and that I can (Mora                 	
          Printed/Typed Name
         T, ,~c.-'Tkw   '5". I-
                                                          Signature
                                                                                                            Month Day  VMT
                                                                                                            \r\7  \Jj
       17 Transporter 1  Acknowiftdganwm of Receipt of Materials
          Primed/Typed Name
                                                            Signature
                                                                                                          Month Dty  y»u
                                                                                                          I/  I 7 \yf
       18. Transporter 2 AcKnowtodgement erf Receipt of Matenais
          Printed/Typed Name
                                                          - Signature
                                                                                                          Month  Day
       19. Discrepancy indication Space
•sf
       20. Facility Owner or Operator Certification o( receipt of hazardous materials covered by this manifest except as noted in Item 19.
      Printed/Typed Name
                   YAhcriv-G
                                                          Signat
                       Month  Off
   SlyiePiSHEV-6  LiDetmaster Oiv of American uoeimark Co In:. 60646
                                                                                EPA Form 8700-22 (Rev. 9/86I Previous editions are oBsolen.

-------
                      APPENDIX H

MATERIAL SAFETY DATA SHEETS, WASTE MATERIAL ANALYSES
      (BY SAFETY KLEEN), AND HAZARDOUS WASTE SHIPMENT
    MANIFESTS (JUNE 2, 1988, AUGUST 3, 1988, SEPTEMBER 27,1988,
          DECEMBER 19,1988, APRIL 12,1989, JUNE 15,1989)

-------
                                                                PACE:  1
     DATE:    12/22/89         ACCT:    0*934-5-02
     INDEX:   018935*0016      CAT NO:  T3971            PO NBR:  9C29757

  1*TETRAHYDROFURAN**
  **TETR«HYDROFUR«N«*
  **TETRAHYOROFURI»N*»

                      MATERIAL  SAFETY DATA SHEET


FISHER SCIENTIFIC                       EMERGENCY NUMBER:    C201)  796-7100
CHEMICAL  DIVISION                        CHEMTREC ASSISTANCE:  C800D 4-24--9300
1 REAGENT  LANE
FAIR LAyN  NJ  07*10
C2D15 796-7100

THIS INFORMATION IS BELIEVED  TO BE ACCURATE  AND  REPRESENTS  THE BEST
INFORMATION  CURRENTLY AVAILABLE TO US.   HOWEVER,  WE MAKE NO WARRANTY OF
MERCHANTABILITY  OR ANY OTHER  WARRANTY,  EXPRESS OR IMPLIED,  WITH RESPECT TO
SUCH INFORMATION,  AND WE ASSUME NO LIABILITY  RESULTING FROM ITS USE.   USERS
SHOULD MAKE  THEIR OWN INVESTIGATIONS TO DETERMINE THE SUITABILITY  OF THE
INFORMATION  FOR  THEIR PARTICULAR PURPOSES.


                       SUBSTANCE IDENTIFICATION

                                                       CAS-NUMBER 109-99-9
SUBSTANCE: «»TETRAHYDROFURAN««

TRADE NAMES/SYNONYMSi
  FURAN,  TETRAHYORO-;  BUTANE,  ALPHA,  DELTA-OXIDE,  CYCLOTETRAMETHYLENE OXIDE;
  FURANIDINE,  OXACYCLOPENTANE,  OXOLANE) TETRAMETHYLENE OXIDE;  THF;  RCRA U213,
  STCC 1-908290;  UN 2056, Tt-25,  T4-24-;  T397; T4-00,  C*H8O,  ACC23010

CHEMICAL  FAMILY:
ETHER. ALICYCLIC

MOLECULAR FORMULA:  CS--HS-O

MOLECULAR WEIGHT:  72. 10

CERCLA RATINGS  CSCALE 0-3).   HEALTH=2  FIRE:3  REACTIVITY:!  PERSISTENCE:1
NFPA RATINGS CSCALE 0 - 4-) i    HEALTH;2  FIRE;3   REACTIVITY:!

                      COMPONENTS AND CONTAMINANTS

COMPONENTi TETRAHYDROFURAN                                    PERCENT)  >33

OTHER CONTAMINANTS:  MAY CONTAIN TRACES OF A  PEROXIDATION INHIBITOR.

EXPOSURE  LIMITS:
TETRAHYDROFURAN:
  200 PPM CS90  MG/M3) OSHA  TWA;  250 PPM C735  MG/M3) OSHA STEL
  200 PPM C590  MG/M33 ACGXH TWA,  250 PPM  C735 MG/M33 ACGIH  STEL

  1000 POUND CERCLA SECTION 103 REPORTABLE QUANTITY


                              PHYSICAL DATA

DESCRIPTION.  COLORLESS,  VOLATILE.  MOBILE  LIQUID  WITH AN ETHER-LIKE ODOR.

BOILING POINT,  153 F C67 Cl     MELTING POINT,  -162 F C-108  CJ

SPECIFIC  GRAVITY:  0.8832     VAPOR PRESSURE:  1*3  MMHG a 20 C

EVAPORATION  RATE:  CN-8UTYL  ACETATE:!} 1*.5     SOLUBILXTV XN WATER)  COMPLETE

ODOR THRESHOLD:  20-50 PPM     VAPOR DENSITY:  2. 5

SOLVENT SOLUBILITY:  SOLUBLE IN BENZENE. ALCOHOLS.  ETHERS.  KETONES,  ESTERS.
HYDROCARBONS.

VISCOSITY: 0. 5  OPS a 20 C


     	FIRE AND EXPLOSION DAT*

FIRE AND  EXPLOSION HAZAROi
DANGEROUS FIRE  HAZARD WHEN  EXPOSED TO HEAT OR FLAME.

VAPOR-AIR MIXTURES ARE EXPLOSIVE.

VAPORS ARE HEAVIER THAN AIR AND MAY TRAVEL A  CONSIDERABLE DISTANCE TO A SOURCE
OF IGNITION  AND  FLASH BACK.

FLASH POINT:  6  F C-l* CJ CCC3     UPPER EXPLOSIVE LIMIT:  11.8*

LOWER EXPLOSIVE  LIMIT:  2*     AUTOIGNITION TEMP. :  610 F C321 CJ

FLAMMABILITY CLASSCOSHAJ:  IB

FIREFIGHTING MEDIA:

-------
                                                             PACE:  2
     DOTE:    12/22/89        flCCT:    0*93*5-02
     INDEX:   018935*0015     CAT  NO:  T3971            PO NBR:  9G29757

DRV CHEMICAL,  CARBON DIOXIDE, HALON,  WATER  SPRAY OR ALCOHOL FOAM
C1987 EMERGENCY RESPONSE GUIDEBOOK,  DOT  P  5800. *3.

FOR LARGER FIRES,  USE WATER  SPRAY,  FOG  OR  ALCOHOL FOAM
C1987 EMERGENCY RESPONSE GUIDEBOOK,  DOT  P  5300.*}.

FIREFIGHTING:
MOVE CONTAINER FROM FIRE AREA IF  POSSIBLE.  COOL  FIRE-EXPOSED CONTAINERS WITH
WATER FROM SIDE UNTIL WELL AFTER  FIRE IS OUT.  STAY AWAY FROM STORAGE TANK
ENDS  FOR MASSIVE FIRE IN STORAGE  AREA,  USE UNMANNED HOSE HOLDER OR MONITOR
NOZZLES.  ELSE WITHDRAW FROM  AREA  AND  LET FIRE  BURN.  WITHDRAW IMMEDIATELY IN
CASE OF RISING SOUND FROM VENTING  SAFETY DEVICE  OR ANY DISCOLORATION OF
STORAGE TANK DUE TO FIRE C1987 EMERGENCY RESPONSE GUIDEBOOK,  DOT P 5800.*,
GUIDE PAGE 263.

EXTINGUISH ONLY IF FLOW CAN  BE STOPPED;  USE HATER IN FLOODING AMOUNTS AS FOG,
SOLID STREAMS MAY NOT BE EFFECTIVE.  COOL CONTAINERS WITH FLOODING QUANTITIES
OF WATER,  APPLY FROM AS FAR  A DISTANCE  AS  POSSIBLE.  AVOID BREATHING TOXIC
VAPORS,  KEEP UPWIND  EVACUATE TO  A  RADIUS  OF 1SOO FEET FOR UNCONTROLLABLE
FIRES.  CONSIDER EVACUATION OF DOWNWIND  AREA IF MATERIAL IS LEAKING.

WATER MAY BE INEFFECTIVE CNFPA FIRE  PROTECTION GUIDE ON HAZARDOUS MATERIALS,
EIGHTH EDITION),

ALCOHOL FOAM CNFPA FIRE PROTECTION  GUIDE ON HAZARDOUS MATERIAL,  EIGHTH
EDITION) .


                         TRANSPORTATION  DATA

DEPARTMENT OF TRANSPORTATION HAZARD  CLASSIFICATION *9CFR17Z. 101.
FLAMMABLE LIQUID

DEPARTMENT OF TRANSPORTATION LABELING REQUIREMENTS *9CFR172.101 AND SUBPART Ei
FLAMMABLE LIQUID

DEPARTMENT OF TRANSPORTATION PACKAGING  REQUIREMENTS.  *9CFR173. 119
EXCEPTIONS)  NONE


                              TOXICITV

TETRAHYDROFURANi
TOXICITY DATA:  25000 PPM INHALATION-HUMAN  TCLO,  21000 PPM/3 HOURS
  INHALATION-RAT LC50,  2*000 MG/M3/2  HOURS  INHALATION-MOUSE LCLO,  2816 MG/KG
  ORAL-RAT LDSO,  2900 MG/KG  INTRAPERITONEAL- RAT  LDSO,  1900 MG/KG
  INTRAPERITONEAL-MOUSE LDSO, 500  MG/KG  INTRAPERITONEAL- GUINEA PIG LDLO,
  MUTAGENIC DATA CRTECS).
CARCINOGEN STATUS.  NONE.
LOCAL EFFECTSi  IRRITANT- INHALATION,  EYE.
ACUTE TOXICITY LEVEL.  MODERATELY  TOXIC  BY  INGESTION,  SLIGHTLY TOXIC BY
  INHALATION.
TARGET EFFECTSi  CENTRAL NERVOUS SYSTEM  DEPRESSANT,  POISONING MAY AFFECT THE
  LIVER AND KIDNEYS.
AT INCREASED RISK FROM EXPOSUREi   PERSONS WITH  IMPAIRED LIVER.  KIDNEY,  OR
  PULMONARY FUNCTION,  EYE OR SKIN  DISORDERS.
ADDITIONAL DATA.  ALCOHOL MAY ENHANCE  THE TOXIC EFFECTS.


                    HEALTH EFFECTS  AND  FIRST AID

INHALATION.
TETRAHYDROFURANi
IRRITANT/NARCOTIC.  20. 000 PPM IMMEDIATELY  DANGEROUS TO LIFE OR HEALTH.
  ACUTE EXPOSURE- TECHNICIANS WORKING WITH  TETRAHYDROFURAN EXPERIENCED SEVERE
    OCCIPITAL HEADACHES AND  DULLNESS. OTHER EFFECTS REPORTED FROM HIGH VAPOR
    CONCENTRATIONS INCLUDE MUCOUS  MEMBRANE  IRRITATION WITH SORE THROAT AND
    COUGHING,  NAUSEA,  CENTRAL NERVOUS SYSTEM DEPRESSION WITH WEAKNESS,
    FATIGUE, UNCONSCIOUSNESS AND  POSSIBLY  ASPHYXIATION.  CONCENTRATIONS ABOVE
    25,000 PPM PRODUCED ANESTHESIA  WITH PROLONGED INDUCTION,  PROFUSE
    SALIVATION,  VOMITING.  MARKED  FALL IN BLOOD PRESSURE, POOR MUSCULAR
    RELAXATION,  AND STRONG RESPIRATORY  STIMULATION IN EXPERIMENTAL ANIMALS.
  CHRONIC EXPOSURE- ANIMALS  EXPOSED  TO  OVER 3000 PPM FOR 20 DAYS EXHIBITED
    IRRITATION OF THE UPPER  RESPIRATORY  TRACT.  LIVER AND KIDNEY DAMAGE WAS
    OBSERVED BUT MAY HAVE BEEN DUE  TO IMPURITIES.


FIRST AID- REMOVE FROM EXPOSURE AREA  TO FRESH  AIR IMMEDIATELY.  IF BREATHING
  HAS STOPPED,  PERFORM ARTIFICIAL  RESPIRATION.  KEEP PERSON WARM AND AT REST.
  TREAT SYMPTOMATICALLY AND  SUPPORTIVELY.  GET  MEDICAL ATTENTION IMMEDIATELY.


SKIN CONTACTi
TETRAHYDROFURANi
  ACUTE EXPOSURE- LIQUID APPLIED  TO  THE SKIN OF  196 PERSONS WAS ESSENTIALLY
    NONIRRITATING.  HOWEVER.  AQUEOUS  SOLUTIONS  IN CONCENTRATIONS ABOVE 20X
    HAVE BEEN REPORTED TO CAUSE IRRITATION  WHEN  APPLIED TO RABBIT SKIN.  SKIN
    ABSORPTION MAY OCCUR.
  CHRONIC EXPOSURE- REPEATED OR PROLONGED  EXPOSURE MAY CAUSE IRRITATION.
    DEHYDRATION AND DEFATTING. AND  SUBSEQUENT  DERMATITIS.

-------
                                                                            PACE:   3
      DOTE:    12/22/89           ACCT:     Of93fS-02
      INDEX:   018935*0016       COT  NO:  T3971              PO  NBR:  9G29757


FIRST AID-  REMOVE  CONTAMINATED CLOTHING  AND  SHOES IMMEDIATELY   WASH  AFFECTED
  AREA  WITH SOAP OR MILD  DETERGENT AND LARGE  AMOUNTS OF  WATER  UNTIL  NO
  EVIDENCE  OF  CHEMICAL  REMAINS CAPPROXIMATEL V 15-20  MINUTES!    GET  MEDICAL
  ATTENTION IMMEDIATELY.

EYE  CONTACT:
TETRAHYDROFURAN:
IRRITANT.
  ACUTE  EXPOSURE-  VAPORS  MAY  CAUSE IRRITATION,   REDNESS,  TEARING,  AND  BLURRED
     VISION.  THE  LIQUID  MAY  CAUSE  SEVERE  IRRITATION  OR  POSSIBLY  BURNS
  CHRONIC  EXPOSURE-  REPEATED  OR PROLONGED  EXPOSURE  TO  IRRITANTS MAY  CAUSE
     CONJUNCTIVITIS.

FIRST AID-  WASH  EYES IMMEDIATELY  WITH LARGE  AMOUNTS  OF WATER,   OCCASIONALLY
  LIFTING  UPPER  AND LOWER  LIDS,  UNTIL NO  EVIDENCE OF CHEMICAL  REMAINS CAT
  LEAST  15-20  MINUTES],  CONTINUE  IRRIGATING  WITH  NORMAL  SALINE  UNTIL  THE PH
  HAS RETURNED  TO  NORMAL  C30-60 MINUTES].  COVER WITH STERILE  BANDAGES   GET
  MEDICAL  ATTENTION IMMEDIATELY.

INGESTION:
TETRAHYDROFURANi
  ACUTE  EXPOSURE-  MAY  CAUSE GASTROINTESTINAL  IRRITATION,  SORE  THROAT,
     ABDOMINAL  PAIN.  NAUSEA,  VOMITING,  DIARRHEA,  AND  DULLNESS.   ASPIRATION
     MAY  OCCUR  AND  CAUSE SEVERE LUNG  IRRITATION  AND  POSSIBLY  DELAYED  CHEMICAL
     PNEUMONITIS.
  CHRONIC  EXPOSURE-  REPEATED  AND  PROLONGED EXPOSURE  HAVE BEEN  REPORTED  TO
     CAUSE  LIVER  AND KIDNEY  DAMAGE.

FIRST AID-  IF  THE  PERSON  IS CONSCIOUS AND  NOT CONVULSING,  INDUCE EMESZS BY
  GIVING  SYRUP  OF  IPECAC  FOLLOWED BY  WATER.   CIF VOMITING OCCURS KEEP  THE HEAD
  BELOW  THE HIPS TO PREVENT ASPIRATION}.   REPEAT IN  20  MINUTES  IF NOT  EFFECTIVE
  INITIALLY.  GIVE  ACTIVATED CHARCOAL.  IN  PATIENTS WITH DEPRESSED RESPIRATION
  OR IF  EMESIS  IS  NOT  PRODUCED,  PERFORM  GASTRIC LAVAGE CAUTIOUSLY  CDREISBACH,
  HANDBOOK  OF  POISONING,   12TH ED.].   TREAT  SYMPTOMATICALLY AND  SUPPORTIVELY .
  GASTRIC  LAVAGE SHOULD BE  PERFORMED  BY  QUALIFIED MEDICAL PERSONNEL.   GET
  MEDICAL  ATTENTION IMMEDIATELY.

ANTIDOTE:
NO  SPECIFIC ANTIDOTE.   TREAT SYMPTOMATICALLY  AND SUPPORTIVELY.


                                     REACTIVITY

REACTIVITY:
STABLE  UNDER NORMAL  TEMPERATURES  AND  PRESSURES  IF PEROXIDATION  IS  INHIBITED.
IF  UNINHIBITED,  MAY  FORM  EXPLOSIVE ORGANIC PEROXIDES WHEN EXPOSED  TO AIR.  IF
DISTILLED  OR EVAPORATED TO  DRYNESS,   AN EXPLOSION  MAY OCCUR.

INCOMPATIBILITIES:
TETRAHYDROFURAN:
  ACIDS:   REACTION  AND  POSSIBLE POLYMERIZATION.
  BORANE-TETRAHYDROFURAN  COMPLEXi   POSSIBLE EXPLOSION ON  STORAGE.
  BROMINE:  VIGOROUS REACTION.
  HAFNIUM  TETRACHLORIDEi   VIOLENT  EXOTHERMIC  REACTION.
  LITHIUM  ALUMINUM ALLOVSi  EXPLOSION.
  LITHIUM  ALUMINUM HYDRIDE  CLITHIUM  TETRAHYOROALUMINATE] i  POSSIBLE IGNITION.
  METALLIC  HYDRIDESi  POSSIBLE EXPLOSION  WHEN  HEATED.
  OXIDIZERS CSTRONG)i   FIRE  AND EXPLOSION  HAZARD.
  PLASTICS,  RUBBER,  COATZNCSi   SOME FORMS  ATTACKED.
  POTASSIUM DIOXIDE AND 2-AMXNOPHENOLi  POSSIBLE EXPLOSION.
  POTASSIUM HYDROXIDEi  POSSIBLE EXPLOSION  IN  PRESENCE OF PEROXIDE
     CONTAMINANTS.
  SODIUM  HYDROXIDEi  POSSIBLE  EXPLOSION IN  PRESENCE OF PEROXIDE  CONTAMINANTS.
  SODIUM  TETRAHYDROALUMINATEi   POSSIBLE VIOLENT  EXPLOSION.
  TITANIUM  TETRACHLORIDEi   VIOLENT EXOTHERMIC  REACTION.
  ZIRCONIUM TETRACHLORIDEi  VIOLENT EXOTHERMIC REACTION.

DECOMPOSITION!
THERMAL  DECOMPO8XTXON  PRODUCTS MAY INCLUDE TOXIC  OXIDES  OF CARBON.

POLYMERIZATIONi                                                         t
MAY  POLYMERIZE  EXOTHERMICALLV IN  CONTACT  WXTH SOME ACXDS.


                              STORAGE AND DISPOSAL

OBSERVE  ALL FEDERAL,  STATE  AND LOCAL  REGULATIONS  WHEN STORING OR DISPOSING
OF  THIS  SUBSTANCE.   FOR  ASSISTANCE.  CONTACT THE  DISTRICT  DXRECTOR OF  THE
ENVIRONMENTAL PROTECTION  AGENCY.


                                   SSSTORAGESI

STORE IN ACCORDANCE  WITH  19 CFR 1910.IDS.

BONDING  AND GROUNDING!  SUBSTANCES WITH LOW ELECTROCONDUCTIVITY,  WHICH
MAY  BE IGNITED BY  ELECTROSTATIC SPARKS,   SHOULD  BE STORED IN CONTAINERS
WHICH MEET  THE BONDING  AND  GROUNDING  GUIDELINES SPECIFIED IN  NFPA  77-1983,
RECOMMENDED PRACTICE ON STATIC ELECTRICITY.

-------
       DATE:
       INDEX:
12/22/89
01893SM-0016
ftCCTi
CAT  NO:
Ot-93H-5- 02
T3971
         PAGE:  H-

PO  NBR:   9G297S7
 PROTECT AGAINST  PHYSICAL DAMAGE.   STORE  IN  A COOL,  DARK,  AND WELL  VENTILATED
 OREfl,   AWOY  FROM  SOURCES  OF  HEAT.   OUTSIDE OR DETACHED  STORAGE  IS  PREFERABLE.
 INSIDE  STORAGE SHOULD BE IN A  STANDARD  FLAMMABLE  LIQUIDS STORAGE  ROOM  OR
 CABINET   PERIODICALLY CHECK FOR PEROXIDE CONTENT  AND  MAINTAIN BELOW  1 •/. BY
 ADDING  INHIBITOR.  SEPARATE  FROM OXIDIZING  MATERIALS  CNFPA  1-9,  HAZARDOUS
 CHEMICALS  DATA,   1975}.

 STORE  AWAY  FROM  INCOMPATIBLE SUBSTANCES.


                                     ••DISPOSALS*

 DISPOSAL  MUST  BE  IN  ACCORDANCE WITH  STANDARDS  APPLICABLE TO
 GENERATORS  OF  HAZARDOUS  WASTE,  H-OCFR  262.   EPA  HAZARDOUS  WASTE NUMBER UZ13.
 AVOID  CONTACT  WITH HEAT,  SPARKS,   FLAMES,  OR  OTHER  SOURCES  OF  IGNITION.  VAPORS
 MAY  BE  EXPLOSIVE  AND  POISONOUS;  DO NOT  ALLOW UNNCECESSARY  PERSONNEL.  DO NOT
 OVERHEAT CONTAINERS;  CONTAINERS MAY  VIOLENTLY  RUPTURE AND  TRAVEL  A
 CONSIDERABLE DISTANCE IN HEAT  OP  FIRE.
                             SPILL  AND LEAK  PROCEDURES

 OCCUPATIONAL  SPILL:
 SHUT  OFF IGNITION  SOURCES.   STOP LEAK  IF  YOU  CAN DO IT WITHOUT  RISK.  USE WATER
 SPRAY TO REDUCE VAPORS.   FOR  SMALL  SPILLS.  TAKE  UP  WITH  SAND OR OTHER
 ABSORBENT  MATERIAL AND  PLACE INTO  CONTAINERS FOR  LATER  DISPOSAL.   FOR LARGER
 SPILLS,  DIKE  FAR  AHEAD  OF SPILL FOR LATER DISPOSAL.   NO  SMOKING,   FLAMES  OR
 FLARES  IN  HAZARD  AREA!  KEEP  UNNECESSARY  PEOPLE  AWAY,  ISOLATE HAZARD  AREA AND
 DENY  ENTRY.

 REPORTABLE  QUANTITY  CRO)>  1000  POUNDS
 THE  SUPERFUND  AMENDMENTS AND RE AUTHORIZATION ACT  CSARA)  SECTION  30*  REQUIRES
 THAT  A  RELEASE EQUAL  TO  OR  GREATER THAN  THE  REPORTABLE  QUANTITY  FOR  THIS
 SUBSTANCE  BE  IMMEDIATELY REPORTED  TO  THE LOCAL  EMERGENCY PLANNING COMMITTEE
 AND  THE  STATE  EMERGENCY  RESPONSE COMMISSION  C *0 CFR  355. t-03 .  IF  THE  RELEASE OF
 THIS  SUBSTANCE IS  REPORTABLE UNDER CERCLA SECTION  103.   THE  NATIONAL  RESPONSE
 CENTER  MUST BE NOTIFIED  IMMEDIATELY AT (8003 1-21--SB02 OR C202D H-26-2675 IN THE
 METROPOLITAN  WASHINGTON,  O.  C.  AREA C H-0 CFR  302.63.
                                PROTECTIVE EQUIPMENT

 VENTILATION:
 PROVIDE  LOCAL  EXHAUST  OR GENERAL  DILUTION VENTILATION TO MEET  PUBLISHED
 EXPOSURE LIMITS.   VENTILATION EQUIPMENT MUST  BE  EXPL OSION- PROOF.

 RESPIRATOR:
 THE  FOLLOWING  RESPIRATORS AND  MAXIMUM USE CONCENTRATIONS ARE RECOMMENDATIONS
   BY  THE U. S.   DEPARTMENT OF  HEALTH AND HUMAN SERVICES,   NIOSH POCKET  GUIDE  TO
   CHEMICAL  HAZARDS,  NIOSH CRITERIA DOCUMENTS OR 8Y THE  U. S.  DEPARTMENT  OF
   LABOR,  29CFR1910  SUBPART  Z.
 THE  SPECIFIC RESPIRATOR  SELECTED  MUST BE  BASED  ON  CONTAMINATION  LEVELS  FOUND
   IN  THE WORK  PLACE,   MUST NOT  EXCEED  THE  WORKING LIMITS OF  THE RESPIRATOR  AND
   BE  JOINTLY APPROVED  BY THE NATIONAL INSTITUTE FOR  OCCUPATIONAL  SAFETY AND
   HEALTH AND THE  MINE  SAFETY AND  HEALTH ADMINISTRATION  C NIOSH- MSHA) .

 TETRAHYDROFURAN:
   1000 PPM-  ANY POWERED  AIR- PURIFYING RESPIRATOR WITH ORGANIC  VAPOR
                   CARTRIDGECS3.
                ANY CHEMICAL CARTRIDGE RESPIRATOR WITH ORGANIC  VAPOR  CARTRIDGEC 8) .

   5000 PPM-  ANY SUPPLXED-AIR RESPIRATOR OPERATED IN  A CONTINUOUS  FLOW MODE.

 10, 000 PPM-  ANY AIR. PURIFYING  FULL FACCPIECE RESPIRATOR C GAS MASK)  WITH A
                   CHIN. STYLE OR  FRONT. OR BACK-MOUNTED ORGANIC  VAPOR  CANISTER.
                ANY SELF-CONTAINED  BREATHING  APPARATUS WITH A FULL FACEPIECE.
                ANY SUPPLIED. AIR RESPIRATOR WITH A  FULL  FACEPIECE.

 20,000 PPM-  ANY SUPPLIED-AIR RESPIRATOR WITH A  FULL  FACEPIECE  AND OPERATED
                   IN  A  PRESSURE. DEMAND OR OTHER  POSITIVE PRESSURE  MODE.

     ESCAPE-  ANY AIR. PURIFYING  FULL FACEPIECE RESPIRATOR CGAS MASK)  WITH A
                   CHIN-STYLE OR  FRONT. OR BACK-MOUNTED ORGANIC  VAPOR  CANISTER.
                ANY APPROPRIATE  ESCAPE-TYPE SELF-CONTAINED  BREATHING  APPARATUS.
FOR FIREFIGHTING AND  OTHER  IMMEDIATELY DANGEROUS  TO  LIFE OR HEALTH  CONDITIONS.

   SELF-CONTAINED BREATHING  APPARATUS  WITH FULL  FACEPIECE OPERATED IN PRESSURE
     DEMAND OR OTHER POSITIVE PRESSURE MODE.

   SUPPLIED-AIR  RESPIRATOR WITH  FULL FACEPIECE  AND OPERATED  IN  PRESSURE.DEMAND
     OR  OTHER  POSITIVE  PRESSURE  MODE IN COMBINATION WITH  AN  AUXILIARY
     SELF-CONTAINED  BREATHING APPARATUS OPERATED IN PRESSURE-DEMAND  OR  OTHER
     POSITIVE  PRESSURE  MODE.

-------
                                                                              PACE!  5
      DOTE:     12/22/89           ACCT:     Ot-93*5-OZ
      INDEX:    013935*0016       CAT  NO:  T3971               PO  NBR:   9G29757


CLOTHING:
EMPLOYEE  MUST WEAR  APPROPRIATE PROTECTIVE  (IMPERVIOUS)  CLOTHING  AND  EQUIPMENT
TO  PREVENT REPEATED  OR  PROLONGED  SKIN  CONTACT  WITH  THIS  SUBSTANCE.

GLOVES:
EMPLOYEE  MUST WEAR  APPROPRIATE PROTECTIVE  GLOVES  TO  PREVENT CONTACT  WITH  THIS
SUBSTANCE.


EYE  PROTECTION:
EMPLOYEE  MUST WEAR  SPLASH-PROOF  OR  OUST - RESISTANT SAFETY GOGGLES AND A
FACESHIELD TO PREVENT CONTACT  WITH  THIS  SUBSTANCE.

EMERGENCY  WASH FACILITIES:
WHERE  THERE  IS ANY  POSSIBILITY THAT  AN  EMPLOYEE'S EYES  AND/OR  SKIN MAY  BE
EXPOSED  TO THIS  SUBSTANCE,  THE EMPLOYER  SHOULD PROVIDE  AN  EYE  WASH FOUNTAIN
AND  QUICK  DRENCH SHOWER WITHIN THE  IMMEDIATE  WORK AREA  FOR  EMERGENCY USE.


                   AUTHORIZED  •  FISHER  SCIENTIFIC,  INC.
             CREATION  DATEi   10/29/81-             REVISION  DATE!   10/13/89

                                   -ADDITIONAL  INFORMATION-
THIS INFORMATION IS  BELIEVED  TO  BE  ACCURATE AND REPRESENTS  THE BEST
INFORMATION  CURRENTLY AVAILABLE  TO  US.    HOWEVER,  WE  MAKE NO WARRANTY OF
MERCHANTABILITY  OR  ANY  OTHER  WARRANTY,   EXPRESS OR IMPLIED,   WITH  RESPECT  TO
SUCH INFORMATION,  AND WE  ASSUME  NO  LIABILITY  RESULTING  FROM ITS  USE.   USERS
SHOULD MAKE  THEIR OWN INVESTIGATIONS TO  DETERMINE THE SUITABILITY  OF THE
INFORMATION  FOR  THEIR PARTICULAR  PURPOSES.

-------
       DOTE:
       INDEX:
11 / OH-/S9
01833050503
flCCT:
CAT  NO:
                                                         - 02
           T3>»-lf
         PAGE:  1

PO  NBR:   9G3H-018
   »»TRICHLOROETHYLENES*
   **TRICHLOROETHYLENE»*
   *XTRICHLOROETHVLENE»*
                            MATERIAL  SAFETY  DATA SHEET
FISHER  SCIENTIFIC
CHEMICAL  DIVISION
1  REAGENT LANE
FAIR  LAyN NJ  07*10
C2013  796-7100
                                  EMERGENCY CONTACTS:
                                    GASTON  L.   PILLORI:   C201}  795-7100
                                    AFTER BUSINESS HOURS;   HOLIDAYS:
                                     C2013  796-7523
                                    CHEMTREC ASSISTANCE:  CS003  *aH--9300
THE INFORMATION  BELOW  IS  BELIEVED  TO  BE  ACCURATE  AND  REPRESENTS  THE  BEST
INFORMATION  CURRENTLY  AVAILABLE  TO US.    HOWEVER,   WE MAKE NO WARRANTY OF
MERCHANTABILITY  OR  ANY OTHER WARRANTY,  EXPRESS  OR  IMPLIED,   WITH  RESPECT  TO
SUCH  INFORMATION,   AND  WE  ASSUME  NO LIABILITY RESULTING  FROM ITS  USE.   USERS
SHOULD MAKE  THEIR  OWN  INVESTIGATIONS  TO  DETERMINE  THE SUITABILITY  OF THE
INFORMATION  FOR  THEIR  PARTICULAR PURPOSES.
                             SUBSTANCE  IDENTIFICATION
                                                                     CAS-NUMBER  79-01-6
SUBSTANCE:   ««TRICHLOROETHYLENE«*
TRADE  NAMES/SYNONYMS:
   ACETYLENE  TRICHLORIDE,  ETHYLENE  TRICHLORIDE,  ALGYLEN,
   1-CHLORO-a, 2-DICHLOROETHYLENE;  1, 1-DICHLORO-2-CHLOROETHYLENE,  TCE,  ANAMENTH,
   ETHINYL TRICHLORIDE;  TRICHLOROETHENE;   1,1,2-TRICHLOROETHYLENE,   TRI;
   CHLORYLEN;  1, 1, 2-TRICHLOROETHENE,  DENSINFLUAT,   CHLORILEN;  TRILEN,   UN  1710;
   U228,   STCC 4-9*1171;  T-3H-0;  T-34-1,  T-H-03;   ACC23850
CHEMICAL  FAMILY:
HALOGEN  COMPOUND,   ALIPHATIC

MOLECULAR FORMULAi  C2-H-CL3

CERCLA RATINGS  CSCALE  0-3}
NFPA  RATINGS CSCALE 0- H-) .

                            COMPONENTS  AND CONTAMINANTS
                              MOL WT:   131. H-0

                     HEALTH:3   FIRErl   REACTIVITYsO   PERSISTENCE:3
                  HEALTHsZ   FIRE=1   REACTIVITYiO
COMPONENTi   TRICHLOROETHYLENE
                                                                              PERCENTi   >99
OTHER  CONTAMINANTSi  MAY  CONTAIN  ANTIOXIDANTS SUCH  AS  AMINES  OR  EPOX-
IDES  AND  ESTERS  TO  STABILIZE

EXPOSURE  LIMITS!
TRICHLOROETHYLENE:
   50  PPM  C270 MG/M3J  OSHA TWA;  200  PPM C1080 MG / M3 ) OSHA  STEL
   SO  PPM  C270 MG/M33  ACGIH  TWA,  200 PPM  C1080  MG/M33  ACGIH STEL
   25  PPM  NIOSH  RECOMMENDED  10 HOUR  TWA

   1000 POUNDS CERCLA  SECTION 103 REPORTABLE  QUANTITY
   SUBJECT TO SARA  SECTION 313 ANNUAL  TOXIC CHEMICAL RELEASE  REPORTING
   SUBJECT TO CALIFORNIA  PROPOSITION SS CANCER  AND 'OR  REPRODUCTIVE  TOXICITY
     WARNING  AND  RELEASE  REQUIREMENTS-  CAPRIL 1.
                                     PHYSICAL  DATA

DESCRIPTION,  COLORLESS,   HEAVY,  MOBILE LIQUID WITH  A  MILD  CHLOROFORM- LIKE ODOR

BOILING  POINT.  188  P  C87 CJ      MELTING POINTi   -99  F  C-73  C)

SPECIFIC GRAVITYi  1. S     VAPOR  PRESSUREi  58  MMHG a ZO  C

EVAPORATION  RATE.  CCCLt-slJ  0.69     SOLUBILITY  IN WATER.   0.1*

ODOR  THRESHOLDi  20  PPM     VAPOR DENSITY.  *. 5

SOLVENT  SOLUBILITY.  ALCOHOL,  ETHER.  ACETONE.  CHLOROFORM,  BENZENE
                              FIRE  AND EXPLOSION DATA

FIRE  AND  EXPLOSION HAZARD.
SLIGHT FIRE  HAZARD WHEN  EXPOSED TO HEAT  OR  FLAME.
UPPER  EXPLOSIVE LIMIT.  10. S  a  2.5 C

AUTOIGNITION TEMP..  770  F CH-10  C3
                                 LOWER  EXPLOSIVE  LIMIT.  8. 0 a  25 C

                               FLAMMABILITY  CLASSCOSHAli   IO
FIREFIGHTING MEDIA.
DRY CHEMICAL,   CARBON  DIOXIDE OR  HALON
C1987  EMERGENCY  RESPONSE  GUIDEBOOK,  DOT  P 5800. HO.

FOR LARGER  FIRES,  USE WATER  SPRAY,  FOG OR STANDARD FOAM
C1987  EMERGENCY  RESPONSE  GUIDEBOOK,  DOT  P 5800. HO.

-------
                                                                             PAGE:  2
      DSTE:    11/OS-/B9           flCCT:     OH-931-5-02
      IMDEX:   01393050503       COT  NO:  T3H-1S-               PO NBR:  9G3S-01S


FIREFIGHTING:
STflY flWOY  FROM  STORAGE TANK  ENDS.  COOL  CONTAINERS  EXPOSED  TO FLAMES  WITH WATER
FROM SIDE  UNTIL WELL  AFTER FIRE  IS  OUT  C19S7 EMERGENCY RESPONSE  GUIDEBOOK,
DOT  P  saoo. s-,  GUIDE PAGE  7so.

USE  AGENT  SUITABLE FOR TYPE  OF FIRE.  AVOID  BREATHING  TOXIC  VAPORS,   KEEP
UPWIND.


                                TRANSPORTATION DATA

DEPARTMENT  OF  TRANSPORTATION HAZARD  CLASSIFICATION S-9CFR172. 101:
ORM-A

DEPARTMENT  OF  TRANSPORTATION LABELING REQUIREMENTS S-9CFR172.101  AND  SUSPART  E:
NONE

DEPARTMENT  OF  TRANSPORTATION PACKAGING  REQUIREMENTS!   S-9CFR173. SOS
EXCEPTIONSi  S-9CFR173. 505


                                      TOXICITY

TRICHLOROETHYLENE.
IRRITATION  DATAi   2 MG/2S-  HOURS SKIN-RABBIT  SEVERE;  20  MG/2S-  HOURS
   EYE-RABBIT MODERATE.
TOXICITY  DATA!  6900 MG/M3/10 MINUTES INHALATION-HUMAN  TCLO,   ISO  PPM/83 MINUTES
   INHALATION-HUMAN TCLO;   812 MG/KG  INHALATION-HUMAN TDLO;  110  PPM/8  HOURS
   INHALATION-HUMAN TCLO,   2900 PPM INHAL ATION-HUMAN LCLO;  8000  PPM/S-  HOURS
   INHALATION-RAT  LCLO;  8S-50  PPM/S- HOURS INHAL AT ION-MOUSE LCSO;  11,000 PPM
   INHALATION-RABBIT LCLO;  32,500  MG/M3/2 HOURS  INHALATION-CAT  LCLO-
   37,200  PPM/S-0 MINUTES INHAL ATION- GUINEA PIG LCLO,  7  CM/KG  ORAL-HUMAN LDLO;
   21S-3  MG/KG ORAL-HUMAN TDLO;  2S-02  MG/KG ORAL-MOUSE LDSO;  7330 MG/KG
   ORAL-RABBIT  LDLO;  53SS-  MG/KG ORAL-CAT LDLO; IS CM/KG
   SUBCUTANEOUS-MOUSE  LDSO;  1800  MG/KG SUBCUTANEOUS-RABBIT  LOLO;   150  MG/KG
   SUBCUTANEOUS-DOG LDLO,   3S-  MG/KG INTRAVENOUS-MOUSE LDSO,  ISO  MG/KG
   INTRAVENOUS-DOG  LDLO,  1282 MG/KG  INTRAPERZTONEAL-RAT LDSO,  1900 MG/KG
   INTRAPERITONEAL-DOG  LDSO,   MUTAGENIC DATA  CRTECS3,  REPRODUCTIVE EFFECTS DATA
   CRTECS),  TUMORIGENIC DATA  CRTECS).
CARCINOGEN  STATUSi  HUMAN  INADEQUATE  EVIDENCE. ANIMAL  LIMITED  EVIDENCE
   CIARC CLASS-3).   ORAL ADMINISTRATION PRODUCED  LIVER  AND LUNG  NEOPLASMS  IN
   MICE;  INHALATION WAS ASSOCIATED WITH  AN INCREASED INCIDENCE  OF LYMPHOMAS
   IN FEMALE MICE,   BUT  NOT IN RATS OR HAMSTERS.
LOCAL  EFFECTS:  IRRITANT-SKIN,  EYE,   INHALATION.
ACUTE  TOXICITY  LEVELi  INSUFFICIENT  DATA.
TARGET  EFFECTS!  CENTRAL NERVOUS  SYSTEM  DEPRESSANT.  POISONING  MAY AFFECT  THE
   LIVER,   KIDNEYS,   LUNGS AND  HEART.
ADDITIONAL  DATAi   THE  PRESENCE OF  TETRACHLOROETHANE AS  AN IMPURITY,  OR THE
   CONSUMPTION  OF  ALCOHOLIC BEVERAGES MAY ENHANCE THE  SYSTEMIC  TOXICITY.
   EPINEPHRINE  OR  OTHER STIMULANTS MAY INDUCE VENTR1~"LAR ARRHYTHMIAS.


                         HEALTH EFFECTS  AND  FIRST AID

INHALATION)
TRICHLOROETHYLENEi
IRRITANT/NARCOTIC.
1000 PPM  IMMEDIATELY  DANGEROUS TO LIFE  OR HEALTH.
   ACUTE EXPOSURE-  LEVELS  OF  90-130  PPM  FOR  8 HOURS HAVE RESULTED IN DECREASED
     PERFORMANCE IN TESTS  OF  PERCEPTION,  MEMORY,  COMPLEX REACTION TIME AND
     MANUAL  DEXTERITY.  ADDICTION  HAS  OCCURRED FROM  DELIBERATE  INHALATION  OF
     MODERATE AMOUNTS  WHICH CAUSE  EUPHORIA,   DISORIENTATION,  VISUAL
     HALLUCINATIONS.  DELUSIONS,  AND  OTHER PSYCHOTIC SYMPTOMS.  AT  LOW
     CONCENTRATIONS MILD RESPIRATORY  IRRITATION,  DROWSINESS.   DIZZINESS,
     HEADACHE,  EXCITATION.  NAUSEA.  VOMITING,  ABDOMINAL  CRAMPS,  AND FLUSHED SKIN
     MAY OCCUR.  AT  HIGHER  CONCENTRATIONS PALLOR,  PROFUSE PERSPIRATION.
     PULMONARY  EDEMA.   NARCOSIS.  FACIAL NERVE DYSFUNCTION,  ANESTHESIA,
     UNCONSCIOUSNESS.   AND  COMA ARE POSSIBLE.  IF  CONSCIOUSNSESS  IS REGAINED.
     NAUSEA  AND  VOMITING MAY  FOLLOW  FOR  SEVERAL  HOURS.   ANEMIA  AND DAMAGE  TO THE
     LIVER,  KIDNEYS,  AND LUNGS MAY OCCUR.  ANIMAL STUDIES HAVE  SHOWN  SPLEEN
     DAMAGE  ALSO.   DEATH MAY OCCUR  FROM RESPIRATORY  ARREST OR  VENTRICULLAR
     FIBRILLATION  AND  PRIMARV CARDIAC FAILURE.
   CHRONIC  EXPOSURE- REPEATED EXPOSURE TO LEVELS BELOW  300  PPM  MAY CAUSE
     NAUSEA,  VOMITING,  ABDOMINAL  CRAMPS,  SLEEPINESS.  DRUNKENNESS,  FLUSHING,
     ANOREXIA,  SWELLING OF THE EYES,   FACE,  AND HANDS.   AND MILD  CARDIAC
     ARRYTHMIA.  OTHER  POSSIBLE SYMPTOMS  MAY  BE WHEEZING,  FACIAL NERVE
     PARALYSIS.  LOSS OF COORDINATION  AND SENSE OF SMELL AND  TASTE,  IMPAIRMENT
     OF  TACTILE  AND AUDITORY  SENSES,   DOUBLE  VISION,  CHANGES  IN  COLOR
     PERCEPTION,  BLINDNESS AND JOINT  AND MUSCLE  PAIN.   INTOLERANCE TO ALCOHOL,
     TREMOR,  GIDDINESS,  BRADYCARDIA,   AND ANXIETY HAVE  BEEN  FOUND  IN  WORKERS
     CHRONICALLY EXPOSED TO S-S30  PPM.  LIVER,  KIDNEY.   AND BRAIN DAMAGE MAY ALSO
     OCCUR.  REPRODUCTIVE EFFECTS  HAVE BEEN REPORTED IN  ANIMALS.  ADMINISTRATION
     BY  INHALATION  WAS  ASSOCIATED  WITH AN INCREASED INCIDENCE  OF  LYMPHOMAS IN
     FEMALE  MICE.   BUT  NOT  IN  RATS  OR  HAMSTERS.

