&EPA
United States
Environmental Protection
Agency
Headquarters
PM-215F
401 M Street, SW
Washington, D.C. 20460
April 1987
Environmental
Impact Statement
Final
Full Containment Facility
Andrew W. Breidenbach
Environmental Research Center
Cincinnati, Ohio
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FINAL ENVIRONMENTAL IMPACT STATEMENT
USEPA FULL CONTAINMENT FACILITY
CINCINNATI, OHIO
Prepared for
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
By
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
CHICAGO, ILLINOIS
with assistance from
SCIENCE APPLICATIONS INTERNATIONAL CORPORATION
McLean, Virginia
Approved by:
Raymond IJ . Lurt Ac
Engineering, Punm'ng
Architecture Branch
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
April 1, 1987
OFFICE OF
ADMINISTRATION
AND RESOURCES
MANAGEMENT
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS AND CITIZENS
The Final Environmental Impact Statement (EIS) for the Full
Containment Facility, Andrew W. Breidenbach Environmental
Research Center, Cincinnati, Ohio, is provided for your in-
formation and review. This EIS has been prepared in compliance
with the National Environmental Policy Act of 1969 and the
subsequent regulations prepared by the Council on Environmental
Quality and this Agency.
Upon publication of a notice in the Federal Register on April 10,
1987, a 30-day comment period will begin. Please send written
comTients to the attention of Russell N. Kulp, P- E. (PM-215),
U. S. Environmental Protection Agency, 401 M Street, S. W.,
Washington, D. C. 20460. After the close of the comment period,
a Record of Decision will be provided to all who received the
Final EIS.
I welcome your participation in the EIS process for the Full
Containment Facility.
Sincerely yours,
Raymond /J. LunfiAChi
Engineering, Planning'^rTTCr'Architecture Branch
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ABSTRACT
The USEPA proposed to build a free-standing full containment facility
adjacent to the Andrew W. Breidenbach Environmental Research Center (AWBERC)
in Cincinnati, Ohio. This EIS was prepared by USEPA because of concerns
expressed in response to an Environmental Assessment prepared in 1985.
On the basis of USEPA's Notice of Intent to prepare an EIS, the EA
prepared by SAIC, and the EIS scoping meeting held on February 4, 1986, the
following issues have been determined to be significant and are addressed in
this Final Environmental Impact Statement.
Procedures for handling hazardous and toxic materials and measures
used during potential emergency situations
Additional traffic and transportation of hazardous and toxic materials
increasing probability for accidents and spills in highly populated
area
Discharge of hazardous and toxic materials into the Metropolitan sewer
system
Effect on surrounding community of a serious accident in the FCF
Discharge of hazardous and toxic materials into the air and its effect
on the surrounding community
Assurance that the proposed facility will not be used for genetic
engineering experiments
o Assurance that no microbiological testing will occur without notifying
the public.
Two alternative structures were considered, as well as a no action
alternative. A free-standing building was selected as the best option for the
full containment research facility located at a 22-acre site in the Uptown
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University-Medical Complex in the center of the city of Cincinnati. No
wetlands, flood plains, significant natural areas or archaeological sites
exist in the study area and land is used primarily for institutional
development with some residential areas.
Wastes from the AWBERC full containment facility will include sample
residuals, spills, solvents, and wastewater from cleaning glassware,
noncontact water, emergency showers, sprinkler systems, and locker room
wastewater. Hazardous wastes will be transported for off-site disposal and
non-hazardous wastes will be discharged via sewers to the Mill Creek Sewage
Plant.
A public health risk assessment was conducted of potential long-term,
low-level release and catastrophic release of chemicals from the FCF. These
assessments were based on available information on the nature and quantities
of wastes anticipated to be present annually at the facility. Of the hundreds
of chemicals that might be present at the FCF over time, subsets of these were
selected as the basis of the evaluation giving consideration to quantity
handled, toxicity, and mobility. In evaluating the potential risks associated
with day-to-day operations, a worst-case assessment was conducted assuming
that the air filtering system removed none (02) of the contaminants that
entered the exhaust stream. EPA-approved complex terrain air dispersion
models were then used to project worst-case exposure levels to the surrounding
population. The results of the risk assessment indicated no substantial
increase in the risk of adverse health effects. For the catastrophic release
scenario, it was assumed that an explosion occurred in the FCF releasing toxic
chemicals to the atmosphere which then transported off-site. The results of
the exposure and risk assessments indicated that no adverse health effects
would be anticipated.
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TABLE OF CONTENTS
Page
_ ..y .
1. PURPOSE AND NEED FOR ACTION 1-1
1.1 PROJECT BACKGROUND 1-1
1.2 LEGAL BASIS FOR ACTION AND PROJECT NEED 1-2
1.3 EIS PROCESS, PUBLIC PARTICIPATION, AND FUTURE STEPS. . . 1-2
1.4 ISSUES 1-3
2. ALTERNATIVES CONSIDERED INCLUDING THE PROPOSED ACTION .... 2-1
2.1 NO ACTION 2-1
2.2 FREE-STANDING BUILDING 2-1
2.3 REMODEL SIXTH FLOOR OF EXISTING AWBERC BUILDING 2-9
2.4 OTHER ALTERNATVE SITES CONSIDERED 2-10
3. AFFECTED ENVIRONMENT 3-1
3.1 NATURAL ENVIRONMENT 3-1
3.1.1 Atmosphere 3-1
3.1.1.1 Climate 3-1
3.1.1.2 Air Quality 3-1
3.1.2 Land 3-1
3.1.2.1 Physiography 3-1
3.1.2.2 Surficial Geology 3-3
3.1.2.3 Soils 3-6
3.1.3 Water Resources and Water Quality 3-6
3.1.3.1 Groundwater 3-6
3.1.3.2 Streams 3-6
3.1.3.3 "Public Water Supplies 3-6
3.1.4 Terrestrial and Aquatic Biota 3-7
3.1.5 Other Natural Features 3-7
3.2 MAN-MADE ENVIRONMENT 3_7
3.2.1 Land Use 3_7
iii
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TABLE OF CONTENTS (Continued)
Page
3.2.1.1 Existing Land Use 3-8
3.2.1.2 Development Controls 3-10
3.2.1.3 Future Land Use Trends 3-10
3.2.2 Populations 3-11
3.2.2.1 Existing Residential Population 3-11
3.2.2.2 Existing Nonresidential Populations
and Economy 3-14
3.2.2.3 Future Populations 3-17
3.2.3 Transportation Facilities 3-17
3.2.4 Wastewater Transport and Disposal Facilities . . . 3-20
3.2.4.1 Residual Samples and/or Solvents
from Laboratory Analyses 3-20
3.2.4.2 Accidental Spills of Solvents
and/or Analytical Samples 3-21
3.2.4.3 Wash Waters From Cleaning
Glassware 3-21
3.2.4.4 Noncontact Water 3-22
3.2.4.5 Emergency Shower and Sprinkler
System Water 3-22
3.2.4.6 Locker Room Sink and Shower Water .... 3-22
3.2.4.7 City Sanitary Sewer Configuration .... 3-22
4. ENVIRONMENTAL CONSEQUENCES 4-1
4.1 PRIMARY IMPACTS 4-1
4.1.1 Construction Impacts 4-1
4.1.1.1 Groundwater 4-1
4.1.1.2 Land Use 4-2
4.1.1.3 Population 4-2
4.1.1.4 Transportation 4-3
4.1.2 Operation Impacts 4-3
4.1.2.1 Risks to Human Health 4-3
4.1.2.1.1 Overview 4-4
4.1.2.1.2 Assessment of Risks of Long-
Term, Low-Level Exposure . . . 4-7
4.1.2.1.3 Assessment of Risks of
Catastrophic Release 4-27
4.1.2.1.4 Interpretation of the Results
of Risk Assessment 4-41
iv
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TABLE OF CONTENTS (Continued)
4.1.2.2 Land Use/Demography 4-46
4.1.2.3 Transportation 4-46
4.2 MITIGATION OF ADVERSE IMPACTS 4-47
4.2.1 Mitigation of Construction Impacts 4-47
4.2.2 Mitigation of Operational Impacts 4-47
4.2.2.1 Potential Impacts to Human Health -
Release of Toxic Substances to the
Atmosphere 4-48
4.2.2.2 Potential Impacts to Human Health and
Aquatic Life - Release of Toxic
Substances to the Mill Creek POTW .... 4-48
4.2.2.3 Potential Impacts to Laboratory
Workers - Hazardous Waste Storage
Accidents 4-49
4.2.2.4 Potential Impacts to Laboratory
Workers - Chemical Storage Accidents. . . 4-49
4.2.2.5 Potential Impacts to Populations Along
Transportation Routes 4-49
4.3 UNAVOIDABLE ADVERSE IMPACTS ....... 4-51
4.4 IRRETRIEVABLE AND IRREVERSIBLE RESOURCE COMMITMENTS . . . 4-51
4.5 EIS RECOMMENDED ACTION 4-51
5. RESPONSE TO COMMENTS ON THE DRAFT EIS 5-1
5.1 RESPONSE TO COMMENTS FROM THE PUBLIC HEARING 5-1
5.2 CORRESPONDENCE FROM FEDERAL AGENCIES 5-4
5.3 CORRESPONDENCE FROM PRIVATE CITIZENS 5-4
5.4 CORRESPONDENCE FROM STATE AGENCIES 5-5
6. LIST OF PREPARERS 6-1
7. GLOSSARY OF TECHNICAL TERMS. 7-1
8. LITERATURE CITED 8-1
9. ACRONYMS 9_1
10. INDEX_
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TABLE OF CONTENTS (Continued)
APPENDIX A - AWBERC-PROVIDED MATERIAL
APPENDIX B - TOXIC SUBSTANCE CONTROL MANUAL
APPENDIX C - CORRESPONDENCE RECEIVED PERTAINING TO DRAFT
ENVIRONMENTAL IMPACT STATEMENT, FULL CONTAINMENT
FACILITY, CINCINNATI, OHIO
vi
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LIST OF FIGURES
Page
Figure 2.1 New Free-Standing Building, Full Containment Facility 2-2
Figure 2.2 Floor Plan - Free-Standing Building 2-3
Figure 3.1 Topography of Uptown Area of Cincinnati 3-4
Figure 3.2 Cross-sections of Topographical Layout of Uptown Area 3-5
Figure 3.3 Land Use and Activitiy Areas Surrounding the
AWBERC Facility 3-9
Figure 3.4 1980 Cincinnati Census Tract Map 3-12
Figure 3.5 Access to the AWBERC Facility 3-18
Figure 3.6 Traffic Counts in the Vicinity of AUBERC 3-19
Figure 4.1 Annual Average Unit Concentration Factor (ug/m3)
due to Emission from the Proposed Full Containment
Facility 4-24
vii
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LIST OF TABLES
Page
Table 3-1 1985 Pollutant Standards Index - Monthly Ranges
and Averages 3-2
Table 3-2 Residential Populations of Census Tracts Near
AWBERC - 1980 Census 3-13
Table 3-3 Age and Race Composition of Population in Census Tracts
Near AWBERC - 1980 Census 3-15
Table 3-4 Uptown Institutions and Associated Populations 3-16
Table 4-1 Proposed Studies, Surveys, and Services at the FCF 4-8
Table 4-2 Types and Estimated Quantities of Contaminated Wastes
Received on an annual Basis 4-10
Table 4-3 Total Quantities of Subject Chemicals Handled Annually
At the FCF: Long-term, Low-level Release 4-12
Table 4-4 Characterization of Subject Carcinogenic Compounds 4-17
Table 4-5 Source Term Estimates for Long-Term, Low-Level Release 4-21
Table 4-6 Exposure and Dose Estimates for Subject Carcinogens 4-25
Table 4-7 Risk Characterization, Long-Term, Low-Level Release 4-28
Table 4-8 Total Quantities of Subject Chemicals Handled Annually
At the FCF: Catastrophic Release 4-30
Table 4-9 Toxicity Endpoints for Subject Compound Short-Term
Catastrophic Release 4-32
Table 4-10 Release Rates and Maximum Exposure Levels Short-Term
Catastrophic Release 4-34
Table 4-11 Maximum One-hour Exposure Level 4-36
Table 4-12 Risk Characterization Short-Term, Catastrophic
Release 4-42
viii
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1. PURPOSE AND NEED FOR ACTION
1.1 PROJECT BACKGROUND
The Andrew W. Breidenbach Environmental Research Center (AWBERC) conducts
testing, research and development in support of the U.S. Environmental
Protection Agency's (USEPA) pollution control programs. To date, research and
development on the use and handling of highly toxic and hazardous materials
has been limited due to the lack of suitable facilities. No known full
containment facility (FCF) for research on these materials currently exists in
the United States.
The USEPA is proposing to build a free-standing, full containment
research facility on its own property adjacent to the existing AWBERC
building. The initial facility plans are presented in the 1985 Concept
Development Plan for a Full Containment Facility, prepared by KZF,
Incorporated.
The study area addressed in this draft environmental statement (DBS) is
located in the city of Cincinnati in the southwest corner of Ohio. The
proposed project site is in the central portion of Cincinnati adjacent to the
University of Cincinnati-Medical complex about one-half mile south of the
Cincinnati Zoo.
In May 1985, Science Applications International Corporation (SAIC 1985a)
prepared an Environmental Assessment (EA) for the proposed facility. Impacts
addressed in the EA include:
Traffic
Air Quality
o Wastewater
Solid Wastes
Internal Waste Handling
Water
Construction Operations
Parking
Noise
Aesthetics/Landscaping.