FIRST AID-  REMOVE  FROM EXPOSURE  AREA TO FRESH AIR  IMMEDIATELY.  IF BREATHING
   HAS STOPPED,  PERFORM ARTIFICIAL RESPIRATION.   KEEP PERSON  WARM  AND AT REST.
   TREAT SYMPTOMATICALLY AND  SUPPORTIVELY.  GET MEDICAL  ATTENTION  IMMEDIATELY.

-------
                                                                             PAGE:  3
      DATE-     ll/Qt/89          flCCT:     0*934-5-02
      INOEX:    01393050503       CAT  NO:   T3M-1H-              PO NBR:   9G3H-01S


SKIN CONTACT:
TRICHLOROETHYLENE:
IRRITANT.
   ACUTE EXPOSURE-  MAY CAUSE  IRRITATION AND CAUSE CONTACT  DERMATITIS.  MAY ACT
     flS  A  SEMSITIZER  IN  PREVIOUSLY  EXPOSED  INDIVIDUALS  AND  CAUSE  GENERALIZED
     EXFOLIATAVE  DERMATITIS,  ERYTHRODERMA,  OR  PAPULOVESICULAR  DERMATITIS.
     WHEN  SKIN  IS  IN  CONTACT  WITH  TRICHLOROETHYLENE  SOAKED  CLOTHING  FOR  A LONG
     PERIOD  OF  TIME,   BLISTERING  MAY  OCCUR.  MAY BE ABSORBED  THROUGH THE SKIN,
     HOWEVER,   DERMAL  ABSORPTION  IS  NOT  LIKELY  TO  BE  OF  TOXICOLOG1CAL
     SIGNIFICANCE  UNDER  NORMAL  USE.
   CHRONIC  EXPOSURE-  MAY  CAUSE  A  DEFATTING  TYPE  OF  DERMATITIS  RSULTING IN
     ROUGHNESS,  CHAPPING,  VESICULATION  AND  SECONDARY INFECTION.  REPEATED
     CONTACT  MAY  RESULT  IN  PARALYSIS OF THE FINGERS.  SENSITIZATION MAY OCCUR IN
     PREVIOUSLY EXPOSED  INDIVIDUALS.  CHRONIC  LOW  DOSE EXPOSURE  MAY CAUSE  SENSE
     OF  INEBRIATION,   IRRITABILITY  AND  PERSONALITY CHANGES.   CHRONIC ABSORPTION
     MAY ALSO  PRODUCE WEIGHT  LOSS,   NAUSEA,  ANOREXIA,  FATIGUE,   VISUAL
     IMPAIRMENT,   JOINT PAIN  AND  WHEEZING.   JAUNDICE  IS RARE.

FIRST  AID-  REMOVE CONTAMINATED  CLOTHING  AND  SHOES  IMMEDIATELY.  WASH  AFFECTED
   AREA  WITH  SOAP  OR  MILD  DETERGENT  AND LARGE  AMOUNTS OF WATER  UNTIL  NO
   EVIDENCE OF  CHEMICAL  REMAINS  CAPPROXIMATELY 15-20 MINUTESi.   GET MEDICAL
   ATTENTION  IMMEDIATELY.

EYE CONTACT:
TRICHLOROETHYLENE:
IRRITANT.
   ACUTE EXPOSURE-  DIRECT  CONTACT  WITH  VAPOR  OR LIQUID  MAY  CAUSE  BURNS OF THE
     LIDS,   CONJUNCTIVA AND  CORNEA  WITH  SYMPTOMS OF  REDNESS.  TEARING AND BLURRED
     VISION.   A  SPLASH IN  THE  EYE  MAY CAUSE  SMARTING  PAIN AND INJURED  CORNEAL
     EPITHELIUM.   EPITHELIUM  MAY  BE  LOST BUT RAPIDLY  REGENERATES AND COMPLETE
     RECOVERY  IS  USUAL.   ACUTE EXPOSURE  MAY  RESULT IN LOSS OF SENSATION IN THE
     DISTRIBUTION  OF  THE  TRIGEMINAL  NERVE  ON  ONE  OR  BOTH SIDES.  THIS  MAY  BE
     COMPLICATED  BY CORNEAL  EPITHELEAL  ULCERATION,   WHICH DOES  NOT  CAUSE
     DISCOMFORT BECAUSE  OF  THE  CORNEAL  ANESTHESIA DUE TO PARALYSIS OF  THE
     SENSORY  NERVE.  OCULOMOTOR  PARALYSIS  MAY  ACCOMPANY  THE  TRIGEMINAL  PALSIES.
   CHRONIC  EXPOSURE-  REPEATED AND  PROLONGED EXPOSURE MAY CAUSE  CONJUNCTIVITIS
     AND CORNEAL  INFLAMMATION.   CHRONIC  INTOXICATION  MAY  CAUSE  OPTIC NEURITIS,
     DOUBLE VISION,  NYSTAGMUS,   CHANGES  IN  COLOR PERCEPTION  AND  BLINDNESS.



FIRST  AID-  WASH  EYES IMMEDIATELY  WITH  LARGE  AMOUNTS OF  WATER  OR  NORMAL SALINE.
   OCCASIONALLY LIFTING  UPPER AND  LOWER LIDS,  UNTIL  NO  EVIDENCE OF CHEMICAL
   REMAINS CAPPROXIMATELY  15-20  MINUTES).   GET  MEDICAL ATTENTION IMMEDIATELY.

INGESTIONi
TRICHLOROETHYLENE:
NARCOTIC/CARCINOGEN.
   ACUTE EXPOSURE-  MAY CAUSE  SEVERE  BURNING SENSATION IN THE MOUTH,  THROAT.
     ESOPHAGUS,  AND STOMACH,  DIARRHEA.  INEBRIATION,   CONFUSION,   TACHYCARDIA,   AND
     CENTRAL  NEK. "JUS  SYSTEM  DEPRESSION  WITH DIZZINESS.   NAUSEA,   VOMITING,
     HEADACHE,  COLLAPSE,  CONVULSIONS,   AND  COMA FOLLOWED  BY  DEATH  FROM
     RESPIRATORY,  CARDIAC  OR  HEPATORENAL  FAILURE.  LOW-LEVEL  CONCENTRATIONS MAY
     CAUSE HEADACHE,  AMNESIA,  NUMBNESS,  WEAKNESS  OF  THE  EXTREMITIES,
     HEMIPARESIS  AND  PSYCHOSIS.
   CHRONIC EXPOSURE-  MAY  CAUSE  IRRITATION  OF  MUCOUS  MEMBRANES.   HEADACHE,
     DROWSINESS,   FATIGUE,  GIDDINESS,  EXCITABILITY,   INDIGESTION,  NAUSEA,
     DISTURBANCES OF  SENSATIONS  IN  THE  EXTREMETIES  AND  OTHER SYMPTOMS  NOTED  IN
     CHRONIC  INHALATION.  REPRODUCTIVE  EFFECTS  HAVE  BEEN  REPORTED  IN ANIMALS.
     REPEATED  ORAL ADMINISTRATION  PRODUCED  LIVER  AND LUNG NEOPLASMS XN MICE.

FIRST  AID-  REMOVE BY GASTRIC LAVAGE OR EMESIS.  MAINTAIN BLOOD  PRESSURE AND
   AIRWAY.  GIVE OXYGEN IF  RESPIRATION  IS  DEPRESSED.   DO  NOT  PERFORM GASTRIC
   LAVAGE  OR  EMESIS IF VICTIM IS UNCONSCIOUS.  GET MEDICAL ATTENTION
   IMMEDIATELY CDREISBACH,  HANDBOOK  OF  POISONING,  11TH  ED.  i .  ADMINISTRATION
   OF  GASTRIC LAVAGE  OR  OXYGEN  SHOULD  BE  PERFORMED  BY QUALIFIED MEDICAL
   PERSONNEL.

ANTIDOTE:
NO SPECIFIC  ANTIDOTE. TREAT  SYMPTOMATZCALLY  AND  SUPPORTIVELV.


                                     REACTIVITY

REACTIVITY:
STABLE UNDER  NORMAL  TEMPERATURES  AND  PRESSURES  IN  A CLOSED CONTAINER.
UNINHIBITED  MATERIAL, ON HEATING  OR EXPOSURE TO  LIGHT,  MAV DECOMPOSE OR
POLYMERIZE,  RELEASING HYDROGEN CHLORIDE.

INCOMPATIBILITIESi
TRICHLOROETHYLENEi
   ALKALI:  FORMS  EXPLOSIVE  MIXTURE.
   ALUMINUM +  DILUTE  HYDROCHLORIC  ACZDi  VIOLENT  POYMERIZATION.
   ALUMINUM:  VIOLENT  DECOMPOSITION MAY  OCCUR.
   BARIUM:  POSSIBLE DETONATION.
   BERYLLIUM:  FORMS IMPACT- SENSITIVE MIXTURE.
   BORON:  FORMS EXPLOSIVE OR IGNITABLE COMPOUND.
   l-CHLORO-2,3-EPOXYPROPANEi  FORMS EXPLOSIVE MIXTURE.
   2, *-BISC1K2-. 3'-EPOXYPROPOXY)PHENYL3PROPANEi   FORMS EXPLOSIVE MIXTURE.

-------
                                                                           PACE:  *
      DflTE:     11/OH-/89          0 C C T :     Ot93f5-02
      INDEX:   01393050503      CAT NO:  T 31-1H-               PO NBR:   9231-018

  DI- 2, 3- EPOXYPROPYL  ETHER  OF 1, 1- - BUT «NEDI OL ;   FORMS EXPLOSIVE  MIXTURE
  EPOXIDES:  POSSIBLE  EXPLOSION.
  LITHIUM:   FORMS  IMP«CT-SENSITIVE  MIXTURE.
  MOGNESIUM:  FORMS  IMP0CT-SENSITIVE  MIXTURE
  METftLS  (POWDERED):  FORMS  EXPLOSIVE OR  IGNITABLE  COMPOUND.
  MONO- 2, 3- EPOXVPROPYL  ETHER OF  1 ,  S-- BUTfl NEDI OL :  FORMS EXPLOSIVE  MIXTURE
  NITROGEN  TETRflOXIDE:   FORMS EXPLOSIVE  MIXTURE.
  OXIDIZERS  (STRONG):  FIRE  AND  EXPLOSION HAZARD
  OXYGEN  (LIQUID):   EXPLODES WHE'  INITIATED  WITH A  BLASTING CAP.
  OXYGEN  CGAS):  EXPLODES UNDER  PRESSURE  AT  ROOM TEMPERATURE.
  PERCHLORIC  ACID:   VIOLENT  REACTION.
  POTASSIUM:  FORMS  EXPLOSIVE CHLOROACETYLENES.
  POTASSIUM  HYDROXIDE:   FORMS EXPLOSIVE  DICHLOROACETYLENE  WHEN  HEATED.
  SODIUM:  FORMS  EXPLOSIVE CHLOROACETYLENES.
  SODIUM  HYDROXIDE:   FORMS EXPLOSIVE  CHLOROACETYLENES.
  TITANIUM:  FORMS IMPACT- SENSITIVE  MIXTURE.

DECOMPOSITION!
TRICHLOROETHYLENEi
UPON CONTACT  WITH CERTAIN METALS,   HIGH  TEMPERATURES,   OPEN  FLAME,  OR
ULTRAVIOLET  LIGHT,   DECOMPOSES INSTANTLY  TO  HIGHLY  TOXIC AND CORROSIVE  FUMES  OF
PHOSGENE  AND/OR  HYDROGEN CHLORIDE,   CHLORINE,  AND DICHLOROACETYL  CHLORIDE.
ABOVE  700 C  VAPORS  DECOMPOSE TO  A  MIXTURE  OF DICHLORETHYLENE,
TETRACHLORETHYLENE,   CARBON  TETRACHLORIDE,   CHLOROFORM,   AND  METHYLCHLORIDE.

POLYMERIZATION!
MAY  POLYMERIZE WHEN CATALYZED BY ALUMINUM  CHLORIDE  IN,A SELF-SUSTAINING
REACTION  WHICH MAY  DEVELOP  TEMPERATURES  UP  TO  1350  C,   A STABILIZER IS
REQUIRED  TO  PREVENT POLYMERIZATION  WHEN  HEATED  OR  EXPOSED  TO  SUNLIGHT.


                              STORAGE  AND  DISPOSAL

STORE  IN  A  COOL,  DRY,  WELL- VENTILATED  LOCATION.  AWAY  FROM  ANY  AREA WHERE  THE
FIRE HAZARD  MAY  BE  ACUTE CNFPA  H-9,   HAZARDOUS CHEMICALS DATA,   19753.

                             EXXXXXXXXXXXXXXXXXXX1
                              CONDITIONS  TO  AVOID

MAY  BURN  BUT  DOES NOT IGNITE READILY.   CONTAINER MAY EXPLODE IN HEAT OF FIRE.

STORE  IN  A  COOL,  DRY,  WELL-VENTILATED  LOCATION,  AWAY  FROM  ANY  AREA WHERE  THE
FIRE HAZARD  MAY  BE  ACUTE. CNFPA,  FIRE  PROTECTION GUIDE ON  HAZARDOUS MATERIALS,
8TH  ED. )

          txxxxxxxxxxxxi              . .   .	
                           SPILL AND  LEAK PROCEDURES

SOIL SPILL:
DIG  A  HOLDING  AREA  SUCH AS  A PIT,   POND  OR  LAGOON TO CONTAIN SPILL  AND  DIKE
SURFACE  FLOW  USING  BARRIER  OF SOIL,  SANDBAGS,   FOAMED  POLYURETHANE  OR FOAMED
CONCRETE.  ABSORB  LIQUID MASS WITH  FLY  ASH  OR CEMENT POWDER.

AIR  SPILL!
APPLY  WATER  SPRAY TO KNOCK  DOWN  AND  REDUCE  VAPORS.  KNOCK-DOWN  WATER IS
CORROSIVE AND  TOXIC AND SHOULD  BE  DIKED  FOR CONTAINMENT.

WATER  SPILLi
USE  ACTIVATED  CARBON  TO ABSORB  SPILLED  SUBSTANCE THAT  IS DISSOLVED.

USE  SUCTION  HOSES TO REMOVE TRAPPED  SPILL  MATERIAL.

USE  MECHANICAL DREDGES  OR LIFTS  TO  EXTRACT  IMMOBILIZED MASSES  OF  POLLUTION AND
PRECIPITATES.

THE  CALIFORNIA SAFE DRINKING WATER  AND  TOXIC ENFORCEMENT ACT OF  1986
CPROPOSITION  65)  PROHIBITS  CONTAMINATING ANY KNOWN  SOURCE  OF DRINKING  WATER
WITH SUBSTANCES  KNOWN TO CAUSE  CANCER  AND/OR REPRODUCTIVE  TOXZCITY.

OCCUPATIONAL  SPILLi
SHUT OFF  IGNITION SOURCES.  STOP  LEAK XF  YOU CAN DO  IT  WITHOUT  RISK.  FOR SMALL
LIQUID  SPILLS,  TAKE UP  WITH SAND,   EARTH  OR  OTHER ABSORBENT MATERIAL.  FOR
LARGER  SPILLS.  DIKE FAR AHEAD OF SPILL  FOR  LATER DISPOSAL.  NO  SMOKING,  FLAMES
OR  FLARES IN  HAZARD AREA! KEEP  UNNECESSARV  PEOPLE  AWAY.

REPORTABLE  QUANTITY CRQ3> 1000  POUNDS
THE  SUPERFUND  AMENDMENTS AND REAUTHORIZATION ACT (SARA) SECTION  30* REQUIRES
THAT A RELEASE EQUAL  TO OR  GREATER  THAN  THE REPORTABLE QUANTITY  FOR THIS
SUBSTANCE BE  IMMEDIATELY REPORTED  TO THE LOCAL  EMERGENCY PLANNING  COMMITTEE
AND  THE  STATE  EMERGENCY RESPONSE COMMISSION C H-0 CFR 3SS. *0 3 .  IF  THE RELEASE OF
THIS SUBSTANCE IS REPORTABLE UNDER  CERCLA  SECTION  103,  THE NATIONAL RESPONSE
CENTER MUST  BE NOTIFIED IMMEDIATELY  AT  CS003 M-2f-S802  OR CZ023 1-26-2675 IN THE
METROPOLITAN  WASHINGTON.  D. C.  AREA  C*0  CFR  302.63.


                              PROTECTIVE  EQUIPMENT

VENTILATION!
PROVIDE  LOCAL  EXHAUST OR PROCESS ENCLOSURE  VENTILATION TO  MEET PUBLISHED
EXPOSURE  LIMITS.

-------
                                                                    PAGE:  S
      DATE:     11/04-/89          ACCT:     04-93*5-02
      INDEX:    01393050503       CAT NO:  134-14-             PO NBR:  9G34-01B


RESPIRATOR:
THE FOLLOWING  RESPIRATORS AND MAXIMUM USE COMCENTRATIONS ORE RECOMMENDATIONS
  BY  THE U S   DEPARTMENT  OF HEALTH  AND HUMAN  SERVICES,  NIOSH POCKET  GUIDE  TO
  CHEMICAL' HAZARDS, NIOSH CRITERIA  DOCUMENTS  OR BY  THE u. s.  DEPARTMENT OF
  LABOR,  29CFR1910'SUBPART Z.
THE SPECIFIC  RESPIRATOR  SELECTED MUST BE BASED ON CONTAMINATION  LEVELS FOUND
  IN  THE WORK  PLACE,  MUST NOT EXCEED  THE WORKING LIMITS OF  THE RESPIRATOR  AND
  BE  JOINTLY  APPROVED  BY  THE  NATIONAL INSTITUTE FOR  OCCUPATIONAL  SAFETY AND
  HEALTH AND  THE MINE  SAFETY  AND HEALTH ADMINISTRATION CNIOSH-MSHA).

TRICHLOROETHYLENE:
AT ANY  DETECTABLE  CONCENTRATION!
         ANY SELF-CONTAINED BREATHING  APPARATUS WITH  FULL FACEPIECE AND
           OPERATED IN  A  PRESSURE-DEMAND OR OTHER POSITIVE PRESSURE MODE.
         ANY SUPPLIED-AIR  RESPIRATOR WITH A FULLFACE-PIECE AND OPERATED IN
           PRESSURE-DEMAND OR  OTHER  POSITIVE PRESSURE  MODE IN COMBINATION WITH
           AN  AUXILIARY SELF-CONTAINED BREATHING APPARATUS OPERATED IN
           PRESSURE-DEMAND OR  OTHER  POSITIVE PRESSURE  MODE.

 ESCAPE-ANY AIR-PURIFYING FULL  FACEPIECE RESPIRATOR  CGAS MASK) WITH  A
           CHIN-STYLE OR  FRONT-  OR BACKMOUNTED ORGANIC  VAPOR  CANISTER.
         ANY APPROPRIATE  ESCAPE-TYPE SELF-CONTAINED BREATHING APPARATUS.


FOR FIREFIGHTING AND OTHER IMMEDIATELY DANGEROUS TO  LIFE OR  HEALTH CONDITIONSi

  SELF-CONTAINED BREATHING APPARATUS  WITH FoLL FACEPIECE OPERATED IN PRESSURE
    DEMAND OR  OTHER POSITIVE  PRESSURE MODE.

  SUPPLIED-AIR RESPIRATOR WITH  FULL FACEPIECE AND OPERATED  IN PRESSURE-DEMAND
    OR  OTHER  POSITIVE  PRESSURE  MODE IN COMBINATION WITH AN  AUXILIARY
    SELF-CONTAINED BREATHING  APPARATUS OPERATED IN PRESSURE-DEMAND OR OTHER
    POSITIVE  PRESSURE  MODE.

CLOTHINGi
EMPLOYEE MUST  WEAR APPROPRIATE  PROTECTIVE CIMPERVIOUSJ  CLOTHING AND  EQUIPMENT
TO PREVENT REPEATED OR PROLONGED SKIN CONTACT WITH THIS SUBSTANCE.

GLOVES:
EMPLOYEE MUST  WEAR APPROPRIATE  PROTECTIVE GLOVES TO  PREVENT  CONTACT  WITH THIS
SUBSTANCE.


EYE PROTECTIONi
EMPLOYEE MUST  WEAR SPLASH-PROOF OR  DUST-RESISTANT SAFETY GOGGLES TO  PREVENT
EYE CONTACT WITH THIS  SUBSTANCE.  CONTACT LENSES SHOULD NOT  BE WORN.


                 AUTHORIZED - FISHER  SCIENTIFIC GROUP,  INC.
           CREATION DATE:  10/24-/84-           REVISION  DATEi  06/27/89

                              -ADDITIONAL INFORMATION-
THE INFORMATION  BELOW  IS  BELIEVED TO  BE ACCURATE AND  REPRESENTS THE  BEST
INFORMATION CURRENTLY  AVAILABLE. TO  US.   HOWEVER,  WE  MAKE NO  WARRANTY OF
MERCHANTABILITY  OR ANY OTHER  WARRANTY,  EXPRESS OR IMPLIED,   WITH RESPECT TO
SUCH  INFORMATION,   AND  WE  ASSUME NO  LIABILITY  RESULTING FROM  ITS USE.    USERS
SHOULD  MAKE THEIR  OWN  INVESTIGATIONS  TO UETERMINE THE  SUITABILITY OF THE
INFORMATION FOR  THEIR  PARTICULAR PURPOSES.

-------
                                **METHYL  ETHYL  KETONE**                        PAGE 01  OF  05

                                **METHYL  ETHYL  KETONE**        I"
                                **METHYL  ETHYL  KETOME**                 j.  -f
                                **METHYL  ETHYL  KETONE**        ,'        ..'"-2  " , -               __
                                                                        !        •'.,-•- ^.            /  \

                              MATERIAL  SAFETY  DATA  SHEET       ' '"^ ',"*".  ......             ^
                                                                                                        X
FISHER  SCIENTIFIC      EMERGENCY  CONTACTS:                          &A«Uu  I ~ 0^5 A 9 / 8 9
CHEMICAL  DIVISION       GASTON  L.  PILLORI:   C201)  736-7100    PO  NBR:  ~9~G2BT8-*-		1
1  REAGENT  LANE            AFTER BUSINESS  HOURS;   HOLIDAYS:        ACCT-      01-931-5-02
FAIR  LAWN  NJ 071-10       C2015  796-7523                             INDEX-    03391380116
C2013  796-7100            CHEMTREC  ASSISTANCE:  CSOO}  1-29-9300  CAT  NO:   M2091-

THE  INFORMATION  BELOW  IS BELIEVED  TO  BE  ACCURATE  AND REPRESENTS  THE BEST
INFORMATION  CURRENTLY  AVAILABLE  TO US.    HOWEVER,   WE  MAKE  NO  WARRANTY  OF
MERCHANTABILITY  OR  ANY OTHER  WARRANTY,   EXPRESS  OR  IMPLIED,   WITH  RESPECT  TO
SUCH  INFORMATION,  AND  WE ASSUME  NO LIABILITY  RESULTING  FROM  ITS  USE    USERS
SHOULD  MAKE  THEIR OWN  INVESTIGATIONS  TO  DETERMINE  THE SUITABILITY  OF  THE
INFORMATION  FOR  THEIR  PARTICULAR PURPOSES.


                               SUBSTANCE  IDENTIFICATION

                                                                         CAS-NUMBER  78-93-3
SUBSTANCE:  *XMETHYL  ETHYL  KETONE**

TRADE  NAMES/SYNONYMS:
   BUTANONE;   2-BUTANONE;   ETHYL  METHYL  KETONE,   METHYL  ACETONE,  3-BUTANONE;  MEK,
   RCR«  U159;  STCC 1-9092*3,   UN  1193,  M-209,  Cf-H8O;  ACClt-1-60

CHEMICAL  FAMILY:
KETONE,  ALIPHATIC

MOLECULAR  FORMULAi   C-H3-C-H2-C-O-C-H3

MOLECULAR  WEIGHTi  72.12

CERCLA  RATINGS  CSCALE  0-33:    HEALTH=3  FIRE:3   REACTIVITY:!!   PERSISTENCE: 0
NFPA  RATINGS CSCALE  0-1-3:    HEALTH=1    FIRE=3   REACTIVITYzO

                              COMPONENTS  AND  CONTAMINANTS

COMPONENT:  METHYL ETHYL  KETONE    °                                   PERCENTi  100

OTHER  CONTAMINANTS:  NONE

EXPOSURE  LIMITS:
METHYL  ETHYL KETONEi
   200  PPM  C590  MG/M3}  OSHA  TWA,  300  PPM  C885  MG/M33  OSHA STEL
   200  PPM  C590  MG/M33  ACGIH TWA,  300  PPM  C885 MG/M3)  ACGIH  STEL
   200  PPM  C590  MC/M33  NIOSH RECOMMENDED  10  HOUR TWA

   5000  POUNDS CERCLA  SECTION  103 REPORTABLE QUANTITY
   SUBJECT  TO SARA SECTION  313  ANNUAL  TOXIC  CHEMICAL  RELEASE  REPORTING


                                       PHYSICAL  DATA

DESCRIPTION:  COLORLESS LIQUID  WITH AN ACETONE-LIKE ODOR.

BOILING  POINTi   176  F  C80  C}       MELTING POINT:  -123 F  C-86  C)

SPECIFIC GRAVITY:  0. 805H-     VAPOR  PRESSURE:  100 MMHC  a  2.5  C

EVAPORATION  RATEi  CETHER=1)  2.7      SOLUBILITY IN WATER:   27. 5/-

ODOR  THRESHOLD!   10  PPM      VAPOR  DENSITYi   2. 5

SOLVENT  SOLUBILITY:  ALCOHOL.   ETHER,  BENZENE,   ACETONE,  OILS

VISCOSITY!  0. 1-0  CPS  a  25  C


                                FIRE  AND  EXPLOSION DATA

FIRE  AND EXPLOSION  HAZARDi
DANGEROUS  FIRE  HAZARD  WHEN  EXPOSED TO HEAT  OR FLAME.

VAPORS  ARE HEAVIER  THAN  AIR  AND  MAV  TRAVEL  A  CONSIDERABLE  DISTANCE  TO  A SOURCE
OF IGNITION  AND  FLASH  BACK.

VAPOR-AIR  MIXTURES  ARE EXPLOSIVE ABOVE FLASH  POINT.

FLASH POINTi  16  F C-9  C)  CCC3      UPPER EXPLOSIVE LIMXTi   ll.f-X 9  ZOO  F

LOWER EXPLOSIVE  LIMITi    1.1-X a 200  F      AUTOICNITION  TEMP, i   7S3  F C»0» CJ

FLAMMABILITY CLASSCOSHAli  IB

FIREFIGHTINC MEDIAt
DRY CHEMICAL,  CARBON DIOXIDE,   HALON,   WATER  SPRAY OR  ALCOHOL  FOAM
C1987 EMERGENCY  RESPONSE  GUIDEBOOK,  DOT  P 5800.  <
-------
                              *«METHYL  ETHYL  KETONE**                      PACE  02  OF  05
FIFtEFIGHTING:
MOVE  CON!T«INER FROM  FIRE  «REA  IF POSSIBLE.  COOL  FIRE-EXPOSED  CONTAINERS WITH
WATER  FROM SIDE  UNTIL  WELL  AFTER FIRE  IS  OUT.  STAY  AWAY  FROM  STORAGE TANK
ENDS   FOR  MASSIVE FIRE  IN  STORAGE AREA,  USE  UNMANNED HOSE  HOLDER  OR  MONITOR
NOZZLES,   ELSE WITHDRAW  FROM AREA AND LET  FIRE  BURN.  WITHDRAW  IMMEDIATELY IN
CASE  OF RISING SOUND FROM  VENTING SAFETY  DEVICE  OR  ANY  DISCOLORATION OF
STORAGE TANK  DUE  TO  FIRE  C1987 EMERGENCY  RESPONSE  GUIDEBOOK,  DOT  P  5800. 4-,
GUIDE  PAGE 26).

EXTINGUISH ONLY  IF FLOW CAN BE STOPPED;  USE  WATER  IN FLOODING AMOUNTS  AS FOG,
SOLIO  STREAMS MAY NOT  BE  EFFECTIVE.   COOL  CONTAINERS WITH  FLOODING QUANTITIES
OF  WATER.   APPLY  FROM AS FAR A  DISTANCE  AS  POSSIBLE.  AVOID  BREATHING  VAPORS,
KEEP  UPWIND.

WATER  MAY  BE  INEFFECTIVE  CNFPA FIRE  PROTECTION GUIDE ON  HAZARDOUS MATERIALS,
EIGHTH EDITION).

ALCOHOL FOAM  CNFPA FIRE PROTECTION GUIDE  ON  HAZARDOUS MATERIAL,  EIGHTH
EDITION) .


                                 TRANSPORTATION DATA

DEPARTMENT OF TRANSPORTATION HAZARD  CLASSIFICATION  4-9CFR172. 101:
FLAMMABLE  LIQUID

DEPARTMENT OF TRANSPORTATION LABELING  REQUIREMENTS  4-9CFR172. 101 AND  172. t-02:
FLAMMABLE  LIQUID

DEPARTMENT OF TRANSPORTATION PACKAGING  REQUIREMENTS:  4-9CFR173.119
EXCEPTIONS:  4-9CFR173. 118


                                       TOXICITY

METHYL ETHYL  KETONEi
350  PPM EYE-HUMAN IRRITATION;   80  MG  EYE-RABBIT IRRITATION,  500  MG/2H- HOURS
SKIN-RABBIT MODERATE IRRITATION;   1-02 MG/2*  HOURS  SKIN-RABBIT  MILD IRRITATION)
13,780 UG/2H-  HOUR OPEN  SKIN-RABBIT MILD IRRITATION;  100  PPM/5  MINUTES
INHALATION-HUMAN  TCLO;   38  GM/M3  INHAL ATION- MAMMAL LCSO;  H-0  GM/M3/Z HOURS
INHALATION-MOUSE  LCSO;   64-80 MG/KG SKIN-RABBIT  LD50,  2737 MC/KC  ORAL-RAT  LDSO;
1-050  MG/KG ORAL-MOUSE LDSO,  607  MG/KG  INTR AP ERITONEAL - R AT  LDSO,  616  MC/KC
INTRAPERITONEAL-MOUSE LDSO,  2000  MC/KC  INTRAPERITONEAL- GUINEA  PIC LDLO,
MUTAGENIC  DATA CRTECS),  REPRODUCTIVE EFFECTS DATA CRTECS).
CARCINOGEN STATUS:  NONE.
   METHYL  ETHYL KETONE IS  AN EYE,   SKIN,   AND  MUCOUS MEMBRANE  IRRITANT  AND
CENTRAL NERVOUS  SYSTEM  DEPRESSANT.  IT  MAY  ENHANCE THE NEUROTOXIC  EFFECTS
OF  N-HEXANE OR METHYL N-BUTYL  KETONE,   AND  PREDISPOSE THE LIVER  TO INJURY FROM
HEPATOTOXINS.  PERSONS WITH  A HISTORY OF CHRONIC SKIN OR  RESPIRATORV  DISEASE
MAY  BE AT  AN  INCREASED  RISK FROM EXPOSURE.


                          HEALTH  EFFECTS AND  FIRST AID

INHALATION:
METHYL ETHYL  KETONE:
IRRITANT/NARCOTIC.  3000 PPM IMMEDIATELY DANGEROUS TO LIFE  OR  HEALTH.
   ACUTE EXPOSURE- INHALATION OF  VAPOR  CONCENTRATIONS OF  100-200  PPM  CAUSED
     MILD  NOSE AND THROAT  IRRITATION,  300-500 PPM  WAS OBJECTIONABLE AND
     CAUSED THROAT IRRITATION,   HEADACHE.  AND   NAUSEA,  3,300  PPM  WAS MODERATELY
     IRRITATING;   AND  MOMENTARY  EXPOSURE  TO  33, 000  AND 100, 000  PPM  PRODUCED
     INTOLERABLE  IRRITATION  OF  THE NOSE  AND  THROAT.   WORKERS  EXPOSED TO
     90-270 PPM/4-  HOURS  SHOWED  SHORTENED TIME ESTIMATIONS IN MEN  AND  INCREASED
     THE VARIATION IN TIME  ESTIMATION TESTS  IN  WOMEN.  EXTREMELV  HIGH
     CONCENTRATIONS MAY  CAUSE COUCHING AND  SHORTNESS  OF BREATH.  AND CENTRAL
     NERVOUS SYSTEM DEPRESSION  WITH HEADACHE.  LICHTHEADEDNESS.   NAUSEA.
     VOMITING.  DIZZINESS,   INCOORDINATION,  AND NARCOSIS.  GUINEA  PIGS EXPOSED  TO
     10,000 PPM DEVELOPED  IRRITATION  RAPIDLY,  AND  NARCOSIS  DEVELOPED  AFTER
     AFTER  5 HOURS,  33, 000  PPM/200 MINUTES  PRODUCED  NARCOSIS AND  DEATH,
     AND 100,000  PPM/55  MINUTES PRODUCED NARCOSIS  AFTER 10  MINUTES.  ODOR  AND
     IRRITATION ARE GENERALLY SUFFICENT  TO  PREVENT OVEREXPOSURE.
     METHYL ETHYL  KETONE MAY ENHANCE  THE NEUROTOXIC  EFFECTS  OF  N-HEXANE  AND
     METHYL N-BUTYL KETONE.
   CHRONIC  EXPOSURE-  WORKERS EXPOSED  VIA INHALATION  AND SKIN CONTACT  TO
     300-600 PPM  COMPLAINED  OF  NUMBNESS  IN  THE  ARMS  AND FINGERS,  ONE  WORKER
     COMPLAINED OF NUMBNESS  IN  THE LEGS  AND  A TENDENCY FOR  THEM  TO GIVE  WAV.
     SEVERAL CASES OF PERIPHERAL  NEUROPATHY,   INCLUDING OPTIC NEURITIS DUE TO
     METABOLITES,  HAVE BEEN  REPORTED  IN  WORKERS.  PERIPHERAL  NEUROPATHY HAS NOT
     SEEN  INDUCED  IN  ANIMALS BY METHYL  ETHYL   KETONE  ALONE.   HOWEVER.  IT HAS BEEN
     DEMONSTRATED  IN  HUMANS  AND ANIMALS  THAT   METHYL  ETHYL KETONE POTENTIATES
     THE NEUROTOXIC EFFECTS  OF  N-HEXANE  AND  METHYL N-BUTYL  KETONE.   EXPOSURE
     RELATED EFFECTS  ON  THE  LIVER AND BRAIN  HAVE BEEN REPORTED  IN  RATS AT
     EXPOSURES UP  TO  5000  PPM.   OFFSPRING OF  PREGNANT  RATS EXPOSED  TO  1,000 OR
     3,000  PPM EXHIBITED ACAUOIA,   IMPERFORATE ANUS,   BRACHYGNATHIA,   AND FETAL
     DEVELOPMENTAL RETARDATION.  THE SAME INVESTIGATORS REPEATED  THE STUDY AND
     3,000  PPM PRODUCED  SLIGHT  MATERNAL  TOXICITY AND  SLIGHT  FETOTOXICITY,
     BUT NO EMBRYO TOXICITY  OR  TERATOCENICITV WERE SEEN.  '

FIRST  AID- REMOVE FROM  EXPOSURE  AREA TO FRESH  AIR IMMEDIATELY.  IF BREATHING
   HAS  STOPPED,  PERFORM  ARTIFICIAL RESPIRATION.  KEEP  PERSON  WARM AND  AT  REST.
   TREAT SYMPTOMATICALLY AND SUPPORTIVELY.   GET  MEDICAL ATTENTION IMMEDIATELY.


SKIN  CONTACT:
METHYL ETHYL  KETONE:
IRRITANT.
   ACUTE EXPOSURE- CONTACT  WITH LIQUID  OR CONCENTRATED VAPORS  MAY  CAUSE
     DERMATITIS.   DIRECT  CONTACT WITH  THE LIQUID MAY  CAUSE EXTREME  THICKENING
                                                                                  I                I'

-------
                              «*METHYL ETHYL  KETONEX*                      PAGE  03 OF 05
     OF THE FINGERNAILS,  WITH PERMANENT DESTRUCTION  OF  THE  NAIL  BEDS.
     APPLICATION  OF  A  LETHAL  DOSE  TO RABBIT SKIN  PRODUCED ERYTHEMA,  EDEMA,  AND
     NECROSIS.  LIVER  AND  INTESTINAL  CONGESTION WERE  ALSO REPORTED
   CHRONIC  EXPOSURE-  REPEATED OR PROLONGED  EXPOSURE  MAY  CAUSE DEFATTING OF THE
     SKIN  PRODUCING  A  DRY,   SCALY,   FISSURED  DERMATITIS.   WORKERS  EXPOSED  VIA SKIN
     CONTACT  AND  INHALATION  TO  300-600  PPM  COMPLAINED OF NUMBNESS  IN  THE  ARMS
     AND FINGERS;  ONE  WORKER  COMPLAINED OF  NUMBNESS  IN  THE  LEGS  AND A  TENDENCY
     FOR THEM  TO  GIVE  WAY.   REPEATED  CONTACT WITH  METHYL  ETHYL KETONE  AND
     TETRAHYDROFURAN  PRODUCED BILATERAL PARESTHESIA  AND  LOSS OF  MUSCLE
     STRENGTH  IN  A WORKER.   SYMPTOMS  PERSISTED  FOR 2  MONTHS  FOLLOWING  CESSATION
     OF EXPOSURE.

FIRST  AID-  REMOVE CONTAMINATED  CLOTHING  AND SHOES IMMEDIATELY   WASH  AFFECTED
   AREA WITH  SOAP  OR  MILD DETERGENT  AND LARGE  AMOUNTS OF WATER  UNTIL  NO
   EVIDENCE OF  CHEMICAL  REMAINS  CAPPROXIMATELY 15-20  MINUTES)   GET  MEDICAL
   ATTENTION  IMMEDIATELY.

EYE CONTACT!
METHYL ETHYL  KETONE:
IRRITANT.
   ACUTE EXPOSURE- EXPOSURE  TO  VAPOR CONCENTRATIONS  OF  200  PPM  CAUSED
     IRRITATION AND  A  BURNING SENSATION OF  THE EYELIDS,   3,300 PPM  PRODUCED
     MODERATE  IRRITATION,  AND 10,000 PPM  WAS INTOLERABLE TO HUMANS   DIRECT
     CONTACT  OF THE  LIQUID  WITH  THE  EYES  CAUSED PAINFUL  IRRITATION  AND
     TEMPORARY  CORNEAL INJURY IN RABBITS,  GRADED  5 ON A  SCALE OF 1-10.  IN
     GUINEA PIGS,  10V-  VAPOR  FOR  30  MINUTES  CAUSED TEMPORARY CORNEAL OPACITY
     WHICH  CLEARED WITHIN 8  DAYS.
   CHRONIC  EXPOSURE-  REPEATED OR PROLONGED  EXPOSURE  MAY  CAUSE CONJUNCTIVITIS
     A  CASE OF  OPTIC  NEURITIS WAS  REPORTED  AS  A RESULT  OF SYSTEMIC  POISONING
     FOLLOWING  REPEATED  INHALATION  EXPOSURE.

FIRST  AID-  WASH  EYES  IMMEDIATELY  WITH  LARGE AMOUNTS  OF  WATER OR NORMAL SALINE,
   OCCASIONALLY LIFTING  UPPER AND  LOWER LIDS,   UNTIL  NO  EVIDENCE  OF  CHEMICAL
   REMAINS  CAPPROXIMATELY 15-20  MINUTES}.  GET  MEDICAL ATTENTION  IMMEDIATELY.

INGESTIONi
METHYL ETHYL  KETONEi
NARCOTIC.
   ACUTE EXPOSURE- INGESTION  MAY CAUSE  IRRITATION OF  THE GASTROINTESTINAL  TRACT
     WITH  ABDOMINAL  SPASMS,   NAUSEA,  VOMITING,   AND POSSIBLY  CENTRAL  NERVOUS
     SYSTEM DEPRESSION,   INCLUDING  NARCOSIS.  ADMINISTRATION  OF A  LETHAL  DOSE TO
     RATS  PRODUCED CONGESTED  AND HEMORRHAGIC LUNGS.   AND  CONGESTION  OF THE
     LIVER,  ALIMENTARY TRACT,  AND  PERITONEAL WALL.  ANIMAL STUDIES SHOW  THAT
     METHYL ETHYL  KETONE  POTENTIATES THE  HEPATOTOXIC  AND NEPHROTOXIC EFFECTS OF
     CHLOROFORM,   AND  MAY  POTENTIATE  THE HEPATOTOXIC  EFFECTS OF CARBON
     TETRACHLORIDE.
   CHRONIC  EXPOSURE-  NO  DATA  AVAILABLE.

FIRST  AID-  REMOVE BY  GASTRIC LAVAGE OR EMESIS AND CONSIDER  USING ACTIVATED
   CHARCOAL.  DO NOT  PERFORM  GASTRIC  LAVAGE  OR  EMESIS  ON  AN  UNCONSCIOUS  PERSON.
   MAINTAIN BLOOD  PRESSURE  AND  RESPIRATION.  GIVE  OXYGEN  IF  RESPIRATION  IS
   SHALLOW  OR  ANOXIA  IS  PRESENT.  CDREISBACH,  HANDBOOK OF POISONING.  12TH ED.}
   TREAT SYMPTOMATICALLY  AND  SUPPORTIVELY.  GET MEDICAL  ATTENTION IMMEDIATELY.
   LAVAGE  AND  OXYGEN  MUST BE  ADMINISTERED BY QUALIFIED  MEDICAL PERSONNEL.

ANTIDOTE:
NO SPECIFIC  ANTIDOTE.  TREAT  SYMPTOMATICALLY AND  SUPPORTIVELY.


                                     REACTIVITY

REACTIVITYi
STABLE UNDER  NORMAL  TEMPERATURES  AND PRESSURES.

INCOMPATIBILITIES:
METHYL ETHYL  KETONEi
   CHLOROFORM!  VIGOROUS.  EXOTHERMIC  REACTION IN THE  PRESENCE  OF  A BASE.
   CHLOROSULFONIC  ACID:   MIXING  IN  CLOSED  CONTAINER MAY RESULT IN INCREASED
     TEMPERATURE  AND  PRESSURE.
   HYDROGEN PEROXIDE,  NITRIC  ACIDi  PRODUCES SHOCK AND HEAT  SENSITIVE OILY
     PEROXIDE.
   ISOPROPANOL,  ACCELERATES  PEROXIDATION  OF THE ALCOHOL  PRODUCING AN EXPLOSIVE
     PRODUCT.
   OLEUMi   MIXING  IN  CLOSED  CONTAINER MAY  RESULT IN INCREASED  TEMPERATURE AND
     PRESSURE.
   OXIDIZERS  CSTRONG):  POSSIBLE  FIRE AND  EXPLOSION HAZARD.
   PLASTICSi  MAV  BE  ATTACKED.
   POTASSIUM  TERT-BUTOXIDEi   IGNITION REACTION.
   RESINSi  MAY  BE  ATTACKED.
   RUBSERi  MAV  BE  ATTACKED.

DECOMPOSITION!
THERMAL DECOMPOSITION PRODUCTS  MAV  INCLUDE TOXIC OXIDES OF  CARBON.

POLYMERIZATION!
HAZARDOUS  POLYMERIZATION HAS NOT  BEEN  REPORTED TO OCCUR UNDER NORMAL
TEMPERATURES  AND  PRESSURES.


                               STORAGE AND DISPOSAL

OBSERVE ALL  FEDERAL.  STATE  AND  LOCAL REGULATIONS WHEN STORING OR DISPOSING
OF THIS SUBSTANCE.   FOR  ASSISTANCE.  CONTACT THE DISTRICT DIRECTOR OF THE
ENVIRONMENTAL  PROTECTION AGENCY.


                                    ««STORAGE«*

-------
                              XXMETHYL  ETHYL  KETONEXX                       PACE 01-  OF  05
STORE  IN  flCCOROflNCE  WITH  29  CFR  1910.106.

BONDING flND  GROUNDING:  SUBSTANCES  WITH LOW ELECTROCONDUCTIVITY,   WHICH
MBY BE IGNITED  BY  ELECTROSTATIC  SPARKS,   SHOULD  BE  STORED  IN  CONTAINERS
WHICH  MEET THE  BONDING  AND GROUNDING GUIDELINES SPECIFIED IN  NFPA  77-1933,
RECOMMENDED  PRACTICE  ON STATIC ELECTRICITY.

STORE  AWOY FROM  INCOMPATIBLE  SUBSTANCES.


                                     XXDISPOSALXX

DISPOSAL  MUST BE IN  ACCORDANCE WITH STANDARDS APPLICABLE  TO
GENERATORS OF HAZARDOUS WASTE,  tOCFR 262.  EPA HAZARDOUS WASTE NUMBER U1S9.

                              IXXXXXXXXXXXXXXXXXXXJ
                               CONDITIONS  TO  AVOID

MAY BE IGNITED  BY  HEAT,  SPARKS OR  FLAMES.  CONTAINER MAY EXPLODE  IN  HEAT OF
FIRE   VAPOR  EXPLOSION  HAZARD  INDOORS,   OUTDOORS  OR  IN SEWERS.   RUN-OFF TO
SEWER  MAY  CREATE FIRE  OR  EXPLOSION  HAZARD.
                             SPILL  AND  LEAK PROCEDURES
SOIL  SPILL.
DIG HOLDING  AREA  SUCH  AS  LAGOON,

ABSORB BULK  LIQUID  WITH FLY  ASH,
SORBENTS.
POND  OR  PIT  FOR  CONTAINMENT.

CEMENT POWDER,  SAWDUST,   OR  COMMERCIAL
AIR SPILL:
APPLY  WATER  SPRAY TO KNOCK DOWN  VAPORS.

WATER  SPILL,
LIMIT  SPILL  MOTION  AND  DISPERSION WITH  NATURAL  BARRIERS OR OIL SPILL CONTROL
BOOMS.

USE SUCTION  HOSES TO REMOVE  TRAPPED  SPILL  MATERIAL.

OCCUPATIONAL  SPILLi
SHUT OFF  IGNITION SOURCES.  STOP  LEAK IF YOU  CflN  DO  IT  WITHOUT RISK.  USE WATER
SPRAY  TO  REDUCE  VAPORS.  FOR  SMALL SPILLS,  TAKE  UP WITH SANO  OR OTHER
ABSORBENT  MATERIAL  AND  PLACE  INTO CONTAINERS FOR LATER DISPOSAL.  FOR LARGER
SPILLS,  DIKE  FAR AHEAD  OF  SPILL  FOR  LATER  DISPOSAL.  NO SMOKING,   FLAMES  OR
FLARES IN  HAZARD AREA I  KEEP  UNNECESSARY PEOPLE  AWAY,  ISOLATE  HAZARD  AREA AND
DENY ENTRY.

REPORTABLE QUANTITY  CR«)i  5000 POUNDS
THE SUPERFUND AMENDMENTS AND  REAUTHORIZATION ACT CSARA) SECTION  3Of  REQUIRES
THAT A RELEASE EQUAL TO OR GREATER THAN THE  REPORTABLE QUANTITY  FOR  THIS
SUBSTANCE  BE  IMMEDIATELY REPORTED TO THE LOCAL  EMERGENCY  PLANNING COMMITTEE
AND THE STATE EMERGENCY RESPONSE COMMISSION  C H-0  CFR 355. H-0).   IF  THE  RELEASE OF
THIS SUBSTANCE IS REPORTABLE  UNDER CERCLA  SECTION 103,  THE NATIONAL  RESPONSE
CENTER MUST  BE NOTIFIED IMMEDIATELY  AT  C800)  1-2H--SS02  OR  C202) t-Z?-2675 IN  THE
METROPOLITAN  WASHINGTON,  D. C.  AREA C t-0  CFR 302.63.


                               PROTECTIVE EQUIPMENT

VENTILATIONi
PROVIDE LOCAL EXHAUST OR GENERAL DILUTION  VENTILATION  TO  MEET PUBLISHED
EXPOSURE  LIMITS.  VENTILATION  EQUIPMENT  MUST  BE  EXPLOSION-PROOF.

RESPIRATORi
THE FOLLOWING RESPIRATORS  AND MAXIMUM USE  CONCENTRATIONS  ARE  RECOMMENDATIONS
BY  THE U. S.   DEPARTMENT  OF  HEALTH AND HUMAN SERVICES,  NXOSH POCKET GUIDE TO
CHEMICAL  HAZARDS OR  NIOSH  CRITERIA DOCUMENTS,  OR DEPARTMENT  OF LABOR,
29CFR1910  SU8PART Z.
THE SPECIFIC  RESPIRATOR SELECTED MUST BE BASED  ON CONTAMINATION  LEVELS  FOUND
IN  THE WORK  PLACE AND BE JOINTLY APPROVED  BY THE NATIONAL  INSTITUTE  OF
OCCUPATIONAL  SAFETY  AND HEALTH AND THE  MINE  SAFETY  AND HEALTH ADMINISTRATION.

METHYL ETHYL  KETONE:
1000 PPM-  ANY POWERED AIR-PURIFYING  RESPIRATOR  WITH ORGANIC  VAPOR CARTRIDGE.
             ANV CHEMICAL  CARTRIDGE RESPIRATOR  WITH FULL  FACEPIECE  AND  ORGANIC
                VAPOR CARTRIDGE.

3000 PPM-  ANY AIR-PURIFYING  FULL FACEPIECE RESPIRATOR  CGA8 MASK)  WITH
                CHIN-STYLE  OR  FRONT- OR  BACK-MOUNTED ORGANIC  VAPOR CARTRIDGE.
             ANY SUPPLIED-AIR RESPIRATOR OPERATED  IN CONTINUOUS  FLOW MODE.
             ANY SELF-CONTAINED  BREATHING  APPARATUS WITH  A FULL  FACEPZECE.
             ANY SUPPLIED-AIR RESPIRATOR WITH FULL  FACEPIECE.

   ESCAPE-  ANY AIR-PURIFYING  FULL FACEPIECE RESPIRATOR  CGAS MASK)  WITH
                CHIN-STYLE  OR  FRONT- OR  BACK-MOUNTED ORGANIC  VAPOR CANISTER.
             ANY APPROPRIATE  ESCAPE-TYPE SELF-CONTAINED BREATHING APPARATUS.
FOR FIREFIGHTING AND OTHER IMMEDIATELY  DANGEROUS TO LIFE  OR  HEALTH  CONDITIONSi

   SELF-CONTAINED BREATHING APPARATUS WITH  FULL  FACEPIECE  OPERATED IN PRESSURE
     DEMAND OR OTHER POSITIVE  PRESSURE  MODE.

   SUPPLIED-AIR  RESPIRATOR  WITH  FULL  FACEPIECE AND OPERATED IN PRESSURE-DEMAND
     OR OTHER  POSITIVE  PRESSURE  MODE  IN  COMBINATION  WITH AN AUXILIARY
     SELF-CONTAINED  BREATHING  APPARATUS  OPERATED IN  PRESSURE-DEMAND  OR  OTHER
                                                                                   I               I'

-------
                              ••METHYL  ETHYL  KETONE**                      PAGE  05  OF  OS
     POSITIVE  PRESSURE  MODE.

CLOTHING.
EMPLOYEE  MUST WEAR  APPROPRIATE PROTECTIVE  CIMPERVIOUS3  CLOTHING  AND  EQUIPMENT
TO  PREVENT REPEATED OR PROLONGED SKIN  CONTACT  yiTH  THIS SUBSTANCE.

GLOVES:
EMPLOYEE  MUST yEAR  APPROPRIATE PROTECTIVE  GLOVES  TO PREVENT  CONTACT  yiTH THIS
SUBSTANCE.


EYE PROTECTION;
EMPLOYEE  MUST yEAR  SPLASH-PROOF  OR  DUST-RESISTANT SAFETY  GOGGLES TO  PREVENT
EYE CONTACT WITH THIS  SUBSTANCE.  CONTACT LENSES  SHOULD  NOT  BE  yORN.


                    AUTHORIZED  -  FISHER  SCIENTIFIC  GROUP,  INC.
             CREATION  DATE:   03/28/8*             REVISION DATE:   01-/03/89

                                   -ADDITIONAL  INFORMATION-
THE INFORMATION BELOW  IS  BELIEVED TO BE ACCURATE  AND REPRESENTS  THE  BEST
INFORMATION CURRENTLY  AVAILABLE  TO  US.   HOWEVER.  WE MAKE  NO  WARRANTY  OF
MERCHANTABILITY OR  ANY OTHER  WARRANTY,  EXPRESS OR IMPLIED,  WITH  RESPECT  TO
SUCH  INFORMATION,  AND  WE  ASSUME  NO  LIABILITY  RESULTING  FROM  ITS  USE.   USERS
SHOULD MAKE THEIR OWN  INVESTIGATIONS TO DETERMINE THE SUITABILITY  OF  THE
INFORMATION FOR THEIR  PARTICULAR PURPOSES.

-------
30920   R2273 (RUN 01/17/90)
     * « REVISED « «
FUELS
ATLANTIC RESEARCH CORP
          SAFETY-KLEEN CORP.
     PREQUALIFICATION EVALUATION
          MATERIAL ANALYSIS
                                         ENVIROSYSTEMS
         REVISED •
         CONTROL*:
         SAMPLE* :

        ACCEPT
PAGE 2 OF
01/17/90
0016741-1
017226
GENERAL ANALYSIS OF TOTAL SAMPLE
          COLOR                  DARK BROWN
          FLAMMABILITY          NOT APPLICABLE
          pH                       EXTRACT  BY METER
                    5 .0
GENERAL COMPOSITION:
          AQUEOUS PHASE (FREE WATER).
          ORGANIC PHASE (FEEDSTOCK).
          BOTTOM SLUDGE (SEMI SOLIDS)...
          BOTTOM SOLID (SETTLED SOLIDS)

          TOTAL
                                              SPECIFIC
                                              GRAVITY
               1  158
                          VISCOSITY
                        (CENTIPOISE)
GENERAL COMPOSITION BY:
              APPEARANCE TOTAL
               (VOL%)   (VOLX)
                 50.0     50 0
                 50.0     50,0
                  0.0      00
                  0.0      00
                                                         100.0
                                                                  100.0
RECOVERY EVALUATION OF ORGANIC PHASE
          BOTTOMS OIL ...
          BOTTOMS NON-OIL	
          PHASED DISTILLATE WATER.
          DISTILLATE SOLVENT
                                                                    COMPOSITION OF:
                                                        ORGANIC   TOTAL
                                                        PHASE     SAMPLE
                                                         (VOL%)   (VOL%)
          TOTAL
          BOTTOMS DESCRIPTION
                                                           0.0
                                                           4.0
                                                           3.0
                                                          93.0

                                                         100.0
DIRT
                          0.0
                          2.0
                          1 .5
                         46.5

                         50.0
VOLATILE ORGANIC COMPOSITION OF ORGANIC PHASE BY GAS CHROMATOGRAPHY
          SAMPLE PREPARATION METHODS:
          DETECTION METHODS           FID
COMPOSITION OF: VOLATILE VOLATILE
ORGANICS ORGANICS
COMPOUND NAME
METHYLENE CHLORIDE
ETHYL ALCOHOL
TOLUENE
BUTYLENE OXIDE , 1,2-
TRICHLOROETHANE , 1,1,1-
METHYL FORMATE
PERCHLOROETHYLENE
MINERAL SPIRITS, ALIPHATIC (C9-C13)
LOW BOILING ALIPHATIC HYDROCARBONS
TOTAL
SUMMARY OF VOLATILE ORGANIC COMPOSITION
ALCOHOLS
AROMATIC HYDROCARBONS
ESTERS
GLYCOL ETHERS
KETONES
CODE CAS NUMBER
MECL 75-09-2
ETOH 64-17-5
TOL 108-88-3
BO 106-88-7
111 71-55-6
MEF 107-31-3
PERC 127-18-4
MS 8032-32-4
LAHC 0-31-7

BY COMPOUND CHEMICAL CLASS VOL%:
12.6 ALIPHATIC HYDROCARBONS
S.6 CHLORINATED SOLVENTS
1.6 ETHERS
0.0 INHIBITORS
0.0 NITROGEN COMPOUNDS
(VOL%)
64.3
12.6
8.6
7.9
4. 1
1 .6
0.7
0. 1
0. 1
100.0

0.2
69. 1
0.0
7.9
0.0
(VOL%)
64. 3
12.6
8.6
7.9
4 . 1
1 .6
0.7
0. 1
0. 1
100.0






TOTAL
SAMPLE
(VOLX)
29.9
5.9
4.0
3.7
1 .9
0.7
0.3
0.0
0.0
46.5






SPECIFIC ORGANIC COMPOSITION
          POLYCHLORINATED BIPHENYLS (PCBS): NONE DETECTED  <
LABCRA"
LEVEL :
rORY

REVIEW:

LAB REVIEWERS:
MECL2





A
SEG
CMC



CODE: 77
KAB



RELEASED:
ANALYZED:



01/13/88
01/1 1/88


TRACKING INFORMATION:
SURVEY RECEIVED :
SAMPLE RECEIVED .
RESAMPLE SHIPPED :
RESAMPLE RECEIVED:
DATE
12/28/87
12/28/87
12/28/87
01/04/88
FACILITY
SK

SK
SK
ELGIN,

HEBRON,
HEBRON,
IL.

OH.
OH
REVISION   NOTES   ** (01/17/90) **
            (OOO1)
NOTICE OF LAND DISPOSAL RESTRICTION OF WASTE  IS  REQUIRED UNDER 40 CFR PART 268.

-------
80'.  t  - R2273 (RUN 01/17/90)
    «  « REVISED * *
    FUELS
                    PREQUALIFICATION EVALUATION
                          CUSTOMER SURVEY
                                                                                REVISED
                                                                                CONTROL*
                                                                                SAMPLE*
                                                                                         PAGE   1 OF 2
                                                                                          01/17/90
                                                                                          OO18749-8
                                                                                          017227
                                                          ACCEPT
                                              sateni-Hieen
                                           ENVIROSYSTEMS
"CUSTOMER INFORMATION:  0000-60-7759
          ATLANTIC RESEARCH CORP
          5945  WELLINGTON
          GAINESVILLE                  VA  22065
   ATTN:  MELISA  COHEN
 SALESPERSON: BILL MOIANDER
 FEDERAL EPA ID; VAD023741705
            TERRITORY•
         STATE  EPA:
                                                 COUNTY •
                                             ID:
 MATERIAL: ANTIFREEZE
           VOLUME :
  STORAGE CAPACITY:
            COLOR:
1-99-0-0/H20  1-99-0-0
  500  GALS  PER QUARTER
    0  IN
                                          LAYERS:
                                                            PROCESS:
                                                         VOLUME ON HAND:
                                                     SHIPPING  FREQUENCY:
                                                         PHYSICAL STATE:
                                                           IN DRUMS
                                                               VISCOSITY:
 RESTRICTED SUBSTANCES:  NONE
. P .0. NO :
I CONTACT:
(CORPORATE REVIEWS
TECHNICAL
REGULATORY
OPERATING
MELISA COHEN
: DISPOSITION
: ACCEPT
: ACCEPT
: ACCEPT

REVIEWER
JWH
JWH
LWG
SUBMITTER:
TITLE:
DATE
01/13/88
01/13/88
01/13/88
8888
HANDLING
MISC
CODES
ENVIROSYS ACCT
: S02/T50
DATE:
PHONE :
12/28/87
703-642-641
1
PRICING CODE : FW
 APPROVED FACILITIES:
   (658) SAFETY-KLEEN CORP
        STATE HWY 146
        NEW CASTLE KY 40050
 I  FED  EPA*: KYD053348108
 I:
       (635)  SAFETY-KLEEN CORP
             1200 SYLVAN ST
             LINDEN NO 07036
             NJD002182897

             201/«62-20OO
  FED EPA*:
 STATE EPA*:
 TELEPHONE:  502/845-2453
 IL. AUTH*:

WPPROVED 0001055 DRUM OR BULK
:|)OT-EPA  DISCARDED MATERIAL (SEE NMFC LIST)
:DESC.    (NOT  USDOT HAZARDOUS MATERIAL)
         (NOT  USEPA HAZARDOUS WASTE)
.COMMENTS:  OK FOR WASTE WATER FUEL.
1         ADDED SHIPPING DESCRIPTION BASED ON RECEIPTS
 \
                                                  OOO1109 DRUM OR BULK
                                                  DISCARDED LIQUIDtSEE NMFC  LISTHNJ X90O)
                                                  (NOT USDOT HAZARDOUS MATERIAL)
                                                  (NOT USEPA HAZARDOUS WASTE)
                                                       JWH
            THIS SERVES AS NOTICE PER,  40CFR284.12(B), THAT THE FACILITY(IES)  NOTED ABOVE
            HAS THE APPROPRIATE PERMITS AND  IS WILLING TO RECEIVE THE MATERIAL DESCRIBED.

-------
80920   R2273 (RUN 01/17/90)
     * * REVISED » «
FUELS
ATLANTIC RESEARCH CORP
            SAFETY-KLEEN CORP.
       PREQUALIFICATION EVALUATION
            MATERIAL ANALYSIS
                                         ENVIROSYSTEMS
                 REVISED
                 CONTROL*
                 SAMPLE*

                ACCEPT
               PAGE 2 OF 2
               01/17/90
               0018749-8
               017227
GENERAL ANALYSIS OF TOTAL SAMPLE
          COLOR
          FLAMMABILITY
          PH
 GREEN TRANS
NOT APPLICABLE
   DIRECT   BY PAPER
                      8.0
GENERAL COMPOSITION:
          AQUEOUS PHASE (FREE WATER)
          ORGANIC PHASE (FEEDSTOCK).
          BOTTOM SLUDGE (SEMISOLIDS ) . . .
          BOTTOM SOLID (SETTLED SOLIDS)
                                           GENERAL COMPOSITION BY:
              SPECIFIC      VISCOSITY                     APPEARANCE TOTAL
              GRAVITY     (CENTIPOISE)                     (VOL%)   (VOL%)
                                      	         . ...  100.0    100.0
                                                             0.0      00
                                                             0.0      0.0
                    	       ..       	          0.0      0.0
TOTAL
RECOVERY EVALUATION OF AQUEOUS PHASE
1 .030 35 CPS
COMPOSITION OF:
100.0
AQUEOUS
PHASE
(VOLX)
100.0
TOTAL
SAMPLE
(VOL%)
          BOTTOMS OIL	
          BOTTOMS NON-OIL	
          PHASED DISTILLATE WATER.
          DISTILLATE SOLVENT

          TOTAL
                                                            23.0
                                                             0.0
                                                            77.0
                                                             0.0

                                                           100.0
                                 23.0
                                  0.0
                                 77.0
                                  0.0

                                100.0
VOLATILE ORGANIC COMPOSITION OF AQUEOUS PHASE BY GAS CHROMATOGRAPHY
          SAMPLE PREPARATION METHODS:
          DETECTION METHODS           FID
                                                            COMPOSITION OF:
COMPOUND NAME
WATER
ETHYLENE GLYCOL

TOTAL
                            CODE
                             EG
CAS NUMBER
     0-00-0
   107-21-1
SPECIFIC ORGANIC COMPOSITION
          POLYCHLORINATED BIPHENYLS (PCBS): NONE DETECTED <
VOLATILE
ORGANICS
  (VOL%)
    99.5
     0.5

   100.0
VOLATILE
ORGANICS
  (VOL%)
    99.5
     0.5

   100.0
TOTAL
SAMPLE
(VOL%)
  0.0
  0.0

  0.0
SUMMARY OF VOLATILE ORGANIC COMPOSITION BY
ALCOHOLS
AROMATIC HYDROCARBONS
ESTERS
GLYCOL ETHERS
KETONES
COMPOUND CHEMICAL CLASS VOL%:
0.0 ALIPHATIC HYDROCARBONS
0.0 CHLORINATED SOLVENTS
0.0 ETHERS
0.5 INHIBITORS
0.0 NITROGEN COMPOUNDS
0.0
0.0
0.0
0.0
0.0
ADDITIONAL ANALYTICAL INFORMATION: CYANIOt-NEGATIVE
LABORATORY REVIEW: A
LEVEL.             SEG CODE: 95   RELEASED: 01/12/88
LAB REVIEWERS:     GLL GLL        ANALYZED: 01/11/88
DISPOSE OF WATER/POSSIBLE FUELS FOR OIL
                          TRACKING  INFORMATION:
                              SURVEY  RECEIVED  :
                              SAMPLE  RECEIVED  :
                              RESAMPLE  SHIPPED
                              RESAMPLE  RECEIVED:
               DATE      FACILITY
               12/28/87 SK  ELGIN, IL.
               12/28/87
REVISION   NOTES   ** (01/17/90) **
            (0003)
NO LAND DISPOSAL RESTRICTION OF WASTE CAN BE IDENTIFIED  BASED ON S-K ANALYSIS.

-------
8092
             (RUN 01/17/90)
               PREQUALIFICATION EVALUATION
                     CUSTOMER  SURVEY
   * * REVISED * *
   WASTE FOR RECYCLING
                                              sateni'Hieen.
          PAGE   1  OF  2
 REVISED :  01/17/90
 CONTROL*:  OO35114-4
 SAMPLE* :  043022
                                                                                ACCEPT
                                                                                NO ATTACHMENT
                                           ENVIROSYSTEMS
CUSTOMER INFORMATION:  OOOO-80-7759


          ATLANTIC  RESEARCH  CORP
          5945  WELLINGTON  RD.
          GAINESVILLE                  VA 22065


  ATTN:  MELISA T.  COHEN

 SALESPERSON:  BILL MOLANDER       TERRITORY:  3SOO COUNTY: PRINCE WILLI
 NATURE OF BUSINESS:  PROPULSION FUEL
 FEDERAL EPA ID:  VAD023741705  STATE  EPA:    .  ID:
[MANIFEST ADDRESS IS  BILLING	MANIFEST  TO  SAFETY-KLEEN	
'•MAI
IS*
  TERIAL: METHYLENE CHLORIDE
           VOLUME:       55 GALS PER  QUARTER
  STORAGE CAPACITY-        0 IN DRUMS
            COLOR:  BROWN	LAYERS:
                                                  ONE
                                   PROCESS: PARTS CLEANERS
                               VOLUME  ON HAND:      55
                           SHIPPING FREQUENCY-         IN DRUMS
                               PHYSICAL STATE: LIQUID	VISCOSITY :
                                                                                                LOW
^MATERIAL COMPOSITION VOL%) :
1 METHYLENE CHLORIDE
* PROPYL ALCOHOL, ISO-
•IL. PETROLEUM
CODE
MECL
IPA
0
MIN
60.0
5.0
10.0
MAX
80.0
15.0
20.0
TYPICAL
70.0
1 .0
15.0
.
1
JD
   .STRICTED SUBSTANCES: CARCINOGENS
             IDENTIFY  : METHYLENE CHLORIDE
        PROPER SHIPPING NAME: WASTE METHYLENE CHLORIDE
 D.O.T. HAZARDOUS MATERIAL:
 EPA HAZARDOUS WASTE:
1 CODES: TOXIC
                                                       HAZARD CLASS:  ORM-A
                                                    NO(S):  D001  F001
                                                              NUMBER: UN1593
        P.O.  NO:
  TYPE OF SAMPLE:
 	CONTACT:
                 MELISA T.
                 SUBMITTER:
   NUMBER OF DRUMS SAMPLED:
COHEN	TITLE :
                                                      0901 RANDY CUNNINGHAM
                                                       ENV.  ENG.
    DATE:  03/29/89
TAKEN BY-  CUSTOMER
   PHONE:  703-642-6448
 CORPORATE REVIEWS:  DISPOSITION REVIEWER   DATE
        TECHNICAL:     ACCEPT     EJE     04/24/89
       REGULATORY:     ACCEPT     JWH     04/24/89
        OPERATING:     ACCEPT     LWG     04/25/89
                                                   HANDLING CODES:  S02/T63
                                                    PRICING CODE: R8
 APPROVED FACILITIES:
   (635) SAFETY-KLEEN  CORP
        12OO SYLVAN ST
        LINDEN NJ 07036
   FEC EPA#:  NJDOC2132897
 STATE EPA*:
  TELEPHONE:  201/862-20CO
  IL.
                            (658) SAFETY-KLEEN CORP
                                  STATE HWY 146
                                  NEW CASTLE KY 40O5O
                                  KY0053348108

                                  502/845-2453
                           (642)  SAFETY-KLEEN CORP
                                 581  MILLIKEN OR SE
                                 HEBRON, OHIO    43025
                                 OH0980587364

                                 614/929-3532
 APPROVED OOO0515 DRUM
 UOT-EPA  WASTE METHYLENE CHLORIDE
 •ESC.    ORM-A UN1593 (EPA FOO1)(ERG *74)

 •COMMENTS: OK FOR CRUDE MECL RECOVERY.
            THIS SERVES AS NOTICE  PER,  40CFR284.12(B),  THAT THE  FACILITYfIES) NOTED ABOVE
            HAS THE APPROPRIATE  PERMITS AND  IS WILLING  TO  RECEIVE THE MATERIAL DESCRIBED.

-------
80920   R2273 (RUN 01/17/90)
         REVISED * *
WASTE FOR RECYCLING
ATLANTIC RESEARCH CORP
                                            SAFETY-KLEEN  CORP.
                                       PREQUALIFICATION EVALUATION
                                            MATERIAL  ANALYSIS
                                         ENVIROSYSTEMS
                                                                           PAGE 2 OF
                                                                 REVISED   01/17/90
                                                                 CONTROL*:  OO35114-4
                                                                 SAMPLE*   043022

                                                                ACCEPT
                                                                NO ATTACHMENT
GENERAL ANALYSIS OF TOTAL SAMPLE
          COLOR
          WATER CONTENT
          FLAMMABILITY
          PH
          RADIOACTIVITY
                                 BLACK
                                     0.5 WT%
                                NOT APPLICABLE
                                   EXTRACT  BY PAPER
                                NONE DETECTED
                                    7.0
GENERAL COMPOSITION:
          AQUEOUS PHASE (FREE WATER).
          ORGANIC PHASE (FEEDSTOCK)...
          BOTTOM SLUDGE (SEMI SOLIDS )....
          BOTTOM SOLID (SETTLED SOLIDS)

          TOTAL
                                              SPECIFIC
                                              GRAVITY
                                                 1.210
                                                            VISCOSITY
                                                          (CENTIPOISE)
                                                                50 CPS
                                                        GENERAL COMPOSITION BY:
                                                                      APPEARANCE TOTAL
                                                                       (VOL%)   (VOLX)
                                                                          0.0     00
                                                                	  100.0    100.0
                                                                          0.0     0.0
                                                                          0.0     00
                                                                                           100.0
                                                                                                    100.0
                                                                                                        I
RECOVERY EVALUATION OF TOTAL SAMPLE
          BOTTOMS OIL...
          BOTTOMS NON-OIL	
          PHASED DISTILLATE WATER.
          DISTILLATE SOLVENT
                                                 COMPOSITION OF:
          TOTAL
          BOTTOMS DESCRIPTION
                                                        TOTAL   TOTAL
                                                        SAMPLE   SAMPLE
                                                         (VOLX)  (VOL%)
                                                                                            16.0
                                                                                             0.0
                                                                                             0.0
                                                                                            84 .0

                                                                                           100.0
                                                                                 1S.O
                                                                                 0.0
                                                                                 0.0
                                                                                 84.0

                                                                                100.0
                                  OIL
VOLATILE ORGANIC COMPOSITION OF DISTILLATE
          SAMPLE PREPARATION METHODS:
          DETECTION METHODS           OTHER
COMPOUND NAME
METHYLENE CHLORIDE
TETRAHYDROFURAN
METHYL ETHYL KETONE
 TOTAL OTHERS ('1.0% EACH)

TOTAL
                                              BY GAS CHROMATOGRAPHY
COMPOSITION OF:

CODE
MECL
THF
MEK
TO

CAS NUMBER
75-09-2
109-99-9
78-93-3
0-05-5
VOLATILE
ORGANICS
(WT%)
90.4
4.9
4.5
0.2
VOLATILE
ORGANICS
(VOLX)
85.8
7.0
7.0
0.3
TOTAL
SAMPLE
(VOL%)
72. 1
5.9
5.9
0.3
                                                                                   10O.O
                                                                                             100.0   84.0
SUMMARY OF VOLATILE ORGANIC COMPOSITION
ALCOHOLS
AROMATIC HYDROCARBONS
ESTERS
GLYCOL ETHERS
KETONES
BY COMPOUND CHEMICAL CLASS WTV
0.0 ALIPHATIC HYDROCARBONS
0.0 CHLORINATED SOLVENTS
0.0 ETHERS
0.0 INHIBITORS
4.5 NITROGEN COMPOUNDS

0.0
90.4
4.9
0.0
0.0
SPECIFIC ORGANIC COMPOSITION
          POLYCHLORINATED BIPHENYLS  (PCBS):  NONE  DETECTED <
ADDITIONAL ANALYTICAL INFORMATION:  EPD"154F
                                                                                                         I
LABORATORY REVIEW:
LEVEL:
LAB REVIEWERS:
SEG CODE:
LM  LM
RELEASED: 04/24/89
ANALYZED: 04/24/89
TRACKING INFORMATION:
    SURVEY RECEIVED   :
    SAMPLE RECEIVED   :
    RESAMPLE SHIPPED  :
    RESAMPLE RECEIVED:
DATE      FACILITY
04/04/89 SK TECHNICAL CE
04/04/89
REVISION   NOTES   ««  (01/17/90)  «*
            (0001)    G
NOTICE OF LAND DISPOSAL RESTRICTION OF WASTE IS  REQUIRED UNDER 40 CFR PART 268.

-------
30920  - R2I73 (RUN 01/17/90)
« «  REVISED * *
   FUELS
                                     PREQUALI FI CATION  EVALUATION
                                           CUSTOMER  SURVEY
                                                                                       PAGE  1  OF  2
                                                                              REVISED :  01/17/90
                                                                              CONTROL*:  0018741-1
                                                                              SAMPLE* :  017226
                                                                             ACCEPT
                                             safeni'Hieen
                                         ENVIROSYSTEMS
CUSTOMER INFORMATION:
         ATLANTIC  RESEARCH  CORP
         5945  WELLINGTON RD
         GAINESVILLE                  VA  22065
  ATTN:  MELISA COHEN
SALESPERSON:
FEDERAL EPA ID:  VAD023741705
                              TERRITORY:
                          STATE  EPA:    .
                                                COUNTY:
                                           ID:
 MATERIAL: MECL 1-99%/OIL  1-99%
           VOLUME:      55  GALS PER QUARTER
  STORAGE CAPACITY:        0  IN
            COLOR:                        LAYERS:
            IDENTIFY  :  ORM-A UN 1593
                                                           PROCESS:  BROWN  LIQUID
                                                       VOLUME ON HAND:       0
                                                 SHIPPING  FREQUENCY:
                                                     PHYSICAL STATE:
                                                                               IN DRUMS
                                                                                  VISCOSITY-
P.O. NO :
CONTACT:
CORPORATE REVIEWS
TECHNICAL
REGULATORY
OPERATING
MELISA COHEN
: DISPOSITION
ACCEPT
: ACCEPT
: ACCEPT

REVIEWER
JWH
JWH
LWG
SUBMITTER:
TITLE :
DATE
01/15/88
01/15/88
01/15/88
0034
HANDLING
VOID
CODES: S02/T50
DATE :
PHONE :
12/28/87
703-642-641
1
PRICING CODE: FM
APPROVED FACILITIES:
  (658) SAFETY-KLEEN  CORP
       STATE HWY 146
       NEW CASTLE KY 40O50
  FED EPA*: KYD053348108
STATE EPA/*>:
 TELEPHONE: 502/845-2453
 IL.  AUTH*:
COMMENTS: OK FOR MIX  CHLOR FUEL
           THIS SERVES  AS  NOTICE PER, 40CFR284.12(8),  THAT THE FACILITY(IES)  NOTED ABOVE
           HAS THE APPROPRIATE PERMITS AND IS WILLING  TO RECEIVE THE MATERIAL DESCRIBED.

-------
a«*u trm or ryce.  (Form Jeav»i3 tar me on elmi |12-ortcM>
                                                                                                       Form Aoorovwe) OMB Mo  2050-0039 Eiom 9.
                                            I
A I i tuicnou WA7ARDOUS 1 G«n^«Wf s US EPA ID No. Mamtest Document No
TUNWA®TEM^FEST VAD023741705 | 01003
a
E
H
E
R
A
T
O
B
I
1
I
4
f
!
1
C
P
1
1
1
1
;
<
3 Generator's Name and Mailing Address
ATLANTIC RESEARCH CORPORATION
5945 Wellington Road
Sainesvj He, VA 22065 /7rmfi47-fi4ll
4 Generator! PhoneT ) \ /UJ > OHt-O*»il
5. Transponer i Company Name
HAZMAT Environmental Group
7 Transporter 2 Company Name
9 Designated Facility Name ano Site Address
Safety Kieen En vi rosy stems
State Highway 146
New Castle, Kentucky 40050
11. USD
HtU
a.
D.
" '
d.
6. US -PA ID Number
NYD080769947
8. US EPA ID Numper
10. US EPA ID Numoer
KYD053348108
12. Coma
OT Descnption (Including Proper Shipping Name, Hazard Class and ID Number)
No.
RQ Haste Flaimable Liquid N.O.S.
Flanmable Liquid UN 1993 ll
Waste 1,1,1-Trichloroethane
ORM-A UN 2831 \\


J. Additional Descriptions tor Materials Usted Above
2. Page 1 Information m tne snaaed art:
Q( l is not required by Federal laJ
A, State Manifest Document Numoer T
01003
B. State Generator's 10
VAD023741705

C. State Transporter's 10 NVU^U/69?
D. Transporter's Phone ( 7"
Lb)8//-5S
E. State Transporter's 10
F. Transporter's Phone *
G- WfiKmfioa .1
H. Facilitys Phone
(502)845-2453
mers 13. 14.
Total Unit
Type Quantity Wt/VoJ
DH P
10;T-00
DH P


1
Waste No. j
0001
f
F001 »
I
1

K. Handling Codes for Wastes Listed Above 1
i
15. Special Handling Instructions and Additional Information
f \ / \L - 1
( ^ TiTT^c^ ** o) ^ n n ^"M^> '
1 6. GENERATOR'S CERTIFICATION: 1 hereoy deeUre that tne comenti of tnii conaignmeffl are tuHy and accurately detcrioed aOove By
proper thipping name and are ctaaartied. packed, marked, and labeled, and are m all respect* in proper condition lor tranaport By highway 1
according to apphcatte tntarnational and national government regulation*. 1
it I am a large quantity generator. I certify tnal 1 have a program m place to reduce me volume and toiioty of waste generated to the degree 1 have determined 10 R
•conomicaiiy practicaeie and tnal 1 have selected the pracucatte method of treatment, itorago. or disposal currently avaiiaoie to me which mimmiiai in* priMflt IM
future threat to human nealtn and the environment: ON. if 1 am a smaH quantity generator. 1 have made a good laitn effort to minimize my waat* generation ind MW<
to* beat wasi* management method that n avartaaM to me and that 1 can attord. 1
Pnnted/Typed Name
Signature
Month Day Jj
1 7. Transponer 1 Acknowledgement of Receipt of Materials |
Primed/Typed Nama.
Sionaturj _ +^*\
V_-X>»^ C^ £****'"*&'
1 8. Transponer 2 Acknowledgement of Receipt of Materials
Printed/Typed Name
Signature
19. Discrepancy indication Space
20. Facility Owner or Operator: Certification of receipt of haz
ardous materials cq*Ved by this manifey e>

-------
  •>leaee pnnt ot rype. (Form angnad lor UM on ek
                                                                                     Approved OMB No. 206O-0039. €xanu 9-30-68
  t
  UNIFORM HAZARDOUS
    WASTE MANIFEST
     3. Generator's Name and Mailing Addret~
           Atlantic Research  Corporation
             945  Wellington Road
              mVn.l1e'  VVgln
                                                  (703)642-6411
 2. Page i
   of   !
      Information in the snaoed areas
      is not required Dy Federal law
                                                                                 A. State Manrteet Document Numoer
                                                                                   01004
B. State Generator'* 10
   VAD023741705
     5. Transponer i Company Name
           HAZMAT  Environmental  Group
                                                  6.       US EPA 10 Number
                                                  I	NYD980769947
C. StaleTransporter1»ID NYD98Q769947
D. Transported Phone (716)877-5533
     '. Transponer 2 Company Name
                                                          US EPA ID Numoer
E. SUte Transporter's 10
                                                                                     F.  Transporter's Phone
     9. Designated Facility Name and Site Address
            Safety  Kleen.  Envirosystems
            State Highway  146
            New  Castle,  Kentucky  40050
                                                  10.      US EPA ID Numoer
                                                      KYD053348108
G. State Facility's ID
    KYD053348108
H. Facility's Phone
       (502)845-2453
     11. US DOT Description (Including Prop* Shipping Name, Hazard C/ass and ID Number)
                                                                         12. Containers
                                                                          No.   Type
         13.
         Total
       Quantity
             14.
            Unit
            WWol
 Waste No.
              RQ Waste  Flammable  Liquid N.O.S,
              Flammable Liquid UN 1993
                                                                          17
DM
10200
DOOl
     b.
              Waste 1,1,1- Trichloroethane
              ORM-A UN 2831
                                                                                 DM
       1400
                   FOOl
     c.
     d.
* J. Additional Oescnpoona tor Materials Ustaxl Above
                                                                                    K. Handling Codee tor Waste* U«ted Above
      15. Special Handling Instructions and Additional Information
      16. QENCH ATOM'S CERTIFICATION: I hereby declare (Ml the content o< ttM consignment are tufty end accurately described above ay
         proper shipping n»m* and w« dawided. packed, marked, and laMMd. and an in an rvapecu in proper condition lot traiwpen By lugnway
         according u> applicable mwfnauonai and national gonetnmem regulatiena.

         it l am a large quantity generalot I cerUty thai I have a program in place M reduce the votom* and Wocrty o4 wane generated to tha degrae I have determined lo be
         •conomwally practicable and mat I have aelaciad the practical* mcthed ol tnMtmem. nerage. or dnpOMl cunantty available to ma wnich mrntrnu** \ttt prtaent and
         luturt thrtat lo human health and the en»«cnment: OH. M I am a amaN quantity generator I have made a good latth effort to mmmxe my waste generation and select
         the beat watte management method that le available to me and that I can atfocd.
      17. Transporter 1 Ac*no*«edQ«me
-------
    print or tvo«.
                                                                                                        QMB No. 2O50-O039 Exor^ 9-3
   UNIFORM HAZARDOUS
      WASTE MANIFEST
                                                                                     ;nt No
  3  Generator s Name
4  G' r*rator-s Phone (
                                 (tf ^ Q   (
                                                                                          2. Page 1
                                                                                            of
                                                                                                            Information m the snaded areas
                                                                                                            is not required oy Federal law
                                                                                          A.  State Manifest Document
                                                                                          	&I&& Q	
                                                                                          B.  State Generators ID     7
                                                         6.
                                                                 US EPA 1
                                                                                            C.
  7  Transporter 2 Company Name
                                                                 US EPAIDNumoer
                                                                                          E.  Stat* Tnan«pon«r's 10
                                                                                            F. Trmn«pon«f'i Phone
  9. Designated Facility Name and Sup Address
                                                                 US EPAIDNumoer
                                                                                          G. State FacilitVs ID
                                                                                            H.
   11. US DOT Description (Including Proper Shipping /Ya/ne, HazanJ C/«M »nv«
                                                                                         K. Handling Codes (of Wastes Listed Above
   15.  Special Handling Instructions and Additional Information
   1 6. GENERATOR'S CERTIFICATION: I nereoy declare mat the contents ol thu consignment are tuUy and accurately described above by
       prooer snipping name and are classified, packed, marked, and laoeted. and are m alt reipecia m proper condition lor transport oy highway
       according to applicable international and national government reguutwns.

       ill am a large quantity generator. I cartHy that I have a  program m otace to reduce the volume and toiioty ol waste generated to the degree I have determined to M|
       iconomically practicable and that I have selected the practicable method ol treatment, storage, or disposal currently available to me whicfl mmmizes the prsstnt IM
       future threat to human health and the environment: ON.  rt I am a small quantity generator. I nave made a good lartn effort to miramue my waate generation ind tefcct
       me e«st waste management method mat is available to me and that I can afford.
     ^Printed/Typed Na
     IW3  A-
                                                               Signals
                                                                  rhi
                                                                                                                   Month
    17. Transporter 1 Acknowledgement of Receipt of Materials
       Printed/Typed Name
                tfcT     R
    18. Transporter 2 Acknowledgement of Receipt of Materials
                                                                                            »"^Xx*4«£.
                                                                                                                   Month Off
       Pnnted/Typed Name
                                                                                                                   Month Off  »*•
    19. Discrepancy indication Space
    20. Facility Owner or Operator Certification ot receipt of hazardous materials covered by tnu manifest except as noted in Item 19.
Style FlSflEV-6 Lafi«ma«er. Orv. ot American Laowmark Co. inc. 60644

-------
        or typex fftjfin
        Acoroved QMS No. 20*O-003S. Eon. 9-3O-W
1
a
c
N
C
A
*
T
0
'».
^
-
1
)
4
t
i
1
1
1
UNIFORM HAZARDOUS 1 1 G«"«f«tors u;> tr* 'u ™
WASTE MANIFEST [VAD023741705
r^.,.,.,^. Document No
I 01012
3. Gerierajor's Name and Mailing, Add/ess
Atlantic Research Corporation
5945 Wellington Road
Gainesville, VA 22065 ,_,-,.,.-. ,..„
4 GeneratoiTPhone ( ) (703)642-6448
5. Transponer 1 Company Name) 6. US EPA iD^iumoer
Hazmat Environmental Grouc NYD980769*I47
7. Transponer 2 Company Name 8.
US EPA ID Number
9. Designated Facility Name and Site Address 10. US EPA ID Number
Safety Kleen Eiivirosystems
State Highway 146
New Castle, KY 40050 KYD053348108
1 1 . US DOT Description (Including Proper Shipping Name, Hazard Class
*M
a.
b.
c.
d.
J. Addtt

RQ Waste Flammable Liquid N.O.S.
Flammable Liquid UN1993
Waste Ethylene Glycol
Combustible Liquid N.O.S. NA1993
12. Coma
and ID Numotr)
No.
10
6


enriftl nMrnnfuvkfi fnr Uat*rial« 1 ratArt AhfrVt*

2. Page 1 informatic
o) . is not reqi
m m the snaded areas
jired by Federal law
A_State Manifest Document Number
fl-Sia^e Genefator's 10
C State Transporters ID Mttiai^ia9Ma>
0. TranaporMr'«Phone(7l6)877-5533
E. State Tranaportefs ID
F. Transportef'a Phone
G. State Facility's 10 I
KTO053348108 f
H. Facility's Phone
(502)845-2453
mers 13. 1
Total U
Type Quantity Wt
CM 6000
CM 3600 F



4. I.
nit Waste No.
/Vrt
P D001
' NR


K. Handling Code* for Waste* Usied Abov»)
T50
15. Special Handling Instructions and Additional Information
Uui^b 33 lies'!
16. «N
prop
•CCO
II l a
•con
lulur
the 6
ER ATOR'S CERTIFICATION: I hereby declare thai the contents ol this consignment are lully and accurately described above by
er shipping name and are daaartied. packed, mariud. and labeled, and are tn all reapects m proper condition lor transport by highway
m a large quantity generator. 1 certify that l have a program m place to
omicaily practicable and thai 1 have selected the practicable method o*
>est waste management method that is available to me and that l can atlo
Printed/Typed Name)
' Melisa T. Cohen
reduce the volume and touoty ol waste generated to the degree l have determined to be
treatment, storage, or disposal currently available to me which minimizes the present and
my generator. 1 have made a good taitn afton to mtmmue my waste generation and select
Signature
Montn Day /ear
IT. I ^ Isa
r 17. Transporter 1 Acknowttdgwncnt of Receipt of Materials
Printed/Typed Name) .
J 18. Tra

nsporwr 2 ACKnowieogejmern 01 necetpi OT Materials
[ Printed/Typed Name)
i
Signaujrey 7?.*^
(LJL 4Zf
Month Day Ytar
/?
Signature
Month Day year
I I I
19. Discrepancy Indication Space
t
'20. Facility Owner or Operator Certification of receipt of Hazardous matenals covered Dy this man test except as noted in item 19.
'j^WgT'-C /fTklV3QK)

Momfi o«y Y9»fr
StyteFtSREV4 Laoetmaster. Oiv. o« American LaMwiark Co. Inc. 60646
EPA Form »700-22 (Be» 9nJ6) Prevnu* e
-------
                  (Form
                               for	
                                                                                                 torn Approved OMB No. 2050-0039 Eioires 9-30-88
      UNIFORM  HAZARDOUS
         WASTE MANIFEST
. Generators US EPA ID No.

 dfl 01.37'*  I  7  Q.
                                                                           Manifest uocumeni No
                                          2.  Page 1
                                            o.    /
     Information in me snaded areas
     is not required Oy Federal law
I
        Generator's Name and Mailing Address
                                                                                                 A. Slate Manitest Document Numoer
                                                                                                 8. State Generator's ID
     5. Transponer 1 Company Name
                                                             6.
                                                                      US EPA ID Number
                                                         C, State Transporter's ID
                                                                                                 D. Transported Phone
                                                                                                                              57 7 -
     7. Transponer 2 Company Name
                                                                      US EPA 10 Number
                                                         E. State Transporter's
                                                                                                 F. Transporter's Phon«
     9. Designated Facility Name and Site Address
                                                             10.      US EPA ID Number
                                                         G. State Facility's ID
                                                                                                 H. Facility's Phon*
     11. US DOT Description (Including Proper Shipping Name, Hazard Class and ID Number)
                                12. Containers
                                 No.    Type
   13.
 Total
Quantity
 14.
 Unit
Wt/Vd
                                                                                           I.
                                                                                       Waste No.
              t«
i-lQv1 \ A      Nt.o . >.