1-1
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Upon completion of the EA, USEPA issued a Finding of No Significant Impact
(FNSI).
In response to the FNSI issuance, USEPA received a number of comments
regarding the proposed project. Because of these concerns, USEPA issued a
press release, dated October 7, 1985, indicating its interest in preparing an
Environmental Impact Statement (EIS). The Notice of Intent to prepare this
EIS appeared in the December 27, 1985 Federal Register. A scoping meeting was
held for the EIS on February 4, 1986.
1.2 LEGAL BASIS FOR ACTION AND PROJECT NEED
The National Environmental Policy Act of 1969 (NEPA) requires a Federal
agency to prepare an EIS on "...major Federal actions significantly affecting
the quality of the human environment..-" In addition, the Council on Environ-
mental Quality (CEQ) has established regulations (40 CFR Parts 1500-1508) to
guide Federal agencies in determining whether expenditures of Federal funds or
Federal approvals would result in a project that would significantly affect
the environment. USEPA has developed its own regulations (40 CFR Part 6) for
the implementation of the NEPA review. Because of the concerns expressed in
response to the EA, the USEPA decided to prepare an EIS.
1.3 EIS PROCESS, PUBLIC PARTICIPATION, AND FUTURE STEPS
In the Cincinnati FCF study area, participants in the planning process
have included: the city of Cincinnati (Mayor and Deputy Mayor, Environmental
Advisory Council), Ohio EPA, USEPA-Headquarters and Region V, SAIC (EIS
Consultant), and other Federal, State, local, and private organizations.
An EIS scoping meeting (required under NEPA) was held February 4, 1986 at
the AWBERC facility in Cincinnati. No additional issues, other than those
outlined in the December 27 Federal Register, were identified during the
meeting.
1-2
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A public hearing was held February 23. 1987 at the AWBERC facility. The
draft EIS was made available to the public 30 days prior to the hearing. The
comment period on the draft EIS closed March 10 at which time the comments
received to date were incorporated in the final EIS.
1.4 ISSUES
On the basis of USEPA's Notice of Intent to prepare an EIS, the EA
prepared by SAIC, and the EIS scoping meeting held on February 4, 1986, the
following issues have been determined to be significant and are addressed in
this DBS.
Procedures for handling hazardous and toxic materials and measures
used during potential emergency situations
Additional traffic and transportation of hazardous and toxic
materials, increasing probability for accidents and spills in highly
populated areas
Discharge of hazardous and toxic materials into the Metropolitan sewer
system
Effect on the surrounding community of a serious accident in the FCF
Discharge of hazardous and toxic materials into the air and its effect
on the surrounding community
Assurance that the proposed facility will not be used for genetic
engineering experiments
Assurance that no microbiological testing will occur without notifying
the public.
1-3
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2. ALTERNATIVES CONSIDERED INCLUDING THE PROPOSED ACTION
2.1 NO ACTION
A no action alternative was considered and eliminated because it would
not meet the programmatic needs of USEPA in furthering research and
development in the area of toxic chemicals.
2.2 FREE-STANDING BUILDING
The principal option currently considered for the USEPA FCF is a
free-standing building to be constructed approximately 90 feet from the
existing AWBERC laboratory. The free-standing building would be situated as
shown in Figure 2-1. The free-standing building is to occupy 6,743 square
feet (as floor space). A floor plan of the proposed laboratory is shown in
Figure 2-2 (KZF 1986).
The laboratory facility will include the following rooms:
Waste sample log-in room
Sample storage room
Special handling room
Organics laboratories
Inorganics laboratory
Balance room
Water Engineering Research Laboratory (WERL)
Hazardous Waste Engineering Research Laboratory (HWERL)
Environmental Monitoring and Support Laboratory (EMSL)
Shower/locker rooms
Glove box room.
The sample log-in room will be used to receive samples and to file
chain-of-custody, sample log-in, and staffing sheets for samples. Samples
received will be stored in the sample preservation room. This room will be
specially designed to permit cold storage of samples, as well as storage of
flammable solvents and samples containing highly toxic substances (PCBs,
dioxins, etc.). The special handling room is to be used for carrying out
sample extraction and other work-up techniques prior to analysis.
2-1
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\
7 .- «i»nri*
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FLOOR PLAN
Figure 2.2 Floor Plan - Free-Standlng Building
Source: KZF, Incorporated 1986
2-3
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It is expected that highly toxic organic and inorganic substances will be
processed in this room. The room is to be equipped with two fume hoods and
two glove boxes for use in sample handling and processing.
The organics laboratories will be used for analysis of samples containing
hazardous organic material. These rooms will house specialized instrumen-
tation for organic chemical analysis, such as a gas chromatograph (GC), gas
chromatograph/mass spectrophotometer (GC/MS), high resolution GC/MS, and/or
high performance liquid chromatography (HPLC) apparatus. A fume hood will be
installed in each organics laboratory. The inorganics laboratory will be used
for analyzing samples containing toxic inorganic contaminants. Instrumen-
tation for analysis of samples containing metal contaminants, such as atomic
absorption (AA) equipment, will be used in this room. This laboratory also
will be equipped with a fume hood.
Precise measurements of sample weights will be conducted in the balance
room, using sensitive laboratory balances. Traffic through this room
consequently should be kept to a minimum.
The Water Engineering Research Laboratory (WERL) will be used for
projects involving drinking water and wastewater research. WERL laboratory
space will be used for toxics treatability studies on various treatment
technologies. Toxics involved in these studies will include priority
pollutants, azo dyes, and other chemical substances as designated by USEPA's
Office of Toxic Substances. A provision will be made for disposal of
residuals from pilot-scale treatment units. These residuals can be expected
to consist of biological sludges and/or spent activated carbon contaminated
with the above-listed toxic substances. WERL is to perform pilot-plant
studies on the removal of low levels of toxics in water. The WERL laboratory
will be equipped with a fume hood. Glove boxes also will be installed for
preparing samples and spike samples for dioxin/dibenzofuran analysis.
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The Hazardous Waste Engineering Research Laboratory (HWERL) will be used
for studies on the characterization, destruction and detoxification of toxic
and hazardous materials. Materials to be studied in this laboratory will con-
tain highly toxic contaminants, including dioxins, dibenzofurans, PCBs, etc.
The HWERL laboratory will be equipped with a fume hood and glove boxes for
handling samples containing these highly toxic substances. HWERL's work will
include, in part, studies of soils containing hazardous components.
Special provisions will be made for chemical handling and waste disposal
in this area, owing to the highly toxic nature of the chemicals involved.
Current HWERL contractors for laboratory analysis of samples for dioxins are
required to wear special protective clothing and self-contained breathing
apparatus in their laboratory. A similar requirement may exist for all
personnel handling dioxins and dibenzofurans in the new USEPA facility,
depending on the quantities, tests and engineering controls applied.
The EMSL (Environmental Monitoring and Support Laboratory) will be used
for preparation of quality assurance samples for use by regional, State, and
local regulatory agencies' laboratories. Research also will be conducted in
the EMSL laboratory to develop new laboratory procedures for analysis of
samples for toxic contamination. The EMSL laboratory can be expected to
process trace amounts of highly toxic substances in pure or highly concen-
trated form. This laboratory will be equipped with a fume hood for use in
sample preparation.
No genetic engineering experiments will be conducted at the facility.
The proposed USEPA laboratory will conform with the toxic substances
control policies of USEPA (USEPA 1982). These policies include installation
of the following facilities in all laboratories conducting experiments with
toxic substances:
Handwashing Facility. A handwashing facility must be available within
each work area.(Tnis need not be a facility used exclusively for
handwashing). The use of liquid soap is recommended. In new
facilities, foot or elbow operated faucets should be provided.
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Shower Facility. A shower facility, other than emergency drench
showers, must be located in the building in which toxic substances are
used. The shower facility must be available at all times. Shower
facilities adjacent to the work areas are highly recommended.
Eye Wash Facility. An emergency eye wash facility must be located in
each laboratory. The eye wash facility should be designed to wash
both eyes at the same time with a continuous stream of potable water.
Exhaust Air from Primary Containment Equipment. The exhaust air from
glove boxes must be treated by filtration, reaction, absorption,
adsorption, electrostatic precipitation or incineration, as appro-
priate, depending on the nature of the compound. The need for, and
type of, treatment for other primary containment equipment, including
laboratory fume hoods and biological safety cabinets, must be deter-
mined by the Chief Safety Officer. Exhaust air treatment systems that
remove toxic substances from the exhaust air by collection mechanisms
such as filtration, absorption, and adsorption must be serviced in a
manner that avoids direct contact with the collection medium. Trained
maintenance employees may remove the spent collection medium with a
bag-in/bag-out collection system or must be garbed in appropriate
personal protective clothing and equipment. All exhaust air from
primary containment equipment must be discharged by roof-mounted
blowers to the outdoors so that such air is dispersed clear of
occupied buildings and air intakes.
Exhaust Ventilation. A mechanical exhaust ventilation system must be
provided for controlling laboratory room air movement. The movement
of air must be from areas of lower contamination potential to areas of
higher contamination potential (i.e., from entry corridors to the
laboratory). This directional air flow may be achieved by a common
building exhaust system, provided that the exhaust air is not recir-
culated to any other area of the building. The exhaust air from
laboratory areas must be discharged outdoors in a way that entry into
that or any other building's air supply is minimized. Exhaust air
from laboratory areas that is not derived from primary containment
equipment can be discharged to the outdoors without being treated.
In addition, the proposed USEPA laboratory will conform with the following
USEPA policies (USEPA 1982) regarding operational practices:
Work Area Identification. Entrances to all work areas where toxic
substances are being used or stored must be posted with signs bearing
the legend: CAUTION - TOXIC SUBSTANCE - Authorized Personnel Only,
followed by the name of Principal Investigator.
Access Control. Work areas where toxic substances are used or stored
may be entered only by persons authorized by the Principal
Investigator. Access doors to work areas must be kept closed while
experiments with toxic substances are in progress.
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Work Surfaces. All work surfaces (bench tops, hood floors, etc.) on
which toxic substances are used must be covered with stainless steel
or plastic trays, dry absorbent plastic-backed paper, or other
impervious material. The protective surfaces must be examined for
possible contamination immediately after each procedure with a toxic
substance has been completed. Contaminated surfaces must be
decontaminated or disposed of as described in the Safety Plan.
Use of Primary Containment Equipment. Procedures involving volatile
toxic substances and those involving solid or liquid toxic substances
that may result in the generation of aerosols must be conducted in a
laboratory fume hood, a glove box, or other containment equipment
approved for toxic substances by the Chief Safety Officer. Examples
of aerosol-producing procedures are: the opening of closed vessels,
transfer operations, weighing, and preparation of mixtures. Primary
containment equipment used for containment of toxic substances must
display a label bearing the legend: CAUTION-TOXIC SUBSTANCE. All
bidding documents and installation plans for primary containment
equipment must be reviewed by the Facilities Management and Services
Division prior to procurement.
Use of Analytical Instrumentation. Toxic vapors or aerosols produced
by analytical instruments must be captured through local exhaust
ventilation or an appropriate trap at the site of their production.
The instruments may be placed entirely within a laboratory fume hood
if this will not impair hood performance (i.e., towards the back and
raised on legs to minimize turbulence of inflowing air). When a
sample is removed from the analytical instrument, it must be placed in
a tightly stoppered sample tube or otherwise prevented from con-
taminating the laboratory. In the event that the analytical equipment
becomes contaminated, it must be labeled "CAUTION - TOXIC SUBSTANCE"
until it has been completely decontaminated. This operational
practice applies to analytical equipment even when it is only
infrequently used for toxic substances.
Use of Respirators as Personal Protective Devices. A respirator use
program must be provided for emergency and maintenance personnel who
enter areas where a potential for inhalation exposure to a toxic
substance is present. This program will meet the requirements of the
Occupational Safety and Health Administration (OSHA) General Industry
Standards for respiratory protection, as detailed in 29 CFR 1910.134.
The respirators must be certified in accordance with the requirements
of the National Institute for Occupational Safety and Health (NIOSH)
under the provisions of 30 CFR Part 11. The selection and use of
respirators must be approved by the Chief Safety Officer.
Storage Inventory and Identification. Stock quantities of toxic
substances must be stored in a specific storage area that is secured
at all times. The storage area must be posted with a sign bearing the
legend: CAUTION - TOXIC SUBSTANCE - Authorized Personnel Only.
Principal Investigators must maintain inventory records of toxic
substances for which they are personally responsible and must provide
copies to the Chief Safety Officer. The inventory records must
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include the quantities of toxic substances acquired and dates of
acquisition and disposition. Storage vessels containing stock
quantities must be labeled: CAUTION - TOXIC SUBSTANCE. Additional
storage precautions may be required for compouunds with properties
such as flammability, radioactivity, etc.
Working Quantities. Quantities of toxic substances present in the
work area must not exceed the amounts required for use in one week or
the limits set by III.A. This does not include amounts stored in a
specific toxic substance storage area or cabinet that is located
within the laboratory work area. Storage vessels containing work
quantities must be labeled: CAUTION - TOXIC SUBSTANCE.
Laboratory Transport. Storage vessels containing toxic substances
must be placed first in an unbreakable outer container before being
transported to the laboratory work areas. Good standard transfer
practices must be used. Freight elevators must be used to transfer
regulated substances from one floor to another. Plastic-coated glass
bottles with polypropylene caps, which can satisfy a 4-foot drop test,
are currently available and can serve as both the storage vessel and
the unbreakable outer container combined. Contaminated materials
that are transferred from work areas to disposal areas must first be
placed in a closed plastic bag or other suitable impermeable and
sealed primary container. The primary container must be placed in a
durable outer container before being transported. The outer container
must be labeled with both the name of the toxic substance and the
warning: CAUTION - TOXIC SUBSTANCE.
Housekeeping. General housekeeping procedures that suppress the
formation of aerosols, such as the use of a wet mop or a vacuum
cleaner equipped with a High-Efficiency Particulate Absorption (HEPA)
filter to remove particulates, must be used. Dry sweeping and dry
mopping are prohibited because of the hazard of aerosol formation.
Training of personnel in appropriate cleaning techniques to avoid or
minimize exposure is the responsibility of the Principal Investigator.
In those instances where the toxic substance or contaminated material
is spilled, special procedures developed for the individual compounds
must be followed, as described in the approved Safety Plan.
Protection of Vacuum Lines. Each vacuum service, including water
aspirators, must be protected with an absorbent or liquid trap and a
HEPA filter to prevent entry of any toxic substance into the system.
When using a volatile toxic substance, a separate vacuum pump or other
device approved for toxic substances must be used.
Decontamination. Contaminated materials must either be decontaminated
by procedures that decompose the toxic substance to produce a safe
product or be removed for subsequent disposal. Toxic substances that
have spilled out of a primary container so as to constitute a hazard
must be inactivated in situ or must be absorbed by appropriate means
for subsequent disposalAdequacy of clean-up must be tested with
wipe-test or fluorescence tests or by other appropriate means, as
described in the approved Safety Plan.
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Handling and Disposal. Prior to the start of any laboratory activity
involving a toxic substance, plans for the handling and ultimate
disposal of contaminated wastes and surplus amounts of the toxic
substance must be completed. The Principal Investigator and Chief
Safety Officer should jointly determine the best methods available
that are in compliance with Federal, State and local codes and
ordinances.
USEPA Toxic Substances Control Manual (See Appendix B).
PERSONNEL PRACTICES
Laboratory personne.. must observe the following rules:
Precautionary Considerations
- Know the safety rules and procedures that apply to the work being
done; note the appropriate safety precautions and potential hazards
before beginning any operation.
- Review the applicable emergency procedures; know where the
emergency equipment is located, how to use it, and how to obtain
help in an emergency.
- Assure the availability of the proper protective equipment and use
the proper type for each operation.
Safety precautions will be incorporated in the research plans developed for
any hazardous materials experiments to be conducted at the FCF.
2.3 REMODEL SIXTH FLOOR OF EXISTING AWBERC BUILDING
As an alternative to the free-standing building, USEPA has considered
remodeling the sixth floor of the existing AWBERC building to accommodate the
FCF- The sixth floor space of the existing AWBERC building comprises 7,500
square feet of gross floor space.
Remodeling the AWBERC sixth floor is generally considered a secondary
option for the following reasons:
The hazard and nuisance involved with transporting toxic, flammable,
and/or corrosive chemicals between the first and sixth floors of
AWBERC
2-9
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Expected difficulties associated with the engineering aspects of waste
disposal from the sixth floor of an existing building (e.g., instal-
ling air ducts and filters, plumbing associated with laboratory sink
drains, etc.)
Larger population at risk of immediate exposure to toxic chemicals in
the event of an accident
The loss of this space for conventional laboratories.
2.4 OTHER ALTERNATIVE SITES CONSIDERED
An off-site location and the sixth floor of AWBERC were considered as
alternatives. The off-site location was eliminated from the preliminary
design because its distant location would not have met programmatic needs.
A remote location was inconvenient for staff and administration. Staff from
the existing AWBERC facility require easy access to the FCF for supplies and
administrative support and for access to AWBERC experts for consultation. The
sixth floor location also was eliminated, because the existing site could not
adequately accommodate the necessary facilities.
2-10
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3. AFFECTED ENVIRONMENT
3.1 NATURAL ENVIRONMENT
3.1.1 Atmosphere
3.1.1.1 Climate
The Cincinnati regional climate is basically continental, with a wide
range of temperature. Cincinnati is subject to frequent changes in wsather
due to the passage of numerous cyclonic storms in the winter and spring, and
thunderstorms in the summer. The thunderstorms may be accompanied by hail and
strong winds as well as tornados. The fall season has less rainfall and an
abundance of sunny days and comfortable temperatures.
The Cincinnati area receives an average of 39.5 inches of precipitation
annually, including about 20 inches of snowfall. During 231 days of the year,
the precipitation is received in increments of less than 0.01 inches. Average
wind speed is 9.1 miles per hour, and the prevailing direction is from the
south-southwest (National Weather Service 1986).
3.1.1.2 Air Quality
Air stagnation and associated high pollution periods may occur 40 to 50
days per year based on the 10-year period 1960-1970. During the 1936-1970
period, a total of about 140 stagnation days were identified (Southwestern
Ohio Pollution Control Agency 1985).
Air quality in the area of the AWBERC facility is largely determined by
high traffic volumes. Monthly ranges and averages for the pollution standards
index for Hamilton County are shown in Table 3-1.
3.1.2 Land
3.1.2.1 Physiography
The proposed project site is located at the southern edge of Ohio's
Glacial Till Plain physiographic province. However, only one element
3-1
-------
TABLE 3-1. 1985 POLLUTANT STANDARDS INDEX - MONTHLY RANGES AND AVERAGES
Hamilton/Clermont Counties
MONTH
January
February
March
April
May
June
July
Augus t
September
October
November
December
HIGH
59*
60
59
78
70
77
100
75
82
61
54
68
LOW
15
26
22
27
24
37
35
39
37
25
13
21
MONTHLY
AVERAGE
35
43
41
48
51
54
63
56
56
45
31
37
1-50 Good
51-100 Moderate
101-199 Unhealthful
Source: Southwestern Ohio Air Pollution Control Agency Data Sheet, 1985.
3-2
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constitutes the physical setting of the project site, and that is hill and
valley formation with slopes exceeding 15 percent.
The topography of the Uptown area of Cincinnati (the area encompassing
the AWBERC facility) ranges in elevation from 500 to above 850 feet and
contains significant hills north, south, and west of the proposed site (Figure
3-1). The hillsides are generally susceptible to landslides, depending upon
soil type, topography, and geology. Cross-sections of the topographical
layout of the Uptown area and the location of the EPA facility are provided in
Figure 3-2.
3.1.2.2 Surficial Geology
The significant geological feature of the study area is its hillside
bedrock and stability. Between 450 and 750 feet above sea level, a
sedimentary formation of alternating layers of limestone and shale is
prominent. This formation, identified as the Kope or Eden Formation of the
Cincinnati Series, is typically composed of 80 percent shale and 20 percent
limestone and is visible along deeper stream valleys. The Kope Formation is
important because of its instability when exposed during construction.
Typically, the weathering process makes the formation soft and highly
susceptible to landslides in certain areas.
The proposed facility is a small, two-story building. Significant
disruption of the soils will not occur during construction. Four soil borings
were taken in May 1986 by Soil and Material Engineering Incorporated. The
borings ranged from 15 to 24 feet. Lean clay and weathered shale were
encountered at depths ranging from 2 to 10 feet and 7.5 to 17 feet,
respectively. KZF Engineering used the rusults of the borings to plan the
foundation of the FCF. (KZF pers. comm. 3/10/87.)
The FCF is designed based on a seismic zone 2 even through the immediate
vicinity is zoned 1 (a lower potential seismic activity rating). The nearest
seismic 2 zone is 50 miles from the proposed FCF.
3-3
-------
Figure 3.1 Topography of Uptown Area of Cincinnati
Source: City of Cincinnati, City Planning Department
Preliminary Reconnaissance - Uptown Today,
1986
Uptown Boundary
500 - 550tt
551 - 600ft
601 - 650ft.
f||| 65,1 - 700ft.
:$;i||i 701 - 750ft.
751'BOOK*
80T- 851ft »
851 - and up
3-4
-------
o
u>
SECTION B
SECTION A
SECTION A
SECTION B
»«o» I»M««
SECTION B
SECTION B
Figure 3.2 Cross-sections of Topographical Lay-out of the Uptown Area
Source: City of Cincinnati, City Planning Department,
Preliminary Reconnaissance - Uptown Today, 1986
-------
Based on these factors and the presence of numerous large commercial and
institutional buildings in the immediate vicinity, potential landslide impacts
are not of concern.
3.1.2.3 Soils
Soils in the vicinity of AWBERC are classified as RtB, Rossmoyne, in the
Hamilton County soil survey. Depth to bedrock is greater than 60 feet. Soil
composition is 1 to 3 percent organic matter and 13 to 45 percent clay
(percent clay increases with depth). Permeability at 0 to 26 inches is 0.6 to
2 inches per hour. It decreases to 0.06 to 0.2 inches per hour at depths
greater than 26 inches.
3.1.3 Water Resources and Water Quality
3.1.3.1 Groundwater
The project site is located in the upland area composed of extensive
deposits .of glacial till overlying limestone and shale bedrock. Groundwater
between June and December is for the most part insignificant, with potential
yields of less than 5 gallons per minute. The depth of groundwater during
this time is estimated to be at approximately 295 feet below the surface of
the project site. A perched high water table occurs between January and April
1.5 to 3.0 feet below the surface (Hamilton County Soil Survey undated).
3.1.3.2 Streams
No natural streams occur within a close proximity to the proposed project
site. A lake has been constructed in Burnet Woods, approximately two city
blocks from the present AWBERC building. Overflow from the lake flows beneath
Brookline Drive northwest of AWBERC to a waterfall constructed of rock and
terminates in a combined sewer that parallels the lake. The lake does not
have a drainage structure of any kind, except for overflow at the waterfall.
3.1.3.3 Public Water Supply
The main source of drinking water for Hamilton County and the City of
Cincinnati is the Ohio River. Over 100 million gallons are taken daily from
3-6
-------
the Ohio River by means of a submerged intake crib near the Kentucky shores,
opposite the suburb of California.
The Cincinnati Water Works, owned and operated by the City of Cincinnati,
serves 23 municipalities and villages and most of the unincorporated area of
the county. It also serves part of Butler County and part of Warren County.
3.1.4 Terrestrial and Aquatic Biota
Terrestrial communities in the project vicinity are largely confined to
an urban environment with corridors for parks and greenways. Birds compose
the most abundant and diverse portion of the wildlife population. The
Hamilton County Park District identified as many as 76 different species in
the nine county-owned parks in one winter season. Migrating waterfowl have
been sighted in the Burnet Woods Lake.
Mammals in the project area are generally limited to those species common
to suburbanized areas, including opossum, mole, raccoon, skunk, squirrel,
chipmunk, rabbit, and various rodents. No known threatened or endangered
species occur in the project area.
Plant communities in the area are plantings on the institutional grounds
and woods typical of Eastern Mesophytic forests. The deciduous canopy is
dominated by white and green ash, sugar maple, cottonwood, elm, black willow,
sycamore, hackberry, box elder, and yellow poplar. The steeper hillsides are
similar but with an introduction of various hickories and oaks.
3.1.5 Other Natural Features
There are no wetlands, floodplains, significant natural areas, or
archaeological sites in the study area. Therefore, no impact on these
features would be expected from the proposed facility.
3.2 MAN-MADE ENVIRONMENT
3.2.1 Land Use
3-7
-------
3.2.1.1 Existing Land Use
The AWBERC site is located on 22 acres in the middle of Cincinnati's
Uptown University-Medical complex. The AWBERC facility is bordered by Nixon
and West Nixon Streets (north), West Saint Clair Street (south), Vine Street
(east), and the backs of residences and offices that front on Bishop Street
(west). The site is nearly in the geographic center of Cincinnati.
The EPA facility contains a ten-story laboratory and office building,
support facilities, parking, and landscaped areas. Abutting land uses include
apartments, houses, small businesses and office space, and the University of
Cincinnati campus.
Surrounding land uses are shown by the map in Figure 3-3. The area
surrounding AWBERC is dominated by high density institutional development.
The east side of the University of Cincinnati campus borders AWBERC to the
south. Major medical facilities within a half-mile of AWBERC include the
University of Cincinnati Nursing School, Veterans Administration Hospital,
University Hospital and College of Medicine, Holmes Hospital, Children's
Medical Center, Jewish Hospital, the Shriner Burns Institute, Rollman's
Psychiatric Hospital, and Good Samaritan Hospital.
Other major institutional land uses within a mile of AWBERC include
Hebrew Union College, several schools (Rockdale, Condon, Columbian, Taft,
Merry, Hughes, Fairview, Clifton, AHC/South Avondale), several more hospitals
(Christ, Bethesda, and Deaconess), and the Cincinnati Zoo. In addition to the
zoo (about half a mile north of AWBERC), major recreational land uses in the
vicinity include Burnet Woods (100 feet west of AWBERC) and Corryville
Playground (east of the School of Nursing). Several small business and office
areas catering to the medical complex and the university population are
located near AWBERC to the northwest (Jefferson Avenue), directly north
(Glendora Avenue), and southeast (University Village).