 VWV113
                                                                                         \\
                                                                                     CCO)
     c.
     d.
     J. Additional Descriptions tor Materials Listed Above
                                                        K. Handling Codes for Wastes Listed Above
      15.  Special Handling Instructions and Additional Information
      15  GENERATOR'S CERTIFICATION: I nereOy declare thai the contents of this consignment are luily and accurately described above by-
          proper shipping name and are classified, packed, marked, and labeled, and are in all respects in proper condition for transport by highway
          according 10 applicable international and national government regulations.

          if I am a large quantity generator. I certify that I have a program m place to reduce the volume and loilctty of waste generated to the degree I have determined 10 M
          economically  practicable and that I nave selected the practicable method at treatment, storage, or disposal currently available to me wnicn minimizes the prtuni ma
          future threat to human health and the environment: OR. it I am a smalt quantity generator. I have made a good laitn effort to minimize my waste generation in) WKCI
          me best waste management method that is available to me and that I can afford.
          Pnmed/Typed Name
                              Signature
                                                                   Month Day
      17. Transporter 1 Acknowledgement of Receipt of Materials
           'nnted/TypedJ'iame
                              Signature
                                  Oi  i  >J
       18. Transponer 2 Acknowledgement of Receipt of Materials
                                                                   Monp Dty  W
          Printed/Typed Name
                              Signature
       19. Discrepancy indication Space
       20. Facility Owner or Operator: Certification q< receipt of hazardous materials coyred by this manifest eyept as, noted in Item 19
   ST)rte F15REV-6 UB*m«»t»r. On. ot American Uoatmart Co. inc. 60646
                                                      ERA Form 8700-22 (R«v. 9,96) Preview edrtioni in o

-------
P*te« arm or rype  iFprm desqned tor LCM wi (Me 112-on

    UNIFORM HAZARQQIJ3-
        WASTE MANIFEST
                                        G*"eral
                                 \oorov«d OM6 So  2050-O039 E
                                                                9-3O-88
                                 J
                                        Information m the snaaed areas
                                        is not required Dy Federal law
    3. Generator's Name and Mailing Address
                           Hr"5fate Manifest Document Numoer
                                                                                                6. Stata Generator's ID
    5. Transporter" Company Name
                                                                     US EPA ID NumDer
                           C.  State Transporter's ID
                                                                                                D.
    7. Transporter 2 Company Name
                                                            8.
US EPA ID NumDer
                                    i.  Slate Transporter's ID
                                                                                                F.  Transporters Phone
    9. D«s»gnated Facility Name and Site Address
10.       US EPA ID NumDer
                           G.  State Facilttys ID
                                       t>f 1-3
                                                                                                                                       L
                                                                                                H. Facilityj Phone
    11. US DOT Description (Including Proper Shipping rVa/ne, Hazard C/ass and /O Number)
                  12. Containers

                    No.   | Type
                                                .
                                             Total
                                            Quantity
                                                                                                                    WWoi
Waste No.
    d.
    J. Additional Descriptions (or Materials Listed Above
                           K.  Handling Codes tor Wastes Listed Above
     15. Special Handling Instructions and Additional Information
     1 6 GENERATOR'S CERTIFICATION: I htrcby Mdvt that in* eonttnit ot tnit coniqnmvni irt lully ind iccurtttly dt $criD«d «oov« Dy
        proe«f (hipping n»m« and trt ct«**il«d. paetod. marked, and l«b*(*d. ind ir» m M rtipccti m proper condition tor tranioort oy higrtwiy
        tccording m tpetcaDM inlcmational and nation*! gtrmnmur* f
        It I am a large quantity generator. I certify that I have a program in place to reduce th* volume and toiioty of waste generated to the degree I nave determined 10 be
        economically practicable and that I have selected the practicable method ot treatment, ttorage, or diapoaal currently available to me whicn minimises the present and
        tuture threat 10 human health and (he environment: ON. rf I am a small quantity generator. I have made a good taith effort to minimize my waste geneiation and setect
        the best waste management method met is avertable to me and that I can afford.
        Printed/Typed Name
Signature
                                                             Month  Day   Vear
     17. Transporter i Acknowledgement of Receipt of Materials
        Printed/Typed Name
        Sigi
                                                     Month  Day   Vear
     18. Transporter 2 Acknowledgement of Receipt ol Materials
                                                      yle F15REV4  LaDeimaster. Oiv. ot American Uoetmani Co. Inc. 40644
                        EM Form 6700-22 (Rev 9/M) Previous edruons are oMowe
                                                             .BCT1IQM TO

-------
             APPENDIX I



THERMAL TREATMENT INSPECTION REPORTS

-------
      LOCATION
BARREL COLOR
1 BARRELS
PIT
                                                         «*.-*
    7/0
                                                         A
COMMENTS:  p, J-  /
                                                                                l/)r.

-------
                                                           OPERATOR
                                     T*/^
                                    '.1 JlS&su r
           LOCATION
BARREL COLOR
1 BARRELS
PIT
                                                     f)P
                                                  -3
                                                 e,
         75
                                                 /3

                                                  -3
                                                                        /
                                                 e,
                                                                         /
        r
                                                  2.
pected by:
             (Safety RepresentaUve)

-------
       '   LOG AT I ON
                           BARREL COLOR
BARRELS
PIT
                                                                                  3
                                                                z.
               23.
                7
                                                                  //
                                                                        y
COMMENTS:
                                fr
ctedby:
            (Safety Representative)

-------
                       HOT TRASH LOG
  DATE:
                                                          OPERATOR:
LOCATION
                     BARREL COLOR
                                                      /' U A 1< KILLS
 A'
                                                                     A
 7V
                                                                           a
SZ
 V/
SAFETY INFRARED CHECK:
COMMENTS:
                      Signature

-------
                     HOT TRASH LOG
DATE:
                                                   OPERATOR:
1 LOCATION
?23
25^
7T
$~b
/V3
74
76)
/of

7V
7V
73
wr
vT















BARREL COLOR




























^ // ^
II BARRELS
V
•^
I
/
2 t(.-es-
2
^)
/^ /
-------
                            HOT TRASH LOG
        DATE:
                        70
                            OPERATOR:
	 • 	 — — ' 	 ,. — — 	 -— - — . — 1
(^ w*ky^-/-' |
LOCATION
^?3
7 )-\"
1C

7^
7k
7k
7>/
7 ff
cX §

3 f
/ *
2 1
1





[

|
1







l
	 _— 	 _— _ 	 — . 1
SAFETY INFRARED CHECK: / /^V'> ' /' ^ /•^'••- *^/^
COMMENTS:
S i g n a t u r e

-------
                       HOT TRASH LOG
  DATE:
                                                    OPERATOR:
LOCATION
                            BARREL. COLOR
                                                // BARRELS
PI
                                                      3
                                                                         3
   ffl
                                                      r
                                                                               2,
                                                                        2-
  73
                                                     r
                                                                         2-
                         //
SAFETY INFRARED CHECK:
COMMENTS:
                                      /-.
-------
                                       HUT TKAS1I LOG
                  DATE:    -J
    OPERATOR :Jj7W,/
-------
                        HOT TRASH LOG
  DATE:
                                                            OPERATOR: _
                                                                      --
LOCATION
                             BARREL  COLOR
// BARRELS
PIT
SAFETY  INFRARED  CHECK:   / /r.it.


COMMENTS:
                                    -t—-
                       Signatyre

-------
                                        HUT TKASI1 LOG
                  DATE:
                               OPERATOR:
             1   LOCATION
BARREL COLOR

BARRELS
                                                                     3
                                                                                        PIT
              355
                                5
                                  / 1
                                                                                    P
                                                                                    /
                                                                        -7


                It. IDS'
:Inspected by:
                  (Safety Representative)

-------
                              HOT TRASH LOG
DATE:
       LOCATION
                   BARREL COLOR
                                                          OPERATOR:
BARRELS
         -70

        JZl
                                                   le
.SAFETY  INFRARED CHECK:
COMMENTS:
                     Signa cure

-------
DATE:  2- '/£•  7<
                                                     OPERATOR:   ^
LOCATION
                     BARREL COLOR
                                              // BARRELS
SAFETY INFRARED CHECK:
COMMENTS :
                        {V <^_^/
                                  y
                       S i g 131 u r e //

-------
       I  TJATE: 3 •  i  '
                             HOT TRASH LOG
                            OPERATOR:
I..  LOCATION.'/     \   !•> BARREL. COLOR
                                                    // UARRELS
                                                          a
                                              PIT
        70
                                                         &
        Vf
        76
                               L
                                                          e
        76
       22i
                                                         &•
                                                           o
                                        x
•SAFETY INFRARED CHECK:
COMMENTS:  ;

S igrature /

-------
        DATE:
                       HOT TRASH LOG
              9*
OPERATOR:
LOCATION
                    BARREL COLOR
                                                     .'/  BARRCLS
 IilL
                                                          r
  vr
   r
                                                                     ,9
SAFETY INFRARED CHECK1.
COMMENTS:
                      S i g r>^t u r e

-------
                                       HOT TRASH LOG
DATE:
                                                                   OPERATOR'.
             .'.  LOCATION
                  BARREL COLOR
f BARRELS
                                                                  /
                                                T7
PIT
                                                                                     -7
                                                                  K
                                                                  ,7
               fS
                                                                  '7
             7*
            /*$
                                                 z.
                                                                    y
            75
         COMMENTS:
:Inspected by:
                  (Safety Representative)

-------
                                         HUT TRASH LG(J
                   DATE:
OPERATOR:
' LOCATION
IC\"




BARREL COLOR





* BARRELS
/V Uvtr




PIT





           COMMENTS:
::Inspected by:
                        /
                        A_- ,
                   (Safety Representative)

-------
                              HOT TRASH LOG
DATE:
                                                           OPERATOR:
LOCATION  ;
                            11ARREL COLOR
                                                 BARRELS
                                                                         I'll'
                                                          0
SAFETY  INFRARED  CHECK:
COMMENTS:
                     S i gna t^»re

-------
                           HOT TRASH LOG
      DATE:  t/- /?
                                                           OPERATOR:
    LOCATION
         ££_
                         BARREL COLOR
                                                       It BARRELS
                                                                              PIT
          is,
'-SAFETY INFRARED CHECK:
 COMMENTS:
                            Signature
7 y
             *

-------
               APPENDIX J

FACILITY SAFETY AND EMERGENCY EQUIPMENT
           INSPECTION REPORTS

-------
                          WEEKLY APPARATUS RE POUT (WOO)
ATE:
OOMETER READING:
ARKING  CODES:  OK =,/, REPAIRS NEEDED « X, ADJUSTMENT MADE  -  8
1.
2.
3.
4.
5.
6.
7.
8.
9.
START ENGINE
(OBSERVE OIL PRESURE)
TURN ON ALL LIGHTS AND ENSURE
EACH IS WORKING
ENSURE FUEL LEVEL IS NOT LESS
THAN .75 TANK
START ONBOARD GENERATOR
VISUALLY CHECK WATER LEVEL
CHECK ALL DOORS, LATCHES, AND
HANDLES
ENSURE ALL TOOLS ARE IN PLACE
AND CLEAN
CHECK HOSE LOADS FOR CORRECT
FINISH
CHECK ALL HAMD LIGHTS
S
^
f

S
V/
/
r'
V
10.
11.
12.
' 13.
14.
15.
r 16.
. 17.
18.
CHECK AUDIBLE WARNING DEVICES
OPERATE VALVES
OPERATE DRAINS
CHECK PRIMER PUMP OIL LEVEL
ENGAGE PUMP IN GEAR
CHECK PRESURE GOVERNOR
OPERATE TRANSFER VALVE
ENSURE ALL LIGHTS AND ELECTRIC
SWITCHES ARE OFF
CLEAN WINDOWS, WASH VEHICLE
IF NEEDED
V/
y
I/
v
^
v
i/-
t/-
I/
 IGNITURE



 EMARKS:
                                                                                 T
                                                           •p T.

-------
                    WEEKLY APPARATUS REPORT (B-30)
FE:
OHETER READING:    //
DICING CODES:  OK =v/,  REPAIRS NEEDED = X, ADJUSTMENT MADE = 8
i. START ENGINE
>. TURN ON ALL LIGHTS. ENSURE EACH
IS WORKING.
3. ENSURE VEHICLE FUEL LEVEL IS"
NOT BELOW .75 TANK.
1. ENSURE P. A. SYSTEM IS OPERATING
PROPERLY.
5. ENSURE THE RADIO IS OPERATING
PROPERLY.
i. ENGAGE 4-WO
7. IS THE APPARATUS INVENTORY
COMPLETE?
}.. START THE PUMP. ENSURE WATER
PRESURE IS MAINTAINED.
V
is
V
t
\s
\s
\s
\s
S* OPERATE ALL VALVES.
m<~~ENSURE WATER TANK IS FULL.
<-tt. ENSURE WATER PUMP GAS TANK IS
FULL.
. 12. ENSURE SPARE GAS TANK IS i
FULL.
^. CHECK HOSE LOADS FOR CORRECT
FINISH.
x!4. START GENERATOR AND CHECK THE
CIRCLE-D LIGHTS.
' 15. ENSURE THE ENERATOR GAS TANK IS
FULL.
16. ENSURE THE SPARE GAS TANK FOR
THE GENERATOR IS FULL.
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3NITURE:




4ARKS:

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               APPENDIX K

FACILITY SAFETY AND EMERGENCY EQUIPMENT
            INSPECTION PLAN

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                     ATLANTIC RESEARCH CORPORATION

PROPULSION DIVISION 7511 WELLINGTON HO. GAINESVILLE, ViPGlNlA 32065-1699 7O3-S42- 6CCr
     Regional Administrator                       November  1,  1988
     Environmental Protection Agency
     Region III
     841 Chestnut Building
     Philadelphia, PA.  19107

     Dear Sir:

          Atlantic Research Corporation  (ARC)  submits a  Part  B
     application under  Subpart X of RCRA for  the  Facility  at  5945
     Wellington Road, Gainesville, Virginia.   Three  copies of the
     permit application are hand delivered on this date.   ARC has made
     a good faith attempt at fulfilling  the requirements of Subpart  X
     but stands ready to supply any additional information that might
     be required once the guidance documents  become  available.
          Three courtesy copies of this  application  have been sent over
     night express to the Department of  Waste Management,  Commonwealth
     of Virginia as previously requested by your  staff.  If you should
     have any questions or need additional information please call me
     at 703-642-6411.
                                             Sincerely,
                                          Michael  E. Young
                                         Environmental Officer
                                     Atlantic Research Corporation

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PART B APPLICATION FOR  THERMAL TREATMZ.'jT'
OF WASTE EXPLOSIVES AND PROPELLANTS FOR
  THE ATLANTIC RESEARCH CORPORATION'S
   FACILITY AT 5945 WELLINGTON ROAD,
         GAINESVILLE, VIRGINIA
         EPA ID #  VAD023741705


            NOVEMBER 7,  1988

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                     TABLE OF CONTENTS

1.   Part A Application
2.   Facility Description
    a.  Summary
    b.  Topographical Map
    c.  Floodplain Standard
    d.  Traffic Information
3.   Waste Energetics, Characteristics and Analysis
    a.  Summary
    b.  Propellants Utilized (by year)
    c.  Containerized Waste
    d.  Waste Analysis Plan
    e.  Test Methods
    f.  Sampling Methods
    g.  Frequency of Sampling
    h.  Ignitable, Reactive and Incompatible Waste Provisions
4.   Description of Containers
    a.  Summary
    b.  Frea Liquids Testing
    c.  Container Management Practices
    d.  Container Storage Area Drainage
5.   Security, Equipment and Inspections
    a.  Summary
    b.  Inspections
    c.  Equipment
    d.  Storage Requirements/Aisle Space
6.   Prevention Procedures
    a.  Summary
    b.  Loading, Transport and Unloading
    c.  Run Off Prevention
    d.  Water Supplies
    e.  Equipment and Power Failure Mitigation
    f.  Personnel Protective Equipment
7.   Special Precautions for Handling Energetics
    a.  Summary of Safety Program
    b.  Management of Containers and Treatment Areas
    c.  Procedures to Insure Compatibility
8.   Contingency Plan
9.   Training
    a.  Summary
    b.  Training Staff
    c.  Training Outline
    d.  Job Title/Description
    e.  Training Frequency
    f.  Relevance of Job Training
    g.  Training in Emergency Response/Contingency Plan
10. Closure Plan
11. Financial Responsibility
12. Site Remediation Under 3008h Order

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13. Thermal Treatment in Containment Systems
    a.  Summary
    b.  Unit Design
    c.  Compliance With Subpart X
    d.  Compliance With Post Closure Requirements
    e.  Effectiveness of Treatment
    f.  Protective Distances to Borders
14. Risk Assessment

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SECURITY, EQUIPMENT AND INSPECTIONS

Summary

     The facility manufactures military equipment and thus has a
high level of security due to classified operations concerns.  in
addition, the safety concerns mandate that the facility be
protected from unauthorized  individuals.  The entire plant is
surrounded by a six foot chain link fence topped with three
strands of barbed wire.  All gates are controlled by security
guards when unlocked.  Access to the plant is strictly controlled.
 At least two guards are on duty at all times.  Radio
communications are maintained between all guards.  A patrol of the
perimeter is conducted at least once each eight hours.
     Access to the thermal treatment units is strictly controlled
by procedures, gates and signs.  Only personnel trained in
propellant handling are allowed into the thermal treatment unit
area.  Appendix 3  (Energetic Trash Disposal) contains the site
access control procedures utilized by the disposal team.
Inspections

     There are three types of inspections conducted in relation to
the waste explosives and propellant handling and disposal.  First,
the storage pads are inspected weekly to insure that the drums
used to store energetic wastes are in good condition.  The
inspection log for storage pads is included in Appendix 4.  The
second type of inspection is conducted at the thermal treatment
units before waste is treated.  Each unit is inspected to ensure
that no foreign materials are in the unit before waste energetic
materials are introduced.  The emergency equipment inspection is
the third type.  The equipment list and the inspection log is
included in Appendix 4.  The equipment inspection is conducted
every time the fire truck is used, which is a minimum of once a
week.  The operator inspects the equipment and notes materials
requiring replacement.
Equipment

     In addition to the equipment listed in Appendix 4, the
facility emergency response personnel all carry two way radios
operating on 153.3200 MHZ.  Each person assigned a radio
participates in a radio check every Monday at 9 AM.  An additional

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   APPENDIX L



CONTINGENCY PLAN

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    SECURITY,  EQUIPMENT AND  INSPECTIONS

    Summary

        The  facility manufactures  military  equipment  and  thus  has  a
    high level  of  security due  to classified operations  concerns.   in
    addition,  the  safety  concerns mandate  that  the  facility  be
    protected from unauthorized individuals.   The  entire  plant is
    surrounded by  a six foot chain  link  fence topped with  three
    strands of  barbed wire.  All gates are controlled  by security
    guards when unlocked.  Access to the plant  is strictly controlled.
    At  least  two guards are  on  duty at all times.   Radio
    communications are maintained between  all guards.  A patrol of  the
    perimeter is conducted at least once each eight hours.
        Access to the thermal  treatment units  is strictly controlled
    by  procedures, gates  and signs.  The signs  around  the  thermal
    treatment units read  as  follows:

              Danger, Authorized Personnel Keep Out

    Another set of signs  around the units  reads

              No unauthorized entry into pit area.  Authorized
              personnel must receive approval from  propellant MFG.
              M. Dodd  ext 6007 before depositing material.


    In  addition to the above signs, another  sign that  describes the
    flag system that is used to determine  when  the  units may be
    approached  by  trained personnel is placed at all road  entrances to
    the units.   This system of assess control  is fully  described in
    Appendix  III,  in the  orginial submission.


    Only personnel trained in propellant handling are  allowed into  the
    thermal treatment unit area.  Appendix 3 (Energetic  Trash
    Disposal)  contains the site access control  procedures  utilized  by
    the disposal team.
Revision 1, June 30, 1989

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   Inspections

        There are three types of  inspections  conducted in relation to
   the waste explosives and propellant  handling and disposal.   First,
   the storage pads are inspected weekly  to  insure  that the drums
   used to store energetic wastes are in  good condition.   The
   inspection log for storage pads  is included in Appendix 4.   The
   second type of inspection is conducted at  the thermal  treatment
   units before waste is treated.   Each unit  is inspected to ensure
   that no foreign materials are  in the unit  before waste energetic
   materials are introduced.  The emergency equipment inspection is
   the third type.  The equipment list  and the inspection log  is
   included in Appendix 4.  The equipment inspection is conducted
   every time the fire truck is used, which is a minimum  of once a
   week.  The operator inspects the equipment and notes materials
   requiring replacement.
   Equipment

        In addition to the equipment listed  in Appendix  4,  the
   facility emergency response personnel  all  carry  two way  radios
   operating on 153.3200 MHZ.  Each person assigned a radio
   participates in a radio check every Monday at  9  AM.   An  additional
   hand held radio has both the plant and the local fire department
   frequencies.  This radio would be utilized in  the event  that
   outside assistance would become necessary.

        The plant has a general alarm siren  that  is sounded daily at
   noon.  The contingency plan describes  the  emergency response
   procedures and •'-.he emergency communication system in  detail.

        In an emergency, security can be  reached  by dialing 6666 on
   any plant telephone.  Security acts as the central communications
   point if outside help is required (see contingency plan).

        Fire fighting procedures and equipment are  described in
   detail in the contingency plan.  Propellants in  general  cannot be
   extinguished once ignited.  These materials are  allowed  to burn
   themselves out unless personnel are trapped in a structure.  Some
   buildings have deluge systems designed to  flood  certain  areas if a
   fire should occur.  These deluge systems  are not involved with
   waste material handling, storage or treatment.

        Portable fire extinguishers around the plant are not part of
   the hazardous materials response equipment, with the  exception of
Revision  1, June 30,  1989

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   the  extinguishers  on  the  fire  trucks  as  listed  in  the  contingency
   plan.  ARC  hazrdous material  incidents  are  handled soley by the
   First Response  Team.   The team has  the  special  training as
   required  by new OSHA  regulations.   The  potential  for  injury to
   untrained personnel is unacceptable.  Portable  extinguishers would
   not  be effective against  burning  explosives or  propellants  and
   special fire fighting technics are  required.  For  the  reasons
   stated above, only the portable extinguishers on  the fire trucks,
   as detailed in  the contingency plan,  should be  concidered
   emergency equipment for hazardous materials or  hazardous waste.
   The  fire  trucks are housed in  building  36 as is the response
   equipment listed in the contingency plan.
        Waste material fires  at a  storage pad,  should  one  ever  occur,
   would be  allowed to burn  out.   Waste  material fires in the  thermal
   treatment area  would  also be allowed  to  burn out.   In  both  cases,
   the  areas are situated sufficiently.far  from other structures that
   the  safest  approach is to let  the fire burn out.
   Storage Requirements/Aisle  Space

        All energetic  storage  areas  are  situated  so  that  in  the  event
   of  a fire  or  spill  there  is sufficient  space for  emergency
   equipment   and  response personnel.  In  all  but one  case,  only a
   single row of drums is kept on  each pad and access  on  both  sides
   is  available.   In the only  case where more  that one row of  drums
   is  stored  an  aisle  at least three feet  wide is maintained.
Revision 1, June 30, 1989

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CONTINGENCY PLAN

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CONTINGENCY PLAN FOR ATLANTIC RESEARCH CORPORATION'S GAINESVILLE
                                FACILITY


This document is developed in accordance with the requirements for a
Contingency Plan established in 40 CFR 270.14{b)(7), 264 Subpart D, and
264 Subpart X; and Virginia Hazardous Waste Management Regulations,
Section 9.00, paragraph 9.04.  A copy of this Contingency Plan is
available to all local police and fire departments,  hospitals, and State
and local emergency response teams that may be called upon to provide
emergency service.

1.   GENERAL

This Contingency Plan is for the Gainesville, Virginia facility of the
Atlantic Research Corporation Propulsion Division located at 7945
Wellington Road.  The Contingency Plan is located in and maintained by
the Safety Office.  Additional copies are kept at the Emergency
Operations Center and the Environmental Office.

The Gainesville Facility  is engaged primarily in the development of
solid propellant rocket motors in addition to the technological research
associated with these propulsion systems.  Operations consist mainly of
the mixing and casting or  pressing of  solid propellants, and
laboratory scale testing/evaluation of these propellants.

The excess solid propellant remaining after mixing and the spent
solvents associated with propellant development comprise the facility's
solid wastes. These wastes are, for the most part, fire hazards, DOT
prohibited for transportation, and require specialized handling.

This plan is designed to minimize hazards to human health or the
environment from fires, explosions, or any unplanned sudden or
non-sudden release of solid propellant materials or hazardous waste
constituents to air, soil or surface water.  The existing Gainesville
Emergency Procedures Plan (EPP; see Attachment A) will remain effective
for the remainder of the plant.

The provisions of the plan will be carried out immediately whenever
there is an imminent threat of or actual fire, explosion, or release of
hazardous waste or hazardous waste constituents which could threaten
human health or the environment.

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2.0  EMERGENCY COORDINATION

If an emergency situation develops involving the Gainesville facility,
the individual discovering the incident will immediately contact the"
Emergency Operation Center (Guard Office, Bldg. 150) by: (1) dialing
6666 (ie. emergency call number) on any facility phone;  (2) depressing
an evacuation alarm button found within the operating building; or (3)
if a guard or any other individual assigned a  two-way radio unit, by
radio communication (see Attachment A; Emergency Procedures Plan (EPP),
SOP COMI-1-2).  Upon receiving notification of an emergency, the on-duty
guard will immediately implement the Emergency Incident Procedure (ie.
page 2  of the EPP; Attachment A).

During all working shifts a First Response Unit, comprised of both
medical and fire fighting personnel, will be alerted via portable radio
or belt pagers as specified in the Emergency Incident Procedure and
Emergency Paging Procedure (SOP COMM-1) in Attachment A.  The First
Response Unit Command structure in effect during such am emergency is
given in SOP OP-1 of the Standard Operating Procedures section of
Attachment A.  The Officer in charge (i.e. Chief Officer)will be known
in this Contingency Plan as the Primary Emergency Coordinator.

At all times, there is at least one employee either on the facility
premises or on call (ie. available to respond  to an emergency by
reaching the facility within a short period of time) with the
responsibility for coordinating all emergency  response measures.  During
non-operating hours, one of the on-duty guards will follow the Urgent
Question or Emergencies procedure, pages 14-16 of Attachment A, and
contact an emergency coordinator according to  the integrated call
listings.  The Safety Manager and Safety Engineer are to be contacted
via the Metropage system if neither is at home.  This procedure is
specified in the Urgent Questions or Emergencies Procedures Addendum,
page 16 of Attachment A.

Whenever there is an imminent or actual emergency situation, the
Emergency Coordinator has the duty to implement the Contingency Plan.
The decision to implement the plan depends upon whether or not an
imminent or actual incident could threaten human health or the
environment.  Once the plan is implemented, the Emergency Coordinator
must coordinate all activities undertaken and  is authorized to commit
the resources of ARC, as needed, in implementing the Plan.  This policy
is clarified on page 1 of Attachment A.


3.0  IMPLEMENTATION OF THE CONTINGENCY PLAN

The Contingency Plan will be implemented in any situation as defined in
the Emergency Incident Procedures of Attachment 1  (ie. page 2).
Specific emergency situations and the appropriate procedures are listed
within the EPP, Attachment A.

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4.0  EMERGENCY RESPONSE PROCEDURES

Notification:  The first person aware of an emergency shall activate the
Emergency Incident Procedure by immediately sounding the building
evacuation  alarm or otherwise effect the prompt evacuation of the
incident area and alert Emergencies Operation Control by calling 6666 on
any facility phone (if outfitted with a two-way radio,respond via the
communicator).

Upon responding to the scene, the Emergency Coordinator will assess the
possible hazard to human health or the environment that may result from
the fire, explosion or release of hazardous waste.

If the Emergency Coordinator determines that the facility has had, or
may have, an incident such as a fire, explosion, or spill which could
threaten human health or the environment, he/she must report his/her
findings as delineated in the Control Procedures Section (page 5)


In that the Emergency Coordinator has the authority and responsibility
to call upon whatever outside aid necessary to minimize the threat to
human health and environment, the decision to gain assistance from any
source including but not limited to the entities listed in Attachment
III of the EPP, Emergency Contacts, will be conveyed and initiated by
the Emergency Operation Center according to the Emergency Incident
Procedures, Attachment A.

If an emergency affecting the facility and potentially threaten human
health or the environment beyond the confines of the facility, the
appropriate authorities listed in Attachment III will be alerted
immediately.  If specifically requested by the Corporate Environmental
Compliance Officer, the Virginia State Hazardous Wastes Emergency
Response Team (804 323-2300), or the National Response Center
(1-800-424-8802 or 202-267-2675) will be included in the notification
effort. Specifically, the report will include:  (a) name and telephone
number of the reporter; (b) name and address of the facility; (c) time
and type of incident (eg. fire, release of hazardous waste); (d) name
and quantity of material(s) involved to extent known; (e) extent of
injuries,if any; and (f) the possible hazards to human health or the
environment, and cleanup procedures.

5.0  IDENTIFICATION OF HAZARDOUS MATERIALS

Material Safety Data Sheets containing current data characterizing the
hazardous materials contained in the Gainesville facility are kept in
the Safety Office.

These Material Safety Data Sheets contain pertinent data on the
chemicals at the site including:

   *    Identification of chemical components of the processed
        propellant;

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   *    Identification of the propellants and/or ingredients of
        hazardous characteristics (eg. toxicity, reactivity,
        and ignitability);
   *    Important chemical  and physical properties for which data are
        available;
   *    Fire Control procedures (eg. water or chemical foam); and,
   *    Appropriate procedures to counteract human exposure.

6.0  HAZARD ASSESSMENT

The Emergency Coordinator will assess possible hazards to human health
or the environment  that may result from fire, explosion, or a release.
The Emergency Coordinator will assess the hazards posed by an emergency
through the following steps, by designate or as otherwise appropriate:'

   *  Identify the  ingredients and/or propellants involved in the
      incident;
   *  Consult the appropriate Material Safety Data Sheets and/or any
      other source  of pertinent emergency data including on or off site
      technical expertise to determine the potential effects of
      exposure/release, and appropriate safety precautions, if
      necessary; and,
   *  Identify exposure and/or release pathways and the quantities of
      propellant and/or ingredient involved.

This assessment will consider both the direct and indirect effects of
the fire, explosion, or release (eg. the effects of any toxic gases that!
are generated or the effects of any hazardous surface water runoff from I
water or chemical agents used to control fire and heat-induced
explosions).

Based on this assessment, the Emergency Coordinator will determine what
risk is posed to site workers and neighboring populations.  If the
emergency cannot be controlled by site personnel without incurring unduei
risk, the Emergency Coordinator will follow the measures as outlined in '
the Emergency Incident Procedure, Attachment A, and notify the nece3sary
agencies listed in Attachment III of the situation and extent of       '
assistance required.

If the Emergency Coordinator determines that any persons outside of the
Gainesville facility are at risk due to an emergency, he will contact  ;
the appropriate agencies and departments listed in Attachment III and
advise them of the risk and the need or potential need to institute
off-site evaluation procedures.


7 . 0  CONTROL _PROCEDURES

Potential accidents fall under two general classifications:   (1) fire
and/or explosion and  (2) spills or release of hazardous materials.  The
following sequence of events constitutes the specific responses and
control procedures to be taken in the event of  a  fire, explosion, or
release of hazardous material to the  land or water.

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If a fire or an explosion appears imminent,  or if either have occurred,
all activity related to the specific site will be ceased and emergency
activities initiated in accordance with the Emergency Procedures Plan,
Attachment A.


Upon notification that a hazardous material release or spill or process
upset resulting in a hazardous material release or spill has occurred,
the Emergency Operation Center will immediately relay the information on
to the Emergency Coordinator as specified in the Emergency Incident
Procedures, Attachment A.

The Emergency Coordinator will assess the magnitude and potential
seriousness of the hazardous material release or spill by reviev/ing the
following information:

   1.  Safety fact sheets for the material released or spilled.
   2.  Source of the release or spillage of hazardous material.
   3.  An estimate of the quantity released and the rate at which it is
       being released, if applicable.
   4.  The direction in which the hazardous material release or spill is
       heading, if applicable.
   5.  Personnel who may be or may have been in contact with material
       and possible injury or sickness as a result.
   6.  Potential for fire and/or explosion resulting from the situation.
   7.  Estimate of area under influence of the release or spill.

If the emergency is determined to lie within Gainesville First Response
Team's capabilities, the Emergency Coordinator will implement
appropriate remedial action.

Specifically, this will include utilization of the First Response
Team's hazardous material (HAZMAT) expertise and emergency equipment.
As a minimum:  (1) First Response Team members will don self-contained
breathing apparatus if necessary; (2) provide appropriate medical
attention to any individuals affected by the explosion/fire or
release/spill; (3) control access to the explosion/fire or release/spill
area; (4) impede the travel of any liquids released by diking, spreading
absorbent materials or plugging leakage; (5) employ the aid of facility
personnel to the extent possible toward controlling the explosion/fire
or release/spill; and (6) ultimately prepare the hazardous waste for
shipment or treatment, in an approved manner, after consulting with the
Corporate Environment Compliance Officer.

If the explos_ion/fire or release/spill involves propellants, the
Emergency Coordinator will, upon assessing the situation: (1) secure
access to the area and remove any source of potential ignition (if this
step is impossible, the situation will be considered grounds for
coordinated evacuation); (2) call upon qualified facility personnel to
plan and aid in a cleanup plan; (3) convene a meeting of the Unique or
Unusual Hazards Review Committee (ie. according to PP-F-23) if
appropriate; and (4) mobilize manpower and equipment as needed to
eradicate the emergency.

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If the explosion/fire or release/spill is beyond the capabilities of thf
tear,, the Emergency Coordinator will coordinate emergency medical needs!
evacuate and secure the explosion/fire or release/spill area, and in
conjunction with the Corporate Environmental Officer and pertinent
management personnel, solicit aid of a special explosion/fire or
release/spill cleanup contractor after notifying the appropriate
governmental bodies of the incident.

8.  PREVENTION OF RECURRENCE OR SPREAD OF FIRES, EXPLOSIONS OR SPILLS

The Gainesville facility is strictly regulated relative to safeguarding
personnel and facilities from a single or recurring incident by
Department of Defense regulations.  Inasmuch as the safety provisions
specified in DoD 4145.26M DoD Contractor's Safety Manual for Ammunition
Explosives, and Related Dangerous Materials address any probable
contingency, this document's requirements will be utilized to prevent
hazardous material emergencies.  A copy of DoD 4145.26M is available in
the Gainesville facility's Safety Office.  This document specifies the
use of quantity-distance relationships applicable to structures
and hazardous material amounts, as an example.

9.  STORAGE AND TREATMENT OF RELEASED MATERIAL

Immediately after an emergency, the emergency coordinator, in
cooperation with the  Environmental Compliance Officer, will make
arrangements for the treatment of recovered wastes, contaminated soil,
surface water, or any other contaminated materials.

10.  HANDLING OF INCOMPATIBLE WASTES

The Emergency Coordinator, in cooperation with the Environmental
Compliance Officer, v/ill ensure that, in the affected area(s) of the
facility, that no waste that may be incompatible with the released
material is treated, stored, or disposed of until cleanup procedures are
completed.


11.  POST-EMERGENCY EQUIPMENT MAINTENANCE

After an emergency event, all emergency equipment listed in Attachment
I will be cleaned so that it is fit for use or will be replaced.
Before operations are resumed, an inspection of all safety equipment
will be conducted according to existing emergency response protocol.
The Regional Administrator, State, and/or local authorities, as
appropriate, will be notified that post-emergency equipment maintenance
has been performed and operations will be resumed.

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12.   EMERGENCY EQUIPMENT

In case of a fire, explosion,  or release of hazardous material, the list
of firefighting, containment,  and emergency equipment given in
Attachment I is available.   Personnel performing any propellant
development activities involving are also  required to wear eye
protection, conductive shoes,  impervious gloves, flame retardant
clothing and either supplied air breathing apparatus or respirators.
Any required resources that may not be readily available at the
Gainesville facility will be obtained immediately from local commercial
sources.

13.  COORDINATION AGREEMENTS

ARC has made the following arrangements to assist in response to
emergency situation:

   a)  Copies of the contingency plan are available to and have been
       discussed with local police and fire departments and the
       hospital.

14.  EVACUATION PLANS

    a)  Evacuation plans are outlined in the Emergency Incident
        Procedures section of the Emergency Procedures Plan,
        Attachment A.

15.  REQUIRED REPORTS

Any emergency event (eg. fire, explosion, etc.) requiring implementation
of the Contingency Plan will be reported to the EPA Regional
Administrator and State Air Pollution Control Board v/ithin 15 days after
the incident.

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       ATTACHMENT A




EMERGENCY PROCEDURES PLAN

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                    GENERAL INFORMATION

     This Emergency Procedures Plan is intended as a guide for use
by affected individuals during an emergency at Atlantic Research
Corporation's Gainesville facility located at 5945 Wellington
Road, Gainesville, Virginia 22065.  Atlantic Research is a
subsidiary of SEQUA Corporation and manufactures solid rocket
propellant motors and other related propulsion equipment. Figure l
is a general site plan for the Gainesville facility located at
LAT 38° 47'30"N LONG 77° 35'30"E in Prince William County,
Virginia.  The procedure is intended to supplement existing
group~specific procedures currently in existence.

     There is a common thread through all of the procedures that
follow.  In the event of ANY emergency situation, employees are
to: 1) notify the guard station by calling the emergency telephone
number, extension 6666; and 2) if applicable, evacuate the
immediate area as quickly as possible.

     By following these guidelines, the mechanics of neutralizing
the emergency ~ whatever its nature - may be set in motion.

     The main thrust of any emergency-oriented operation must be
in the direction of prevention.  However, when the unexpected
occurs, employees in responsible positions must be prepared to act
promptly, and appropriately, and to remain calm.  It is toward
such occurrences that this procedure is directed.
(Revised 9/88)

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                  TABLE OF CONTENTS

                                                        Page Number(s)

Emergency Coordinators                                          1

Emergency Incident Procedures (Fire, Explosion,
   Building Collapses, Sudden Release or Hazardous
   Materials, etc.                                              2-4

Control Procedures                                 '             5-7

Post Clean-up Procedures                                        8

Spill Incident Reports                                          9

General Communications                                          10

Access to Emergency Scene                                       11

Upon Receipt of an Automatic Alarm
12-13

Urgent Questions or Emergencies (General)                       14-16

Telephone Failure Procedure                                     17-20

Storm Procedures                                                21-23

Threatening Telephone Calls Procedure                           24

Bomb Threat Procedure                                           25-26

Bomb Threat Procedures - Actions to be Taken                    27-28

Standard Operating Procedures (Introduction)                    29
   SOP COMM-1  (Emergency Paging)                                30-31
   SOP COMM-2  (Radio Unit Designations)                         32-33
   SOP COMM-3  (Mutual Aid Incidents)                            34
   SOP COMM-4  (Communications Protocol)                         35-36
   SOP COMM-5  (Special Dispatching)                             37-38
   SOP OP-1    (First Response Team Command  Structure)           39-40
   SOP OP-2    (Use of Protective Clothing)                      41
   SOP OP-3    (Handlines in Fire Suppression)                   42
   SOP OP-4    (Assistance from  PWC Units)                       43-44
   SOP TR-1  _ (Portable Extinguisher Training)                  45-47

Attachments:
   Attachment  I  (List of Equipment on Fire  Truck)
   Attachment  II  (Key Person List)
   Attachment  III  (Emergency Contacts List)

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    Description  of  Emergency  Coordination

         The  ARC First  Response  Unit  is  structured  to  require  as
    little  outside  assistance as possible,  however,  ARC  has  a  strong
    working relationship  with the appropriate emergency  agencies  in
    the  area.  This coordination takes the  form of:
         l. distribution  of ARC  contingency plans to all appropriate
           response groups,
         2. participation on  the Local Emergency Planning Commission,
         3. fire department biannual  inspections,
         4. and  yearly  site familiarization presentations, tours  and
           planning with the fire departments in the  area.

    Each of these activities  is  described below.

         The  contingency  plans are under constant review and updates
    incorporate  the suggestions  of the emergency response agencies  in
    the  area.  The  contingency plan covers  all the  major emergencies
    that could potentially occur at the  site.   This  document explains
    the  preplanning ARC has done to address each potential emergency.

         The  ARC safety manager,  Rick Shults,  has assumed a  dominant
    position  in  the Local Emergency Planning Commission.   ARC  and IBM
    personnel have  been extremely active in developing the area's
    response  plans  and  the coordination  of  emergency response
    agencies.  Information on the materails on the  site,  their
    locations and quantities  have been forwarded to the  commission.
    Our  staffs are  currently  involved in coordinating  an area  wide
    approach  to  chemical  incident response.

         The  Prince William County Fire  and Rescue  Department  inspects
    the  site  twice  a year.  Tours of  various buildings are conducted.
    Review  and upgrading  of pre-plans is conducted.  Inspection of  the
    site for  fire code  compliance occurrs during each  visit.

         Annually,  the  1st due response  units  from  the fire  department
    are  invited  in  for  a  tour of the  facility.  This involves  Prince
    William County  Stations 4, 11,  15 and Fauquier  County Station 40.
    The  capabilities of the ARC  first repsonse unit are  presented.  An
    orientation  tour of the plant,  describing  response concerns,
    building  markings related to response,  and discussions of  response
    coordination is conducted.