The vicinity of the AWBERC facility also contains some relatively
low-density residential neighborhoods, mainly in the Clifton area, to the
north and west of AWBERC, in Corryville to the southeast, and across the
3-8
-------
Figure 3.3 Land Use and Activity Areas Surrounding the AWBERC Facility
Source: city of Cincinnati, City Planning Department,
Preliminary Reconnaissance - Uptown Today, 1986
3-9
-------
University of Cincinnati campus in the Clifton Heights, University Heights,
and Fairview neighborhoods. Avondale, to the northeast of the medical
complex, is also a low-density residential neighborhood.
3.2.1.2 Development Controls
The major development controls that apply to the AWBERC complex and
surrounding vicinity are the City of Cincinnati's zoning, building, and fire
ordinances. The city is implementing its local development plans through the
use of these standard mechanisms.
Zoning designations in the vicinity of the existing AWBERC facility are
mainly R-3 through R-6, B-3, and B-4. The site itself is zoned R-5, which
also permits single- and multi-family dwellings, churches, elementary and high
schools, recreation facilities, public administration buildings, libraries,
museums and galleries, shared housing for the elderly, colleges, day care
centers, adjustment homes, crematories, hospitals, and nursing and rest homes
(Cincinnati Zoning Ordinance, June 1985 edition).
In addition to conventional zoning and building code controls, the
Clifton neighborhood, northwest of AWBERC, is designated as an Environmental
Quality Urban Design District and an Environmental Quality Hillside District.
Both of these designations impose standards on new construction and renovation
to protect the neighborhood's aesthetic values, hillside views, and drainage
patterns.
3.2.1.3 Future Land Use Trends
Future land uses in the vicinity of AWBERC are expected to continue along
essentially the same patterns as current land use. The neighborhood plans
that the city has adopted for the area all prescribe an essentially conserva-
tive development strategy, including preservation of the current housing
stock, consolidation of commercial development, and containment of instit-
utionl expansion (City of Cincinnati, Departments of City Planning and
Neighborhood Housing and Conservation, Clifton Community Plan, Hay 1982;
Clifton Heights, University Heights, and Fairview Community Plan, Draft
December 1984).
3-10
-------
The Cincinnati Department of City Planning and Department of Neighborhood
Housing and Conservation are currently preparing an Uptown Comprehensive Plan
to be completed in September 1987. The plan will incorporate specific
recommendations for each neighborhood within the Uptown planning area, with
the AWBERC facility located at its approximate center (City of Cincinnati,
Department of City Planning and Department of Neighborhood Housing and
Conservation for Uptown Task Force, Reconnaissance - Uptown Today, January
1986).
Many of the institutions in the Uptown area are currently upgrading or
expanding their facilities, either on their own land or on adjacent sites.
Because virtually all of the local plans call for containing institutional
encroachments on residential areas in particular, much of the future insti-
tutional development will probably be confined to property already owned by
the institutions, many of which have purchased land around their existing
facilities to provide for future growth.
3.2.2 Population
3.2.2.1 Existing Residential Population
Population in the vicinity of the AWBERC facility was enumerated in the
1980 Census. The AWBERC facility is located in the northeast part of
Cincinnati's Census Tract 30, as shown in Figure 3-4. Adjacent Census Tracts
include 29 (also in the University Heights area); 32 and 33 (Corryville); 70,
71, and 72 (Clifton); and nearby Avondale (Tracts 34, 66, 67, 68, and 69).
Mean incomes and household data for each of these tracts are shown in Table
3-2. The census figures include populations of university residences and
other residential institutions, but not of hospitals.
The residential population surrounding the AWBERC facility is diverse.
The area immediately north and south of AWBERC includes a large student
population. Census Tract 30, in which AWBERC and the University of Cincinnati
are located, also has the highest average number of people per dwelling unit
in the the vicinity (5.03 people per dwelling unit), reflecting the student
population. Approximately 2,400 undergraduate students live in university
3-11
-------
U)
I
Figure 3.4 1980 Cincinnati Census Tract Map
Source: 'City Planning Commission
Cincinnati, Ohio, August 1980
-------
TABLE 3-2. RESIDENTIAL POPULATIONS OF CENSUS TRACTS NEAR AWBERC -
1980 CENSUS
CENSUS
TRACT
28
29
30
32
33
67
68
69
70
71
72
POPULATION
2,198
5,001
5,525
2,170
2,432
4,014
5,369
5,888
3,103
3,710
2,517
DWELLING
UNITS
900
2,547
1,099
861
1,455
1,882
2,260
2,490
1,358
1,819
1,596
MEAN POPULATION
PER UNIT
2.44
1.96
5.03
2.52
1.67
2.13
2.38
2.36
2.21
2.04
1.58
MEAN HOUSEHOLD
INCOME
$ 9,374
14,358
10,310
10,016
11,881
10,850
14,146
13,092
19,732
24,851
15,122
Source: City of Cincinnati, City Planning Department (from 1980 U.S. Census
STF 1A)
3-13
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dormitories during the academic year, plus additional graduate students,
faculty, and guests in other parts of the campus. During the summer,
dormitory space is occupied by various visiting groups (Patty Hayden,
University of Cincinnati Residence Hall Administration, 1986). Corryville
(especially Census Tract 32) also has a large student population and the
lowest mean household income in the vicinity.
The northern and eastern vicinity of AWBERC (Univeristy Heights, Clifton
Heights, and Fairview) tends to be composed of a larger proportion of family
households (as opposed to student households) than the rest of the area and is
characterized by higher household incomes. Within the Clifton neighborhood
(Census Tracts 70, 71, and 72), the southern tract (72) is a mix of single-
family homes and apartments, the eastern tract (70) is a"mix of single-family
homes and duplexes, and the northern tract (71) is predominantly single-family
homes. The highest population densities per residential acre, with predomi-
nantly multiple-unit dwellings, are around the Clifton-Ludlow business
district, the Lowell-Dixmuth axis, Vine Street, and the west ends of Ludlow-
McAlpin (City of Cincinnati, Clifton Community Plan, 1982).
The age and racial composition of the residential population within
approximately one mile of AWBERC, based on 1980 census data, is shown in Table
3-3. The area immediately surrounding AWBERC and the university is primarily
white, with approximately 25 percent minority populations. In the northern
parts of Clifton, the proportion of minorities is much lower. The population
of the Avondale area is predominantly black, with a small percentage of white
minorities.
3.2.2.2 Existing Nonresidential Populations and Economy
The AWBERC facility itself employs between 600 and 750 people (600
daytime workers according to the facility staff; 750 people according to the
City of Cincinnati, City Planning Department, Burnet Woods Basic Planning
Policy). Approximate populations of other institutions within one mile of
AWBERC on a typical weekday were estimated based on a survey by the City
Planning Department for the Uptown Task Force in 1985. These estimates are
shown in Table 3-4 and can be keyed to institutional locations on previously
presented maps.
3-U
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TABLE 3-3. AGE AND RACE COMPOSITION OF POPULATION IN
CENSUS TRACTS NEAR AWBERC - 1980 CENSUS
CENSUS
TRACT
28
29
30
32
33
68
69
70
71
72
POPULATION AGES
Under 5
182
123
111
127
107
370
424
164
140
82
5-18
514
255
1,195
340
272
1,142
1,331
539
475
191
19-64
1,280
4,035
4,091
1,441
1,844
2,775
3,274
2,002
2,298
1,973
Over 65
222
588
128
199
209
1,082
859
308
797
271
Total
2,198
5,001
5,525
2,107
2,432
5,369
5,888
3,013
3,710
2,517
White
1,953
4,505
4,170
679
1,426
358
419
2,066
3,599
2,243
RACES
Black
230
377
958
1,390
975
4,993
5,431
900
64
175
Other
15
119
397
38
31
18
38
47
47
99
Source: City of Cincinnati, Cincinnati City Planning Department (from 1980 U.S.
Census Reapportionment File Released March 1981, and City Planning
Commission, February 1982).
3-15
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TABLE 3-4. Uptown Institutions and Associated Populations
INSTITUTION
University of Cincinnati (Clifton)
College of Medicine
College of Nursing and Health
College of Pharmacy
Hoxworth Blood Center
Hebrew Union College
Hughes High School
Bethesda
Children's Medical Center
Christ
Board of Health 310 Burnet
North Central Health Dist. 2939 Vernon PI.
Deaconess
Good Samaritan
Group Health Associates
Holmes
Jewish
(tollman's Psychiatric
Shriner Burns Institute
University Hospital
Veteran's Administration
ZOO
STAFF STUDENTS BEDS
STAFF STUDENTS
IN-PATIENT
ARRIVALS
6.000
2.350
104
110
200
100
127
2.083
2.200
2. 054'
132
46
757
3.000
175
498
2.400
192
220
2,900
1.200
28,000
1.018
821
200
N/A
175
1,232
306
300
312
1
N/A
234
N/A
N/A
150
8
4
480
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
498
350
700
N/A
N/A
276
765
N/A
90
607
126
30
664
354
4.000
2.000
75
76
180
100
125
1.4001
1,500
1,700
128
42.
505 *
1.400
175
225
1.650
192
185
2.400
1.000
15.000
750
522
170
N/A
175
972
250
100
200
1
N/A
.
200
N/A
N/A
100
4
4
280
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
65
60
80
N/A
N/A
70
N/A
10
75
8
5
70
35
TYPICAL WEDNESDAY
OUT-PATIENTS VISITORS
DAILY TOTAL
N/A
N/A
N/A
N/A
200
N/A
N/A
200
400
350
84
N/A
400
650
270
100
N/A
30
.308
400
3.000
500
30
12
25
35
15
500
550
1.900
60
4
1,500
350
140
1,200
30
25
600
1,000
22,000
3.250
627
258
405
310
1.112
2,415
2.610
4.230
273
46
3.570
1.175
645
3.125
234
249
4.658
2.435
97
40J
N/A
90
40
N/A
N/A
3,000J
3,130
1. Figure not supplied this 1s an estimate based on approximately 2/3 of full
employee count.
2. There are actually 2.737 employees but 2,054 full time equivalents.
3. Cincinnati Public Schools Natural Resources Management school year only.
4. Additionally up to 30 volunteers a day and 50-60 summer seasonal employees.
5. In summer week day count is 3.000-5,000. weekend 8.000-10.000.
In winter daily count range between 600-1,000.
* Source: Survey for City of Cincinnati City Planning Department
Uptown Task Force except Deaconess Hospital figures
which came from a table in the August £0, 1984
edition of the Cincinnati Business Courier (p. 10)
-------
In addition to institutional employment and users, hundreds of offices
and commercial establishments employ and serve daytime populations. A recent
listing of establishments in 1980 census tracts near AWBERC shows a mixture of
small service-related businesses, neighborhood-oriented retail shops, gas
stations, construction contractors, restaurants, and professional offices
(primarily physicians near the university-medical complex) (Cincinnati, City
Planning Commission, Data Services, 1980 R.L. Polk Detail Listing of
Business). Specific data on employment and clients of these businesses are
not available but may be prepared in conjunction with the Uptown plan.
Business clusters are shown in previously presented Figure 3-3, Land Use and
Activity Areas Surrounding the AWBERC Facility.
3.2.2.3 Future Populations
The vicinity of AWBERC is fully developed. Open space is entirely in
designated parkland, some temporarily vacant lots, and on the grounds of
existing institutions. In this context, there is little opportunity for
further increases in density in the neighborhoods around the facility,
especially considering the resolve on the part of most local citizens and the
City Planning Commission to control residential and institutional density in
the area. Hospitals also report that they expect no increase in in-patient
treatment, but possible increases in out-patient treatment, based on recent
trends and current plans (City of Cincinnati, Neighborhood Plans, 1982 and
1984).
3.2.3 Transportation Facilities
The AWBERC facility is located halfway between 1-71 and and 1-75 adjacent
to the campus of the University of Cincinnati. Main arteries leading to the
facility are Jefferson Avenue, St. Clair Street, and Vine Street. Access
routes to the EPA facility are shown in Figure 3-5. Parking is provided for
400 vehicles on the EPA property. However, parking in the surrounding
neighborhood is extremely scarce relative to demand. The facility may also be
reached by bus.
Traffic around the university-medical complex is heavy and often
congested. Traffic counts at major checkpoints in the area are shown on
Figure 3-6.
3-17
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Andrew W. Breidenba'.^
Environmental
Meeearch
Center
Test and
Evaluation
Facility
to Greater
Cincinnati
Airport
Greater
Cincinnati
Airport
Figure 3.5 Access to the AWBERC Facility
3-18
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(153)
U.S. EPA
ST. CLASH FACILITY
«...
AT WHS TOINT EXIT
INTBttTATt 71 CM 78
TO (PA FACILITY.
INTfOTATg 78 TO
OMAT8I CINCINNATI
AIRPORT
FROM GREATER CINCINNATI AIRPORT
TO U.S. EPA ST. CLAIR FACILITY
Inttrstne 78 (North or South)
EXIT HOPPLE ST. TO CENTRAL PKY.,
RIGHT TO MARSHALL AVE., LEFT
TO RIDDLE RD.. RIGHT TO ST. CLAIR
AND EPA FACILITY.
Intareau 71 (North)
EXIT READING RD. TO BURNET AVE. TO
Wm. H. TAFT RD, LEFT TO JEFFERSON AVE.
RIGHT TO EPA FACILITY.