         The  contingency  plan discusses  in  detail how  response
    coordinati-on in each  type of emergency  would be conducted.
Revision 1, June 30, 1989

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                    EMERGENCY COORDINATORS

I.   Responsibility in Times of Emergency

     A.   Inasmuch as the senior member of management present at
any given time is responsible for plant activities, this person
shall, in times of emergency, be ultimately responsible for
control activities.  For the purposes of this procedure, the
senior member of management is hereinafter referred to as the
Emergency Operations Director.

     B.   Line authority for actual control activities
(firefighting, spill control, rescue, medical care, etc.) shall
belong to the Officer in Charge (OIC) af the Gainesville Emergency
First Response Team (hereinafter referred to as the Incident
Commander),  in coordination with the local Fire Chief having
Jurisdiction.  The Incident Commander shall report directly to the
Emergency Operations Director.

     C.   The Personel Manager or his designate shall be
responsible  for any public relations functions to be performed
during an emergency until relieved by a representative of the
Public Relations Department.

     D.   Responsibilities of individual supervisors shall
include,  but shall not necessarily be limited to the following:

          1.   Compliance with instructions received from the
               Emergency Operatic.'.? Center.
          2.   Supervising the orderly evacuation of personnel,
               when appropriate.
          3.   Obtaining an accurate count of personnel present
               in his area, as well as a list of any personnel
               under his supervision who may be trapped or
               injured.
          4.   Safeguarding classified and company proprietary
               materials.
          5.   Overseeing the shut-down of equipment in his
               area which could pose a hazard if left unattended.
          6.   Notifying the Emergency Operations Center of any
               discrepancies between orders received and actions
               performed.
                              -1-

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              EMERGENCY INCIDENT PROCEDURES
(Fires,  Explosions, Building Collapses, Sudden Release
              of Hazardous Materials, Etc.)

I.   General

     A.   An emergency incident is defined as any incident:

          1.   Which requires or may require response by the
               Gainesville Emergency First Response Team.
          2.   Which requires or may require response by out-
               side fire or rescue equipment and/or personnel
               as requested by the individual reporting the
               incident.
          3.   Which poses a clear threat to the safety of
               personnel or facilities.
          4.   Which is so declared by the Safety Department.
               the Officer in Charge of the First Response Team,
               or the senior member of management present.

     B.   Upon receiving notification of an emergency incident on
plant,  the guard will immediately, and without exception, issue a
"00" alert over the emergency paging system.

          1.   This standing order cannot be countermanded during
               normal working hours by anyone other than
               the Safety Department representative.

               a.   On the rare occasions in which the plant
                    nurse requests that an ambulance be called
                    for a non-emergency transport, and in which
                    she specifically says that the First Response
                    Team will not be needed, the guard shall not
                    issue a "00" page.

                    1)   On these occasions it will remain the
                         guard's responsibility to contact the
                         officer in charge of the First Response
                         Team as soon as possible via radio and
                         apprise him of the situation.  The guard
                         shall make it clear at this time that the
                         nurse has specifically said that the
                         First Response Team need not be called.
                         -2-

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                    2)   The Officer in Charge of the First
                         Response Team may, at his discretion
                         and with cause, countermand the nurse's
                         decision and order that a "00" page
                         be issued anyway.

     C.    From the onset of an emergency incident, until it is
declared over by the Incident Commander, all relevant
communications between the Emergency Operations Center and the
First Response Team will be transmitted via radio, whenever
possible,  to the Incident Commander.  All other pertinent
communications involving the EOC (interpersonal, telephone, etc.)
will be relayed without delay via radio.

     D.    During the initial phase of any emergency on plant, the
Guard Station shall serve as the Emergency Operations Center.  if,
as emergency control activities progress, it becomes necessary to
relocate the EOC.  this will be done at the direction of the
Incident Commander and/or the Emergency Operations Director.

          1.   The EOC will be in charge of communications during
               an emergency.
          2.   Radio communications during an emergency shall be
               kept to the minimum amount that will insure
               adequate, complete transfer of information.
          3.   Personnel in the EOC during an emergency must  be
               kept at a minimum.  Under most circumstances,
               personnel present in EOC should be limited to  the
               following:

               a.    Facility Security Supervisor or another member
                    of Security.
               b.    One member of Guard Staff.
               c.    Fire Chief from local Prince William
                    Jurisdiction.
               d.    One assistant to the Fire Chief.
               e.    One or more reprsentatives from the Safety
                    Department.
               f.    One or more representatives from the
                    Environmental Department (if the emergency
                    poses a threat to the environment, as judged
                    by the Emergency Operations Director).
                        -3-

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     E.   Emergency instructions will be issued  to employees by
EOC via telephone or radio communications to individual section
heads or group chiefs, who will then pass the information on to
affected employees.

     F.   A Management Crisis Center (MCC) is to be immediately
established within the Personnel Manager's Office, Building «150.
The purpose is to provide EOC support of a top management nature
when necessary.  The MCC is where managerial decisions to major
incident-related issues and formal press releases are to be made.

          Representatives from the various plant disciplines may
be summoned to the MCC for support as deemed necessary.  At a
minimum, the following should report to the MCC.

          1.   The senior member of management present, or his
               designate
          2.   Personnel Manager
          3.   Management Safety Committee Members

     G.   Emergency Escort:  During an incident, emergency
equipment needs to be directed to the emergency scene.  For most
incidents, "Unit One" (Guard) will do the escorting.  If
additional escorts are needed, the Head of Inventory Control,
"Unit 36", Extension 6160, can be contacted.
                       -4-

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                    CONTROL PROCEDURES

I.   General

     A.   Any employee who witnesses a. fire, explosion, sudden
escape of hazardous materials, or injury to plant personnel shall
immediately sound the evacuation alarm (if applicable) and notify
the guard staff via the emergency telephone number (extension
6666).  The guard, in turn, will notify the First Respose Team via
r ad i o.

     B.   Upon notification of a fire in a building,  all employees
shall immediately evacuate via the nearest emergency exit and
report directly to their designated evacuation areas.

          1.   If the fire is in its incipient stage and easily
               controllable, local supervision may choose to
               extinguish the fire with a proper portable hand
               extinguisher.  However, these efforts should be
               abandoned immediately when it becomes apparent
               that the fire is growing in size and intensity,
               or when the heat, smoke or other products of
               combustion maKe the environment untenable.
          2.   No employee shall attempt to extinguish a fire
               involving propellant.
          3.   Under no circustances will any employee (except
               this properly equipped and trained members of the
               First Response Team) attempt to enter a structure
               involved in fire.
          4.   Under no circumstances shall any employee attempt
               to move his or her vehicle (company or privately
               owned) unless specifically directed to do so.
                        -5-

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     C.   Upon receipt of an alarm over the radio/pager system,
members of the First Response Team and designated members of
management shall immediately secure the work they are doing and
report to their assigned locations.

          1.   When applicable, the Personnel Manager shall
               serve as liaison between ARC and members of the
               press.  Representatives of the Public Relations
               Department are ultimately responsible for this
               function and may, if available, serve in this
               capacity.

     D.   The decision to call for assistance from local Prince
William County firefighting or emergency medical (EMS) units will
be made by the Incident Commander or by the Emergency Operations
Director, in consultation with the Incident Commander.

     E.   Similar to the above procedures, if a sudden harard
material spill is reported in a building, evacuation of the
immediate area will be necessary.

          1.   If there are no injuries or fires, the guard
               shall be notified of that and the guard shall
               in turn, report by radio that only the Spill
               Response portion of the First Response Team will
               be required.
          2.   Upon their arrival, the First Response Team will
               assess the situation.  Information will be
               gathered from the evacuees to determine chemicals
               involved and extent of spill.  The team shall
               also determine if further evacuation is necessary.
          3.   If insufficient information is available, at least
               two. but the minimum necessary number of Spill
               Response team members, shall enter,  each with a
               self contained breathing apparatus (SCBA), to
               gather the necessary assessment data.
          4.   If the hazard is deemed to be beyond the remedial
               capabilities of ARC'S Spill Response Team, the
               Incident Commander may call for additional
               assistance from the following as needed:

               a.   Atlantic Research Gainesville Fire Brigade
               b.   Prince William County Fire and Rescue Dept.
                            -6-

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               c.   Fairfax County Hazardous Materials Response
                    Team
               d.   National Response Center

               Atlantic Research has a good working relationship
with all of the of these units.

          5.   If no other outside assistance is necessary
               the Spill Response Team will take whatever
               action is necessary to contain the release and.
               if the spill is indoors, prevent its spread to
               outside areas.  Particular attention should be
               paid to prevent spilled chemicals from reaching
               floor drains or soil.  All other chemicals shall
               be removed from the release area, particularly
               any incompatible materials.  After containment,
               clean-up shall commence.  Containment and clean-up
               equipment will be stored on ARC's firetruck.

     F.   The decision to order a general evacuation of the
plant will be made at the discretion of the Emergency Operations
Director.

          1.   Such an evacuation, if ordered, shall taUe place in
               an orderly manner, with one area being released
               at a time, in order of the relative magnitude of
               the dangers faced by employees in those area.

     G.   Non-sudden hazardous material escapes, including
underground storage tank leaks, are not considered emergancies but
should be reported to the environmental staff, immediately.   The
environmental staff will in-turn evaluate and deal with these
situations on individual bases.
                         -7-

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               POST CLEAN-UP PROCEDURE

I.   General

     A.   All spill residuals shall be placed in the chemical
waste handling area near building 107, and the Environmental
Department shall arrange for its final disposal.

     B.   No chemicals shall be moved back into affected area
until clean-up is complete and the Incident Commander has given
approval.

     C.   Incident investigation shall determine the cause of
spill and  procedures shall be implemented or changed to minimize
the possibility of recurrence.

     D.   All equipment shall be thoroughly cleaned or disposed
with other residuals immediately following completion of clean-up
opertions and orderly placed back on the firetruck.
                         -8-

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                    SPILL INCIDENT REPORTS

     I.    General

          A.    Atlantic Research Corporation will report all spill
incidents as  required by law.  The Gainesville Environmental
Department will have he responsibility of reporting.

          1.    Spill of a reportable quantity of a regulated
               material will be reported to:

               Commonwealth of Virginia
               Department of Waste Management
               llth Floor,  Monroe Building
               101 N. 14th  Street
               Richmond, Va 23219

               (804)225-2667

          2.    Spills to navigable waterways will be reported
               to:

               Commonwealth of Virginia
               Water Control Board
               5515 Cherokee Avenue
               Suite 404
               Alexandria,  VA 22312

               (703)750-9111

         3.     All other spills will be evaluated and reported
               as necessary.
                       -9-

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   Submission of Emergency  Incident Reports

        The head of the ARC environmental  staff,  or his  designant,
   shall note in the operating record the  time, date, and details  of
   any incident that requires implementing the  contingency  plan.
   Within 15 days after the incident, he shall  submit a  written
   report to the Executive  Director.  The  report  shall include:

    a. Name, address, and telephone number of the owner  or  operator;
    b. Name, address, and telephone number of the facility;
    c. Date, time and type  of incident;
    d. Name and quantity of material(s) involved;
    e. The extent of injuries, if any;
    f. An assessment of actual or potential hazards to human health
       or the environment,  where this is applicable;
    g. Estimated quantity and disposition  of recovered material that
       resulted from the incident; and
    h. Such other information specifically requested by  the
       Executive Director,  which is reasonably  necessary and relevant
       to the purpose of an operating record.
Revision 1, June  30, 1989

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                    GENERAL COMMUNICATIONS

I.   General

     A.   Efficient and effective communications during an
emergency incident will be the responsibility of the on-duty
guard staff.

     8.   Telephone communications with the guard station shall be
kept to a minimum, and shall be limited to that which is NECESSARY
to ensure timely resolution of the emergency.

     C.   When applicable, the Incident Commander will utilize
Prince William County Fire Sr Rescue radio frequencies to
coordinate emergency control activities with the local
Jurisdictions.  Wnen such a decision is made, the Incident
Commander shall so inform the EOC.

     D.   It will be the responsibility of the Incident Commander
to provide periodic updates regarding the status of emergency
control activities to the EOC.
                        -10-

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                ACCESS TO THE EMERGENCY SCENE

I.   General

     A.   Access to the scene of an emergency incident while it is
in progress shall be limited to those persons who are critical to
the control function.  All non-essential personnel shall be denied
access until all control and investigative steps have been
completed.

     B.   Access to the emergency scene by anyone not employed by
ARC or who is not part of the control effort may be authorized
only be the Incident Commander or the Emergency Operations
Director.

     C.   Upon extinguishment of all fires, clean-up of releases,
and completed rescue/recovery of all personnel, the incident scene
shall be closed to ALL personnel except those who are actively
engaged in the investigation of the incident.

          1.   It is the prerogative of the Safety Department to
               determine when the scene may be made available
               for restoration/recontruction.
          2.   Care should be taken to ensure that no item at the
               emergency scene is disturbed, relocated, changed.
               tampered with, or removed.

     D.   Controlled access to the emergency scene shall be
monitored by the Security force.
                        -11-

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          UPON RECEIPT OF AN AUTOMATIC ALARM


I.   General

     A.    During Working Hours

          1.   Upon receipt of an emergency/evacuation alarm
               on the guard station's anunciator panel, the
               guard shall IMMEDIATELY issue a "00" alert on
               the paging system and activate the plant fire
               alarm.
          2.   When dispatching the First Response Team, the
               guard shall state clearly the nature of the
               incident:  "Emergency alarm sounding in Building


     B.    Weekends and Holidays

          1.   Upon receiving an alarm from one of the affected
               buildings, the on-duty guard shall immediately call
               Prince William County Fire and Rescue Services and
               report a "fire alarm sounding".
          2.   "Unit One" shall be dispatched to the scene to
               provide a situation report.  If the emergency is
               real, "Unit One" shall return to the main gate to
               direct incoming fire units to the scene.
               Conversely, in the event of a false alarm, the
               guard station shall be so informed so that Prince
               William County Fl~e and Rescue Services may be
               notified and incoming units put back in service.
          3.   Individuals on the emergency phone listing provided
               in the Urgent Questions and Emergencies section are
               to be notified as soon as possible.

     C.    Building 350 Alarm System

          1.   If the smoke detection system is activated one
               of three (3) codes Mill be displayed.  Depending
               on the code number, the guard will need to call
               Prince William County Fire and Rescue Services and
               report a "fire alarm sounding on the 	, at
               5230 Wellington Road".  The blank should have the
               location of the fire alarm; i.e. second floor,
               first floor - north, first floor - south.

                        -12-

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     D.    Building 107 Alarm

          1.   Building 107 smoke detector system has *n
               automatic dialer.  When the smoke detector
               is activated, the guard station will receive
               a phone call on the 6666 extension with a
               recorded message.  The guard needs to verify
               the alarm by a phone call to building 107,
               extension 6828, or by "Unit One" personally
checking the building.

     E.    Building 300 Alarm System

          1.   If the smoke detection system is activated.
               "Unit One" shall report to building 300 with
               combination(s) and keys needed to gain access
               to all areas of the building.
                        -13-

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I.
     URGENT QUESTIONS/EMERGENCIES (GENERAL)

General
     A.   When an emergency occurs after hours, such as an
explosion, serious accident or illness, fire, etc., the guards
shall obtain assistance from the following persons, in the order
in which they are listed:
    NAME
                   EXTENSION
HOME TELEPHONE
Shults, R.H.
Knox, D.
Lawrence, C.G.
Meyer, B.
Kirkland, G.C.
Johnson, G.
Hostettler, S.
6081
6328
6462
6525
6065
6277
6245
(703)335-1110
(703)754-7937
(703)253-5684
(703)830-1666
(703)754-8006
(703)972-9010
(703)698-8797
Manassas
Gainesville
The Plains
Centreville
Nokesville
Boyds, MD
Annandale
     B.   In the event of a security problem, such as illegal
trespass or theft, the guards shall obtain assistance from:
     NAME
                   EXTENSION
HOME TELEPHONE
Sayre.  L.

Glover, R.


Kirkland,  G.C.
                    6425


                    4213


                    6065
(703)788-9478

(703)323-9361


(703)754-8006
                        -14-

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     C.   In the event of an emergency involving a hazardous
material release, the guard shall notify:

     NAME               EXTENSION        HOME TELEPHONE

Young,  M.                6411      (703)335-1110  Manassas

Cohen,  M.                6448      (703)237-4717  Arlington

Constant, D.             6503      (703)978-7941  Fairfax

Shults, R.               6081      (703)335-1110  Manassas

Lawrence. C.G.            6462      (703)235-5684  The Plains

Knox, D.                 6328      (703)754-7937  Gainesville

Meyer,  B.                6525      (703)830-1666  Centreville

     D.   Should your questions or problems be of an urgent nature
(but not an emergency) which might relate to guard procedure,
absence of a guard scheduled for duty and other like problems,  you
should  obtain assistance from:

           NAME                   HOME TELEPHONE

     Weaver, B.                    (703)439-3538

     Sayre, L.                      (703)788-9478

     Glover, R.                    (703)323-9361
                        -15-

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        URGENT QUESTIONS OR EMERGENCIES (Continued)

I.   General

     A.   Contacting Safety Staff Off-Plant

          1.   C.G. Lawrence and Rick Shults are reachable
               by long-range belt pagers when they are off-plant.
               The pagers are telephone-activated, and programmed
               to provide the wearer with the telephone number
               he should call to receive a message.
          2.   To activate one of the pagers, use a touch-tone
               phone and dial the appropriate telephone number
               for the person whom you want to contact.  Wnen
               the connection is made, you will hear three quick
               beeps.  When you hear these beeps, punch in the
               telephone number you want to call, Just as you
               would dial any phone number.  Wait on the line
               until you hear another series of beeps, followed
               by a busy signal, then hang up.  In 60 seconds or
               so, the message will be received by the party to
               whom you intended it.
          3.   For example, suppose there was an important message
               for C.G. Lawrence while he was off plant.  To reach
               him, you would call his pager telephone number -
               825-0322 (this is a Washington, D.C. phone number),
               after the connection is made, you will hear three
               quick beeps, followed by silence.  During this
               silent period, use the telephone on which you're
               calling to punch in, i.e. 642-6282.  Stay on the
               line until you hear another series of beeps
               followed by a busy signal, then hang up.  Within
               a minute or so. the pager on C.G.'s belt will
               beep and display the numbers...642-6282.  At his
               earliest convenience, he will call in for the
               message.

*In the event of an emergency incident, simply use "6666" as the
number to be called.
     To contact C.G. Lawrence's pager call:  202/825-0322
     To contact R.H. Shults' pager call:     202/825-0309

Note:  Attempt to contact Safety personnel by belt pager ONLY
when efforts to contact them by phone have failed.

                         -16-

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                TELEPHONE FAILURE PROCEDURE

I.   General

     A.   Upon outage of any or all Internal communications
capabilities or loss of the main outside telephone link, or both,
this emergency procedure will go into effect.

     B.   When the telephone system is down, the safety and
security of the plant becomes threatened.  Efficiency in
completing the following responsibilities will aid in
re-establishing communications links between critical plant areas.
Once internal communication lines are established, the guard
office, equipped with emergency telephone capabilities, will
function as the plant's main connection to the outside.  Use of
this back-up system is reserved exclusively for critical or
emergency communication.

II.  Procedure

     A.   Once it has been established, the internal telephone
system is not fully operational, the guard shall check whether
outside lines are functioning on his regular-use phone.

          1.   If outside lines are not functioning, the guard
               office emergency phone and the following office
               phones are permanently connected to the Continental
               Telephone system:

                    a.   Guard Office (754-2896)
                    b.   Personnel Manager's Office (754-4148)
                    c.   Main Gate pay phone (754-9952)
                    d.   Bldg. 79 pay phone (754-9934)
                    e.   Bldg. 40 pay phone (754-9949)

          2.   During total phone system failure, eight facility
               emergency by-pass phones will automatically tie-in
               to the Continental Telephone system.  These numbers
               are company private and may be used for emergency
               traffic only by the assigned user.  If the guards
               are alerted that the by-pass switch-over did not
               occur automatically, the manual override switch
               located in the guard office is to be activated.


                        -17-

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          3.   Emergency phones are:
               a.   To be used only for critical or •mergency
                    calls.
               b.   To remain ON until all telephone capabilities
                    are restored and OK given by Personnel
                    Manager, Safety Engineer, or senior member
                    of management.
               c.   Never to be left unattended.
the
 B.    The following people shall
situation:
                                     be contacted and apprised of
          1.   Security Supervisor
          2.   Safety Manager/Engineer
          3.   Personnel Manager
          4.   V.P. of Virginia Operations
          5.   Director of Technology
          6.   Officer in Charge of the First Response Unit
               (if other than safety person(s) listed above)
          7.   Director of Gainesville Manufacturing Operations
     C.   The following
equipped with a two-way
system failure.
                    individuals or their designate are
                    radio for emergency use during telephone
          1.   Assignment Radio Designation

               a.   Patrolling Guard
               b.   Richard Shults
               c.   Brush Truck
               d.   Fire Pumper
               e.   Dave Knox
               f.   Richard Romine
                    Giles Darr
                    Rodney Carter
               g.   Bud Kirkland
               h.   Jim Martin
               1.   Randy Brown
               J.   Mike Young
               k.   C.G. Lawrence
                                              "Unit One"
                                              "Unit Two"
                                              "Brush Thirty'
                                              "Wagon Thirty'
                                              "Unit Four"

                                              "Unit Five"

                                              "Unit Six"
                                              "Unit Seven"
                                              "Unit Eight"
                                              "Unit Nine"
                                              "Unit Ten"
                         -18-

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               1.   Dave Constant            "Unit Eleven"
               m.   Bernie Brien             "Unit Sixteen"
               n.   Bill Meyer               "Unit Seventeen"
               o.   Maintenance Chief        "Unit Eighteen"
               p.   Melisa Cohen             "Unit Nineteen"
               q.   Dave Sprecher            "Unit Thirty-six"
               r.   Lou Sayre                "Unit Forty"
               s.   Anne Lashenka            "Unit Seventy"
               t.   Kern Wnite                "Unit Seventy-one"

          2.   A two-way radio check shall be initiated by the
               guard to ascertain that appropriate units are on
               the air.

          3.   For the duration of time that this procedure is in
               effect, all of the individuals assigned two-way
               radios will have those radios in their physical
               possession at all times.

     D.   Upon notification of a telephone failure, energetic
operations shall be shut down until it is determined that the
radio-based emergency communication system is in effect.  The
prerogative to keep operations shut down shall remain with the
Safety Department, and with the Directors of Technology and
Gainesville Manufacturing Operations in their respective areas of
responsibility.

     E.   For the duration that this procedure is in effect, no
visitors shall be permitted within the operating areas of the
facility.
                        -19-

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III. Emergency Incidents During Periods of Telephone Outages

     A.  The portable radios distributed throughout the plant will
serve as the in-plant communication link.  If an emergency call is
received over the two-way radio during a telephone outage:

          1.   The guard shall follow existing emergency
               procedures,  utilizing the pager system if
               possible, and plant siren to alert First
               Response Team personnel.

     8.    All emergency calls to the outside, including those to
the fire department or hospital, shall be made over the emergency
outside  lines as necessary.
                        -20-

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                    STORM PROCEDURES

I.    General

     A.    Electrical storms, tornadoes, high winds,  and other
natural  events will occur periodically, and may present hazards to
employees working in energetic areas.   This procedure outlines the
steps to be considered (in energetic areas) during the approach or
onset of hazardous environmental conditions.

     B.    Static build-up and discharge becomes a major safety
concern during severe environmental conditions.  The degree of
hazard and the decision to initiate this procedure is the
responsibility of the supervision in charge of each  area.  Certain
operations will be more susceptible to incident than others.
Responsible supervision is given the task of determining the need
to implement this procedure to the degree necessary  to insure
personnel safety.


II.  Evacuation of Hazardous Areas

     A.    Wnenever an electrical storm (or other hazardous natural
event) approaches the near vicinity of the plant, the area
supervision should evacuate personnel from locations containing
energetic materials that may be initiated by lightning or static
discharge.

          1.   When an electrical storm or other hazardous
               weather condition is anticipated, supervision
               should give a first alert, whereupon  unnecessary
               operations will be discontinued.

          2.   An electrical storm is considered in  the "near
               vicinity" or imminent when the time between the
               lightning flash and the thunder is five seconds
               (or less).  This will place the flash approximately
               one mile from the observer.  Although the intensity
               of the storm is a direct consideration, it is at
               this point that a static hazard exists.
                        -21-

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     a.    Weather conditions of this type cannot
          be correctly evaluated in every instance
          by untrained personnel.  It may t>«
          necessary to contact the Weather Bureau
          for storm duration or other additional
          information.  Both fire trucks have a weather
          radio on board.  Safety may be contacted
          for more information.

     b.    Where existing or scheduled operations
          create exceptional hazards, the area
          supervision may arrange for specific
          weather warnings to be provided.

3.    Areas where evacuation shall be considered during
     times of severe weather include:

     a.    Operations of facilities without approved
          lightning protection systems,  which contain
          energetic materials, and locations within
          the immediate vicinity of such facilities.

     b.    Buildings containing explosive dusts or
          vapors whether or not equipped with lightning
          protection and locations nearby (grain
          finishing, paint operations).

     c.    Magazines, open storage sites or loading
          docks, which are not equipped  with lightning
          protection, and vehicles containing energetic
          materials and locations nearby to such
          structures, sites and vehicles.

     d.    Locations (with or without lightning
          protection) where operations involving
          electro-explosive devices are being
          performed.

     e.    Rocket Test (Static testing must cease.
          However, evacuation of main areas may not
          be necessary.).
               -22-

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          4.   Once • o«cl»ion to • va.cua.ta it mad«, the area
               supervisor is responsible to insure that personnel
               are warned and that the appropriate Director is
               informed of the decision.

          5.   For operations requiring constant 'attention,
               the decision may be made to continue manning
               the operation with a minimum crew consistent
               with safety considerations until the operation can
be brought to a condition in which it is safe to
leave without producing hazardous rejected
components or products.

          6.   Wnen it is decided that personnel should be
               evacuated, the operation should be shut down
               (when possible, in accordance with normal
               equipment shut down procedures.  If conditions
               warrant, emergency shut down procedures may
               need to be implemented.)  Windows and doors
               should be closed, and electrical switches
               thrown to the off position.

          7.   If the decision to evacuate is made, evacuated
               personnel shall go to places at inhabited building
               distances from the hazardous location.  If this
               is not possible, shelter located at intra-line
               distances should be sought (e.g. Building 79
               for operations in D-5, Mix and Cast, and Grain
               Finishing areas).  These locations must be
               assigned and posted.

          8.   Personnel in charge of vehicles containing ex-
               plosives should, when possible, move the
               equipment to locations of comparative safety
               before evacuating.

     8.   Area supervision shall decide when personnel may return
to abandoned operations or facilities.
                            -23-

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          THREATENING TELEPHONE CALLS PROCEDURE
I.
General
     A.   If an employee received a telephone call from
someone who makes threats to either company employees or to
company property, he/she should:

          1.   Obtain as much information as to the exact nature
               of the threat as possible, including such things
               as when the action is to occur, location involved,
               and what will happen, etc.

          2.   Contact one of the following who will advise you of
               what, if any, further action you shold take:
     NAME

Sayre, L.

Glover, R.

Johnson, G.

Kirkland, B.

Hostettler,  S
                   EXTENTION

                    6425

                    4213

                    6277

                    6C65

                    6245
HOME TELEPHONE

  (703)788-9478

  (703)323-9361

  (301)972-9010

  (703)754-8006

  (703)698-8797
NOTE:
     Stats Polict and Princ* William County Police telephone
numbers:

     STATE POLICE:
               Independent Hill
                    (Prince William County)

                    Warrenton

                    For Emergencies ONLY

             Prince William County Police
  (703)791-3101


  (703)347-3237

  (800)572-4510
    (Toll Free)
   363- 3333   :
   (Non-Emergency)
   911 - EMERGENCY
                       -24-

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                BOMB  THREAT  PROCEDURE
I.   General

     A.    Bomb  threats  are  usually  received  by the  receptionists
(or the guards  during non-working hours)  on a publicly  listed
number.   These  few  seconds  will  probably  be  our only contact with
the caller; so  it is important that  any available information be
recorded  accurately.

           1.    There are two essential points of information which
                must be  obtained.  They are:

                a.   The expected explosion time;

                b.   The location of  the bomb.

     B.    For investigative purposes, it  Is  important to find out
as much as possible about the caller.  Conversation should be
gently encouraged.  The longer the caller is on the phone, the
greater are the chances of  tracing him via the telephone company.
Also, by  engaging the caller in  conversation, we may learn more
about him  or her or hear clues that  will  be  useful  for later
investigations.  This applies not only to the caller's regional
accent or  ethnic origin, but also to background noises, such as
the sounds of road  repairs, traffic  or trains, machinery, music,
conversation, etc.

           1.    Be careful that you do not upset or  panic a bomb
threat caller.  Asking  too  much  for  too long can make the caller
nervous and cause him to hang up.  The essential information is
the time  and place of the explosion—get this information and only
then, try  to get more.


           2.    ENCOURAGE THE INDIVIDUAL TO TALK.  The longer the
caller can be kept on the line,  the  better.  Keep listening to
everything they say, and pay attention to any background noises.
If the caller remains on the line, ask him why he has planted the
bomb.  He may want to talk  about some emotional problem,
grievance, or political idea.  Your  sympathy and interest may hold
the caller on the line  long enough for the call to  be traced, or
encourage him to give essential  information.

                             -25-

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You should complete as much of the following form as quickly as

possible.  Give it to the Security Office immediately for their
follow-up i investigations.
ALLEGED BOMB'S LOCATION

ALLEGED EXPLOSION TIME .

PHONE BOOTH (CALL BOX)

CALLER'S EXACT WORDS:
              TIME OF CALL _

              YES 	 NO
CALLER'S SEX:  MALE
  FEMALE
CALLER'S AGE:
                                        (CHILD/YOUTH/ADULT)

CALLER'S MENTAL STATE (EXCITED, NERVOUS, IRRATIONAL, CALM)
SPEECH/VOICE
          REGIONAL OR OTHER ACCENT
BACKGROUND NOISES
NUMBER CALL WAS RECEIVED ON
OPERATOR'S ACTIONS AFTER RECEIVING THE CALL
ANY ADDITIONAL INFORMATION
OPERATOR'S NAME

HOME ADDRESS
DATE OF REPORT
         HOME PHONE NUMBER
TIME
                                                SIGNATURE
                           -26-

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           BOMB  THREAT  PROCEDURES  -  ACTIONS TO  BE TAKEN
I.   General

     A.   In the event of & bomb threat to any portion of the  Pine
Ridge facility, the guard, receptionist, or any other employee who
receives the threat shall contact one of the  following who will
act as a coordinate and will be responsible for taking the
appropriate action:

     NAME              EXTENSION          HOME TELEPHONE

Sayre, L.                6425             (703)788-9478

Kirkland, 8.             6065             (703)754-8006

Hostettler, S.           6245             (703)698-8797

Martin, J.               6033             (703)281-3723

Lawrence, C.             6462             (703)253-5684

     B.   The first of the above people contacted, whether on or
off the plant, will act as coordinator and remain in control
unless they specifically relinquish that responsibility to
another.

          1.   The coordinator contacted will call the suspected
               area and direct those who answer to quickly summon
               the highest level of supervision in the area to the
               telephone for an urgent message.  The supervisor
               responding should then be told the nature
               of the emergency.  In any areas threatened all
employees should be asked to evacuate unless  it
               is unsafe to do so because of  the nature of the
               work underway.  Employees should note any odd
               packages or objects and report them to their super-
               visor.   The coordinator will designate employee
               assembly locations from among  the following:

               a.   Picnic area across from Building 153
               b.   Building 40. parking lot


                           -27-

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                      c.   Building 77, Mixer Control
                      d.   Building 59, Test Bay
                      c.   Building 24, Change House
                      f.   Building 153. Cafeteria
                      g.   Volleyball Court west of Building 212
                      h.   Any cells in Building 40 designated  by
                           Rocket Assembly supervision on duty.

                 2.   The first supervisor arriving at any designated
                      evacuation site shall promptly organize a search
                      of the area to assure that no local hazards
                      exist.  Should anything suspicious be found IT
                      IS NOT TO BE TOUCHED and the area will be blocked
                      off immediately and all personnel kept away.  The
                      coordinator shall be informed at once of  any such
                      findings.

                      c.   After arranging for evacuation, the
                           coordinator will notify the following persons
                           of the threat:

                                              TELEPHONE NUMBER/EXTENSION

*                     Plant Security                6483. 6425. 6279
                      Security Operations Center          6282

                      State Police - Independent Hill
                                     (Prince Mm. County) (703)791-3101
                                     Warrenton           (703)347-323/~
                      Toll Free for EMERGENCIES ONLY     (800)572-4510

            D.   The coordinator will arrange with area supervision for
       detailed search of the evacuated areas under their Jurisdiction.
       Those performing the search must be instructed not to touch any
       bomb or suspicious item, but to notify the coordinator at once.
       If examination, deactivation, or disposal of a bomb or item
       suspected to be a bomb becomes necessary, arrangements will be
       made by the State Police.

            E.   If it is determined to the satisfaction of the
       coordinator that an area is free from hazard, he will contact that
       area's supervision, who may then instruct workers to return to
       their normal duties in that area.


                                -28-

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               STANDARD OPERATING PROCEDURES
Introduction

     The following Standard Operating Procedures are intended
primarily for use by members of the Gainesville Emergency First
Response Team when responding to and dealing with any of a broad
range of emergencies on the Gainesville facility.  Upon
completion,  this document will offer four (4) classes of SOPs:
Communications (SOP COMM), Operations (SOP OP), Training (SOP TR)
and Administration (SOP AD).  Because emergency incidents are
unpredictable and -- at least in most cases -- unforeseeable, it
is difficult to establish procedures capable of dictating actions
to be taken under all circumstances.  Where this is not possible,
we have tried to establish guidelines to be followed during most
emergency incidents.  The most basic safety tenets (for example,
the wearing of self contained breathing apparatus (SCBA) and the
use of the 1 1/2" hoseline on structure fires) must be considered
inviolable.   Beyond this, however, there must be room for some
degree of discretion on the part of the Officer In Charge of the
emergency incident, based on the authority granted by the most
basic yet least stated of all Standard Operating Procedures:
"Common Sense Supercedes SOPs".

     For those not directly involved in emergency control
activities,  as defined in the first portion of the Emergency
Procedures  Plan (under "General Statement of Policy"), these
changes are for general information.  For those who are directly
involved in emergency activities, these SOPs -- as revised --
will reflect current policy and procedures.  As such, it is
imperative that they be carefully read and periodically reviewed.
                         -29-

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                                                       SOP-COMM1

                 EMERGENCY PAGING PROCEDURE

Purpose:

     To establish a procedure to be used by the Emergency
Operations Center (EOC)  - located in the guard office - to
dispatch the Gainesville First Response Unit to emergencies on
plant.

Scope:

     This procedure is to be used to dispatch the First Response
Unit on any and all Emergency Incidents, as defined in the Pine
Ridge Emergency Procedures Manual.

Procedure:

     A.   Upon receipt of an emergency call or an evacuation alarm
          indicator in the guard office, the on-duty guard shall
          issue a brief  pre-alert over the radio:

          1.   The pre-alert shall be given before activation of
               the "00"  page.
          2.   The pre-alert shall consist of a very brief
               announcement of the emergency.
          3.   The pre-alert announcement shall be made only
               once.

     B.   Immediately following the pre-alert, the guard shall
issue a "00" page to activate pagers of the First Response Team
member.

          1.   The dispatch of the First Response Team shall also
               be brief, consisting only of the location, the
               nature of the incident and the fact that the
               First Response Team should respond.

               a)   An example would be: "Building 	. Injury.
                    First Response Team respond."

                    1)   Note that it is not necessary (or
                         acceptable) to dispatch "all first
                         aiders," or "all fire fighter." The
                         entire First Response Team shall be
                         dispatched to all incidents.


                           -30-

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     C.   Immediately following the first page,  the EOC shall
issue a second "00" page, after which the brief  dispatch shall be
repeated.

     D.   After completion of A thru C above, EOC will provide
whatever additional information is available.
                         -31-

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                                             SOP  COMM-2
                RADIO UNIT DESIGNATIONS
Purpose:

     This procedure is intended to clarify the identification of
individuals in emergency operations on the Gainesville facility.

Scope:

     This procedure shall affect all those individuals currently
assigned  radio equipment (two-way radios and pagers)  for use
during emergencies.

Procedure:

     A.   The radio unit designations listed below apply to the
corresponding individuals at all times,,  regardless of the
equipment the inc_vidual is using.

          1.    For example, if Jim Barlow (Unit 13)  is using
               the radio from the Brush  Truck, he remains Unit
               13.  Similarly, if Norm Grady (Unit 28) is using
               the Fire Pumper, he remains Unit 28.

               a.    However, when personnel from Maintenance or
                    Rocket Test who do not normally carry unit
                    designations are using the brush truck for
                    whatever reasons, the driver of the brush
                    truck will assume the radio designation
                    "Brush 30".

     B.   The following is a revised list of assigned radio unit
designations  (revised 9/88).
     UNIT DESIGNATION
 Pine Ridge"
 Unit 1"
 Unit 2"
 Unit 3"
        IDENTITY

Emergency Operations Center
Patrolling Guards
Rick Shults
This unit is considered a "floater"
identifying the driver of the brush
truck unless the driver is elsewhere
identified on this list.  This
usually indicates that Maintenance
is using the vehicle.
-32-

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"Unit 4"
"Unit 5"

"Unit 6"
"Unit 7"
"Unit 8"
"Unit 9"
"Unit 10"
"Unit 11"
"Unit 12"
"Unit 13"
"Unit 14"
"Unit 15"
"Unit 16"
"Unit 17"
"Unit 18"
"Unit 1 9"
"Unit 20"
"Unit 21"
"Unit 22"
"Unit 23"
"Unit 24"
"Unit 25"
"Unit 26"
"Unit 27"
"Unit 28"
"Unit 29"
"Unit 31"
"Unit 32"
"Unit 33"
"Unit 34"
"Unit 35"
"Unit 36"
"Unit 37"
"Unit 38"
"Unit 39"
"Unit 40"
"Unit 41 "
"Unit 42"
"Unit 43"
"Unit 44"
"Unit 50"
"Unit 60"
"Unit 70"
"Unit 71"
"Brush 30'
"Wagon 30'
Dave Knox
R. Romine/G.  Darr/R.  Carter
     (Production Foremen)
Bud Kirkland
Jim Martin
Randy Brown
Mike Young
C.G. Lawrence
Dave Constant
Charlie McCool
Jim Barlow
Ed Robinson
Mary Hurrey/Alta Smith
Bernie Brien
Bill Meyer
Chief, Maintenance Services
Melisa Cohen
Paul Anderson
Tim Patton
Mike Brown
Tom Barb
Ron Mahoney
Ken Locke
Dave Fogle
Mark Harlow
Norm Grady
Steve Wasz
Dave Payne
**Vacant**
John Kemper
Don Connors
Bill Fones
Dave Sprecher
Pat Spangler
Bill Burke
Lewis Golladay
Lou Sayre
Harvey Craun
David Owens
David Thompson
**Vacant**
Roger Falls
Al FoltS
Anne Lashenka
Kern White
Brush Truck
Fire Pumper
                             -33-

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                                             SOP COWM-3

               MUTUAL AID INCIDENTS

Purpose:

     The  purpose of this procedure is to guarantee effective
communication between ARC emergency control personnel and
assisting personnel from Prince William County Fire and Rescue
Services.

Scope:

     This procedure affects all personnel who are directly
involved  with emergency control activities.

Procedure:

     A.   Both ARC fire units have radios capable of communicating
with the  Prince William County Firefighting and EMS units.
(Channel  5 on both units).

     B.   If the officer in charge feels information needs to be
passed on to the incoming units, the QIC must:

          1.   Go direct to dispatcher, not units.
          2.   Use the identification:  Atlantic Research Mobile,
               or Atlantic Research Portable.
                          -34-

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                                                  SOP COHM-4

                  COMMUNICATIONS PROTOCOL


Purpose:

     The purpose of this procedure is to establish a formal
protocol governing fireground communications,  so as to limit
confusion generated by large numbers of radios in operation during
an emergency.

Scope:

     This procedure shall apply to any individual operating a
two-way radio on the Gainesville emergency frequency during an
emergency incident.

Procedure:

     A.   It shall be the responsibility of the Emergency
Operations Center (EOC) to direct and control  communications
during an emergency incident.

     B.   All radio communications between the EOC and fireground
units shall be directed through the Officer in Charge (QIC of the
First Response Team or his designate.

          1 .   All communications generated by fireground units
               shall be directed to the QIC or his designate.

          2.   All communications between ARC emergency personnel
               and County firefighting/EMS personnel shall be
               directed to the County officer  in charge via the
               OIC.

     C.   All units not directly involved with emergency control
activities shall refrain from speaking on the  radio unless they
are specifically addressed by the OIC or EOC.

     D.   It shall be the responsibility of the OIC to provide EOC
with periodic updates of the emergency control activities.
                         -35-

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     E.    It shall be  the sole responsibility  of  the  OIC  to
declare  an Emergency Incident under control  or over.

          1.   Similarly,  it shall  be  the  sole responsibility  of
               of the  OIC (or the Emergency  Operations Director)
               to request for outside  assistance.
                         -36-

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                                                  SOP COMM-5

               SPECIAL DISPATCHING PROCEDURE

Purpose:

     This procedure is intended to minimize the occasions when the
First Response Team is dispatched to "false" alarms resulting from
maintenance work on telephone lines within the plant.

Scope:

     This procedure is intended to augment SOP COMM-1,  "Emergency
Paging Procedure", and is to be implemented only at the expressed
direction of the Safety Department, or, in the absence of a
representative of the Safety Department, by the Director of
Production.

Procedure:

     A.   Upon notification by whatever source that
maintenance/repair work is being performed on the phone lines in
an area of the plant, the guard staff shall so notify a
representative of the Safety Department, who shall then determine
whether or not to implement this procedure, and to what degree.

     B.   When an automatic evacuation alarm sounds in a targeted
area, the on-duty guard shall call the contact number in that area
to determine the validity of the alarm.

     1 .   The guard shall allow three rings only.  If the phone
          is not answered within three rings, the alarm will  be
          assumed to be real, and the normal dispatching procedure
          shall be implemented.

     2.   If the telephone is answered within three rings, the
          guard shall ask the person on the other end:   "Is an
          alarm sounding in your building?"

          a)   If the answer is in the affirmative, or if the
               guard can hear the alarm in the background, he will
               immediately implement the usual emergency
               notification/dispatching procedure.


                             -37-

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          b)   If the answer is in the negative,  the  guard  shall
             notify the Safety Department or,  in  the  absence  of
            a representative of the Safety Department,  the
       Director of Production, or in both their absences
     the ranking official of the Security Department  for
     further instruction.

     C.    This procedure shall be implemented  only by order of a
representative of the Safety Department or in  their absence by the
Director of Production,  and only for the buildings specified  in
that order, for the time duration specified.

     D.    This procedure shall affect operations  only between the
hours of 0800 and 1700.   At all other times,  the  normal
dispatching procedure shall be observed.
                          -38-

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                                                  SOP OP-1

          FIRST RESPONSE TEAM COMMAND STRUCTURE

Purpose:

     The purpose of this procedure is to establish the continuity
of command during emergency incidents when the chief officer of
the Team is not present.

Scope:

     This procedure will directly concern all individuals involved
in emergency control activities at Gainesville.

Procedure:

     A.   The Officer in Charge (Chief) of the First Response Team
will service as the Incident Commander for the duration of an
emergency operation on the Gainesville facility.

          1 )   If on duty, the Assistant Chief will serve as
               second in command.

          2)   The designated Captain (Safety Inspector)  will
               serve as next in command, after Assistant Chief.

          3)   Inasmuch as the first due Fire Chief for Prince
               William County cannot be expected to surrender
               the control - and therefore safety - of this
               manpower  to the leadership of the First Response
               team over which he has no control, close
               coordination will be required between the Incident
               Commander and the Fire Chie ,  during all emergency
               operations.

     B.   The Officer in Charge shall wear the white helmet marked
with their rank, for the duration of an emergency incident to
facilitate fireground identification.