FROM GREATER CINCINNATI AIRPORT
TO U.S. EPA RIDGE RD. FACILITY
Intwstit* 71 (North)
INTERSTATE 76 TO INTERSTATE 71
TO RIDGE RO. (NORTH) EXIT TO
EPA FACILITY.
FROM ST. CLAIR FACILITY
TO RIDGE RD. FACILITY
JEFFERSON TO MCMILLAN, LEFT TO
INTERSTATE 71 NORTH. EXIT RIDGE
RO. NORTH TO FACILITY.
FROM U.S. EPA ST. CLAIR FACILITY
TO GREATER CINCINNATI AIRPORT
RIGHT ON ST. CLAIR TO RIDDLE RD..
LEFT ON MARSHALL AVE., RIGHT ON
CENTRAL PKY.. LEFT ON HOPPLE ST..
RIGHT TO INTERSTATE 75 SOUTH.
FROM U.S. EPA RIDGE RO. FACILITY
TO GREATER CINCINNATI AIRPORT
RIGHT ON flIDQC RO., RIGHT TO
INTERSTATE 71 SOUTH TO
INTERSTATE 78 SOUTH.
Figure 3.6 Traffic Counts in Vicinity of AWBERC (in thousands)
3-19
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Deliveries to the AWBERC facility are routinely received from common
carriers and carrier services in the Cincinnati area, including the following
companies:
Yellow Freight System Roadway Express Company
Carolina Carriers Corp. Smith Transfer Company
C.W. Transport, American Freight System UPS
Arkansas Best Freight System Federal Express
Consolidated Freightways DHL.
3.2.4 Wastewater Transport and Disposal Facilities
Wastes to be generated by the proposed EPA hazardous waste laboratory can
be broadly classified as follows:
Residual samples and/or solvents from laboratory analyses
Accidental spills of solvents and/or analytical samples
Wash waters from cleaning glassware
Noncontact water (e.g., condenser water, steam bath condensate)
Emergency shower and sprinkler system water
Locker room sink and shower waters.
The disposal methods to be employed for each of these types of wastes, as
outlined in EPA's Toxic Substances Control Manual and engineering plan, are
described below.
3.2.4.1 Residual Samples and/or Solvents from Laboratory Analyses
Residual samples and solvents from all experiments conducted at the
Hazardous Waste Engineering Laboratory will be removed by a licensed hazardous
waste transport and treatment/disposal firm. In addition, all expendable
equipment as well as labware, toweling, gloves, and other material that, have
come in contact with chemical carcinogens will also be disposed through a
contract hauler rather than reused. To the extent practicable, all hazardous
wastes should be rendered less hazardous at the laboratory prior to storage/
hauling. For example, strong acids/bases should be neutralized. Carcinogenic
contaminants can often be destroyed by the addition of oxidizing agents.
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As the chemical reaction characteristics of hazardous wastes generated by
the laboratory will most likely be relatively unknown prior to testing, mixing
of hazardous wastes should be avoided. The hazardous waste storage area
within the laboratory should be explicitly designated as such, and the area
should be curbed to contain accidental spills.
3.2.4.2 Accidental Spills of Solvents and/or Analytical Samples
Chemicals spilled in fume hood areas will be contained and discharged to
fume hood funnels. These funnels will be installed flush with the fume hood
workspaces to permit easy cleanup of spills. These funels drain into 5-gallon
stainless steel containers. The contents of these containers will be hauled
and disposed of by the laboratory's hazardous waste disposal contractor. All
spills of hazardous chemicals onto the laboratory floor will be treated in
situ and/or absorbed by appropriate hazardous waste cleanup techniques. All
chemicals and cleanup apparatus (e.g., absorbents) shall be treated as
hazardous and will be disposed of by the laboratory's hazardous waste
contractor.
3.2.A.3 Wash Waters from Cleaning Glassware
Glassware that previously had contained hazardous wastes will receive
several cleanings/rinsings. Wash waters from the initial cleaning and rinsing
will be dumped into stainless steel containers for removal by the laboratory's
hazardous waste disposal contractor. Subsequent cleanings/rinsings may also
be reserved for hazardous waste removal or may be discharged into the
facility's laboratory sinks, which drain into the city's sewer system. The
determination as to wash water disposal methods will be made on a case-by-case
basis by the Laboratory Supervisor.
All wash waters for the cleaning of precleaned glasswater that had
previously contained nonhazardous waste will be dumped into the laboratory
sinks. Again, determinations as to wash water disposal in laboratory sinks
will be made by the Laboratory Supervisor on a case-by-case basis in
accordance with the rules and regulations published by the Metropolitan Sewer
District.
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3.2.4.A Noncontact Water
All noncontact water used in the laboratory, such as that for condensers
and steam baths, will be discharged to elevated funnels installed on the fume
hoods. These elevated funnels will be installed 6 inches above the surface of
the fume hood workspaces to prevent entry of any spilled chemicals or waste-
waters. The elevated funnels will drain directly to the city's sewer system.
3.2.4.5 Emergency Shower and Sprinkler System Water
As the EPA laboratory will not be equipped with floor drains, any water
discharged by the laboratory's emergency shower and/or sprinkler system will
accumulate on the laboratory floor. Such waters may or may not be contami-
nated with hazardous chemicals. Thus, the Supervisor should determine on a
case-by-case basis how emergency shower and/or sprinkler system water should
be contained, mopped up, and disposed. If hazardous chemicals are in fact
present in these waters, disposal by dumping into the laboratory sinks (with
direct connection to the city sewer system) will be avoided.
3.2.4.6 Locker Room Sink and Shower Waters
Locker room sink and shower waters can reasonably be expected to be free
of chemical contaminants from the laboratory. Therefore, the locker room
sinks and showers will drain directly to the city sewer system.
3.2.4.7 City Sanitary Sewer Configuration
The FCF will ultimately discharge sanitary and storm sewer effluents to
the Mill Creek Sewage Disposal Plant located west-southwest of the proposed
FCF site.
The actual connection to the sewers will most likely consist of an 8-inch
storm and 8-inch sanitary sewer pipe running north from the proposed FCF. The
storm pipe will connect to an existing 15-inch pipe at the property boundary
abutting Nixon Street, and the sanitary pipe will feed into an existing 12-
inch pipe at the same boundary. Both of these pipes merge in the middle of
Nixon Street into a 15-inch combined sewer main with northerly flow under
Glendora Avenue. The combined sewer main will eventually flow westerly, then
southerly, down the Mill Creek valley to be processed by the Mill Creek Sewage
Plant.
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4. ENVIRONMENTAL CONSEQUENCES
4.1 PRIMARY IMPACTS
4.1.1 Construction Impacts
Construction of the free-standing building can be expected to generate a
short-term, localized nuisance due to airborne dust and dirt. Some soil
erosion resulting from building construction can also be expected but will be
minimized by construction practices in accordance with Ohio and Cincinnati
erosion control requirements. Construction of the free-standing building
could potentially affect groundwater; however, it is not expected that the
building's foundation will be so deep that construction will result in
long-term groundwater impacts. Construction of the free-standing building
should not adversely affect surface waters, as all surface waters are located
some distance from the proposed construction site.
4.1.1.1 Groundwater
Before the construction of the existing AWBERC facility, a perched water
table was present at 1.5 to 3 feet below the ground surface. This perched
condition existed only between the months of January and April and was the
result of the extremely low permeability clay soil and presence of a fragipan
layer just below ground level. It is not presently known if the fragipan was
disturbed during construction of AWBERC. If it was, the perched conditions
may not exist anymore, and a surface spill would not contaminate groundwater.
Sufficient data concerning the fragipan beneath the site and its disturbance
during previous construction are not available to provide a reliable basis for
impact evaluation. Given the small quantities of hazardous materials
projected to be handled at the FCF, a spill to soil in the vicinity of the
facility is unlikely to result in groundwater contamination. If for some
unforeseen reason a large quantity of highly soluble waste was accidentally
released to soil and transported to groundwater, there would be no risk to
public health. Drinking water for city residents is obtained from municipal
supplies using the Ohio River as source water.
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4.1.1.2 Land Use
Construction of a free-standing FCF structure would affect land use only
on the AWBERC site. In addition to the approximately 6,800 square feet of
land that the structure would cover, a short new driveway would be needed on
the east side of the building, and sidewalks would be built on the west side
between the free-standing structure and the existing AWBERC building.
Construction vehicles, equipment, and materials would take up consider-
ably more space during construction of a free-standing building than they
would for modification of the sixth floor of the existing facility, due to the
more extensive nature of new construction. The construction period for the
free-standing facility would probably be longer than for modification of the
sixth floor. Measures would need to be taken to minimize inconvenience to
AWBERC staff and protect aesthetic values in the area, including preserving
any surrounding landscaping, designating alternate walkways, and minimizing
construction noise and dust.
4.1.1.3 Population
The major group to be affected would be workers at the AWBERC facility.
No significant external population impacts are expected, as there is little
direct interaction between the area population and the AWBERC facility.
Inconvenience related to building a free-standing structure would involve
possible obstruction of foot paths, some additional dust and mud, and
temporary use of parking spaces for workers' vehicles.
4.1.1.4 Transportation
No lasting effects on transportation are anticipated as a result of
construction at the AWBERC site. Some slow traffic may be expected for a few
minutes on several occasions when materials and construction equipment are
initially moved onto the AWBERC site, in the case of building the free-
standing facility, but this could be scheduled outside of peak traffic
periods.
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4.1.2 Operation Impacts
4.1.2.1 Risks to Public Health
A primary issue of concern in evaluating the proposed operation of the
FCF is the assessment of risks to human health associated with exposure to
chemicals released from the facility. This evaluation includes consideration
of both long-term, low-level exposure due to day-to-day operations (i.e.,
assessment of chronic toxicity) as well as the potential for acute toxicity
due to catastrophic release of larger quantities of chemicals. The approach
for conducting the public health risk assessment includes the following:
Step 1: Hazard Identification - Examine the activities at the FCF and
the nature and quantity of chemicals and wastes handled. Select a
subset of the compounds present to be the focus of the assessment.
Step 2: Toxicity Assessment - Examine the inherent toxicity of the
substances under investigation. Identify and select appropriate
toxicity measures for use in evaluating carcinogenic and
noncarcinogenic effects.
Step 3: Exposure Assessment - Quantify the release of contaminants
from the facility.Delineate (i.e., model) the transport of the
chemicals through the environment and estimate concentrations in
environmental media. Determine maximum individual exposure levels and
estimate dose.
Step 4; Risk Characterization - Combine the results of the exposure
and toxicity assessments.Compare dose versus toxicity measure for
each subject compound to obtain an indication of the likelihood of
adverse effects (carcinogenic and noncarcinogenic) in exposed human
receptors.
A more thorough and detailed discussion of methods is presented in the
sections that follow. It is important to recognize that the degree to which a
quantitative evaluation of risks to public health may be carried out is
directly related to the adequacy of the data for conducting the component
analyses identified.
4.1.2.1.1 Overview
In the day-to-day activities at the FCF, the potential for release of
chemicals to the environment would be associated with discharge of waste
4-3
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liquids to the sanitary sewer system and venting of exhaust air to the
atmosphere. The proposed FCF has been designed to minimize the potential for
release of toxic substances and hazardous waste to the sanitary sewer system.
Only waste liquids from the shower, toilet areas, and Laboratory sinks will go
directly to the sever. Laboratory wastes will be segregated to prevent mixing
of hazardous and non-hazardous liquids (Personal Communication, J. Castelli,
March 1986). In the fume hoods, there will be two separate funnels: one at
work station level and one elevated approximately 6 inches above the surface.
The funnel at work station level is for the disposal of toxic liquid wastes to
a stainless steel holding container below the work surface and are eventually
removed for disposal to an approved hazardous waste disposal facility.
The elevated funnel in the fume hoods is for disposal of noncontaminated
water (e.g., condenser water), and this is the only funnel connected directly
to the sanitary sewer line. As specified in Section 3.2.4, waste water from
the first washing of all used laboratory glassware will be dumped into a
separate stainless steel container and handled and disposed as hazardous. An
ordinary sink will also be available in the laboratory, connected directly to
the sanitary sewer line, although no hazardous waste materials will be
introduced to this sink. Finally, the. facility is designed without floor
drains, preventing floor spills from entering the sanitary sewer.
The proposed design of the plumbing system at the FCF minimizes the
potential for discharge of contaminants to the sanitary sewer system. As
discussed in Section 4.2.2.2, even if small amounts of toxic substances were
discharged to the sanitary sewer line, dilution in the system would render
these compounds essentially undetectable at the Mill Creek POTW.
The Mill Creek POTW discharges treated wastewater to the Ohio River
downstream from Cincinnati drinking water intakes. Because of the sewer
line/POTW system configuration, discharge of pollutants from the FCF to the
sanitary sewer line cannot result in contamination of Cincinnati drinking
water supplies.
4-4
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Release of contaminants from the FCF to the atmosphere surrounding the
building is the second potential source of exposure of the public to hazardous
substances. In order to minimize the potential for release of toxic chemicals
from the FCF, EPA has proposed a ventilation system with the following
characteristics (USEPA 1985a):
« System will control supply and exhaust air to provide a negative
pressure gradient, causing air to flow from areas of low risk
potential (i.e., minimum ambient concentrations of toxic chemicals) to
areas of high risk potential
Exhaust air from the laboratory, the hoods, and the glove boxes will
pass through a bag-in/bag-out filtering system consisting of the
following elements: (1) a roughing filter, (2) a high-efficiency
(99.99 percent) particulate adsorption (HEPA) filter, (3) a high-
efficiency (99.99 percent) gas adsorption (HEGA-activated carbon)
filter, and (A) a second HEPA filter
The HEGA filter will be provided with test ports for monitoring.
The heart of the filtration system proposed by EPA is the HEGA filter.
The activated carbon in this unit filters contaminants from the airstream by
adsorbing these onto the carbon matrix. Three types of adsorption occur.
Kinetic adsorption removes substances present in vapor phase by electrostatic
attraction to the carbon granule. Radioactive materials may be adsorbed by
isotopic exchange. Finally, chemisorption captures airborne contaminants
through chemical complexation with carbon filter impregnates (e.g., tertiary
amines).
Because of the unlikelihood of discharge of pollutants from the FCF to
the sanitary sewer, and given that such a release, if it occurred, would not
adversely affect Cincinnati residents (i.e., incomplete exposure pathway), the
discharge of contaminants from the FCF to the atmosphere will be the focus of
the public health risk assessment. As noted previously, the long-term,
low-level emissions to the atmosphere will be evaluated as well as short-term
catastrophic release. In the catastrophic release scenario, it is assumed
that a leak has occurred in the natural gas line to the FCF. Natural gas
accumulates in the chemical and sample storage area, then ignites and explodes
with sufficient force to cause a break in the facility roof, with large-scale
release of contaminants. A subset of the chemicals prqjected to be present at
4-5
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the facility at the time of explosion was selected (based on quantity and
toxicity) as the basis for generating source terms for use in dispersion
modeling and in the subsequent characterization of acute toxicological effects
in exposed receptors.
In evaluating the risks to public health associated with day-to-day
activities at the FCF, the assessment should realistically reflect activities
and events projected to occur at the facility. Ideally, the following
information should be known:
Detailed characterization of experimental activities to be conducted
at the FCF, such that daily or weekly releases of subject chemicals to
the air filtering system may be predicted
Efficiency of the particulate and carbon filters in removing specific
contaminants from the airstream
Effects of filter age and quantity of entrapped chemicals on
contaminant pass-through
Typical source-terms for day-to-day or weekly release of contaminants
from the FCF to the atmosphere.
This information was unavailable for the proposed FCF, and source-terms had to
be calculated using the limited data available. Several EPA laboratory
facilities, similar in operation to the proposed FCF, were contacted to
collect existing information of importance. This included Research Triangle
Park in North Carolina, the National Enforcement Investigation Center in
Denver, and the Las Vegas laboratory. Very few data of value were obtained.
No monitoring information was available on the loss of contaminants to the
exhaust system, subsequent release to the atmosphere, or exposure to humans in
the vicinity of the facilities.
Because of the lack of critical data needed to characterize the rates of
release of contaminants to the air filtering system, the influence of the HEPA
and HEGA filters on contaminant pass-through, and the quantity of chemicals
lost to the atmosphere, and because of the uncertainties associated with
developing this information, a worst-case approach was adopted in conducting
the public health risk assessment. It was assumed that all materials lost to
4-6
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the air filtering system will be released/vented to the atmosphere (i.e.,
0 percent removal of chemicals from the exhaust stream). Release rates were
estimated on this basis, air dispersion modeling was conducted, and worst-case
maximum individual exposure levels were projected.
In the following discussion, the results of the public health risk
assessment are presented in two parts: (1) the assessment of long-term, low-
level exposure and chronic toxicity; and (2) the evaluation of catastrophic
release, short-term exposure, and acute toxicity.
4.1.2.1.2 Assessment of Risks of Long-Term, Low-Level Exposure
Hazard Identification
As described in Section 2.2, there are three major EPA Office of Research
and Development laboratories at AWBERC that plan to use the FCF: (1) the
Environmental Monitoring and Support Laboratory (EMSL) involved in the
development of standardized test procedures and quality assurance materials;
(2) the Hazardous Waste Engineering Research Laboratory (HUERL) investigating
the destruction/detoxification of hazardous materials; and (3) the
Water Engineering Research Laboratory (WERL) conducting toxics treatability
studies and evaluations of pollutant contamination of drinking water and
wastewaters. A more detailed overview of the activities of these laboratories
is summarized in Table 4-1. This information should not be taken to be an
exhaustive listing of all activities anticipated over the lifetime of the FCF.
It is, however, a basis for evaluating the projected level of activity at the
facility.
The classes of compounds and wastes likely to be handled in the FCF
laboratories include the following (Liberick 1986, Lichtenberg and Winter
1986, Winter 1986, Dobbs 1986):
Polychlorinated biphenyls (PCBs)
Polycyclic aromatic hydrocarbons (PAHs)
» Polychlorinated dibenzodioxins
Polychlorinated dibenzofurans
Halogenated ethers
4-7
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TABLE 4-1. PROPOSED STUDIES, SURVEYS, AND SERVICES AT THE FCF
Source: Winter 1986, Lichtenberg 1986, Thurnau 1986
Description of Study, etc. Specimen Type or Matrix
Chemical(s) or Contaminant
Type(s) Involved
Soil Mobility
Treatment, Destruction,
Detoxification, and/or
Alternative Disposal
Industrial and Hazardous
Waste Site Sample Analysis
Wastewater Treatability
Studies (Sorption,
Volatilization, etc.)
Waste Sample Standards
("Spiking")
Soils
Hazardous materials;1spils;
water; oils
Mining wastes; industrial
process wastes
Water; wastewater; waste
treatment solids
Solid sludges; industrial
wastes; liquid and solid
wastes; soils; sediments
Preparation of Standard
solutions for Performance
Evaluation
Solvents used, mainly
methanol,; also acetone,
methylene chloride,
hexane, etc.
PCBs; dioxins; furans
PCBs; dioxins; furans;
phthalate esters; PAHs;
heavy metals; halogenated
aliphatics; halogenated
ethers; organochloride
pesticides
Unspecified toxic organics
Unspecified toxic organics
Already containing toxic
compounds but spiked with
ppm to percent levels with
pesticides; metals;
phenolics; polynuclear
organics; aldicarb; PCBs;
Appendix VIII chemicals;
other priority pollutants
Appendix VIII compounds
4-8
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Halogenated aliphatics
Phthalate esters
Organochlorine and organophosphorous pesticides
Phenolics
o Heavy metals
Asbestos
Other Clean Water Act priority pollutants
Other Appendix VIII compounds (Resource Conservation and Recovery Act)
Other Appendix A chemicals (Comprehensive Environmental Response,
Compensation and Liability Act).
Typically, the FCF would receive samples of soils, oils, or solvents
contaminated with parts-per-billion (ppb) to low percentage concentrations of
the subject chemicals. EMSL estimates that it will receive 1 quart to
5 gallon amounts of-liquid or solid wastes, approximately once per month, for
evaluation (Lichtenberg and Winter 1986). Each month, HWERL anticipates that
it will receive approximately 2 to 10 pounds of contaminated soil, 1 gallon of
contaminated water, and 1 to 5 gallons of contaminated oil and solvents
(Liberick 1986). WERL anticipates that environmental samples may be tested on
an irregular basis at the FCF and may be received in 55-gallon quantities or
more (Dobbs 1986). Estimated use of environmental samples by WERL will be as
follows: (1) seawater - 55 gallons bimonthly, (2) surface water - 55 gallons
biannually, (3) groundwater - 55 gallons biannually, (4) leachate - 110 gal-
lons biannually, (5) industrial process water - 55 gallons biannually,
(6) municipal wastewater - 55 gallons bimonthly, and (7) industrial wastewater
- 100 gallons biannually. Table 4-2 summarizes the types and quantities of
wastes received on an annual basis by each laboratory in the FCF.
In conducting research at the FCF, a large number of reagents and
standards will be kept on hand. Appendix A contains several lists of
chemicals that may be used in proposed studies at the FCF. In addition to
these compounds, other chemicals would be obtained as needed from the USEPA
Repository for Toxic and Hazardous Materials.
4-9
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TABLE 4-2. TYPES AND ESTIMATED QUANTITIES OF CONTAMINATED
WASTES RECEIVED ON AN ANNUAL BASIS
Laboratory
Waste Sample Description
Quantity per Year*
HWERL
EMSL
WERL
Contaminated soils
Organic contaminated water
Waste oils and solvents
24-120 lb/11-55 Kg
12 gal/60 Kg
12-60 gal/60-300 Kg
Contaminated liquid and solid waste 3-60 gal/15-300 Kg
Seawater
Surface water
Groundwater
Leachate
Industrial process water
Municipal wastewater
Industrial wastewater
330 gal/1650 Kg
110 gal/550 Kg
110 gal/550 Kg
220 gal/1100 Kg
110 gal/550 Kg
330 gal/1650 Kg
220 gal/1100 Kg
*An average density of 5 Kg/gal is assumed for liquid mixtures.
Sources EPA Memoranda: Dobbs (3/3/86); Winter (1/30/86); Liberick (2/28/86);
Lichtenberg and Winter (2/28/86); and Thurnau
(5/15/86).
4-10
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Based on discussions with EPA Office of Research and Development staff,
it is not possible to specifically identify all materials that may be
evaluated or handled at the FCF, nor is it possible to exactly quantify the
amounts likely to be stored at the facility over time. HVERL research
scientists note, for example, that the nature of any future vork in hazardous
waste treatment at the FCF "... will depend on new chemical compounds that
become available, [and that] predictions of work to be undertaken at the FCF
over the next decade is virtually impossible" (Memo received from J. Castelli,
1986).
In evaluating risks to public health, it is unnecessary to examine all
substances anticipated to be present at the FCF. Rather, a subset of all
chemicals identified is selected to be the focus of the risk assessment
(compounds that will "drive" the risk assessment, i.e., those for which the
greatest risks to human health are associated). The concept of selecting
indicator compounds or a subset of the total number of chemicals present as
the focus of the assessment has been advanced by EPA in evaluating risks to
public health due to the release of contaminants from hazardous waste sites
(USEPA 1985b,c). The selection of these subject chemicals is based upon
several fundamental considerations: (1) the estimated quantity present at the
facility on an annual basis; (2) the potential for loss of these compounds to
the air filtering/exhaust ventilation system (e.g., volatility); and (3) the
inherent toxicity of the chemicals. No quantitative index was developed and
used to select subject compounds. The selection was based instead on best
professional judgment given the available information. Note when considering
the risks associated with long-term, low-level exposure, the compounds of
primary health concern are the carcinogens of greatest potency. Table 4-3
identifies the compounds that have been selected.
In order to estimate quantities of chemicals handled/present at the facil-
ity over time, it is useful to divide the substances into two broad categories;
(I) chemicals kept on hand as a necessary vart of laboratory analyses, such
as reagents, solvents, standards solutions, etc. and (2} compounds that enter
the laboratory as materials to be tested or as contaminants in liquid and
so. id waste samples and that constitute the typical materials under investisa-
tic.i by the laboratories. The total quantity of a given chemical handled
at :he laboratory is taken to be the sum of (1) and (2}. Estimates of
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TABLE 4-3. TOTAL QUANTITIES OF SIBJBCT CffiMCALS HflNXED ANUAUY AT TEE FCF: LOG-TERM, LCW-LEVEL RELEASE
Compound Name* Quantity of chemicals Concentrations/Total Quantities of Chemicals in Waste Samples Handled by
kept on hand as liquid PCF on Yearly Basisb'°'d'e
solvent or as reagent
chemicals, g/yr
Contaminated Soils Contaminated Surface Contaminated liquids Industrial process
(55 kg/yr) Water and Groundwater and solids, waste water, municipal
(1100 kg/yr) oils and solvents, wastewater, and
leachate (1700 industrial waste-
,1 Aldrin
to
Benzene
Carbon Tetrachloride
Chloroform
Ghromiun VI
Hethylene Chloride
PCBs
TOD
Tetrachloroetnylene
3
3340
12080
5920
52h
26600
.010
I
810
10 ppn/0.55 g
10 ppn/0.55 g
10 ppa/0.55 g
10 ppn/0.55 g
10 ppn/0.55 g
10 ppn/0.55 g
10 ppn/0.55 g
10 ppb/0.55 g
10 ppn/0.55 g
10 ppn/11 g
10 ppu/llg
10 ppn/11 g
lOppn/Ug
lOppn/Ug
10 ppn/11 g
10 ppn/11 g
lOppb/Umg
10 ppn/11 g
kg/yr)
2.0 ppn/3.4 g
577 ppn/981 g
342 ppn/581.4 g
20.5 ppn/34.9 g
806 ppa/1370g
781 ppn/1328g
390ppn/663g
10 ppb/0.017 g
1345 ppn/2.287 g
water (3300 kg/yr)
0/0f
.310 ppn/1.020 g
7.2 x 10~2 ppn/
0.024 g
.25 ppn/0.83 g
.29 ppn/0.% g1
1.08 ppn/3.560 g
1.1 x 10~4 ppn/
3.6 x 10~4 g
0/0£
1.8 x 10~2 ppn/
Total Contam- Total
inant in waste Annual
g/yre Quantity
g
15.0
994
593
47.3
1382
1343
675
0.029
2299
18.0
4334
12673
5967
1434
27943
675
1.03
3109
Trichloroethylene
1460
10 ppn/0.55 g
10 ppn/11 g
2173 ppn/3.694 g
0.059 g
9.9 x 1C
0.033 g
9.9 x 10~3 ppn/
3706
5166
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a) List of chanicals compiled from infotnation supplied by EPA: Winter (03/07/86); Dobbs (03/03/86); Lichtenberg (03/06/86); Lichtenberg and Winter
(02/28/86).
b) Quantities taken from information received in a) above and from: Liberick (02/28/86); Winter (01/30/86). Where liquid volumes were given, an average
density of 5 kg/gallon was assumed. Maximum estimate of quantity was used when a range was given.
c) TED concentrations taken from UEEPA 1985d.
d) Concentrations in contaminated liquids and solids, waste oils and solvents, and leachates taken from Blackman et al. 1984.
e) Concentrations for industrial process waters, municipal waste-waters, and industrial wastewaters taken from USEPA 1986a and SAIC 1985.
f) No data were found on levels of subject chemicals in sea water (1650 kg/yr handled at the BCF). Concentrations were therefore assumed to be zero.
g) Incorporated in 100 g chromium trioxide, Cr03-
h) For Cr VI and other forms of chromium.
i
CO
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projected yearly "consumption" or use of solvents and reagents at the FCF are
provided in Appendix A. From this information, the carcinogens with the
highest annual consumptions were identified. In some instances, more than one
estimate of annual use was given for a chemical. The highest use values
identified in the information were selected (see Appendix A).