     C.   The attached is an organizational chart for the First
Response Team.
                             -39-

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    FIRST RESPONSE TEAM ORGANIZATIONAL CHART
                 CHIEF OFFICER
                (Emergency .Coordinator)
                 C.G. Lawrence
 Anne Lashenka
               Richard H. ShultB
 Jim Barlow
 Dan Payne

  FIRE BRIGADE

Tom Barb
Bill Burke
Don Connors
Dave Fogle
Bill Fones
Lewis Golladay
John Kemper
Dave Knox
Ken Locke
Ron Mahoney
Dave Owens
Tim Patton
Steve Wasz
Dave Thompson
Mark Harlow
  CAPTAINS

 Norman Grady
  Mike Brown
Charlie McCool

  EMS TEAM

   Pat Spangler
   Roger Falls
Kern White
                 SPILL RESPONSE TEAM

                  C.G. Lawrence
                  Mike Brown
                  Dave Constant
                  Melisa Cohen
                  Mike Young
                  Rick Shults
                  Dave Knox
                  Tim Patton
                  Norm Grady
                     -40-

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                                                 SOP OP-2

      USE OF PROTECTIVE CLOTHING ON EMERGENCY INCIDENTS

Purpose:

     The  purpose of this procedure is to provide a standard by
which to  assess the need for protective clothing on Emergency
Incidents.

Scope:

     This procedure is directed toward all First Response Team
personnel.

Procedure:

     A.   Running Gear (helmet, coat, pants, boots, 3/4 boots,
gloves).

          1 .   Full running gear shall be worn on all structural
               fires, vehicle fires or at the discretion of the
               OIC.

          2.   On most brush or grass fires, full running gear
               will be optional so long as firefighting personnel
               meet the minimum personal protection requirements
               of 3/4-length  fire boots, helmet safety glasses
               and ARC approved flame resistant clothing.

     B.   Self-Contained Breathing Apparatus (SCBA)

          1 .   SCBA shall be worn by all First Response Team
               personnel entering a building in which a fire has
               been reported.

          2.   When smoke or fire is evident, face masks shall be
               in place and the breathing apparatus set in the
               "positive pressure" mode.

          3.   SCBAs shall remain in place until the "all clear"
               has been issued by the OIC.
                         -41-

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                                             SOP  OP-3

        USE OF HANDLINES IN FIRE SUPPRESSION ACTIVITIES

Purpose:

     The purpose of this procedure is to establish a  standard for
selecting the proper hose line for use in fire suppression
activities at Gainesville.

Scope:

     This procedure affects all of those involved in fire
suppression activities at Gainesville.

Procedure:

     A.   The primary attack line for structural  fires at ARC
shall be the 1-1/2" hose line.

          1.   The 1-3/4" hoseline shall be advanced  into any
structure from which smoke and/or fire are emanating.

               a.    The hose line shall be charged at  the
                    direction of the OIC.

     B.   The primary attack line for vehicle fires at ARC shall
be the 1-3/4" hose line.

     C.   The 3/4" Booster hose line shall be the primary attack
line for exterior brush and grass fires.

          1.   During such outside fire suppression activities,
the variable-flow nozzle on the Booster lines shall be pre-set to
ten (10) gpm, in the interest of conserving water.

               a.    If this flow rate proves ineffective in
                    extinguisher the fire, the nozzle  may be
                    re-set at the discretion of the OIC or the
                    nozzleman.

     D.   Under NO circumstances shall the 3/4" Booster line be
advanced as an attack line for a structural or vehicle fire.

          1.   This paragraph is in no way intended to preclude
               the use of a Booster line during overhaul and
               mop-up operations.

                            -42-

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                                                      SOP OP-4

     CALLING FOR ASSISTANCE FROM PRINCE WILLIAM COUNTY
                       FIRE/RESCUE UNITS


Purpose:

     This procedure is intended to clarify the Company's policy
on calling for outside assistance from Prince William County Fire
and Rescue units in the event of an emergency incident on the
Gainesville facility.

Scope:

     This procedure affects all individuals acting in the capacity
of the Office in Charge (OIC) of the First Response Unit, as well
as senior members of management who may serve as the Emergency
Operations Director, as established in the Gainesville Emergency
Procedures Manual.

Procedure:

     A.   The decision to call for outside assistance to
neutralize emergency incidents on plant lies exclusively with the
OIC of the First Response Unit or with the Emergency Operations
Director in consultation with the OIC.

     B.   The OIC shall call for outside assistance on any
reported structure or vehicle fire when, upon his arrival on the
scene, there is visible evidence of a free-burning fire.  (This
includes visible flames, unusual heat, billowing smoke, etc.)

          1 .   Discretion may be used by the OIC when the fire  is
               limited to a reinforced concrete structure,
               provided that his size-up of the situation shows
               there is no potential for uncontrolled fire spread
               or extension.

     C.   The OIC shall call for outside medical assistance for
any incident in which an employee or visitor has received a
first-degree burn over a total body area of 10% or greater, second
degree burn over a total body area of 5% or greater, or a third
degree burn, regardless of the size of the area involved.


                           -43-

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          1.    Outside medical assistance shall be called for any
               individual who has an employee who has received
               burns to the face or neck, regardless of the
               severity of these burns.
          2.    Outside medical assistance shall be called for any
               individual who has received second or third degree
               burns to any articulated  joint.

     D.   The OIC shall call for outside medical assistance for
any incident  in which an employee or visitor has been reported to
have a major  medical emergency.  This includes, but is not limited
to: heart attack, stroke, seizure, trouble breathing, unconcious
person, electrical shock, severe traumatic injury.

          1.    The request for assistance in these cases shall
               be made when first responding to the incident;
               before arrival on the scene.

     E.   The OIC shall routinely call for outside medical
assistance on any incident in which he is informed by the EOC that
the person making the original report of the emergency
specifically  requested an ambulance.

     F.   The OIC shall call for outside medical assistance on any
incident in which the EI1S Team leader has requested an ambulance.

     G.   If, for whatever reason, the OIC cannot be reached,
outside medical assistance may be called at the discretion of the
EMS Team leader.

          1.    The OIC shall be informed of this decision as soon
               as is practically possible.
                        -44-

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                                                   SOP TR-1

          PORTABLE FIRE.EXTINGUISHER TRAINING

Purpose:

     This procedure establishes guidelines for conducting employee
training  sessions on the effective use of portable fire
extinguishers.

Scope:

     This procedure shall affect all personnel involved with
portable  fire extinguisher training, whether in the capacity of
instructor, assistant or student.

Procedure:

     A.   Safety

          1.    The primary consideration during any and all
               training sessions shall be the safety of personnel
               involved.
          2.    Training sessions shall be held only at the
               designated training facility near the pond behind
               Building 109.
          3.    No practical fire extinguisher training shall be
               held on days when the sustained wind velocity is
               greater than 5 mph, or when gusts are recorded in
               excess of 10 mph.

               a.   Wind measurements shall be made at Building
                    110 by the assistant instructor no longer
                    than 15 minutes before the actual training
                    is to begin.

                    1)   The assistant instructor shall watch the
                         anemometer in Building 110 (burn pit
                         control room) for a minimum of sixty (60)
                         seconds.  If, during that time, the
                         average wind velocity is greater than 5
                         mph, or if any gusts are recorded at
                         greater that 10 mph, the assistant
                         instructor shall so inform the instructor
                         and the live-fire extinguisher training
                         shall be postponed.
                           -45-

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     4.    During ail phases of actual fire extinguisher
          evolutions,  the firetruck will be on stand-by
          at the training facility with two (2)  members
          of the Fire Brigade (exclusive of the instructor)
          present.

          a.   One  of the fire brigade members shall remain
               at the fire truck to serve as pump operator.
               The  second member of the fire brigade shall
               stand ready with a charged 1-1/2" hose line.

               1)   The hoseman shall wear full protective
                    clothing, less breathing apparatus, for
                    the duration of the training exercise.

B.   Training Evolution

     1.    Didactic  Portion

          a.   Before being permitted to participate in live
               fire training, each student shall attend a
               lecture approved by the Safety Department on
               the  use of portable fire extinguishers.  The
               lecture shall include the NFPA film,  "Using
               Fire Extinguishers the Right Way".

     2.    Practical Portion

          a.   Only one student shall be permitted on the
               training pad at any time during live fire
               evolutions.
          b.   The  Instructor will remain in close contact
               with the student while the student approaches
               the  fire.

               1)   The Instructor nust be wary of any
                    signs of panic on the part of the
                    student.  Should any such signs become
                    apparent, or should the student state
                    unequivocally that he/she does not
                    want to participate, the Instructor
                    shall immediately retreat from the
                    fire with the student.

          c.   Students shall be required to .wear ARC-
               approved fire resistant clothing, gloves and
               eye protection.
                          -46-

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     1)    Students with long hair shall be asked
          to wear it "up" or "back" in such a
          way that it will not pose a hazard to
          its wearer.

d.   The Instructor shall be required to wear full
     protective clothing, less breathing apparatus
     for the duration of the practical portion of
     the training evolution.

e.   Training fires shall routinely be fueled with
     kerosene obtained from the drum near the
     training pad.  On occasion,  special provisions
     may be made to train on Class A fires. At no
     time, however, shall highly volatile fuels
     such as gasoline be approved for use at the
     training facility.

     1)    Prior to the addition of kerosene, the
          containment drum on the training pad
          shall be filled with 15-20 gallons of
          water.
     2)    Only the minimum amount of kerosene
          necessary to provide an adequate training
          fire shall be added to the water in the
          containment drum.  Under most circum-
          stances, one (1) quart should suffice.
          At no time shall more than four (4)
          quarts of kerosene be added to the drum.

f.   Only the Instructor shall be permitted t c
     ignite the training fire.

     1 )    The Instructor should use a road flare or
          other similar extremely hot ignition
          source to ignite the training fire.

g.   It shall be the responsibility of the
     Assistant Instructor to refill the portable
     fire extinguishers used in the training
     evolutions, as they are emptied.

h.   Following the final extinguishment evolutions,
     the fire shall be re-ignited and permitted to
     burn until all of the fuel is consumed.  The
     stand-by Fire Brigade team shall remain at the
     training facility until this burning is
     completed.
          -47-

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           ATTACHMENT I



LIST OF EQUIPMENT ON FIRE TRUCK

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   LOCATION OF EMERGENCY EQUIPMENT

        Emergency equipment  for hazardous material  incidents  is  not
   pre-staged and is stored  on the  fire  trucks  and  in  the  fire house
   (building 36).  Portable  fire  extinguishers  around  the  plant  are
   not to be used by plant personnel  for hazardous  material
   incidents.  This policy is required by new OHSA  regulations on
   training for hazardous material  incident  responders.  Only members
   of the first response unit have  the appropriate  training to
   adequately respond to chemical emergencies.   In  addition,  portable
   fire extinguishers would  not be  effective in most explosive and
   propellant fires, and special  response technics  are required.
        The emergency equipment that  will be utilized  in chemical
   emergencies, including all hazardous  waste material response  are
   listed on the following pages.   The materials are stored on the
   two firetrucks, wagon 30  and brush 30, and in the firehouse
   (building 36) as indicated on  the  following  pages.  Note that the
   materials include spare equipment  so  that in the event  some
   equipment is damaged or consumed during a response, the first
   response unit still has adequate equipment to response  to  other
   incidents until equipment can  be replaced.   In this regard the
   equipment should not be considered the minimum necessary for
   operation but rather the  stock usually maintained to insure
   adequate reserves for multiple incidents  before  replacement
   equipment arrives.
Revision 1, June 30, 1989

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 HUSH 30
Rt. front
Bt. liddle
Air  packs  (2)
Aid  box • contents:
lit.  riar
Oxygen supply

Fire blanket
Atbu * bag
Air splint kit
Kendrick Extrication Device (KED)
Padded board $plints(l long,  2 short)
Shoring
AIC fire extinguisher
30 lin. SCIA

ace bandage 3 in.
ace bandage 4 in.
adhesive pads (10)
adhesive tape 1 in. (1 roll)
adhesive tap* 1/2 in. (1 roll)
adhesive tap* 2 in.
alcohol prep, pads (13)
aMonia inhalants (10)
antiseptic »ipes (10)
anti-bacteria ointeent (8)
band aids (2S)
bandage shears
bite sticks (2)
blood pressure cuff nitti stethoscope
burn sheets (3)
clMp
cling gauze 2 in. (1)
cling gauze 3 in. (2)
cling gauze 4 in. (3)
cling gauze 6 in. (2)
combine dressing 5 x 9 in. (8)
coabine dressing 8 x 7.S in. (4)
cravats (3)
eye pads
eye Hash kit
forceps
gauze pads 2 x 2 in. (12)
gauze pads 3 x 3 in. (6)
gauze pads 4 x 4 in. (22)
ice packs (7)
insta-glucost
iodine ointaent (6)
kerlix roll 2.25 in. (2)
kerlix roll 4.5 in. (2)
latex gloves (1 pair)
•ulti'trauta dressing (2)
oral airnay kit
penny cutters
poisoning kit (act. char. 4/ipecac 1)
rescue blanket
sterile nater
stiffneck c-collar

(2) size E cotprtsstd bottles 2000-2300 psi
650 Liters regulated at 2-15 LPfi.
                                                           20  lb.

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Lt. front
Lt. liddle
Lt. reir
Rear
Cab
Class 0 extinguisher
1C Halon extinguisher
Kneel chock
Handlight ricks (2)
Spinner »rinches (2)
(is can filler neck
1 1/2 nozzle
Irush rake heads (2)
Adapters (S)
Fire line ribbon
lubber boots (2 pair)
Extinguisher scale
Float dock
Hot trash destruction procedure
Haz Bat handbook
C02 extinguishers (2)
Spill control boots
Spill control pi lions
Absorbent
ABC extinguisher
C02 extinguisher
Materjel blanket
Indian tanks (2)
Gas can (for puip)
lack board
Hard suction sleeves (2 sections)
Irush brooi
Haligan tool
Pickhead axe
Irush rakes cotplete (2)
Shovel
Flashlight
Ear plugs
Fire extinguisher labels (class)
Fire extinguisher libels (inspection)
20 Ib.
9 ib.
                                                            establishes a  hot  zone  on  the  fire  ground
NFPA Emergency Response Guidebook
20 Ib.
4 ft. and 10 ft, lengths
1 ft. X 1 ft. and 2 ft. X 2 ft.
SO Ib. big
20 Ib.
20 Ib.

portable S gal. vater tanks nith puip
                                                            forcible  entry  tool
                                                            forcible  entry  tool
NAGOM  30

fit.  loo front  Aid box contents:
                                             •dhesive tap* 1 in.
                                             adhesive tape 2 in.
                                             alcohol prep, pads (IS)
                                             iMonia inhalants (13)
                                             bandage tfiears
                                             bandaids (20)
                                             blood pressure cuff and stethoscope
                                             burn sheets (S)
                                             cling gauze 1 in. (IS)
                                             cling gauze 2 in.
                                             cling gauze 3 in.
                                             cravats (7)
                                             EOA • Esophageal Opturator Airnay
                                             •ye pads (S)
                                             eye lash kit
                                             first aid creae
                                             forceps

-------
               Oxygen  supply
               Air  splints
               Etergency  blanket
Rt. higfi front Closet  hooK
               Haligan tool
               Drynall hook
               Squeegies  (2)
               Squeegy handles  (2)
fit. high rear   Tie  dovn strap
               Rope (2 sections)
Rt. Ion rear   Stoke ejector
               Gas  can
               Funnel
               Fan  hangar
               Salvage covers  (2)
Rt. side       Extention  ladder
               Roof ladder
               Pike poles (2)
               Class 0 extinguisher
               C02  extinguisher
               Spanner trenches  (2)
It. ION front   Air  packs  (2)
               Sprinkler  kit
Lt. high front Adapters (10)
               Discharge  cover
               Foai eductor
               Forcible entry  kit, contents:
Lt. high rear
Lt. rear
feted t
Hydrant irench
lubber tallet
Nozzle (1 1/2)
Stall bolt cutters
Nozzle (2 1/2)
Large bolt cutters
Sledge hmer
Prybar
Generator
                                                            giu:«  pads 2x2  (20)
                                                            gauze  pads 4 x  4  (20)
                                                            ict  packs (3)
                                                            resusi-tube
                                                            sting  relief pads (10)
                                                            tube dressing
                                                            turniquet
                                             forcible  entry  tool
                                             forcible  entry  tool
                                             forcible  entry  tool
                                             fan  ustd  to  eject  stoke  fron  structure
                                             24  ft.
                                             16  ft.
                                             forcible  entry  tool
                                             30  Ib.
                                             20  Ib.

                                             30  tin. SCBA
                                             replacetent  sprinkler  heads  for  building  2S3
                                             hicks* Hith 3 blades
                                             statbelt tool
                                             vire brush
                                             tn
                                             crash axe
                                             rope host tool
                                             pliers
                                             vis* grips
                                             nut drivtr set (7 pitcts)
                                             •rtncn set (i pitcts)
                                             box end urtnch
                                             scrndrivtrs (4)
                                             leak plugs (3 vood, 2 rubber)
                                                            4000 Mtts

-------
 Riar           How  rups  (2)
                Portible 9in«rator
                Cord  reel
                SO feet 2 1/2 in. hose
 It.  side        Hard  suction sleeves (2 sections)
                Foil  line (ISO feet 1 1/2)
                6 in. supply line (10 feet)
                Cited sltuese
 Top             Circle D lights (2)
                Indian tank
                Katerjel blanket
                Deluge gun •/ 4 stack tips
                Shovel
                Aqueous Fill Foning Fou (AFFF)
                Hose  claip
                200 feet of 1 3/4 in. line H/SN30F nozzle(2)
                200 feet of 2 1/2 in. line H/SH30FG nozzle
                1000  feet 3 in. supply line
                Shoring
                Spare bottles for air packs (2)
                10 foot folding attic ladder
 Buckets         Air packs (2)
                Pick  head axe
                Flat  head axe
 Cab             Air pack
                Chief's axe
\               Hand  light
                flashlights (2)
                           2500 *«tts
                           200 ft.
                           (4) 5 gal.  buckets
                           30 tin.  SCIA

                           30 lin.  SCBA
                           forcible entry tool
                           forcible entry tool
                           30 tin.  SCIA
                           forcible entry tool
 BUILDING 136
 SPILL RESPONSE
   STORAGE      Salvage Druis
               Spill Pillois
               Absorbent Boots
EQUIPMENT
          DESCRIPTION/SPECIFICATION

65 gallon - 2 ti.
1 box, 100 count • 4 qt.  capacity  ea.
50 ft.

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   Equiptraent Decontamination

   Procedures for ensuring proper cleaning and fitness of  emergency
   equiptment listed in the contingency plan  include the  following:

    a. Contaminated equiptment used on site is deposited  on  plastic
       before decontamination.

    b. Boots are scrubbed with a detergent/water solution
    contained in a wading pool using a long-handled brush.

    c. Detergent solution is rinsed off with  water contained  in a
       second wading pool using a pressurized water device and a
       long-handled brush.

    d. Tape is removed from around boots and  gloves and deposited in
       an appropriate container.

    e„ Boot covers and then outer gloves are  removed and deposited in
       plastic-lined containers.

    f. The SCBA and face piece are scrubbed and rinsed following the
       procedures in b. and c., removed and deposited on plastic.

    g. The tyvek suits are removed and deposited in a plastic-lined
       container.

    h. The inner gloves are removed and deposited in plastic-lined
       containers.

    i. The SCBA is inspected and filled using a cascade system of
       three cylinders of breathing air.

    j. All contaminated materials including decontamination  items are
       disposed of following routine chemical disposal procedures

    k. The incident comander will insure that all the steps  listed
       above are completed before the first response team  is  placed
       back in service.  Any expended disposable equipment is
       replaced from the inventory at the firehouse before operations
       continue.
Revision 1, June 30,  1989

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 ATTACHMENT II



KEY PERSON LIST

-------
                                                           CT'
PAGE ONE
                                                  SEPTEMBEf
                        VIRGINIA  PROPULSION DIVISION -  KEY PERSON  LIST
LAST NAME/FIRST NAME
ANDERSON, BILL
BAETZ, JAY
BANE, JIM
BEYER, RODNEY
BOWMAN, GARY
BOWMAN, GLENN
BRENN, CARL
BRIEN, BERNIE
BRITTON, STEVE
BRLETIC, ANDREW
BROWN, RANDY
BUTLER, HARRY
CAMERON, PAUL
CAMPOLMI, RICHARD
CARTER, RODNEY
CASEY, JOHN
CEPHAS, KELVIN
CHILDRESS, JOHN
COLVIN, TOM
COHEN, MELISA
CONSTANT, DAVE
COUPE, SUSAN
DIBELL, DAVE
DODD, MARTIN
DOMPKOWSKI, ALEX
DUNFEE, DAN,
ESSICK. MARTIN
FALKENBORG. PHIL
FALLS, ROGER
FIELDS, JERRY
CITY/STATE
MANASSAS, VA
VIENNA, VA
WASHINGTON, VA
DUMFRIES, VA
WARRENTON, VA
ALEXANDRIA, VA
GAINESVILLE, VA
MANASSAS, VA
MANASSAS, VA
WOODBRIDGE, VA
WASHINGTON, DC
FAIRFAX, VA
WARRENTON, VA
MANASSAS, VA
MANASSAS, VA
WARRENTON, VA
NOKESVILLE, VA
HAYMARKET, VA
SPERRYVILLE, VA
ARLINGTON, VA
FAIRFAX, VA
LORTON, VA
VIENNA, VA
CATHARPIN, VA
WARRENTON, VA
FAIRFAX, VA
MANASSAS, VA
MANASSAS, VA
MARSHALL, VA
GREAT  FALLS, VA
A.C. HOME PHONE
(703) 368-6250
(703) 938-0780
(703) 987-8183
(703) 680-1622
(703) 349-9084
(703) 765-3927
(703) 754-9844
(703) 791-5694
(703) 684-8332
(703) 491-2271
(202) 723-4703
(703) 620-2682
(703) 349-9254
(703) 791-5679
(703) 368-5101
(703) 347-3387
(703) 754-8693
(703) 754-7165
(703) 987-8467
(703) 237-4717
(703) 978-7941
(703) 339-6199
(703) 281-0735
(703) 754-7312
(703) 347-0703
(703) 273-2766
(703) 368-5805
(703) 368-8144
(703) 364-1579
(703) 450-5471
LOC./BLDS./RM./En
B/49/  /6072
A/C-Wfng/  /4394
B/300/141/6190
B/234/  /6474
B/233/  /6288
A/CM/  /4484
B/79/  /6115
B/124/  /6131
B/69/  /6424
B/300/275/6558
B/40/  /6102
B/350/129/280
B/150/ 9/6527
B/113/  /6255
B/79T/  /6093
B/71/  /6516
B/40/  /6549
B/40/  /6265
B/122/ 7/6080
B/13/77/6448
B/13/79/6503
A/B-WING/227/4223
B/300/277/6225
B/79T/  /6007
B/13/45/6312
B/300/274/6236
B/13/40/6215
B/69/  /6322
B/97/  /6848
A/C-WING/   /4128
B/300/   /6028

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                                    U; 'v-if. .
                                    ii'-v'L-ri
                                    ^K.IttS
PAGE TWO
LAST NAME/FIRST NAME
F1TZPATRICK,  JACKIE
FOLTS,  AL
FRAZIER, DAVID
GATTO,  ANTHONY
GROVE,  MAYNARD
GROVER, CHERYLE
GRUIA,  SORIN
HART, RON
HARTWELL, JON
HEREFORD, WADE
HOLLEN, GEORGE
HOSTETTLER, STEVE
HUDSON, FRED
HUSS, BOB
JENKINS, PATRICK
JOHNSON, GARY
JONES,  MARY
KARNES, ELBERT
KHADDURI, FARID
KIMBEL, VAL
KIRKLAND, BUD
KNIGHT, WILLIAM
KNOX, DAVE
KOCH, GEORGE
KOZLOSKI, JOE
KREITZ. BILL
LAPOSAY. GEORGE
LARIMER, MERL
LAWRENCE, C.6.
LEFTWICH, JIM
LEWIS,  GARY
LOFDAHL, EUGENE
LUDLOW, TIM
CITY/STATE
DUMFRIES, VA
REMINGTON, VA
SUMMERDUCK, VA
WARRENTON, VA
MANASSAS, VA
MORRISVILLE, VA
VIENNA, VA
REMINGTON, VA
MANASSAS, VA
GAINESVILLE, VA
FREDERICKSBURG, VA
ANNANDALE, VA
MANASSAS, VA
CHANTILLY, VA
VIENNA, VA
MARSHALL, VA
OAKTON, VA
GAINESVILLE, VA
BETHESDA, MD
MANASSAS, VA
NOKESVILLE, VA
LINDEN, VA
GAINESVILLE, VA
HAYMARKET, VA
SPRINGFIELD, VA
OAKTON, VA
WARRENTON, VA
FRONT ROYAL, VA
THE PLAINS, VA
ELKVOOD,  VA
GAINESVILLE, VA
GAINESVILLE, VA
STERLIN6, VA
A.C. HOME PHONE
(703) 670-7971
(703) 439-3694
(703) 439-8194
(703) 347-7818
(703) 369-6381
(703) 439-2842
(703) 971-0444
(703) 439-3848
(703) 791-3001
(703) 754-4273
(703) 898-6428
(703) 698-8797
(703) 791-3127
(703) 378-5273
(703) 281-0283
(703) 364-3652
(703) 281-6483
(703) 347-1296
(301) 656-1185
(703) 361-9200
(703) 754-8006
(703) 635-1565
(703) 754-7937
(703) 754-4038
(703) 451-5505
(703) 938-6248
(703) 349-8728
(703) 636-9651
(703) 253-5684
(703) 399-1439
(703) 754-2482
(703) 347-2475
(703) 437-0272
LOC./BLDG./ROOH/Err.
B/13/11/6066
B/9/  /6084
B/17/  /6085
B/124/  /6130
B/16/  /6585
B/350/  /249
A/G-WING7  74333
B/3507  7229
B/3507  7226
B/151/  76087
A/CM/  /4489
B/300/218/6526
B/13/31/6304
A/G-WING/223G/4478
B/300/297/6252
B/150/ 6/6277
B/300/146/6191
A/CM/  /4476
B/300/251/6200
B/13/71/6226
B/13/13/6065
B/13/38/6114
B/13/78/6328
B/79/  /6336
A/G-WING/  /4479
B/300/  /6490
B/1507  /6149
B/233/  /6283
B/13/82/6462
B/50/  76329
B/49/  76351
B/507  76137
A/6-UING/222G/4461
B/2127  76335

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                                    Cf)Mn*:;\/   r.
                                    ii^Wir V   K
                                    Lit,!/is     f
PAGE THREE
LAST NAME/FIRST NAME
MANGANO. MIKE
HARTIN, JIM
HATTOX, TONY
MCHALE, ED

MEYER, BILL
MILLAR, TOM
MILLER, FRANK
MONROE, MARTY
MORRIS, JOHN
MOYER, KEITH
NOONE, KEVIN
O'CONNOR, ROBERT
O'NEILL, KEVIN
ORTMYER, HARVEY
PETERS, VINCE
POLEND, SAM
PRICE, DAVE
RENFROE, DON
RITENOUR, ELMER
ROBINSON, ED
ROBINSON, RON
ROHRBACK, FRANK
ROVITO, BOB
RUBY,  RONALD
RUSM1SEL. JEFF
SARNESE, JOHN
SAYRE, LUTITIA
SCHRACK, PHIL
SCISCIANI, TONY
SERBU, PAUL
SHACKLEY, ROBERT
CITY/STATE
UNIONVILLE, VA
MANASSAS, VA
VIENNA, VA
ANNANDALE, VA

CENTREVILLE, VA
FAIRFAX, VA
MANASSAS, VA
LORTON, VA
WARRENTON, VA
MANASSAS, VA
DALE CITY, VA
WARRENTON, VA
ALEXANDRIA, VA
CATLETT, VA
HERNDON, VA
HAYMARKET, VA
FAIRFAX, VA
GAINESVILLE, VA
CATLETT, VA
MANASSAS, VA
MANASSAS, VA
MCLEAN, VA
MANASSAS, VA
STRASBURG, VA
FREDERICKSBURG, VA
CENTREVILLE. VA
CATLETT. VA
MANASSAS. VA
DUMFRIES, VA
GAINESVILLE. VA
MANASSAS. VA
A.C. HOME PHONE
(703) 854-6236
(703) 369-2204
(703) 620-6592
(703) 323-1925
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
(703)
830-1666
273-0105
368-9532
339-5925
344-3221
361-4266
670-5548
349-8821
836-5740
788-4785
435-5694
754-7691
378-6216
347-7794
788-4415
368-5563
361-8552
821-6887
368-0990
465-3921
371-5285
266-2751
788-9476
369-5908
680-1662
754-2042
361-6482
LOC./BLDG./ROOH/EXT
B/350/  /325
B/200/01/6033
B300/  /6447
A/C-WING/  /4088
B/200/13/6009
B/13/  /6525
B/13/55/6270
B/40/  /6103
A/CM/  /4461
B/113/12/6017
A/CM/  /4029
A/CM/  /4018
B/13/41/6201
B/350/  /268
B/50/  /6331
B/13/ 2/6473
B/107/  /6146
B/350/  /275
B/300/153/6062
B/17/  /6085
B/8/  /6092
B/50/13/6132
B/300/256/6232
B/122/ 9/6340
B/175/  /6429
B/8/  /6086
A/G-WING/  /4209
B/113/11/6425
B/122/ 8/6109
B/13/12/6349
B/300/235/6165
B/40/7/6117

-------
PAGE FOUR
LAST NAME/FIRST  NAME
SHELTON,  KEITH
SHENTON.  ROB
SHEPHERD, DON
SHULTS. RICHARD
SIDES, JIM
SNYDER, ROGER
SPRECHER, DAVE
STEGER, ED
STOVER, RICHARD
SWIMS, DOUG
TERSHAK.  ROBERT
THIBODEAU,  BOB
THOMPSON, HAROLD
WEATHERFORD, SAM
HEAVER, BARRET
WEEKS, BILL
WHITE,  KEM
WILLIAMS, MARY
win, RUSS
WRIGHT, JIM
YESCAVAGE,  ROBERT
YOUNG,  MICHAEL
                                    tiv
Cm/STATE
WARRENTON, VA
MANASSAS, VA
TRIANGLE, VA
WARRENTON, VA
OAKTON, VA
STRASBURG, VA
WARRENTON, VA
FAIRFAX, VA
WARRENTON, VA
CENTREVILLE, VA
FAIRFAX, VA
DUNN LORING, VA
MANASSAS, VA
FRONT ROYAL, VA
REMINGTON, VA
BRANDY STATION, VA
ALEXANDRIA, VA
BURKE, VA
WARRENTON, VA
FAIRFAX, VA
FAIRFAX  STATION, VA
MANASSAS,  VA
A.C. HOME PHONE
(703) 347-3601
(703) 791-6949
(703) 221-1851
(703) 347-5164
(703) 591-3794
(703) 636-6587
(703) 347-5408
(703) 273-1665
(703) 347-2398
(703) 830-4950
(703) 323-7828
(703) 698-7728
(703) 368-9001
(703) 636-6579
(703) 439-3538
(703) 825-5699
(703) 971-6357
(703) 250-5493
(703) 349-8434
(703) 830-9074
(703) 250-1787
 (703) 335-1110
LOC./BLD6./ROOH/Err.
B/150/  /6004
B/13/29/6287
A/CM/  /4248
B/13/73/6081
A/H-WING/217H/4601
B/13/33/6327
B/150/13/6160
B/48/  /6307
B/13/ 7/6147
B/350/EMP/265
B/49/  /6045
B/300/  /6348
B/150/  /6067
B/13/61/6256
B/113/8/6302/6282
B/49/  /6054
B/l/  /6478
A/CM/  /4095
B/13/ 5/6156
B/7T/  /6292
A/G-WING/  /4530
B/13/81/6411
                                                      HBFE

-------
     ATTACHMENT III



EMERGENCY CONTACTS LIST

-------
                            ATTACHMENT III
OGAM [ IA I I ON/ AGC-MC V                                     EMERGENCY NUMIJER

FJ r i n c e W i 1 1 i a m Cos. .1 n t y  Firs and
 Rescue '.i.e. ambul ,-.!- ce or -firs fighting) ..................... 9-911

Prince William County  Fire Marshall .................... (.703) 369 — 97.00

Pr.; no::- Wi 1 1 i am County  F'ol ice Department  ............... k703) 335-6500

F-'rince William Count1.-  Shsr i -f- f " € Department". ............ (703) 361-5151

Pr: nee William Hospital E;-erq=ncy Department ........... (703) 369-30')0
                                                         (703) 369-9333

Forestry Service, Wild Fire Control .................... (703) 235-9344

Virginia State Police
Prince William County/ Independent Hill ................. (703) 791-3101
Warrenton .............................................. (703) 347-3237
Emergency Only ......................................... 1-800-572-4510

Dr . Barry Lu.pt on , M. D.  Faci 1 i ty ....................... (703) 253-5
-------
 rational  Response Center  	

                                                                        (202) 267-2675

 r . .-  -,.-.-: •-,•;-• ,  ,"-.,; n r; r >	       .    	' .."'.'2 .'  426 — 4'!" '0
—!: _ •!." c; L •'_< 5  i.'a-itf-  bur c--.-. LI	     	     	(2'.'2.1  ~2ti--2l '""5
             h F-Spori^G?	' .J'.'_.'  H_ij -M^iij

Cheiritrec	1-B'i'0-424-9 30'j

Bureau  of  Mines,  U.S.  Fumes  trcm  £;; p 1 osi •. c?s	(4112)  675-6415

B u r;? a i.1.  of  A1 c o h c i ,   T o fc a c c o  a n d  Firearms
Lost, btoler,  Explosive-	1-800-424-^555
E.- pi ciri -.'f=  Inci dsnt	< 202)  566-7135

Or-.  Richard  I.  Ch _-,i-ber 1 i n  ( &*3rvl 1 i urn  Hyg 3. ene/ba-f et y
Cc.nsui tant;	(617)  253-5360
                                                                        (o!7)  253-1741

-------
 APPENDIX M



BURN PIT LOGS

-------
                                                                 OU
                                             BURN PIT LOG
TIME  OUT     TIME  IN
                                     AMOUNT  (Iba
                                                              OF MATFRTATS







                                                        CQCj I n

-------
                               i t\ u i i-, LS LI / v
                                       BURN PIT LOG
DATE
        TIME OUT
       0130
TIME IN
PIT NO.
                                  AMOUNT  (Ibs)
                                               TYPE OF MATERIALS
                                                                   NAME
 -A7
                                              /A/- 7^/
                            f-/o j- 7/xs ^
fa (ft

                                             *J)-

          -?
                             0
1-2
   o
           0
                                               (_
                                        /-*•
-------
                               fRCrPTTLLANT  M A K-~- *'A U T OTTTN G "CTTO U P







                                        BURN PIT LOG
 TIME OUT
TIME IN
PIT NO.
AMOUNT (Ibs)
TYPE OF MATERIALS
                                                                            NAME
               3S
                                   jl.ttr.
                                               Un.jh r
                                                                               / /L f J
           JAOO_

  r- 7- p
            7J;jA.
             JL
                           r.
                                                                                 JtL
                                                                           /^_L
    z

                                                                     /
                                                                        Iv^W^j/
0800
            / / . 5
                                                          ^2_

-------
                                        y
                                    BURN PIT LOG
DATE
        TIME OUT
TIME IN
                         PIT NO.
AMOUNT (Iba)
                                           TYPE OF MATERIALS
                                                               NAME
                       /-r
fa&
       osoo

                        I 2
                        11 *~j
                        >jiL
                                              /V/f
                                                             7  -
       MOO
W/y
                                1000
                  yc
                                1600
                               /oo
                                                  c
                 /DO
                                                               -x
                                                              /

-------
                                             BURN PIT LOG
DATE
         TIME OUT
                    TIME IN
            PIT NO.
AMOUNT  (lh«)
TYPE OF MATERIALS
                                                                              NAME
   ±
>-2 7.9ft
  '  f
^
                                                                          QA
                                                                           1?
                                                     Ai^_
/3/Z'l
           JO

                                                                           a
        /? -'
                      X
       ll

                                                               5 K
5////gL
                                                                               -e
                                        1
                                 3
                                                                         -C^liJ^J

-------
                                   ELLANT MA ' VACTURING GROUP
                                       BURN PIT LOG
DATE
TIME OUT
TIME IN
                           PIT NO.
AMOUNT (Ibs)
                                       TYPE OF MATERIALS
                                                                    NAME
/
 Q/ff ?
        fs-
M00/AS
                                                                      er

                                                f. -Vlt> r
                                                                tjrr-.A ~t / /? v.fh
                                               £L
W.
       O
                                              AP-
                                  IS 'oo
                         /

-------
                                   *pna**n.^A
                                            BURN  PIT LOG
(DATE
         TIME OUT
TIME IN
PIT NO,
AMOUNT  (lb«;>
TYPE OF MATERIALS
NAME
                                                                         Ji
                                                       m
  '/ 'ff?

                                                                              ^^j^Lzlzli^.
                                                                          £
'hf/t?
                                                    ^i3-^Juzk_L
                   !±L
                          <
                                         Mat*'.,
                                           ^44±v^C/
                                        J
                                                              /Us)
                                         A//A
                                                               HQ~LI^
                    //
                        tf,
                                                                                —
                                                                   ;

-------
                           PROPELLANT MAI ^ACTURING GROUP
                                  BURN PIT LOG
DATE
TIME OUT
TIME IN
PIT NO.
AMOUNT (Ibs)
TYPE OF MATERIALS
                                                           NAME
                              £00
                              30.0^
                                           y**
  •JSSL
                        i
                                  d.
                                            ^^1^^
                              /ZTbO
                                 A.p
                                            30
                              / we
                                                                      TL
fat
      T7^
                                 AP
                S"
                      L
                                                                -r
'Ml
       «,3o
v-
    (

                                       ffis:
                                                                    L r A./ i
                                                Ri ,  ^7
                                                ^^^Ms^uA


-------
                 PTTOP'ELLATT
                                                               GROUP
                                               BURN PIT LOG
DATE
          TIME OUT
1 J ni_
PIT NO.
AMOUNT (Ibs)
                                   TYPE OF MATERIALS
                                                                                   NAME
                                                                                                 "7
                                                                                                  V
 '•4
                    JJ,
                                            ~J

?
                                                                                V if! |
                                                                                       7
                                                                                                  76

                                                                                         /ft>/>>"
g/ffa
                               ,7
         I
                                                                               \,  / /*••
                                                                vr
                                                             ••- r/ / .
-------
                                 LLLAN i MAM' >"ALiUKiNL, UKUUf
                                        "
                                     BURN PIT LOG
 DATE
       TIME OUT
TIME IN
PIT NO.
AMOUNT (Ibs)
TYPE OF MATERIALS
NAME
4&a
      -C7
               101(90
       1:20
                                           Jtot

Mi
    M
LLL
il/'i?/^
                6^00
                                           C
                                 i}/
                                                                       
-------
                                        f i^^^^S. L. L-
                                                              f* oFo u «
                                                 BURN PIT  LOG
DATE
TIME OUT
TIME IN
PIT NO.
AMOUNT (Iba)
TYPE OF MATERIALS
                                                                                      NAME
                                                                                    n^H- /Af\~
r
             H'30

-------

                                  PROPELLANT MAN'1J AC i U K iNb
                                       "AA
                                           BURN PIT LOG
        TIME OUT
            TIME  IN
            PIT NO.
AMOUNT  (Iba)
TYPE  OF MATERIALS
    NAME
                                    l-7fg?
                 Mio
                                                    fC>,.'~.:~\
                                                        ^^
'tfjfff
T30
i no
          err* I
Tenn trhh) frran\er
                 /I •  .7
                  t:/o
                  1.60
                            ,z, 5
                 iroo
                                                                Tenntijl n~s-n*tr'
                                                                       O2n

-------
       o
                                   PROPELLANT MAN.-' KACTUKJ.MU  UKuur
                                            BURN PIT LOG
       TIME OUT
 TIME IN
                             PIT NO.
AMOUNT (Ibs)
TYPE OF  MATERIALS
                                                                              NAME
     f0~*?
                                   /*'rs

 f
•y/fl)
       ft 10
MM
                                                   M)f l/«s/t

                            L^
                                                                              -
Wft
                   12:30
                  £
          c.
                  HIM.

-------
                    APPENDIX N

SATELLITE STORAGE AREA INSPECTION REPORT FOR MAY 17,
                       1989

-------
                            INSPECTOR
   WEEKLY  SATELLITE STORAGE AREA (SSA)  INSPECTION  REPORT
                    (CHECK IF OKAY)

     LIDS/BUNG   LABELLED   GROUNDED IF   CONTAINER  IN
  f   SECURE      CORRECTLY   NECESSARY   GOOD CONDITION
5
	 	 10
2 R


-------
          APPENDIX O



RCRA PART A PERMIT APPLICATIONS

-------
U. POLLUTANT CHARACTUISTICS
                               VAD023741705

                               ATLANTIC RESEARCH CORPORATION

                               7511 Wellington Road
                               Gainesville,  Virginia   22065


                               7511 Wellington Road
                               Gainesville,  Virginia   22065
                                                                                Form Affpnvfd QMS Ho. 159-RQ17*
                                                                                  V A  D 02374170S
             rtwd dna h *mvn /*• VW '
             •M) fcft*/ MM Out tn» IrrfoiT
                     7. PMM prwfcM) It to
             f»-tn OTM/«> Mo*. If tr* Hfc
               •nd corrvct. you nMd not eon
               HI, V. mj VI  rimer VW «
               eomp/MM/ .mgiiitWi Comptn
             no WM< HH bMn proytdKLjgrt
                                                                                tioiv nd tar tM l«gM
                                                                                    iMi dn> b oofl«ctMl
                     rX jfroufh ] to datannina Htwtharyw naod to ufanit any pomft applkatioa form to tho EPA, If you wwmr *yoi* to m
                     Ihii form and ttw aupplomonal farm Ihtad te tte poranthccii fnflowin, ttio quarton. Mari^-m tho box In ttx third coDnff
                                      "oo^tdHeti quwdoo. yon o«d not wtait any of that form You may vw«r "BO" If your icfivtt
                            m Socdon C of ttao inriniction. SM aba, Sactton 0 of tbo imtructiom for dafWtiom of »oM 1m»i Bmn.
«Kfltty«jrflMr«dH*if
           tadbM <
       tedDty NhkA rwulti
 of *• UX7 (FORM 28)
                                                          B, DOM or MB
                                                                                         by VM Pravctv
                                                                                        Wniltu
                                                                                 pbvmMtyf CMT
   FAaUTY CONTACT
                        COUNTY NAM*
EPA Form 3810-1 l«-«0)
                      CONTINUE ON REVtRS

-------
r idid ^r:n; ^,  . f p^ in :na uni.'ddfra areaj oniv
(fill—in trtti ire sp»Cfd tor f/ire rvaa < a., 12 criartcrtrs/incfil
                                                                                            Form Approved OMB No. tS9-S3t
 FORM
 RCRA
   3    xvEPA
                                     U.S. ENVIRONMENTAL PROTECTION AGENCY

                               HAZARDOUS WASTE PERMIT APPLICATION
                                             Consotntited Permits Progrtm
                                 (Thit information it required unditr Section 3005 of RCRA. >
                                                                                            I. EPA l.D. NUMBER
FOR OFFICIAL USE ONLY
 VPPLIC ATVOH
               DATE RECEIVED
                                                                             COMMENTS
II. FIRST OR REVISED APPLICATION
Place an "X" in the appropriate oox in A or B Delow Imtrk onrbox only) to indicate whether this i»-the first application you are submitting lor your fac
revis«d application. If thu is your first application and you already know your facility's EPA l.D. Numoer. or if this is • revised application, enter your t
EPA l.D. Number in Item I above.                                             --                                                   8
A. FIRST APPLICATION iplae* an  X" btlow and grouidf tin appropriate daU>

     [~~Xl • EXISTING FACILITY (See initructioni for definition of "eittlinf" facility.
     ^jp _                      Complete item 5*/oui.j-             __
      53
                    0 1
                          FOR EXITING. FACILITIES. PROVIDE THE oATC-lyr, mo.. A day;
                          OPERATION BEGAN OR THE DATE CONSTRUCTION COMMENCED-
                          ui« tit botet to tht !«/(/
                                     "X" below and complete /Mm / about!
                           2.NEW FACILITY (Complete item be

                                 ~_X          FOR NEW FAT
                                              PROVIDE THg
                                              (yr.. mo., 4 djl
                                              T1ON BEG AMI
                                              EXPECTED TO
                                 23.- '
B.' REVISE'S APPLICAT

    Q] I. FACI4.IT-* H-AS
                          N
                                                                                            |  ; t- FACIblTY HAS A RCRA PERMI1
 III. PROCESSES r-CODES AND DfSIGN.CAPAClTIES
A. PROCESS COOS.*-Enter tfie code from the hit of process-codec below that best describes each process to be usedat theeJaciliry.  Ten lines are provic
   entering code*. If more lines ore needed, enter the codeW in the space provided. If a proses*, will be used that is not included in the list of codes belt
   describe; tne process Lincluoing ia.ct«nyn ctgucity^ in tne space prqvided oatrmnrm (Ittm lll-€t.     '-             3                     J
                                                                                                     J                     1

B. PROCESS D€SKH« CAPACITY - fat sjch code entered In column A emar the capacity of the proom. -           -1
   1.  AMOUNT - Enter the amount.1*   *                                                                 •?*
   2.  UNIT OP MEASURE - For aeon-amount entered in column 8(1), emar the code frorivme list of gnit measure codertjeiow that describes the unit
      measwre used. OrMv tne-uort» o* mBeture that are listed berfov* shotrid be used. ~"        ~~  _....-—-         ^                      >

        ""'                   PRO-    APPROPRIATE UNITS OF        "-   \           £       r'   PRO>   APPROPRIATE UNITS
      " ".'  '-'-                CESS*   MEASURE FOR PROCESS      ""               *              CESi   MEASURE FOR PROC
                                         DESIGN CAPACITY         	    PHQCg^'	    fiflfff	DESIGN CAPACIT'



                                                                                                   Tfff  GALLONS PEN DAY Ol
                                                                                                     —'  LITERS PEN DAY
                                                                                                   TO*  GALLONS PER DAY Ol
                                                                                                    " .  LITERS PER OAV
                                                                                                   T«  TONS PER HOUR OR  ,
                                                                                                  --'*  METRIC TONS PER HO
                                                                                                      9  GALLONS PER HOUR <
                                                                                                     _3  LITERS PER HOUR

                                                                                                   TO4  GALLONS PER DAY Ol
                                                                                                    ' 4  LITERS PER DAY
  Storage:  ._- i
  CONTAIME-*) roan**, drum,
  TANK   = -.;
  WASTE
  •URFACK IMPOUNDMENT
                              _      OAtLONl OK LITEN*-
                              SO a.; GALLON* On UlTEMtV
                              SOT*- CUBIC YARD* OK
                                   - cuaac METERS-
                              l«4 '' aALLOMB ON UTEW*

                                   -""
                                                                            ! IMPOUNDMENT

                                                                    INCINE«ATO«  _;
  INJECTION WELL.
  LANDFILL
  LAND APPLICATION;
  OCEAN DISPOSAL
  •UNPACK IMPOUNDMENT
                                    GALLONS OH
                               oe* J ACRE-FEET (tht oelumt
                                    would eoutr one otjri to a
                                   • dtplrt of 'one footf OXf-
                                  ~  HECTARE-M«TEW
                               OBI 1 ACRES On MECTAHEA.
                               oer :OALLON« r*w OAV ON
                                    LITER* PEN OAV
                               Otl  ttALLONSl ON WEItt)
OTHER ee« protliUd; Jttm 111-C.r
UNIT OF
MEASURE
UNIT OF MEASURE COM
•AULON
ITERS
CUBIC V
* CUBIC M
GALLON
EXAMPLf
other can h
r





	 	 	 L.
AR
ET
• P
•0
old
"••>
9S 	 ' 	 V7
IRS 	 „ 	 e "
EN OAV 	 ...U
1
R COMPUTING ITEM III Uio*n
400 gallons. Th« fsaMty also hea •
i - : " •- _, lit
-"DUP L"

K
• W
ii
-IZ
X-l
X-2



3
4
A. PRO-
CESS
CODE
(from liit
• OOM>
14 - II
s
T
T



0
0
0



2
3
4



i • - it
•. PMOCCSS DESIGN
' ^
/-'•,- y.'- .-t ,•- 1. AMOUNT , -.
• £ . • t**1**
•
600
d
l

*tffir»r
-•.-— li. .' ..-?iV. UNIT OF --'•'3' 	 Ul
* ' MEASURE '"-•. 	 ME
UNIT OF MEASURE • COOS UNITOFJMEASURE (
UTKP
TONS
MBTR
AALL
I.ITVP
Mima*

IS PVR OAV
PEN HOUN
1C TONS PCI
ONS-PEN NO
tSPKN HOUI
nX~1 tntlX-
hat can bunt
-,,T--..- 	 ..W ACME>P^kT. . .

« M
UM
* .
2t>
*i
out*




•/ow/.- A faeUity has two none* tanks, one tank can hold 200 gallon* i
o 20 gallons par hour. : • . • s, 'i*,
v\\\\\\-\\x
CAPACITY
--•T*



«

20
0.9Z



I* - IT
t. UNIT
Or MBA-
SURE
(tntir
eodt)


^:



Oi.
G
E
D



ii






POR
OFFICIAL
: USE
ONLY
•i * "














(





t



U • 11
LINE
NUMBER

5
6
7
8
9
10

A. PR
CCaV
COO
(from
• •04M
cv
•
c
Itt
t
11 • '•



















\ \ \ A X • 'S \ \ \
V\\\\\\\\X
Y\Y
m. FROCKS* DESIGN CAPACITY
• - L l. AMOUNT:. . ; '.[-•• • - •.
,~~ z~ ' • ' f '
II - IT


I -

e>
^

a. UNIT
OP MEA-
SURE
(tntfr
cod*)







1L.












01
a.





tt
 EPA Pom 3810-3 («-«OI
                                                            PAGE  1 OF S
                                                                                                               CONTINUE ON

-------
          *T«m <*«
 ffl. PROCESSES (continued)
 C. SPACE FOR ADDITIONAL PROCESS COOES OR FOR DESCRIBING OTHER PROCESSES Icodt "T04">.  FOR EACH PROCESS ENTERED MERE
            T04;   Open  pit  thermal  treatment of  waste  explosives
j IV.  DESCRJPTION OF "AZARDOUS WASTES	^	
jA""A HAZARDOUS WASTE NUMBER - Enter the four—digit numuer rrom 40 CFR, Suooan 0 lor eacn iisteo nazardoui waste you will nandlB. If you
i      idle hazardous wMtai which ar» not lined in 40 CFR, Subpart D, enter the four—digit number^ from 40 CFR, Subpart C that describe* the charactans-
|   nc* and/or the toxic contaminant! of thot* hazardous wanes.

I 3. ESTIMATED ANNUAL QUANTITY — For each lifted «eata entered in column A ettimate the quantity of that wane that will be handled on an annual
   ba»u. For eech character tie or toxic contaminant entered in column A estimate the total annual quantity of all ttve non—lined wanefW thet will be handled
.   which possess that characteristic or contaminant.
!
 C. UNIT OF MEASURE - For eech quantity entered in column  8 enter the unit of measure code. Units of measure which mun be used and the appropriate
'   codes are:
               ENGLISH UNIT OP MEASURE
                                                           CODE
                                                                             METRIC UNIT OP MEASURE
               FOUNDS.
               TONS. . .
KILOGRAMS

METRIC TONS
    If facility records use any other unit of measure for quantity, the units of measure mun be convened into one of the required units of measure taking into
:    account the appropriate density or specific gravity of the wane.
i
< 0. PROCESSES
;    t. PROCESS COOES:
)      for lifted hazardous WKSS:  For each listed hazardous waste entered in column A select the codefa/ from the I In of process codes contained In Item III
'•      to indicate how the wasu wt.i be stored, treated, and/or disposed of at the facility.
I      For non-Jiatad hazardous weatac  For each characteristic or toxic contaminant entered in column A, select the code/«j from the I in of process codes
:    „  contained in Item III to indicate all the processes that will be used to store, treat, and/or dispose of all the  non—Jined hazardous wastes that possess
•      that charecterinic or toxic contaminant.
i      Note:  Four spaces are provided tar entering prureas codes. If more are needed: (1) Enter the firn three as described above; (2) Enter "000" In the
j      extreme right box of Item IV-O(I): and (3) Enter In the space provided on page 4. the line number and the additional codefoA      • .  „ _
    Z PROCESS DESCRIPTION:  rf e code Is not lerted for a process thet will be used.
       the process In the
provided on the form.
NOT!
more
I.
•>
Z
a.
EXAA
pery«
art co
[JPO »
«
!d
\ JZ
:X-1
i " •
;x-s
iX4
: HAZARfX
then one EPA
Select one o
quantity of t
In column A
•included wi
Repeat nap
»LE roR o
Mr of chrome
erosive only i
oundi per yea
A. CPA
HAZARD.
rVASTENO
Center codtl
K
D
D
D
0
0
0
0
5
0
0
0
4
2
1
2
XI* WASTES DESCRIBED BY MOV
Hazardous Wast* Number (Ml be del
f the EPA Hazardous Waste Numbers
he waste and deecribinfl ail *• proceei
of the next Una entar the other EP>
th above and make) no other entries i
2 for each other EPA Hazardous Watu
OMPtETtNO TOM IV (**** In Hm
shavings from leather tanning and fi
md there will be an estimated 200 pt
r of that wene. Treatment will be in a
•. CSTIMATCD ANNUAL
QUANTITY OF WASTE
900
400
100
»
II THAN ONI EPA HAZARDOUS \
Bribed on the form aa follower .^.
encfantar rt In column^. On the semi
•a to be used to treat, store, and/or di
k Hazardous Waste Number that can
m that Una.
i Number that can be used to daeenbe
r /Nirnaar* X- 1. X-2. X-3. and X-4 AeVc
itiahing operation. In addition, the fee
tunOB par year of each wane. The ot
n Incinerator and dispose) will be in a
C.UN
Of Ml
•UH
rente
eod*




P
P
P

IT
I
T
>




WASTf NUMBER - Hazardous wanee that can be described by~.
Una complete columns B.C. and 0 by animating the total annual
epcea of the wane.
be used to describe tha wane. In column 0(2) on that line enter
wtt nCZVvOUl WeHtij* . - " "".T " ' ^~ ^ ,
twl- A facility will treat and dispose of an enlmetad 900 pounds
llty will treat and dispose of three non— lined wanes. Two wastes
her wane Is coirosive and ignitabte and there will be an eiumated
landfill.
D. PROCESSES
1. PNOCISS) COOCS
f«nr«r;
1 1
T 0 3
T 0 3
T 0 3
i i -
'i i
D &Q
i i
D 8 0
D 8 0
1 T 1
1 1
i i
i i
1 T
1 1
i i
i i
7 I"
t. PMOCEM OBSCRIPTION
(It a eo4« If not entered In Dtl »
,
, \
9
r included with above
 fA Form 3510-3 (S-WI
                                                               PAGE 2 OF 9
                                           CONTINUE ON PAGE 3

-------
Continued from o*g* 2.
/VOTT: Pfiortxocy tfi/i p*9§ beforr como/tting if you htn mart tfttn X wntn to I/it
Form Approved OMB No. 158-S80O
     CPA i.o. NUMBCft Center from pat* 1)
    . DESCRIPTION OF HAZARDOUS WASTES (connnuedl
» •
?0
_lZ
1
2
3
4
5
6
7

9
10
11
.2
13
14
IS

17
18
49
20
21
22
23
~>4
i
-
26
A. EPA
HAZARD.
rVASTENO
(enter eo
D

























n

























n

























1

























11 • ti
B. ESTIMATED ANNUAL
QUANTITY Or WASTE
59.25

























IT • 11
C. UN
or MC
sun
(inte
cod*



























-U-
T
























~"
T
E
r


























0. PROCESSES

1 ]
T 0 4
1 1




1 1
1 >
1 I





*" ( r
i f
i i
i i
i i

i i
i i
i i

1 i


i. pnoccss COOES
(inter)
1 '



1 i




I i


i i

i i
1 i
i I
i i
1 1
1 I
I 1
I I
1 i
4
•-* — ^
\ I
I 1


1 1












1 1

1 1
) 1
1 1
1 1
I 1
1 1

1 1
i i
















1 1


1 I
I 1
1 |
1 1
I 1
1 1
i r



I. PMOCCSS DESCRIPTION
(if a cod» « not entfrd in DID)

















"








1
  EPA Form 351W (6-M)
                                                      PAGE S	OFS
                                         "A", "t". "C". tie. 6«Mn4 th» "3" to Identify p*o

-------
 Contimj«nt*r from pott 1)
 V. FACILITY DRAWING
j  All pitting f»ciliti«« must include in the space provided on page 5 » tcale drawing of iht facility ta» instruction* for mart demit.
I  VI. PHOTOC^APHS"^JJ|^JJ|jj^^^^^JJJgBJJB|JJ^MpgJ|^^JP|aB^MM

I  All existing facilities must include photographs (aerial or ground—level) that clearly delineate all existing structures; existing storage,
  treatment and disposal areas; and sites of future storage, treatment or disposal areas (see instructions for more detail).
  
                                                                                LONGITUDE toffrtt*. mlnutti, 4 tteondt)
                        3 8   4  7   »  3  D
                                                                                      07735
  VIII. FACILITY OWNER
   K] A. If the facility owner is alto the facility operator as listed in Section VIII on. Form 1, "General Information", place an "X" in the box to ttit Itft and
        ikip to Section IX below.    '"-. '-~ _"-._    ••     - "-•                        •   -','-'(,',' '•"   "•      '  " "-."    '"    -' .;   •   l
-------
      Guided Missiles  and Space
Vehicle  Propulsion Units & Parts
       Research and Development
       Laboratories
                                                       r i  i
                                                      3.4. 80
(iptdfyj  Ordnance  and Acessories  Exes
 Vehicles and Guided Missiles
                                                                     Manufacturing, Explosives
   OMUATOB
                                R  C  H.  . C. 0. R. P. 0, R. A. T. I. 0  N
                                      Itrtrr Into tit* »nf**r tout; tf"O+>fr", &tetfy.)
                   PUBLIC CotHtr fftat ftdtr*
                  vss&im&$'i
 5390   CHEROKEE   AVENUE
                         ^                              «» «*  |<*  -^-'-
X. 'X JSTINO tNVIRONMINTAI. PCKMITS
    A. MPOKS [DlM.I>miu to furfun ffttr) •. />'°r • •-«. no t<*-£mioio»u from Propottd Sauna)
     pie (Vndtrpotaid A/Hcrtow ofFMfHt)
                                                 to at hMt OM mlh
        Manufacturing,  research, development and  testing of  solid rocket propellant
        rocket motors.


                ITL« /typt or print)
    unes R. Sides
    j.ce President and General Manager
COMMCMT» TOM Off tUAL UM ONUY

-------
 v. FACILITY DRAWING nee oat?
          SEE ATTACHMENT
EPA Fom 3510-3 (S-aOt
                                              PAGE 5 OF 5

-------
1
j
•T
         •m

-------

-------
                                                                                                             I.
  =OKM
   3    V-/EPA
                                                                              I. EFA I.D. NUMBER
                               U.t ENVIRONMENTAL PROTECTION AGENCY
                           HAZARDOUS WASTE PERMIT-APPLICATION
 FOR OFFICIAL USE OMY
                      wto
   FIRST OR REVISED APPLICATION
              looroorxu ooi in A w 6 b*io«r Imirt on* oar only I to ino>e*t* lOxtrxi inn it m* firtr (opiicstion you *n uomntinf tor you' IKIIHV
               K inn « your fim (ooiiatiofl (no you (irwav know rour fsciiiry'i EPA I.O. NumdBf, or rf tna * • nruBBfl BPOJieition, *nt*r your rtcmi
 EPA 1.0 Numo«r m Htm
 A. flRST APPLICATION rpun
    IT i EX ICTINC FACILITY
                                             UW »*pro»n«t«
                 oil
                         Coflfflftt tttm tfflow.J

                      FOK EXISTING PACILITIE*. PKOVIDE THE DATE IT . me..
                      OPERATION BECAN OK THE DATE CONSTRUCTION COMMENCED
                      IUM IKt t^IH 10 Of lilt}
                                                                                l.MCW r»ClL.ITY
                                                                                               FO" NBW FACILITim
                                                                                               ••OVIOC THI OATll
                                                                                               (*f-. mo 4 Uy open
                                                                                               T1ON >CGAN OO l« 1
                                                                                               t«»tCT«0 TO (ISll
 I. HtVltCfi APPLICATION intft v< "X" toiaw tnacomntli lirm I
    X 1. FACILITY HA( IMTCHIH «TATU«
                                                                                . 'ACH.ITT HAf A MCHA PCMMIT
 Til. PROCESSES - CODES AND DESIGN CAPACITIES
A_ PROCESS CODE - Ennr mt coot trom tn* lin of oraem codn btto
  rnttnn« cod«.  It mor* linM art i-*«O«a, tnnr tt>* eodt/I/ in tn*
  dneriM tn* proota I including iu Omipi etpfciiyl m m* a>*c* pi
                                                    th*t bm iJ»ii i ih» MCT>
                                                    rotnOtd. K I
                                                  3*r«0 in column BUI. smsr ttw .
     m**Burt UHQ. Only rnt unm o< mBBsur* tn*t *r* iat*d owow inouM b* uBBd
                         PRO-  APPROPRIATE UNITS OF
                         CESS  MEASURE FOR PROCESS
         PROCESS         CODE     DESIGN CAPACITY
                                                                o«th*

                                                             from thB list of unit
                                                                                      below rn*i dxenbM tn* unit o<
                                                                                   f»RO-
                                                                                   CESS
                                                                                          APPROPRIATE UN ITS OF
                                                                                          MEASURE FOR PROCESS
                                                                                            DESIGN CAPACITY
  CONTAIMC*
  TANK
  WAiTC PIUC

  »U«FACeIMPOUNDMENT
  INJECTION WIL.U
  U.AHOFIUU
  LAND APPLICATION
  OCEAN DKPOtAL

          IMPOUNDMENT
  UNIT OF MEASURE
                          (*1  GALLONS OR LITERS
                          • 01  GALLON* OK LITERS
                          •*1  CUBIC YARDS OR
                              CUBIC METERS
                          ••*  GALLONS OR LITERS
                          O7*  OALUON* OK LITCIt*
                          D**  ACHE-FECT Ithl rotumt «*•(
                              •toti'd eonvr wu «enr to «
                              4*ptt> a/ on*  HOUR	
                                        METRIC TON» PCM HOUR.
                                        GALLON* PCR MOUK . .  .
                                        LITEK* PEK HOUR	
                       MCCTARC4MCTCK.
                       ACKEI	
                       MKCTARCm	
 EXAMPLE FOR COMPLETING ITEM III Mown M lint numOfn X-1 tn4X-2titlowl: A f*olrtv ho two Rortg* ania. an* t»nk DVI hold 200 aillora *nd tn.
 otn*r un noia «OO aiiiont. Tn* t«ej|iry itto no *n iimnBHim mat o»n bum uo to 20 aiilon* par hour.
              DUP
                                   \\\\\\\\\\\\\\\\
    A.PRO-
    ccas
    CODE
    Ifrom list
               B PROCESS DESIGN CAPACITY
1. AMOUNT
                                        I. UNIT
                                       OP MSA
                                        suns
                                                 re*
                                              OFFICIAL
                                                 USE
                                                ONLY
  w
i!
JZ
A. PRO-
 CESS
 CODE
(from titt
                                                                         . PROCESS DESIGN CAPACITY
                                                         I. AMOUNT
t. UNIT
OP Ml*'
 • UKE
  FOK
OFFICIA1
  USE
  ONLY
X-1
   510  2
                     600
x-:
                      20
                        .97
                                                         10
EPA Form 3510-3 It-W)
                                                       11-37
                                                                                             CONTINUE ON REVERSE]

                                                                                       « APPENDIX 11.1

-------
         T04;    Open  Thermal  Treatment  of  Waste  Explosive
   /.DESCRIPTION OF HAZARDOUS * A.STE5
    EPA HAZARDOUS M/AFTE NUMBER — fcnttr ttw tour—41911 numb»7 trorn *C Cf R, SuOoan 0 'or aten imao ntzardouf want you will rttnaii. i< vovT
    htndK ntztrdoui wtnti wrticri tn not land in 40 CFR. Subean 0. tntar ttw four-diaft numbarOI tram 40 Cf R, turajan C Bwl rtatrrlpai trw crwracwr*-
    tics tnd/or trw tome conumintna of thoM nuaraout wants.
 I. ESTIMATED ANNUAL QUANTITY - For «en I
   Mot. For tccn ttaitHMam. or mxic terrtamirw
   wnicri poawti thtt ctonenriruc or eonamirwnt.

 C UNIT OF MEASURE - For OK* Quantity tnairad if) eo4umn • tnt»r trw unit of nwatun I
        irt:                                                       "
                                 ••• «nt*r«d in eotumn A mui\mm O» ou»rrtrtv e< Owt wvn (not ivtll
                                 I in column A •timm ttw taai trmucl cimrnny of Ml v» nor im»a M
                                                                                Unra of m«Mur( wMeh muft 6* >
                                                                                                            hmdtad on *n «n«u*l
                                                                                                            W tnct will b* iwn«««
                                                                                                             Imd ttvi
              CMftl ISM UNIT QF
                                                                        METHIC UNIT Of Ut»« IBt
              POUMOI.
              TDM*.   .
                                                                          CTHIC TOM*.
                                                                                                               . K
                                                                                                               . M
It facility ncordi UN my ottwr unit ot manun for quantity, ttw unro of mtaaun mujt b>
account tn* toproprittt otntitv or aaacrfic oravrty at ttw wan*.
                                                                                       Into on* of ttw raoutnM unro of rrwnuni aking into
 0. PROCESSES
   1. PROCESS CODES:
      For linad  nacaroam wan:  For tacfi lirad haz^Oowi want tmtrad in column A aiwet trw codtW from nw lift of procaai oocwi eemtinad In mm III
      to indicrt* now mt nant will cw nond, mantd, tnd/or dooottd ot it trw facility.
      For non-4irad rtutraows wanat:  For neh cntracvrmic or tonic contaminant tmarad in column A, •ltd ttw eodafr> from trw lift of
      conttintd  in Inm III  to mdient all ttw orocaawi tnm will bt utae B Ron, mm. tnd/or Oc.-x-- 9f til trw non load rujxareou*
      trtit entracttnnc or toxic contaminant,
      Notr  Four naca* tn oroytoad for tnttrinf proeaai cooai. If mon tn nttdad: (1) Emar trw firn tnnt • eaaartbad aBova; Q) Emar ~000" in ttw
      tirrtmt rifnt oo> of Inm IV-OI1); tno (31 Emar m trw «act prowiotd on pag* 4, ttw lirw numear tnd ttw additional eoo»(tl.

   2. PROCESS DESCRIPTION. If t coda it not linad for t proeaa ttwt will bt uaM, daaerica ttw proeaa in trw aja
 NOTE:  HAZARDOUS (rVACTES OEKRIMD VT MOKE THAN ONE IPA HAZAHOOUS WATTE NUMBER - lwl»Hi.« <
 mori tn*n on* EPA Htnraoui rV«ft» Numovr «n*ll b* dMcrtood on ttw form • fMlowl:
   1  Select on* of ttw EPA H«araotu W«t* NumMrt «rx) (rar It in column A. On trw mm* lirw cam&ra column* I.C, (nd 0 by •Rfmatinf trw tool tnnuil
      ouintitv of trw wvu *nd OMcribirtt (II tn« erammmi to b* uxd to tmt, nort. tnd/or dneow of trw w«n.
   2.  In column A ot mt rwjn lirw inur trw ottwr EPA hujuraowt 
-------
HO Tt tnarocaov fin a**» »n^x» carno
CFA l.C. ««•••€• <«"«rr /Vo«« M|
WJV A
D
C

274170
• tr«f rf rou An* mar* vi«r
r* J
b
^


1
IV DESCRIPTION OF HAZARDOUS WAS
w
Jo
1
A. EPA
M AI A*D
»A(TC NO
• cmwATCD
QUANTITY O»
h \

w
TES /continue
ANNUAL
a oi 013; 101
2 i F1 0! 0 2 !
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
^0
p|n
u





















2















0
n
l
















!








5
31
3













































T 	 : 	 —
C UNIT
or XIA-
















T
































» » IMIIM m /«rt ^o«w **0'^'«'. \\.\\\\
^3

0. PftOCCWU
i. MOCCBS coon
T
0*4











1 1





1 '








1 t
1 1
1 1


[ 1
I 1
1 '






1 1
1 1




1 1

' '

















1 1

1 1




— 1 — 1 —
j.'XFK.'xtsx'Z'gr,,,

TRACE QUANTITIES INSEPARABLE FRO
TRACE QUANTITIES INSEPARABLE RQ
IKACL (JUANI1IILS INStPpAAbLh hKU
ABOVE
TOCE QUANTITIES INStPAKABLh hKU
ABOVE


*NOTE: THIS ONLY ONE WASTE*
*ONLY WASTE EXPLOSIVES ARE BURNED

















EPA Fomt 2S10-3 It-H)
                                                                                            CONTINUt ON RE
                                                     11-39
6 APPENDIX 11.1

-------
 IV  DESCRirriON OF HAZARDOUS WASTES /continued
 I. USE THIS SPACE TO LIST ADDITIONAL PROCESS CO DCS FROM ITEM O( I ) ON
 v FACILITY DRAWING
 All uietine. tKilit'tt mult mclud* in tnt io*c* provioed on MOI 5 • te*i* dr«wm9 o< m« t«cmrv /<•• inimietiom fof most otaiil.
 VI. PHOTOGRAPHS
 All txittmg facilities mutt include photograph! (ttritl or ground—ttvtlt that dearly delineate til existing structures: existing storage,
 treatment and ditpOMl areas; and utes of future storage, treatment or disooul areas /**• inttrucriont for men Ortitl).
 vii. FACILITY GEOGRAPHIC LOCATION
 vui. FACILITY OWNER
  i_, A. It rht taeilitv owner it *lio ttM (•eilirv operator • lined in Section VIII on Form 1, "Senoret Intometion". pteet m "X" m rn« box to cn« Mft *nd
       ikip te Section IX below.
    B. I* the teciliTy owner u not the feeilitv optr*tor e§ lined in Section VIII on Form 1. eomotete rrn
    Stephen J.   Hostettler
Fl  5945 Wellington Road
 IX. OWNER CERTIFICATION,	
 / etnify under pentlty of Itw thtt I hive pentontlly extmined tnd tm femilitr with tht informttion a/omitted in thit tnd til intched
 documtntt. tnd thtt btmd on my inquiry of thorn individutls immedietely nttpontitlt for otittining tht informttion. I btlttv* thtt the
 ubmmtd informttion it true, teeurnt, tnd complete. I tm twen thtt there tre uynifietnt pentltm for mjomming film informttion,
 including the poaibility of fine tnd imprisonment.                     )
 A  HAMt Ifnnl or tfHI                            e. (IOMAJVX    /               s    \       C  DATIflONtO

   Stephen  J.  Hostettler

 X, OPERATOR CERTIFICATION
 / etrtify unotr ptntlty of l»w thtt I /»»• ptnontlly »M*nin*d »nd tm ftmilitr with tt» informttion mjbmitnd in thit tnd til mtchtd
 documtmt. tnd thtt otttd on my inquiry of thorn individutlt immtditttly nupontibto for outlining tht informttion, I 0*V*vt thtt tru
 tuomitnd informttion it trut. tecurtn, tnd compton. I tm •««•/» thtt thtn in tignifictrn ptntton for mjbmining ftlm informttion.
 including tht poaibility of tint tnd imoritonmtnt.                                        I
  • NAMC tfnnt nr t\f*t

   Stephen  J.  Hostettler
                                              e. SIOMATU
C. OATf (lONf O

  6/29/89
       3JIM IC-IO)
                                                                                                      CONTINUE ON PACE S
                                                          11-40
                                                                                                          111

-------
"y  FACILITY DRA*ISC ,tte ,
         SEE   ATTAOMENT
                                                  11-41
§ APPENDIX 11.1

-------
rhermal TreatmeuL

-------
J

-------
ATLANTIC   RESEARCH  CORPORATION
        PINE  RIDGE  PLANT

-------
               APPENDIX P



HAZARDOUS WASTE MANIFEST FOR JULY 14, 1989

-------
lie print or type;    I form deponed for ust on tin* (12-pnchl typtwrHtr)
                                                                WHO it.  mruin   »-w.
                               (As Required By The Alabama Department of Environmental  Management)
                                                                    	                  Form Acproved. OU8 No. 2CSO-0039. €a»n all respects in proper condition lor transport ay rugnwav
    according 10 applicable international and national government regulations
    If i am a large Quantity generator. I certify mat lhavo a program m place to reduce ;he volume and tonoiy o' waste jenera:ec to me decree I nave determined to se
    economically practicable and mat I nave selected the practicable met nod ol ireaim«n:. storage, or disposal currently avaiias.* to me whicn mmim.iestne present and
    luture threat to human health and tne environment: ON. if I am a small Quantity gener.iior. I nave made a good faun t'lort to minimize mv waste generation and select
    the Dest waste manaoernent method that is available tome anc *nat i can a'*ord	^	
   Printed/ yped  ftUmaj..
                                                          Signature
                                                                                                               Month Dty   Yttr
                                                                                                                       '
 17.Transporter 1  Acknowledge^Um of Reee«i of Materiel*
         /Typed Name
                                                           Signet1
  8.Transporter  2  Acknowledgement  at Receipt  of Meteriera
                                                                                                              Month  Oar
   Primed/Typed  Name
      Anthonv  T.  pollard
                                                                                                               Month 0*r
                                                                                                              h '? n  ic
 1 S.Discreoency indication Space
 20.Facility Owner or Operator Certification of receipt of naiaroous  materials covered by tnn Tiianrlest exceeds noted  in Item 19.
   Printed/T9*ed  Nemej    /	      \   T\                N^Signeiure  \X         X       ^
                                               r-^.     i ^^s-BkvV         I j^-^e-T^T
    8700-22  ifi«


-------
SCNT BY: CUM T^CH SUC INC     ; 7-l9-«9   9s
-------
              APPENDIX Q



HAZARDOUS WASTE MANIFEST NO. CWM 289234

-------
                       HAZARDOUS  WASTE  MANIFEST
                                (As Required By The Alabama Department of Environmental Management)
 ,,4te prim or type.   /Form designed for use on elite (12-pitch) typewriter.)	   Form Approved. OMB No. 20OO-Q4O4. £xj>ir«s
      UNIFORM HAZARDOUS
         WASTE MANIFEST
                                       1. Generator t US EPA ID No.
                     Manifest
                  ^Document No.
                                                                                Information in the inaaed areas
                                                                                is not required  by  Federal
                                                                                law
    3T  Generator i Name end Mailing Aooress
    4.  Generator's Phone (  —,-_ •
                               -c-**  K.
                              =    V /.  ,  '<-  '<- - ^ "»'
    5.  I ransponer

       ft", £ t
     "Cor
             Name
        Tipany
                                                 US EPA ID Number

                                                l<- !•-!,< l?|rI-7K'p
    /.  i ransponer 4 company Name
                                                             US EPA ID Number

                                                       I  I   !  I   I  I   I  I   I  I
                          a HO Ofta
                                                             US EPA 10 Number
      CHEMICAL WASTE MANAGEMENT, INC.
      Emelle Facility
      Alabama Highway 17 at Mile Marker 163
      Emelle, Alabama 35459
A|  L|
                                                      62   2
    11. US DOT Description (Including Proper Shipping Hunt. Hezerd Clett.
                                                               12. Containers

                                                                No.    Type

                                       CWM Profile Number . / Tj i. 7^ fJ 7 V
                               OP v   CWM Prof"*Number ^ -:>)/'
I
*^ IA •
         9 c, 7  / n - ^ •   CWM Profil« Number
                        io //,
                                       CWM Profile.Number   ^.-,
                       1  C, t  /  VO
                       for Matartaa
                               ,AM«ien«l (formation
                                                                —.1. \
                                                          : tj -i «n. ttl«t I
                                                                             • -f. -r. .=.
    16. GENERATOR'S CERTIFICATION: I nereby declare that the contents of this consignment are fully and accurately described above by
      proper shipping name and are c4as*ifted. packed, marked, and labeled, and are in all respects in proper condition for transport by highway
      according to applicable international and national government regulations.
      Unless I am a small quantity generator who has been exempted by statute or regulation from the duty to make a  waste  minimization certification
      under Section 3O02(b) of RCRA, I  also certify that I have a program in place to reduce the  volume and toucity of waste generated to the degree I
      nave determined to be economically practicable and I  have selected the method  of treatment, storage, or disposal currently available to me which
      minimina the present and future threat to human hearth and the environment.    f / ^  |-^ r_-. r,, ~e.—	
      Printed/Typed Name

       /V* r
                                            Signature
                                                    Month  Diy   Yetr

                                                    K H I ' !T K i6
    17.Tranaooner 1  Acknowledgement of  Receipt of Materials
      Pn»xwoVTyped  Name	_>_,
                   '
                                            Signature'
                                                    Month  Day   V«»r

                                                    I  I   I / ' '] " '-
    IS.Transporter 2  Acknowledgement of  Receipt of Materials
      Primed/Typed  Name
                                            Signature
                                                    Month Diy   Yeir

                                                    I  I   I     I
     S.Discrepancy Indication Space

    20.F«eilrty
      or Op«r«tor: C«nrftc»t»on of r«c*tpt of  haz»rdou» mattnals cov*r»d t>v thi» m»nrf«»T
                                                                                     as nottd m litm 19

-------
                                      ..•it n2-p«icfll typKwriter j
                             _
                       ....FEST
                 ..uation Sheet)
                                        21.Gen*mor't US EPA ID No.

                                                                        ry-ieum«nt No
          w,ator s Na
                                                               US EPA ID Number
                                                                                            <-
                                                                                               it not required by  Feoeril
                                                                                     L. State Manifest  ocumeot Number
                                                                                      CWM A
                                                                                    M. State Generators  10
                                           N. State  Transporter's ID
    24 Transporter  /  Company Name
                                                    25.
                                                                                                           c/r?r- '
                                                                                    0. Transporter's  Phone "7«J>_-
    2B. Transporter    Company Name
           27.

           1
                                                               US EPA ID Number
                                                                                    P. State Transporter s ID
                                                                                     1. Transporter's  Phone
28. US DOT Description (Including Proper Shipping Name. Hazard Class, and ID Number
29. Containers

  No.    Type
                                                                                               30.
                                                                                              Total
                                                                                            Quannty
                                                               31.
                                                               Unit
    R.
 Waste No.
                                         CWM Profile Number
                                                                                  /
                                                      ^00
    b.
                         fc S /
CWM Profile
                                                      y
Doo )
rbo3
                                         CWM Profile Number I
                                                                                    p  «*.
                                                      5 o o'
    d.
                             /OCO"2-     CWM Profile Number v~T5r4-S<7S'"7 3 <
CWM Profile Number
                                                                                               G oo
F-
                                 .ne^t   CWM Profile Number
                                         CWM P.Mile Number
                                         CWM Profile Number
    S.  Additional Dwcriptionj for Materials Luted Abov»
                                                         -iff
                                                                       <1 Jr4/._
                                            T. Handling Codes for Wanes "Listed Above
 ,
    32. Soeci»l Hindlmg Inrtruction'i tnd Additional Information
    33.
       Tf»n«pofw y Actnowt^gomam of R«e«ipt o< Materials
                                                                         Date
                                              >
                                                                        -e*-e
                                                                                                            Worn/, 0»x  Y.
       Transporter	Acknowledgement' or Receipt of Materials
       Primed/Typed Name
                                                           Signature
                                                                   Month Day
    35 Discrepancy Indication Space
         H L'~- t  ^ 
-------
                APPENDIX R



NOTIFICATION FOR UNDERGROUND STORAGE TANKS

-------
  Notification  for Underground Storage Tanks
1 FOR
TANKS
IN
! VA
RETURN
COMPLETED
FORJj
TO
Russell P. Ellison, III, PG.
Virginia Water Control Board
P.O. 80X11143
Richmond, VA 23230-1143
                                                                  (804) 257-6685
                                                      GENERAL INFORMATION
                                                                                        > 0. Number
                                                                                                       STATI uw o««jr
            i it nqirind b» F«ttnJ taw for iH und4rfrowid unki tint h*v« been
   uMd 10 uorc ntut*t*i wtaanca dim JUMBO I • >'74- "»' m in dM fround u of
   MIY I 1***. or ttai tn broufht into T9
                 *hicn it an mtrastate pipeline facilitv regulated under State lav»s
                 5. surface impoundments, pits, ponds, or lagoons.
                 6. storm viaicr or uaste viater collection ssstems.
                 7. Ho* -through process tanis.
                 8. liquid traps or associated gathenng lines directlv related to oil or
                 gathering operations.
                 9. storage lanks situated m an underground area isuch as a  basement
                 mmeviorking. drift, shaft, or tunnel) ii ihe storage tank is siiuaied upon or abo
                 suriace of the floor.
                                                                                                                      v prod ucnun and
                                                                           Subiunca Art Co»trtd? The notification requirements appiv 10 ^nae'-
                                                                    ground storage tanks that coniam regulated substances  This includes am -L,oMdrxc
                                                                    detlned as ha;ardous m section 101 1 14) of ihe Comprehensive Environmental
                                                                    Response Compensation and Liabilitv Actol l980lCERCl_A>. »nh ihe exception ,n
                                                                    those substances regulated  as ha/ardous v»a.ste under Subtitle C ot RCR-V Ii JNO
                                                                    includes petroleum, e g . crude oil or an\ fraction thereol »hich is liquid j: >undjra
                                                                    conditions of tempenture and prrssure (60 degrees Fahrenheit and 14 7 pounds nvr
                                                                    square inch absolute).

                                                                      W(nr» To Notify? Completed notificanon forms should be sent to  the dddrcss
                                                                    given at the top of this page.

                                                                      Wh«n To No«tfy?  I . Owners of underground storage tanks m us< or irut navi/ txi-n
                                                                    taken out ol operation afier Januarv I. 1974 but snll in the ground, must noun b\
                                                                    Mav 8. 1986 1. Owners v»ho bnng underground storage tanks into ust aiicr Vl^v n.
                                                                    1986. musi notifv vtuhin X) davs of bnnginf the tanks into ux.

                                                                      P*nilti«s: Any owntr wfto knowmjiy (uh 10 nottfy or nkwniti MM nfomuiion
                                                                    ihall ta* tub^tct to i dvti ptmtty not 10 ticctd Slt.M* for nek tank tot which
                                                                    rKHification B not |i**n or for »nieh fata* Momution • wonMtrd.
    Pleas* t\pe or print in ink all items except "signature" m Section V This fonn must b> completed for
  itch location containing underfround «oni|e tanks. 1 f more than 5 tanks arc ow ned at this location.
  photocopy the re\.erie side, and staple continuation sheets to this form.
                                                                                                   Indicate number of
                                                                                                   continuation sheets
                                                                                                   attached
                    I. OWNERSHIP OF TANI{(S)
 Owner Name (Corooration. moiviouai. Puonc Agency, or Otner Entity)

  Atlantic  Research  Corporation
                                                                                       II. LOCATION OF TANK(S)
 Street Address
  5390  Cherokee  Avenue
 County
           Alexandria
                                State
 City                            btati
 Alexandria,   Virginia
                                                 ZIP Code
                                             22312
 Area Code
  703
              Phone Number
                 642-4006
Type of Owner

0 Current
    De,,™—
    Former
                   Q State or LocaJ Govt
                   PI FedtftlOovt
                   |_| ((3SA facility 1.0. no.
Private or
Corporate
Ownership
uncertain
                              (If same as Section 1. mark box here O )
                 Facility Name or Company Site Identifier, as applicable

                  Gainesville  Facility	
                 Street Address or State Road, as applicable
                  7511  Wellington   Road	
                 County
                      Prince  William County	
                 City (nearest)                     State          ZIP Code
                  Gainesville         Va.         22065
Indicate
number of
tanks at mis
location
Mark box here if tank)s)
are located on land witnm   r—i
an Indian reservation or     l_l
on otner Indian trust lands
                                               III. CONTACT PERSON AT TANK LOCATION
  Name (II same as Section.), mark box here  [j )              Job Title
  Michael  E.  Young        Environmental  Compliance  Officer
                                                                                                    Area Code
                                                                                                    703
                                                               Phone Numoer
                                                             642-4006
                                                      IV. TYPE OF NOTIFICATION
                                Mark box here only if tnis is an amended or subsequent notification for tnis location.
                                       V. CERTIFICATION (H««d and ilgn after completing Section VI )
  I certify under penalty of law that I have personally examined and am familiar with the information submitted in this and all attached
  documents, and that based on my inquiry of those individuals immediately responsible for obtaining the information. I believe mat the
  submitted information is true, accurate, and complete.
  Name and official title of owner or owner s authorized representative
Lambert  Murphy,  Vice  President  Admin.
                                                                 Signature
                                                       CONTINUE ON REVERSE SIDE

-------
Jwner Name (from tecaen I) -
                                                              7511  Wellington Rd.
                                                              Gainesville,  Va. «___„_ 2
                   VI OESCRIPTION OF UNDERGROUND STORAGE TANKS (Complete tor aach fan* .if ffiis tocjfion I
T- 'dentrflcatton He. (e.g.. AfS.'jSL ^.n-i_2J )

1. Status of Tank Currently in Use
(***•# *****>**) Temporanly Out of Use
Permanently Out of Use
Brought into Use after 5/8/86
2. Eitlmated Age (Years)
3 Estimated Total Capacity (Gallons)
4. Material of Construction S(ee)
ffWelrw Of'wlw/ /"*«•»>«••»**»
Concrete
Fiberglass Reinforced Plastic
Unknown
Other. Please Specify
' IMmht til that aoo/y B J Cathodic Protection
Interior Lining (e.g., epoxy resins)
None
Unknown
Other. Please Specify
6. External Protection Cathodic Protection
PsintOd (S-Q-t 3Spn3ltlC)
Fiberglass Reinforced Plastic Coated
None
Unknown
Other. Please Specify
7' Rpjn* Bare Steel
rMrt.lttaf.ff*.; Galvanized Ste*
Fiberglass Reinforced Plastic
Cathodically Protected
Unknown
Other. Please Specify
8. Substance Currently or Last Stored . Emory
in Greatest Quantity by Volume Petfatoum
( Mar* art tfmt appry f) ) Petroleum
Kerosene
Gasoline (including alcohol blends)
Used Oil
Other, Please Specify
c. Hazardous Substance
Please I ndicate Name of Principal CERCLA Substance
OR
Chemical Abstract Service (CAS) No
Mark box 3 if tank stores a mixture of substances
d. Unknown
jdltlonal Information (for tanks permanently
ken out of service)
a. Estimated date last used (mo/yr)
b. Estimated quantity of substance remaining (gal.)
c. Mark box 3 if tank was filled with inert material
(e.g.. sand, concrete)
Tank No.

rxn
CZZ
CZZ
cm:
x
6 ,000
m
[~i
i i
LZZ

r— ]
cmD
1 A I
CZZ!

1 	 1
C2ZI
CZZ]
CZZI
CZZI

I 	 1
1 Q J
cm
i i
i i

czm
i — i
cm
czn
cm

i — i



cm



/


CZZ]
Tank No.
2
^n
i i
i i
CZZ
3
2. one
nri
i i
i i
I 	 1

cm
cm
i i
IZ3U

cm
r— i
c i
i i
on

, — ,
cm
cm
cm
on

cm]
czz
i i
IX I
mz

i — i



CZZI



/


1=3
Tank No.