Only limited information was available on the concentration of contamin-
ants in typical waste samples. These estimates were in general wide-ranging
and not specific for given chemicals (Lichtenberg and Winter 1986). Thurnau
(1986) proposed a level of 10 mg/kg as a typical estimate for contaminants in
most types of samples. In order to satisfactorily quantify levels of con-
taminants in wastes handled at the FCF, data obtained from the literature
supplemented the information provided by AWBERC. Table 4-3 is a compilation
of quantities of the selected subject compounds in waste samples of all types
as well as projected quantities of these compounds to be used as reagents or
solvents. In addition, estimates are presented of the total quantities of
each substance handled at the FCF.
Concentration of selected (subject) chemicals in contaminated liquids and
solid wastes, in waste oils and solvents, and in leachate were estimated using
data presented in Blackman et al. (1984).
Two recent studies conducted for EPA and Congress provided information to
characterize expected levels of contaminants in these liquid wastes, indus-
trial wastewater, industrial process water, and municipal wastewater (SAIC
1985b, USEPA 1986a). The studies examined the release of hazardous waste
nationally from more than 40 industrial categories to POTWs. Using estimates
of total pounds of chemical discharged across all industries, and given a
knowledge of total flow, average concentations of given contaminants in
industrial wastewaters were projected. The data obtained were for indirect
discharging industries only from the Clean Water Act Consent Decree list.
Although the results obtained were for industrial wastewater, in the absence
of any other data, these findings were also applied to characterize municipal
wastewater and industrial process water.
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An average level of 10 ppm of the subject compounds was used for con-
taminated soil, surface water, and groundwater samples projected to be
received by the FCF, for all compounds under investigation except tetrachloro-
dibenzodioxin (TCDD). TCDD was estimated to be present in these samples at a
level of 10 ppb based upon the information provided in USEPA (1985a).
Concentrations of the subject compounds in sea water samples were assumed to
be essentially zero.
Toxicity Assessment
In evaluating the risks to public health of long-term, low-level release
of chemicals from the FCF, it is necessary to focus on potential chronic toxi-
cological effects. The chronic effect of greatest concern is carcinogenesis
and the one that may be most meaningfully quantified in evaluating the risks
to public health. Many of the chemicals proposed by EPA for use in the FCF
are potential carcinogens in humans. These include:
Polychlorinated biphenyls (PCBs)
Polycyclic aromatic hydrocarbons (PAHs)
Polychlorinated dibenzodioxins
Polychlorinated dibenzofurans
Organochlorine pesticides (e.g., Aldrin)
Acrylonitrile
4-Aminodiphenyl
4-Nitrobiphenyl
Benzidine and chlorinated benzidines
Bis(chloromethyl) ether
N,N-Dimethyl-4-aminoazobenzene
Ethyleneimine
4,4'-Methylene bis (2-chloroaniline)
(J-Naphthylamine
N-Nitrosodimethylamine
fi-Propiolactone
Vinyl Chloride
Several heavy metals (e.g., beryllium, cadmium, chromium VI, nickel)
Asbestos.
4-15
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The inherent toxicity of carcinogens may be evaluated by examining the
caicinogenic potency factor estimates for the subject compounds. The
carcinogenic potency factor (qx) is defined as the 95 percent upper limit
slope estimates of the linear portion of the dose response curve for a given
carcinogen. The potency factor may be used to give an indication of the
relative carcinogenic response per unit dose. As outlined in the section on
risk characterization, the potency factor values are the toxicity measures
that are used to characterize the lifetime individual risks associated with
exposure to carcinogenic compounds.
Table 4-4 summarizes carcinogenic potency factors for the selected
subject compounds (see Table 4-3) and provides data on molecular weights and
vapor pressures. As noted previously, subject chemicals'were selected based
upon best professional judgment, taking into consideration the availability
and the magnitude of the carcinogenic potency factors, the quantity of the
chemical present at the facility, and the potential for loss (volatility) of
these substances to the air filtering system. Table 4-4 also provides the EPA
Carcinogen Assessment Group (CAG) weight-of-evidence rating of the data
supporting a finding that a compound is a carcinogen in animals and humans.
Exposure Assessment
The exposure assessment consists of three major components: (1) estimat-
ing release of contaminants from the FCF and developing source-terms (mass per
unit time vented to the atmosphere); (2) selection and application of atmo-
spheric transport models to estimate ambient environmental levels of the
subject carcinogens; and (3) quantification of exposure and average annual
lifetime dose.
Ideally, levels of chemicals released from a stationary point source on a
day-to-day basis are best quantified using monitoring data. This information,
of course, is not available for the FCF. As noted in section 4.1.2.1.1,
several other EPA laboratory research facilities were contacted to obtain
relevant data that might be used in generating source-terms (Personal
Communication July 1986: Ken Fischer, National Enforcement Investigation
Center, Denver, Colorado; Wayne Crane, EPA Las Vegas Laboratory; and Jewell
4-16
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TABLE 4-4. CHARACTERIZATION OF SUBJECT CARCINOGENIC COMPOUNDS
Chemical
Aldrin
Benzene
Carbon Tetrachloride
Chloroform
Chromium VI
Methylene Chloride
PCBs
Arochlors
TCDD (Dioxin)
Tetrachloroethylene
Trichloroethylene
Molecular*
Weight
365
78.12
153.82
119.38
52 (atomic
weight)
84.94
257.9 to 375.7
(1016 to 1260)
332
165.83
131.39
Vapor Press
(mmHg)
6 x 10"6
95.2
90
150.5
<10~5
362.4
6.7 x 10" 3
(1221)
7.4 x ID"10
14
57.9
urea
25°C
25°C
20°C
20°C
20°C
25°C
25°C
20°C
20°C
Carcinogenic
Potency tb
Factor: q
(mg/kg/day)
11.4
2.9 x 10"2
1.3 x 10" 1
8.1 x 10" 2
41
6.3 x 10"4
4.34
1.5 x 105
1.7 x 10"3
4.6 x 10"3
Weight of
Evidence"
B2
A
B2
B2
A
B2
B2
B2
B2
B2
Route of
Exposure
0
I
0
0
I
I
0
0
I
I
"Sources: Mabey et al. 1981, Podol et al. 1986.
b95 percent upper limit estimate of the slope of the dose-response curve. Carcinogenic
potency factors were obtained for inhalation route of exposure when available. When these
were unavailable, the potency factors for oral exposure have been included. Source:
USEPA 1985b.
CEPA weight-of-evidence rating of the cause-and-effect relationship between exposure to a
compound and carcinogenesis in receptors. Group A is proven human carcinogen. Group B is
probable human carcinogen. Group C is possible human carcinogen. Group D is "not
classifiable" or no data-available. Group E is no evidence of carcinogenic!ty in humans.
See USEPA 1986b.
dRoute of exposure for which carcinogenic potency was characterized. 0 - oral route, I -
inhalation route.
4-17
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Morris, EPA Laboratory, Research Triangle Park, North Carolina). No monitor-
ing data on atmospheric emissions were available, but assistance was provided
in developing source-terms.
In the absence of monitoring data, source-terms (i.e., mass released per
unit time) for the subject chemicals could be developed by evaluating the
total loss of chemicals from typical experimental activities in the laboratory
facility and evaluating the loading to, and removal of, contaminants by the
air filtering system (i.e., HEPA and HEGA filters). Because insufficient data
were available to conduct this characterization for the proposed FCF, a third
alternate approach was adopted.
In the present assessment, a worst-case evaluation is conducted of the
release of chemicals from the FCF. The assumption is made that the air
filtering system removes none (0 percent) of the chemicals released to the
exhaust and that all (100 percent) of the compounds present in the air stream
are vented to the atmosphere. The assessment of long-term, low-level releases
will focus on the 10 subject carcinogens identified previously (Tables 4-3 and
4-4). These compounds may be grouped into several categories: organic sol-
vents of relatively high volatility (liquid chloroform, carbon tetrachloride,
methylene chloride, tetrachloroethylene, benzene, and trichloroethylene);
organic compounds of relatively low volatility (TCDD, Aldrin, and PCBs); and
one inorganic chemical usually found in aqueous media or solid waste (Chromium
VI).
In the case of liquid organic solvents, it is assumed that, in the course
of a year's operation at the FCF, very little of the subject compound leaves
the laboratory in the form of liquid waste (Thurnau, May 15, 1986, and
personal communication, June 26, 1986). Vapors from solvents are distilled
off and exhausted to the air filtering system during extraction and concentra-
tion operations. All apparatus for these operations, as well as chroma-
tographic equipment, are vented to fume hoods (Thurnau 1986). Given these
assumptions (which are the most conservative ones possible), all solvents used
during the year are vented to the atmosphere, and all relatively volatile
chemicals contained in waste samples brought into the laboratory for study are
extracted, stripped, or otherwise.released in the form of vapor, which
likewise is exhausted through the fume hoods.
4-18
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In order to verify the appropriateness of the above assumptions, informa-
tion was gathered from several EPA regional laboratories (NEIC-Denver, EPA Las
Vegas, and EPA Research Triangle Park.) In general, the laboratories con-
tacted proved to be different from the proposed FCF in size and/or focus of
operations, but the assumption that solvents are mainly exhausted to the
atmosphere rather than as lost liquid waste was upheld (personal communica-
tions with K. Fischer, NEIC-Denver, and W. Crane, EPA-Las Vegas, June 30,
1986). As noted previously, no atmospheric monitoring data were available on
the release of contaminants from the facilities (personal communication,
K. Fischer, W. Crane, and J. Morris, July 19, 1986).
Estimates of atmospheric releases of the substances TCDD, Aldrin, and
PCBs must take into account their low vapor pressures (see Table 4-4). Aldrin
and dioxin are crystalline powders and may be mobilized as such if present in
pure form. More likely, these powders may be adsorbed onto dust particles in
soil samples and may be exhausted from the laboratory in air currents going up
the fume hoods. PCBs are mixtures of isomers of varying molecular weights and
may range in physical state from liquids to waxy solids or semisolids.
Compounds of chromium VI, if present as solids, could be released to the
atmosphere in the form of fine particulates or adsorbed on the surface of dust
particles from soil samples. If chromium in solution is determined by direct
aspiration atomic absorption spectrophotometry and vented to the fume hoods,
the chromium contained in that portion of the solution that was aspirated
would be released in microcrystalline form after passing through the machine.
The question of release of these chemicals from solution (e.g., evapora-
tion from solvent following extraction) has been discussed by Thurnau (1986).
He calculates the amount of solvent contained in a headspace of a given size,
using the Ideal Gas Law and assuming ideal solution behavior (i.e., that the
solution is "ideally dilute," and that the solvent mole fraction approaches
unity, and that all solutes are present in very low concentration). This
approach allows calculation of solvent vapors released by uncapping containers
of a given size a certain number of times per day during the course of a
laboratory study. It also leads to the conclusion that the amount of solute
evaporated is essentially zero.
4-19
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Given the considerations presented above, source-terms (i.e., release
rates over time) for the 10 subject carcinogens were estimated. The estimates
are based on the assumption that the total quantity of chemical handled at the
FCF over a one-year period (i.e., the quantity on hand as reagent as well as
that contained in waste samples) is -completely lost to the atmosphere. In
generating source-term estimates for each chemical, the total quantity handled
is apportioned over a year's time period to generate amounts released in
grams/second. These values are summarized in Table 4-5. In doing this, it is
assumed that release is continuous 24 hours each day, 365 days per year.
Although unrealistic, this is consistent with a worst-case assessment. This
conservative assumption will allow us to generate maximum estimates of
exposure levels.
Once release rates have been estimated for the subject chemical, disper-
sion modeling can be conducted to estimate exposure levels to human receptors
surrounding the proposed FCF. Two air quality dispersion models were selected
to estimate exposure associated with day-to-day release of the 10 subject
chemicals:' the long-term version of the Industrial Source Complex Model
(ISCLT) and LONGZ. Both models were run with the advice of EPA meteorologists
(Koerber 1986, Wilson 1986, Lee 1986), and in order to achieve a conservative
estimate of ambient concentrations, no pollutant transformation or degradation
was assumed.