1 	 1
cm
cm
cm


cm
cm
mz
i 	 i

CZZ]
cm:
i 	 i
i 	 i

rz

CZZ1
CZJ
cm

i — i
cm
cm
cmi
cm

cm
mz
cm
cm
cm

CZZ]



(—1 .
1 1


/


CZZI
Tank No.

1 	 1
cm:
cm
cm


cm
cm
cm
i 	 i

cm
czz
i 	 i
CZZI

i — i
cm
i i
czz
mz

i — i
i — i
czz
cm
i i

czz
czz
czz
czz:
cm

cm



CZZ!
czz


/


L_Z
Tank No.

1 	 1
rm
czz
czz


i — i
i — ;
i — i
cm

m
cm
cm
cm

i — i
m

cm
cm

i — i

i i
czz
r i

cm
cm
CZZl
cm
i i

czz



cm
czz


'


cz:
EPA Form 7530-1 (11-85) HCVWM
Page 2

-------
               APPENDIX S



NOTIFICATION OF UST CLOSURE SAMPLE RESULTS

-------
      GROUNDWATER
      TECHNOLOGY. INC.
                                             08 March 1990
Mr.  Larry Johnson
Virginia Water Control Board
5515 Cherokee Avenue
Suite 404
Alexandria, VA  22312

RE:   Notification of UST Closure Sample Results

Dear Mr. Johnson,
     This letter
                 is
                 f
to
                       document  my  telephone  conversation with Mr.
Frank Jacobeen  of  the Virginia Water Control  Board,  with  whom  I
spoke in your absence on March 1, 1990.   During  this conversation,
GTI provided the Virginia Water Control  Board with the results of
underground storage tank (UST) removal closure  samples.

     On January  2,  1990; GTI removed a  1000-gallon  UST  from the
Atlantic  Research  Corporation   (ARC)  Facility in  Gainesville,
Virginia.    During  removal  of the  tank,  a  small amount of  liquid
hydrocarbons was released from the tank  to the  pit.  Upon removal
of the tank, a hydrocarpon film was visible  on  the surface of the
water in the pit.

     Ms.  Anna  Fix  of  GTI   spoke  with  you  on  January  2,  1990
concerning  the  UST removal  and  the  hydrocarbon  film.  She was
advised to  collect  the  closure  samples  and  to notify your  office
within 24  hours  of  receipt of sample results.   GTI has taken action
to absorb  the hydrocarbons  from the surface of the  water  in the
excavation  pit.    However,   the  closure samples  were collected
through this water and it is suspected that contact  of the sampling
apparatus  with  the  hydrocarbons  on the water surface  may  have
elevated the sample concentrations.

     The  sample results are summarized below.   Copies  of the
laboratory  analysis  are provided  as Enclosure   1.   The   Total
Petroleum Hydrocarbon (TPH)  results range from 102 ppm to  1600 ppm.
The laboratory analysis  of  soil  samples  collected  at the base of
the excavation pit on the north and south sides indicated TPH
levels of  102 ppm and  1600 ppm,  respectively. Laboratory analysis
of soil samples collected at the depth of groundwater on the east
and west sides of  the excavation  pit  indicated TPH levels  of 243
ppm and 1340 ppm, respectively.

     At this time,  the hydrocarbon  film on the water surface of the
excavated   pit has  been   greatly reduced  from that  present  at the
time of closure  sampling. Since the condition  of the water in the
tank pit has changed  significantly,  GTI  recommended in our  phone
conversation of March 1, 1990 that a second  round  of samples be
                     Offices throughout the L'.S.. Canada and Overseas

-------
Mr. La^^v Johnson
Virginia Water Control  Board
07 March 1990
°age 2


collected.   The  second set  of samples  are  expected  to  be more
r-epresen tative of  soil  quality  in  the  area of  the  tank pit.  Mr.
Frank Jacobeen verbally approved the  additional sampling which was
performed on Monday,  March 5.

     Samples  were  collected   at  the  base   of   the  tank  pit
'approximately 5 to 6 feet depth) through the water  in  the tank pit
in a similar manner to the  original  samples.   However, since the
hydrocarbons on the water  surface have  been significantly reduced,
it is believed  that the  sample results will  be more representative.
^hese samples were collected on  tne  north  and  south  sides  of the
tank pit.

     Samples   were   collected  at   the   depth  of   groundwater
(approximately  1  to 2  feet)  at locations  5 feet east of  the pit
( downgradien t )  and  10  feet west  (upgradient)  of  the pit (see
Enclosure 2).   These samples  were  collected outside  the tan« pit
in order  to  eliminate contact  of  the sampling  apparatus with the
water surface of  the  tank  pit.

     If the TPH results of these samoles are  less than  100 ppm, GTI
recommt. ds  closure  of  the  tank  pit.    Sample  analyses will  be
expedited and results are  anticipated  to be available the week of
March  12,  1990.   GTI  will  contact  your  office  upon  receipt  of
samp 1 e *-esu 1 ts .

     Please contact me  with  any questions or comments  you may have
r-egarding this correspondence.

                                    Sincerely ,
                                    GROUNDWATER TECHNOLOGY,   INC.
                                    Linda  A.  Noelte
                                    Site Manager
cc :  Frank Jacobeen  ( VA WCB)
     Mike Young  (ARC)
     Jennifer  Foster (ARC)
     Bill Smith  (GTI)
     Jim Garrett (GTI )
     Tim Havranek  (GTI)
Enclosures:     (1)  Laboratory Analysis  Results    ===_§; GROUNDWATER
                (2)  Sample Location flap                    TECHNOLOGY, INC.

-------

                                                                CHAIN OF CUSTODY RECORD
 PROJECT NO.

'
                    PROJECT NAME
.SAMPLERS: ISlgnttun)


       '' '      /'C"~X /
                ^-^- f /-i .A  ./"—-,,
     NUMBER
                     DATE
                             TIME
                                          cc
                                          (3
                                              IPlilHO(l)
                                                      STATION LOCATION
                                                                                                             PARAMETERS
                                                                                           INDUSTRIAL

                                                                                        HYGIENE SAMPLE
                                                                                                                                             REMARKS
              x
              V
                                                    A/
                            / H -.
                            L^
                    -V
  elinquished by: (signtiun)
           lv  <:xi.,.^ K^^ JOA.
Date / Time
                                                   Received hy: (Siynuturol
                               Hdlinqulxhod by: (Signature)
                                                   (Priniiicl)
                                                                                  (Prlniod)
Date / Time
                                                                                                                         L
Received by: ISIgnnwrs)   '{. '\;;
                                                                                                                                   (Prlntod)                  • ' J, '-'V
                                                                                                                                                            ,<••'* '
                                                                                                                                                            i  ! ; •
'R«llnqul»hed by: ISignawrtl
m*
                                    Date / Time
Received for Laboratory by:
(Signature)
                                                                                      Dato / Timo
'(Printed)
                                                   (Priruud)
                                                                                                    Remarks
Olitrlbudon: Original Plui One Accompanies Shipnicni (whlir und yellow). Copy (o CnonJimiior Piulil l:iU>s (pink)

-------
  Wnsar.
             MC
                        ANALYSIS REPORT
                General Inorganic Chemistry  Section
DATE: 07-Feb-9O
CODE / COKTROL #: ARCGAIN / 1847
CLIENT / SITE: ARC / Gainesville, VA.
PROJECT / BATCH:  420.7 / 44
                                                 PAGE:
LAB *
       I
 94263 I
 94269 I
 94270 I
 94271 I
 94272 I
 94273 I
 94274 I
       I
FIELD *
 3377
 3379
 3380
 3381
 3382
 3383
 3384
FLASHPOINT
    85.
 TRPH
(mg/L)
               <1. 14
               <0.89
 TRPH
(nig/leg)

  102.
            1, 600.
              243.
            1, 340.
              229.
 TOTAL
SOLIDS
                                        91. 8
             87. 0
             88.6
             82. 9
             86. 9
                                             LABORATORY MANAGES

-------
                         O3IEMBIA. ANALYTICAL SERVICES, INC.

                                 Analytical Report
 CLIENT:    Versar,  Inc.
 SOBMITIED BY:   Ken Ives
 PROJECT:   #1847
 SAMPLE EESCKIPnCN:   Water
           DATE RECEIVED:
           DAIE ANALYZED:
           VCRK ORLtK #:
              01/10/90
              01/15/90
              R90095
                       Purgeable Aronatic Volatile Compounds
                                  EPA. Method 8020
                                          (ppb)
Sample Name:
lab Cede:

                          MRL

Benzene                    1
Toluene                    1
Chlordbenzene             1
Ethyl Benzene             l
Total Xylenes             l
1,4-Dichlorobenzene       1
1,3-Dicnlorobenzene       1
1,2-DiciiIorobenzene       1
3378
095-2
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
3379
095-3
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
3380
095-4
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
MRL  means Method Reporting Limit
ID   means None Detected at or above the MRL
Approved by_
    Date
    1317 South 13th Avenue • P.O. Box 479 • Kefao. WA 98626 • (206) 577-7222 • Fix (206) 636-1068

-------
                        COLUMBIA ANALYTICAL SERVICES, INC.

                                Analytical Report
GHENT:   Versar, Ire.                             DATE RECEIVED:   01/10/90
SUa-HTTED BY:  Ren Ives                            DATE EXTRACTED:  01/14/90
PROJECT:  11847                                    DATE ANALYZED:   01/15/90
SAMPLE DESCRIPTICN:  Soil                          WCRK ORDER #:    R90095
                      Purgeable Aronatic Volatile Conpounds
                                  EPA Method 8020
                           raj/Kg  (ppm)  Dry Weight Basis
Sanple Name:                            3377          3381          3382
Lab Code:                               095-1         095-5         095-6

                          MRL
Benzene                   0.05            1.42           1.50         ND
Toluene                   0.05           11.0            7.2          10.1
Chlorobenzene             0.05           ND             ND            ND
Ethyl Benzene             0.05            6.77           5.46         10.1
Total Xylenes             0.05           19.6           22.0          31.7
1,4-Dichlorobenzene       0.05           ND             ND            ND
1,3-Diciilarobenzene       0.05           ND             ND            ND
1,2-Dichlorabenzene       0.05           ND             ND            ND
MRL means Method Reporting Limit
ND  means None Detected at or above the MRL
Approved by	t-   L               pate
    1317 South 13th Avtanjc • P.O. Box 479 • Kdso, WA 98626 • (206) 577-7222 • Fax (206) 6)6-1068

-------
                                                                            CAS
                        OOILMHIA ANALYTICAL SERVICES, INC.

                                Analytical Report
CLIENT:   Versar, Inc.
SUBMITTED BY:  Rai Ives
PROJECT;  11847
SAMPLE CGSGREFTICN:  Hater
       DAIE RECEIVED:
       DATE ANALYZED:
       WCRK ORDER #:
OV10/90
01/15/90
K90095
                      Purgeable Aromatic Volatile Ocnpounds
                                 EPA Method 8020
Sarple Name:
Lab Code:
                                          MRL
                      Methcxi
                        Blank
                        095-MB
Benzene
Toluene
Chlombenzene
Ethyl Benzene
Total Xylenes
1, A-Oichlorobenzene
lf 3—Dichlorcbenzene
1,2-Dichlort±)enzene
1
1
l
l
l
1
l
1
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
MIL  means Method Reporting Limit
ND   means None Detected at or above the MRL
Approved by_
Date
    1317 South 13th Avenue • P.O. Box 479 • Kelso, WA 98626 - (206) 577-7222 • Fax (206) 636-1068

-------
                        OOILHBIA ANALYTICAL SERVICES, INC.

                                Analytical Report
GHENT:   Versar, Inc.
SDEMTTrED BY:  Ren Ives
PROJECT:  11847
SAMPLE DESCKEPriCN:  Soil
                         DATE RECEIVED:
                         rwrc EXISACIHD:
                         DA1E ANALYZED:
                         WCRK CRDER #:
                           OVW90
                           01/W90
                           01/15/90
                           K90095
                      Purgeable Aromatic Volatile Cc
                                 EEA Method  8020
                           mg/Rj (ppn)  Dry Weight Basis
                            pounds
Sample Name:
Lab Code:
Benzene
Toluene
Chlorobenzene
Ethyl Benzene
Total Xylenes
1,4-Dicfclarobenzere
1,3-Dicblorobenzene
1,2-Dichlorobenzene
                          MRL
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
              3383
              095-7
 2.0
 9.29
ND
 6.23
25.9
ND
ND
ND
             3384
             095-8
 0.20
 0.80
ND
 0.83
 3.12
ND
ND
ND
           Jtethod
            Blank
            095-MB
ND
ND
ND
ND
KD
ND
ND
ND
MRL means Method Reporting Limit
ID  means None Detected at or above the MRL
 Approved by_
                   Date
    1317 South 13th Avenue - P.O. Box 479 • Kdso, WA 98626 • (206) 577-7222 • Fw (206) 636-1068

-------
                                           1                       FIELD SAMPLE NO.
                           INORGANIC ANALYSES DATA SHEET
                                                                 I
                                                                 I      3 3 8 4
CiiGitb   : A FLAN r.TC_R£SEARCH._i:ORP- _  Sibe:  GA INESv1 C LLE, _VA  I	
Lab Name: 1,'ERSAR_1NC.   Control  Ho.: 1847	  Code-?: ARCGAIN_  Batch:  '< 4	

Mabrix   : EXTRACT	                              Lab  Sample ID:  1427 4	

Level  (low/meci):  	                              Date Received:  01/08/90

•/. Solids: 	0.0

            Concentration  Units;  (uq/L or  rng/kn dry  weight) :  UG/L_
1 CAS No.
1 7429-90-5
17440-36-0
i 7440 — 53—2
! 7440-39-3
i 7440-41-7
i 7440-43-9
i 7440-70-2
i 7440—47—3
I 7440-43-4
I 7440-50-8
! 7439-89-6
! 7439-92-1
J7439-95-4
17439-96-5
! 7439-97-6
1 7440-02-0
1 7440-09-7
i 7782-49-2
I 7440-22-4
I 7440-23-5
1 7440-28-0
I 7440-62-2
i 7440-66-fa
;
i i II
1 Anaiyte 1 Concentrat i on 1 C 1
! i II
1 A 1 u m i n u m 1 II
(Antimony 1 II
(Arsenic 1 II
1 E< a r i LI m 1 1 1
i Bery 1 1 ium__ 1 	 1 1
i C a ci m i u m 1 II
i Ca 1 c ium 1 II
1 C h r o rn i u m 1 II
i Cobalt 1 ' II
! C o p p e r 1 II
1 Iron 1 i 1
ILead 1 23.0IUI
1 lla gnes ium 1 II
i PI a n a a n e s e 1 1 1
i Plercury 1 1 i
1 Nick el 1 i 1
! Potassium 1 1 1
i S e 1 e n i u m 1 i !
1 S i 1 v e r 1 1 !
1 Sod ium 1 1 1
IThallium 1 1 1
1 Vanadium 1 1 1
IZinc 1 II
1 C / a n i d e 1 II
1 1
Q lit 1
1 1
INRI
INRI
INRI
INRI
	 1 NRI
INRI
1 MR 1
INRI
INRI
INR 1
INRI
i P 1
i MR 1
INRI
1 HR 1
1 NR i
INRI
1 NR 1
1 NR 1
1 NR 1
INRI
1 NRI
INRI
1 NRI
Color  Before:  COLORLESS         Clarity  Before: ULEAR_        Texture;

Color  After  :  COLORLESS          Clarity  After: CLEAR_      Artifacts

Comments:
                                     FORM  I  - IN

-------
                                                 J*a..r
                        •fCOWVjCT— ROB INSOl^'


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SITEiOCATION
ATLANTIC RESEARCH CORP.
GAINESVILLE, VAr :
        GROUNDWATEH
       'I TECHNOLOGY

-------
              FIGURE  1
            SITE  MAP
PHOJLCf; ARC

LOCATION: 59*5  WELLINGTON
         GAINESV,LLE   VA
'(<- SOIL UO/IING

-------
                APPENDIX T

PERMIT TO CONSTRUCT AND OPERATE A BERYLLIUM
ROCKET PROPELLENT LABORATORY AND TEST FIRING
                 FACILITY

-------
EUZABrTK ft. hASKELL, CHAIRMAN
MART1NSVIUE
CARL C. REDINGER, VICE CHAIRMAN
ALEXANDRIA
EDGAR B. BOYNTON
RICHMOND

TIMOTHY E. BARROW
VIRGINIA BEACH

WALLACE E. REED
CHARLOTTESVILLE
COMMONWEALTH of VIRQ1NIA
               Air Pollution Control Board
                   Ron Offic* Son 10089
                  RICHMOND, VIRGINIA 232tO
                  TELEPHONE: (804) 736-2378
                                          June 27,  1986
       Mr. Lambert Murphy
       Vice* President  for  Administration
       Atlantic Research Corporation
       5390 Cherokee Avenue
       Alexandria, VA   22312
       Dear Mr. Murphy:
                                                       Location:   Prince William County
                                                       Registration No:   70033
                                                       County-Plant No:   2520-0014
           Attached  is  a  permit to construct and operate a beryllium rocket propellant
       laboratory and  test  firing facility in accordance with the provisions of the
       Commonwealth  of  Virginia Regulations for the Control and Abatement of Air
       Pollution and the  National Emission Standard for Hazardous Air Pollutants.

           In  the course  of evaluating the application and arriving at a final decision
       to approve the  project,  the Virginia State Air Pollution Control Board (SAPCB)
       deemed  the application complete on April 21, 1986 and solicited written public
       comments by placing  a newspaper advertisement in the Manassas Journal Messenger
       and the Potomac  News on May 19, 1986.  The thirty day comment period (provided
       for in  the regulations)  expired on June 17, 1986.

           This approval  to construct and operate shall not relieve Atlantic Research
       Corporation of  the responsibility to comply with all other local, State and
       Federal air pollution control regulations.

           If  you have  any  questions concerning this permit, please contact the
       Director, Region VII, at (703) 644-0311.

                                                  Sincerely,
       JMDjr/CLC/da
       Attachment
                       (I Actin
                                                   ohn M. Daniel, Jr., P.E.
                                                  Acting Executive Director
       cc:  Director, Division of Source Evaluation
            Director, Division of Computer Services

            Director, Air  Management Division,  EPA
                                  Director, Region VII
                                  Springfield Towers - Suite 502
                                  6320 Augusta Drive
                                  Springfield, VA  22150
                                   "An Equal Opportunity Employer"

-------
EUZABE1U w r.ASKELL. CHAIRMAN
MART1NSVILLE
CARL C. REDINGER. VICE CHAIRMAN""                 S^^zaT'.^                      DSE-345-86
ALEXANDRIA

^GHMONOBOYNTON          COMMONWEALTH of VIRGINIA
                                  Stale Air Pollution Control Board
                                           Post Office Box 10083                             EXECUTIVE DIRE!
WALLACE E. REED                             RICHMOND. VIRGINIA 23240
CHARLOTTESVILLE                             TELEPHONE: 1804) 786-2378
                            PERMIT TO  CONSTRUCT AND OPERATE A SOURCE
            SUBJECT  TO  THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS
            In  compliance with the Federal Clean Air Act and the Commonwealth  of
       Virginia  Regulations  for the Control and Abatement of Air Pollution,

                                Atlantic Research Corporation
                                5390 Cherokee Avenue
                                Alexandria,  VA  22312
                                Registration No.  70033
                                County-Plant No.  2520-0014

       is  authorized to construct and operate

                                a beryllium rocket propellant
                                laboratory and test firing
                                facility

       located at

                                7511 Wellington Road
                                Gainesville, Virginia

       in  accordance with the Specific Conditions (emission limitations, monitoring  and
       testing requirements) and the General Conditions set forth in Parts  I  and  II
       herein.

            Approved this twenty-seventh day of June, 1986.
        Permit  Consists  of 8 pages.
        Part  I    - Specific Conditions 1 to 11.
        Part  II  - General Conditions 1 to 19.
        Part  III  - Document List,  3  items.
        Part  IV  - Source Testing  Report Format.
                                   "An Equal Opportunity Employer"

-------
                                         State Permit to Construct and Operate
                                         Atlantic Research Corporation
                                         Registration No. 70033
                                         June 27, L986
                                         Page 2


PART I - SPECIFIC CONDITIONS - the  regulatory reference  and authority for each
condition is listed in parenthesis  () after  each condition.

    1.   The Atlantic Research Corporation plant is  located at 7511 Wellington
         Road, Manassas (Prince William County).

    2.   Construction and operation  shall be conducted as proposed in the permit
         application dated April 7,  1986.  The permit application and supporting
         documents (see Document List) are a part of this permit.
         (Section 120-02-11 of State Regulations)

    3.   The equipment to be installed consists of:

              - Laboratory Building  (special design)
              - Bofors Testing and Explosives Containment
                Chamber (steel construction)
              - High Altitude Tank  (Steel construction)
                for Rocket Motor Testing
              - Venturi Scrubber (2)
              - Demister (2)
              - Hepa Filter (2)

    4.   The laboratory and test firing facility shall not operate more than
         2,080 hours per year.
         (Section 120-02-11 of State Regulations)

    5.   Beryllium emissions to the  atmosphere from  the  Bofors tank (rocket
         propellant laboratory) shall not exceed 10 grams over a 24-hour period.
         (Section 120-06-0102 of State Regulations and 40 CFR 61.32a)

         Beryllium emissions to the  atmosphere from  the  test firing facility
         shall not cause time-weighted atmospheric concentrations of beryllium
         to exceed 75 microgram minutes per cubic meter  of air within the limits
         of 10 to 60 minutes, accumulated during any 2 consecutive weeks, in any
         area in which an effect adverse to public health could occur.
         (Section 120-06-0102 of State Regulations and 40 CFR 61.42a)

    7.   Beryllium emissions from the high altitude  tank which are the result
         of combustion products from the firing of beryllium propellant shall
         not exceed 2 grams per hour and a maximum of 10 grams per day.
         (Section 120-06-0102 of State Regulations and 40 CFR 61.42b)

    8.   Beryllium emissions from the rocket propellant  laboratory and test firing
         facility will be controlled by venturi scrubbers, demisters and filters.
         The control devices shall be provided with  adequate access for inspection.
         (Section 120-08-01 F of State Regulations)

    9.   Within the time limits specified in General Condition No. 4 of this
         permit, initial stack emission tests for beryllium from the control
         equipment exhausts to the atmosphere shall  be conducted.  Stack tests
         for new or modified sources shall be conducted  and reported and data
<;u'' LLr

-------
                                         State  Permit  to  Construct  and  Operate
                                         Atlantic  Research  Corporation
                                         Registration  No. 70033
                                         June 27,  1986
                                         Page 3
   11,
  reduced as set forth in Section 120-06-03 of State Regulations and the
  test methods and procedures contained in each applicable section or
  subpart listed in Section 120-06-0102.   The details of the emission
  tests are to be arranged with the Director, Region VII.
  (Section 120-08-01 H of State Regulations)

  Stack sampling will be taken during release of exhaust products from
  the tanks in such a manner that compliance with the standards in
  Conditions 5 and 7 can be determined.  Such samples will be taken and
  analyzed over such a period or periods  to accurately determine the
  maximum beryllium emissions which will  occur in any 24-hour period.
  (Section 120-06-03 of State Regulations and 40 CFR 61.33 and 61.44)

v Continuous emission monitors will be installed and operated in accor-
  dance with the monitoring plan to measure and record the atmospheric
  concentrations of the beryllium emitted from the rocket  propellant
  laboratory and test firing facility. Monitors will be maintained and
  calibrated in accordance with methods and procedures acceptable to the
  Board.
  (Section 120-06-04 of State Regulations)
PART II - GENERAL CObTDITIONS

    1.   Within 10 days after receiving this permit the permittee shall notify
         the Board (Director, Region VII) in writing of the estimated start-up
         date of the permitted facility.  This notification is for administra-
         tive purposes only and need not be a firm date.
         (Section 120-02-11 of State Regulations)

    2.   Quarterly reports on the progress of construction shall be submitted to
         the Director, Region VII, beginning July 1, 1986.
         (Section 120-02-11 of State Regulations)
    3.
    4.
  The permittee shall furnish written notification to the Board
  (Director, Region VII) of:

  a.   The anticipated start-up dat,e postmarked not more than 60 days nor
       less than 30 days prior to such date.

  b.   The actual start-up date within 15 days after such date.

  c.   The anticipated date of performance tests of the laboratory and
       test firing facility postmarked at least 30 days prior to such
       date.
  (Section 120-06-05 of State Regulations)

  Each emission point for which a stack test requirement is established
  in Part I of this permit shall be tested to determine compliance with

-------
                                      State Permit to Construct and Operate
                                      Atlantic Research Corporation
                                      Registration No. 70033
                                      June 27, 1986
                                      Page 4
      the emission limits contained herein within 90 days after start-up of
      the permitted facility.  Compliance test results shall be reported to
      the Board (Director, Region VII) in writing within 30 days after test
      completion and conform to the test report format enclosed with this
      permit as a guideline.
      (Section 120-06-03 of State Regulations)

 5.   The permitted facility shall be designed and constructed so as to allow
      emissions testing using the methods prescribed upon reasonable notice
i      at any time.
      (Section 120-06-03 of State Regulations)

 6.   All continuous monitoring systems and monitoring devices, as may be
      applicable for your source type, shall be installed and operational
      prior to conducting performance tests under Section 120-06-03.
      Performance evaluations of the continuous monitoring system must take
      place during the performance tests under Section 120-06-03 or within 30
      days thereafter.  The Board must be furnished with two copies of the
      report of the performance evaluations within 30 days of said
      evaluation.
      (Section 120-06-04 of State Regulations)

 7.   The permittee shall retain records of all emission data and operating
      parameters required by. the terms of this permit.  These records shall
      be maintained by the source for a period of at least two (2) years.
      (Section 120-06-05 of State Regulations)

 8.   All air pollution control equipment operators will be trained and cer-
      tified in the proper operation of all such equipment.  Atlantic
      Research Corporation will maintain records of the required training and
      certification.  Certification of training shall consist of a statement
      of time, place and nature of training provided.
      (Section 120-02-11 of State Regulations)

 9.   Atlantic Research Corporation will develop, maintain, and have
      available to all operators good written operating procedures for all
      air pollution control equipment.  A maintenance schedule for all such
      equipment will be established and made available to the State Air
      Pollution Control Board for reviaw.  Records of service and maintenance
      will be maintained on file by the source for a period of two (2)
      years.
      (Section 120-02-11 of State Regulations)

10.   The Board reserves the right to modify and, if appropriate,  to  reissue
      or to rescind this permit if prior to operation there is a substantive

-------
                                      State  Permit  to  Construct  and Operate
                                      Atlantic  Research Corporation
                                      Registration  No.  70033
                                      June 27,  1986
                                      Page 5
      change  to  the design capacity or the fundamental nature of the process
      or control equipment such that the potential to emit of any facility is
      increased.
      (Section 120-02-11  of State Regulations)

11.    The Board  reserves  the right to modify and,  if appropriate, to reissue
      or to rescind this  permit if prior to operation there is a substantive
      change  in  any of the data upon which the decision to approve this per-
•      mit was based.
'      (Section 120-02-11  of State Regulations)

12.    All local  zoning and building requirements must be met before com-
      mencing construction.
      (Section 120-02-11  of State Regulations)

13.    If, for any reason, the permittee does not comply or will not be able
      to comply with the  emission limitations or other conditions specified
      in this permit, the permittee shall provide in writing to the Board
      (Director, Region VII) the following information as soon as possible
      but no  later than five (5) days after such conditions become known to
      the permittee:

      a.   description of noncompliance;

      b.   cause of noncompliance;

      c.   anticipated time the noncompliance is expected to continue or, if
           corrected, the actual duration of noncompliance;

      d.   steps taken by the permittee to minimize or eliminate the non-
           compliance; and

      e.   steps taken by the permittee to prevent  recurrence of the non-
           compliance.

      Submittal of this  report does not constitute  a. waiver  of  the  emission
      limitations or other conditions of  this permit nor  does it in any  way
      restrict  the SAPCB's authority  to, enforce the permit conditions  pur-
      suant  to  Section 113 of the Clean' Air Act.
      (Section  120-02-11 of State Regulations)

14.   The permitted facility is  to  be constructed and  operated  as  represented
      in the permit application  referenced  in Condition 2 of  Part  I.   No
      changes in the permit application specifications or any existing  faci-
      lities shall be made which alter  the  emissions  into the ambient  air  or

-------
                                      State Permit  to Construct and Operate
                                      Atlantic Research Corporation
                                      Registration  No. 70033
                                      June 27, 1986
                                      Page 6
      alter the impact of the  facility on air quality without the prior writ-
      ten approval of the Board.
      (Section 120-02-11 of State Regulations)

15.   The facility shall operate in compliance with Rule 5-3, Non-Criteria
      Pollutants.  No changes  in ^the facility that alter emissions of any
      non-criteria pollutant or cause the emission of additional non-criteria
      pollutants shall be made without the prior written approval of the
1      Board.
      (Section 120-05-0305 of  State Regulations)

16.   This approval shall become invalid if construction of the proposed
      plant is not commenced within 18 months of the date this permit is
      issued or if it is discontinued for a period of 18 months.
      (Section 120-08-01 I of  State Regulations)

17.   In the event of any change in control of ownership of the permitted
      source, the permittee shall notify the succeeding owner of the
      existence of this permit by letter and send a copy of that letter to
      Director, Region VII.
      (Section 120-02-11 of State Regulations)

18.   The conditions of this permit are severable, and if any provision of
      this permit, or the application of any provision of this permit to any
      circumstance, is held invalid, the application of that provision to
      other circumstances, and the remainder of this permit, shall not be
      affected thereby.
      (Section 120-02-11 of State Regulations)

19.   This permit approval is  only applicable to the permit requirements of
      the State Air Pollution  Control Board and does not alter permit
      requirements by any other local, state, or federal government agency.
      Atlantic Research Corporation is cautioned that approval of this permit
      should not be construed  to mean its operation is automatically in
      compliance with all aspects of the Regulations for the Control and
      Abatement of Air Pollution.  State Air Board personnel will be
      constantly evaluating all sources.for compliance with Part V, Section
      120-05-0103 - Standard for Visible Emissions, Section 120-05-0104 -
      Standard for Fugitive Dust/Emissions, and Section 120-05-0203 -
      Standard for Odorous Emissions.  Compliance with all air pollution
      regulations must be a continuing, full time effort.
      (Section 120-02-11 of State Regulations)

 Annual requirements to fulfill legal obligations to maintain current sta-
 tionary source emissions data will necessitate your response to requests  for
 information to include, as appropriate:   fuel consumption by type, heat
 value,  sulfur and ash content; process and production data; refuse disposal

-------
                                         State Permit to Construct and Operate
                                         Atlantic Research Corporation
                                         Registration No. 70033
                                         June 27, 1986
                                         Page 7
    by incineration including auxiliary fuels burned;  storage, handling and use
    of liquid organic compounds;  and, changes in stack data, control equipment,
    and operating schedules.  Such requests for information from the Regional
    Office will either be in writing or by personal contact of field enforcement
    personnel.  Emissions data provided to the Board by a source must be made
    available to the public upon request;  process data for individual facilities
    and plants will be made available to the public upon request unless the
    source claims,  in writing, the information is proprietary and that it should
    be held as confidential.
    '(Section 120-02-31 of State Regulations)
P_ART III - DOCUMENT LIST

    1.    Atlantic Research Corporation permit application and supporting docu-
         ments,  dated April 7,  1986 (signed by Lambert Murphy).

    2.    State Air Pollution Control Board, Region VII memorandum to Division of
         Source  Evaluation, dated April 29, 1986 providing engineering eva-
         luation and draft permit letter with conditions and draft documents
         concerning public comment period.

    3.    State Air Pollution Control Board, Region VII letter to County
         Administrator,  Prince  William County, clrted April 23,  1986 requesting
         comments on permit application and informing intent to  conduct public
         hearing.

-------
                                         State Permit to Construct and Operate
                                         Atlantic Research Corporation
                                         Registration No. 70033
                 •••:                       June 27, L986
                                         Page 8

                     PART IV - SOURCE TESTING REPORT FORMAT

Cover
    1.   Plant name and  location
    2.   Source  sampled
    3.   Testing company or agency, name, address and report date

Certification
    1.   Certification by team leader
    2.   Certification by reviewer  (e.g., P.E.)

Introduction
    '1.   Test purpose
    2.   Test location,  type of process (indicate Reference No. used by source
                                         in permit or Registration)
    3.   Test dates
    4.   Pollutants tested
    5.   Observers' names (industry and agency)
    6.   Any other important background information

Summary of Results
    1.   Emission results
    2.   Process data as related  to determination of compliance (quantity of ink
         solvents used during text  and amount recovered)
    3.   Allowable emissions
    4.   Description of  collected samples
    5.   Visible emissions summary
    6.   Discussion of errors, both real and apparent

Source Operation
    1.   Description of  process and control devices
    2.   Process and control equipment flow diagram
    3.   Process data and results with example calculations
    4.   Representatives of raw materials and products
    5.   Any specially required operation demonstrated

Sampling and Analysis Procedures
    1.   Sampling port location and dimensioned cross section
    2.   Sampling point  description, including labeling system
    3.   Sampling train  description
    4.   Brief description of sampling procedures with discussion of deviations
         from standard methods           ...
    5.   Brief description of analytical procedures with discussion of
         deviation from  standard methods

Appendix
    1.   Complete results with example calculations
    2    Raw field data  (original,  not computer printouts)
    3.   Laboratory report with chain of custody
    4.   Raw production  data signed by plant official
    5.   Test log
    6.   Calibration procedures and results
    7.   Project participants and titles
    8.   Related correspondence
    9.   Standard procedures

-------
          APPENDIX U



BERYLLIUM PERMIT MODIFICATION

-------
ELIZABETH H HASKELL. CHAIRMAN
MARTI NSVILLE

CARL C. REDINGER. VICE CHAIRMAN
ALEXANDRIA

TIMOTHY E. BARROW
VIRGINIA BEACH

MANUEL OEESE
RICHMOND

WALLACE E. REED
CHARLOTTESVILLE
                                                                       DSE-695-*
COMMONWEALTH of VIRQINIA
       State Air Pollution Control Board
  RICHARD L (
EXECUTIVE DIRE
                                   BOOM 801. NINTH STREET OFFICE BUILDING
                                        POST OFFICE BOX 10089
                                       RICHMOND. VIRGINIA 23240

                                          (8041786-2378
                                      October 31, 1988
       Mr. Bud Kirkland
       Vice President  for  Administration
       Atlantic Research Corporation
       5390 Cherokee Avenue
       Alexandria, VA  22312
                                                    Location:  Prince William  County
                                                    Registration No.:   70033
                                                    County-Plant No.:   2520-0014
                                                    Serial No.:  539-88
       Dear Mr. Kirkland:
           The staff of  the  Department of Air Pollution Control has  reviewed  the
       request of September  12,  1988 from Melisa T. Cohen for the elimination  of
       ambient air sampling  from  the sampling procedures at the beryllium  rocket
       propellant laboratory and  test firing facility in Prince William County.
       The request is  approved.

           Accordingly,  the  Department of Air Pollution Control (formally  State
       Air Pollution Control  Board)  permit of June 27, 1986 is amended as  follows

           1.   Delete Part  I -  Specific Condition Number 6.

           2.   Amend  Part  I - Specific Condition Number 11 to read:

                     "11.  Upon  request of the Board, continuous emission
                     monitors will  be installed and operated  in accordance
                     with the monitoring plan to measure and  record  the
                     atmospheric  concentrations of the beryllium emitted
                     from the rocket propellent laboratory and test  firing
                     facility.  Monitors will be maintained and calibrated
                     in  accordance  with methods and procedures acceptable
                     to  the  Board.
                     (Section 120-06-04 of State Regulations)"
                                "fin fr'nual Ohtinrtiiijilv

-------
Mr. Bud Kirkland
October 31, 1988
Page 2
    All  other conditions  of  the  permit  letter of  June 27,  1986  remain  in
force.

                                     Sincerely,
                                   /Vs    .
                                 .  /yRichard L. Cook
                               4f\J Executive Director
RLC/da
C17/9.1
cc:  Assistant Executive  Director,  Regional Operations
     Director, Division of  Source  Evaluation, JES
     Director, Division of  Computer Services

     Director, Region  VII
     Springfield  Towers - Suite 502
     6320 Augusta Drive
     Springfield, VA  22150

     Director, Air Management  Division - EPA Region III

-------
               APPENDIX V



BERYLLIUM FACILITY OPERATOR TRAINING

-------
   RESEARCH CORPORATION
PROPULSION DIVISION


July 14, 1987

MEMORANDUM

TO:                Bob Lynch

FROM:               Melisa Cohen

SUBJECT:           Monthly Environmental Inspections of the KEW 2.5 Facility
                   June 1987

           The monthly environmental inspection of the KEW 2.5 facility was
conducted on June 30, 1987.  At the time of the inspection, the project was
in full compliance with the environmental permit requirements.

           Stack sampling has now been commenced with facility operations.   The
initial five days of sampling for the facility/Bofors Tank stack has been
completed and routine bi-monthly sampling will now be required.  The high altitude
tank has at this time, been stack sampled once.  The results of the sampling
have shown undetectable beryllium emissions thus far.

           The training of the KEW personnel  who will be conducting the sampling
has now been completed.  Full responsibility for the sampling and completion of
the test report, which must be sent to the EPA, will be given to this personnel
as soon as the SOP and new test report booklets are completed.  I will  continue
to be available for any environmental support needed with this activity.  I  do
recommend that sufficient materials for the stack sampling operation be procured,
particularily the glassware so that operations will not be held up due to an
incomplete sampling train.

           A few sampling requirement issues still need to be resolved.  Mike
Young and I will be meeting with the Air Board to investigate the possibility
of using an alternative beryllium analysis method, as well as to discuss what
actual ambient air sampling requirements are.  A meeting between KEW 2.5 management
and the Environmental Department needs to be scheduled sometime in July to discuss
the samplirfg of the high altitude stack requirements.

MTC:mh

cc:              v/M. Director
                   B. Kreitz
                   E. Muldor

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              APPENDIX W



VIRGINIA AIR CONTROL BOARD REGISTRATION

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COMMONWEALTH OF VIRGINIA
Stale Air Pollution Control Board
SECTION E-3 PROCESSING AND MANUFACTURING OPERATIONS
Company Nam*
Atlantic Research Corp.
Facility Operating Schadula
— 24 Hours/Day _§ 	 Oayi/Waak 52 Weeks/Year
Company Addrau
7511 Wellington Rd., Gainesville, VA 22065
Information For Calendar Yaw
19 83
Parion Computing Form
Mike Young
Registration Number
70033
Data
April 25, 1984
Ralaranca
Number
7
8
9
10

11



i ii«tt4
«#

Process or Oparalion Nama
Paint spray booth
Vapor degreaser (PCE) bldg 40
Vapor degreaser (freon) bldg 22
Vapor deereaser (PCE) bide 74
not vet in service ffiflUpiflted 	 > )
Rorlcef mnt-nr ripening (MKK)






Maximum Ratad
Capacity*
Tom/Hour
20 Ib/hr

not in









Normal Faad Input
H»X/ Hour
8 Ib/hr
<(l Ib/hr
jse at this

^Tlb/hr
4 1h/hr






Tom / Y«ar
2
.15
time

.IS
11






Numbar ol
Emission
Points into
Air
2
1


1
1






Normal Product Ouipul
TOBKM Hour
8 Ibs

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COMMONWEALTH OF VIRGINIA
$(•(• Alt Pollution Conliol Board

SECTION E 3  PROCESSING AND MANUFACTURING OPERATIONS
Person Completing Form
Mike Young
Data
April 25, 198
Huymrdhun Nuinbci
• 70033
Reference
Number
7
8
9
10
11







Sleek or Exhaust Oeie
Sleek
Height
Feel












Inside
Exit
Diameter
Feet












Exit Gel
Velocity
Feel/Minute












Exit Gat
Volume
ACFM ••












Exit Ges
Temperature
Degrees F












Air Pollution Control Equipment
Menulacturer end Model Number
none

T 1 i-^iu _u»Ll_rill J-rn^l- •*»•*. WWW,
Westinghouse Freon Ultrasonic Degreaser
Phillips Model //2CRU - 1012
solvent recovered







Type
(Use Codes
1-1




99







Collection Efficiency
Design












Actual




50%







                                                 •• ACFM - Actual Cubic Feel per Minute
                                     I • Air Pollution Control Equipment Identification Codas
                                        1.  Settling Chamber
                                        2.  Cyclone
                                        3.  Multicydone
                                        4.  Cyclone Scrubber
                                        6.  Orifice Scrubber
 6. Mechanical Scrubber
 7. Veniurl Scrubber
 8. Miit Eliminator
 9. Electrostatic Pracipitaior
10. Baghouw (Fabric Filter)
11. Catalytic Afterburner
12. Director Flame Afterburner
13. Packed Tomer
14. Carbon Adtorptton
16. Refrigerant Condenier
16. Refrigerated Liquid Scrubber
99. Other (Specify)
                                        For Wet Scrubbers. Lift Gallons per Minute Water Flow and
                                        Inches Wblar Pressure Drop Across Scrubber. II Known.
                               i 21

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                    APPENDIX X



LIST OF HAZARDOUS MATERIALS EXCEEDING 10,000 POUNDS

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                       ATLANTIC RESEARCH  CORPORATION

OPULSION DIVISION 7511 WELLINGTON RQ.  GAINESVILLE. VIRGINIA • 22C65-1S93
                                                  October 16,  1987
     Gainesville/Haymarket Volunteer
         Fire Department
     14941 Washington Street
     Haymarket, VA 22065

     Dear Sirs:

         In accordance with the provisions of Section 311  of the  Superfund
     Admendment and Reauthorization Act of 1986 this letter provides  a  list
     of hazardous materials present at the referenced- facility  in amounts equal
     to or greater than 10,000 pounds at any time during the previous year  (or
     are on the list of extremely hazardous substances).  Atlantic Research
     Corporation has opted to submit the chemicals by common name in  lieu of
     the submission of an MSDS for each hazardous chemical;  one of the  allowable
     alternative  reporting methods.
             Facility:
             CHEMICAL
                     ATLANTIC RESEARCH CORPORATION
                     5945 Wellington Road
                     Gainesville, VA 22065
         	                              CAS  j

Aluminum                                 007427-90-5
Carboxyl Terminated Polybutadiene        N/A
Polyvinyl Chloride                       009002-86-2
1,1,1, Trichlorethane                    000071-55-6
Hydroxy Terminated Polydutadiene         N/A
Dioctyl Adipate                          000101-23-1
Isophorone Oiisocyanate                  004098-71-9
Nitrogen                                 007727-37-9
Ammonium Perchlorate                     007790-98-9
Dioctyl Phthalate                        000117-81-7
Cyclotetramethelenetetrainitramine       002691-41-0
Methyl Ethyl Ketone                      000078-93-3
Carbon Dioxide                           000124-38-9
Iron Oxide                               001345-25-1

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PttOPULSION DIVISION

   Letter to:  Gainesvi11e/Haymarket Volunteer
     Fire Department
   Page 2

       Should  any  questions  remain outstanding relative to  this  letter,  or
   an MSDS on  the  aforementioned chemicals  is solicited,  please  contact  my
   office at  (703)642-6031.

                                                Si ncerely,

                                                ATLANTIC  RESEARCH  CORPORATION
                                                 \
                                                Richard  H.  Shults,  Jr.  C.S.P,
                                                Corporate  Safety  Manager

   RHS/mh

   Copies  to:

       Cynthia  Bailey
       Chairman,  Virginia  Emergency  Response
          Council
       James Monroe  Building
       17th Floor
       Richmond,  VA  23219
   and,
       Tom  Hajduk
       Division  Chief
       Fire and  Rescue  Services
       County  of Prince William
       1  County  Complex Court
       Prince  William,  VA  22193-9201

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