The ISCLT model is an advanced, steady-state Gaussian plume model,
preferred by EPA for use in modeling complicated sources in either urban or
rural areas with simple terrain (USEPA 1986c). The FCF is considered a
complicated source because it requires special treatment for dispersion due to
considerations such as aerodynamic downwash. In its most recently released
version (USEPA 1986d), the model incorporates a number of options, including a
regulatory default option that sets several switches or program control
options to those applicable for regulatory situations. The model was run in
the urban mode, incorporating building downwash effects, with this regulatory
switch invoked.
4-20
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TABLE 4-5. SOURCE-TERM ESTIMATES FOR LONG-TERM, LOW-LEVEL
RELEASE OF CONTAMINANTS
Chemical
Release Rate
(grams/second)
Aldrin
Benzene
Carbon Tetrachloride
Chloroform
Chromium VI
Methylene Chloride
PCBs
TCDD
Tetrachloroethylene
Trichloroethylene
5.7 x 10
1.4 x 10
4.0 x 10
1.9 x 10
4.5 x 10
8.9 x 10
2.1 x'lO
3.3 x 10
9.9 x 10
1.6 x 10
-7
-4
-4
-4
-5
-4
-5
-8
-5
-4
4-21
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The source was modeled as a single stack, although the release point(s)
might be more appropriately considered as vents. The following exit con-
c'itions were assumed: a 10-meter stack height, a 1-meter stack diameter, a
1 meter per second exit velocity, and a release temperature of 10 degrees
Centigrade above the annual average ambient temperature.
A receptor grid was generated so that concentrations were calculated at
100-meter intervals to a distance of 3 kilometers from the point of release.
The receptor points (points at which exposure concentrations were determined)
nearest to the source were 70 meters from the FCF.
In addition to the ISCLT assessment, a second model, LONGZ, was also used
to calculate expected annual impacts due to releases from the FCF. This model
is recommended by EPA for use in second-level screening applications where the
source is located in an urbanized complex terrain valley (USEPA 1986c). LONGZ
is a steady-state Gaussian plume model that utilizes an initial smoothing
function so that pollutants are uniformly dispersed within each wind direction
sector (rather than straight-line plume following, as in ISCLT). Recommended
regulatory options were used.
With LONGZ, the facility was modeled as a building source (an option not
available with ISCLT), that is a building with emissions at a low exit
velocity and with minimal thermal buoyancy from vents or short stacks located
on or immediately adjacent to the building (Bjorklund and Bowers 1982).
A polar coordinate system was employed with LONGZ so that concentrations
were calculated along 16 radii (each 22.5 degrees) at seven equidistant
locations in 600-meter intervals. Terrain elevation values were obtained from
USGS maps of the area and input for each of these receptor points. This grid
is not as dense as that used in ISCLT but is considered adequate due to the
fact that the terrain in the immediate vicinity of the FCF is not of greater
elevation than the release point and does not vary appreciably within the
600-meter intervals. Also, because releases from the FCF will have minimum
thermal buoyancy, it is expected that maximum downwind concentrations will
occur very close to the point of release.
4-22
-------
Both ISCLT and LONGZ were executed five times using five years of
meteorological data in the form of joint frequency distributions of wind
speed, wind direction, and atmospheric stability class. These data, obtained
from the National Climatic Center, were measured during the years 1973 through
1977 at the Greater Cincinnati Airport/Covington, Kentucky. This region is
located in an area of terrain similar to that of the proposed FCF, about
10 miles southwest of the FCF site. It should be noted that, for the FCF
site, these are the most appropriate data available for running the selected
dispersion models. Given the available information, an in-depth analysis
cannot be conducted of the significance of using meteorological data from the
Cincinnati Airport area for the FCF site (i.e., how this numerically affects
the results of the dispersion modeling).
The result of the air dispersion modeling of long-term, low-level release
is depicted in Figure 4-1 as isopleths of unit concentration factors in
micrograms per cubic meter based on a gram/second release rate. The values
plotted represent the maximum predicted ground level atmospheric concentra-
tions at each point, taking into account all five ISCLT and LONGZ analyses.
To derive the ground level concentrations of any contaminant in micrograms per
cubic meter, the unit concentration factors were multiplied by the average
annual release rate of the particular contaminant (in grams/second).
In examining Figure 4-1, it can be seen that the maximum atmospheric
level occurs very close to the release point, within 70 meters in the north-
northeast direction, and that values decrease quite rapidly with distance from
the source. Within 150 meters, concentration factors drop by 40 percent; at
200 meters by 60 percent; and by 250 meters from the point of release, by more
than 80 percent. Maximum values close to the release point were predicted by
the ISCLT model. However, further from the source, the LONGZ model predic-
tions slightly exceeded those of ISCLT and were therefore selected in mapping
exposure levels.
The results of the air dispersion modeling of long-term, low-level
release for the 10 subject carcinogens are presented in Table 4-6. Table 4-6
also presents estimates of dose to the maximally exposed individual. In
conducting the worst-case assessment, the focus is determination of the
4-23
-------
500m
N
Source location is denoted by X
Figure 4-1. Annual Average Unit Concentration Factors (ug/m3) due to
Emission from the Proposed Full Containment Facility.
4-24
-------
TABLE 4-6. EXPOSURE AND DOSE ESTIMATES FOR SUBJECT CARCINOGENS
Maximum Average Annual Average Daily Lifetime Dose
Chemical Exposure Level (ug/m ) (mg/kg body weight/day)
Aldrin 2.8 x ICf5 8 x 10~9
Benzene 6.9 x 10"3 2 x 10~6
Carbon Tetrachloride 2 x 10~2 5.6 x 10~6
Chloroform 9.4 x 10~3 2.7 x 10"6
Chromium VI 2.2 x 10"3 ' 6.3 x 10~7
Methylene Chloride 4.4 x 10"2 1.3 x 10"5
PCB 1.04 x 10"3 3 x 10~7
TCDD 1.6 x 10"6 4.7 x 10~10
Tetrachloroethylene 4.9 x 10~3 1.4 x 10"6
Trichloroethylene 7.9 x 10"3 2.3 x 10"6
4-25
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maximum individual lifetime risk of cancer. For the purposes of charac-
terizing carcinogenic risk, dose must be expressed in terms of average daily
lifetime exposure, and in the units of milligrams of chemical/kilograms of
body weight/day (see the following section). It is therefore assumed that
human receptors in the vicinity of the FCF are exposed to the subject
carcinogens over a 70-year period (average human lifetime), that is that the
facility operates for this period of time and that emissions are constant.
In calculating dose, the following additional assumptions have been made:
(1) breathing rate of 20 cubic meters of air/day; (2) 70 kilograms average
human body weight; and (3) 100 percent availability and absorption of the
subject chemicals by the exposed human receptors.
Risk Characterization
The procedure for calculating risk of exposure to carcinogenic compounds
is well established (USEPA 1986b,e). A non-threshold dose-response model is
applied to the results of animal bioassay or human epidemiological studies to
calculate a carcinogenic potency factor (qx) for each chemical. The potency
factor is then multiplied by the estimated average daily lifetime dose
experienced by the exposed humans to derive an estimate of risk. As follows:
R = D x carcinogenic potency factor (1)
where D = average daily lifetime dose in units of (mg/kg body weight/day)
and carcinogenic potency factor in units of (mg/kg body weight/day)"1
R is an explicit, probabalistic estimate of risk and will have a value between
0 and 1. Risks may be calculated for the maximally exposed individual and for
a population as a whole. Individual risk estimates express the increased
probability that the individual will get cancer over a 70-year period given an
average daily lifetime dose. Population risk estimates (not determined in
this study) are generated by multiplying the individual risk estimate by the
number of people exposed at the given average daily lifetime dose. Population
risk estimates express the incidence of cancer (i.e., number of new cases) in
the exposed receptor group over a 70-year period.
4-26
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When risks of exposure to more than one carcinogen are to be evaluated,
in the absence of information on antagonistic or synergistic interaction, the
risks calculated separately for exposure to each subject chemical may be
summed (USEPA 1986e). As follows:
j- -.
^ = ^2 P^ x (carcinogenic potency factor).
i i=1 L i U
(2)
where DA = average daily lifetime dose for chemical i
and (carcinogenic potency factor)i = the potency factor (q*) for chemical i.
The lifetime risk estimates for the maximally exposed individual for the
10 subject carcinogens are summarized in Table 4-7- Risk estimates are
presented separately for exposure to each of the subject carcinogens, and then
are summarized across all compounds (Total Maximum Lifetime Individual Risk
Estimate) .
As shown in the table, risk estimates for individual exposure to each of
the subject chemicals are in the 10" to 10~8 range except for three
compounds: Cr+6, PCBs, and TCDD. The maximum lifetime individual risk
estimates for these chemicals are 2.6 x 10" , 1.3 x 10" , and 7.1 x 10~ ,
respectively. The overall (combined) risk estimate, risk summed across all
compounds, is "driven" by the magnitude of these values. The total maximum
lifetime individual risk for the 10 subject compounds is estimated to be
approximately 1.0 x 10" . The significance of these findings is discussed in
Section 4.1.2.1.4 (Interpretation of Results).
4.1.2.1.3 Assessment of Risks of Catastrophic Release/Short-Term Exposure
In order to evaluate the maximum short-term risks to human health
associated with emission of chemicals from the FCF, it was necessary to
propose a hypothetical catastrophic release scenario. This scenario then
becomes the basis for exposure assessment and risk characterization. As
discussed in Section 4.1.2.1.1, it is assumed that a leak has occurred in the
natural gas line to the FCF. Gas accumulates in the chemical and sample
storage area, ignites, and explodes with sufficient force to cause a break in
4-27
-------
TABLE 4-7. RISK CHARACTERIZATION, LONG-TERM, LOW-LEVEL RELEASE
Chemical
Aldrin
Benzene
Carbon Tetrachloride
Chloroform
Chromium VI
Methylene Chloride
PCBs
TCDD
Tetrachloroethylene
Trichloroethylene
Carcinogenic
Potency Factor
(mg/kg/day)"1
11.4
2.9 x 10~2
1.3 x ICf1
8.1 x 10~2
41
1.4 x 10"2
4.34
1.5 x 105
5.1 x 10"2
1.1 x 10~2
Average Daily Maximum Individual
Lifetime Dose Lifetime Risk
(mg/kg/day) Estimate
8 x 10~9
2 x 10~6
5.6 x 10"6
2.7 x ICf 6
6.3 x 10~7
1.3 x 10"5
3 x 10"7
4.7 x 10~10
1.4 x 10"6
2.3 x 10~6
9.1 x 10~8
5.8 x 10~8
7.3 x 10"7
2.2 x 10~7
2.6 x 10~5
1.8 x 10~7
1.3 x 10"6
7.1 x 10"5
7.1 x 10~8
2.5 x 10""
Combined Maximum Individual
Lifetime Risk Estimate
1.0 x 10
-4
4-28
-------
the facility roof with large scale release of contaminants. It is further
assumed, that once released, the chemicals become airborne and entrained in
the air, that no physical/chemical transformation occurs, and that dispersion
of the chemical "cloud" released results in human exposure.
Hazard Identification
A subset of the chemicals projected to be present at the facility at the
time of explosion has been selected as the basis for generating a source term
for use in dispersion modeling, and in the subsequent characterization of
adverse acute toxicological effects in exposed receptors. Selection of
chemicals for the short-term exposure assessment was based on the inherent
acute toxicity of the substances under examination and the quantities
projected to be present at the FCF on a yearly basis. The selection was based
on best professional judgment. Table 4-8 is a listing of subject chemicals
and quantities present at the FCF on an annual basis. The quantities of each
chemical used as reagent are identified, as well as the total amounts present
in waste samples. (Refer to Table 4-2 for a listing of estimated quantities
of waste received at the FCF on an annual basis.)
Toxicity Assessment
In evaluating the risks to human health due to short-term exposure to
contaminants released from the FCF, it is necessary to obtain acute toxicity
endpoints as a basis for comparison. Ideally, the toxicity endpoint of choice
for evaluating the short-term exposure scenario is the Acceptable Intake (AI)
for acute toxicity via inhalation. The EPA Environmental Criteria and
Assessment Office (ECAO) of the Office of Research and Development was
consulted in order to obtain appropriate toxicity endpoints for the selected
compounds. Currently, however, acute AIs are not available, and no accepted
methods have been proposed for generating the values (Personal communication,
Michael Dourson August, 1986). A limited number of inhalation AIs (ref.) are
available for subchonic and chronic inhalation exposure, but these do not
comprehensively cover all of the subject compounds selected.
In the absence of appropriate acute AI values, and given that the
anticipated exposure period is on the order of hours and not days or weeks
4-29
-------
TABLE 4-8. TOTAL QUANTITIES OF SUBJECT CTOffCALS HAICLED AMWALU AT THE PCF: CATASTROPHIC KEIEASE
Compound Name3 Quantity of chemicals Concentrations/Total Quantities of Chemicals in Waste Samples Handled by
kept on hand as liquid PCF on Yearly Basisb'c'd'"
solvent or as reagent
chemicals, g/yr
Contaminated liquids Industrial process
and solids, waste water, municipal
Contaminated Surface oils and solvents, wastewater, and
Contaminated Soils Water and Groundwater leachate (1700 industrial waste-
Aldrin
Beryllium Compounds
Cadmium
Carbon Tetrachloride
Hexychlorocyclo-
pentadiene
Methylene chloride
Potassium cyanide
Styrene
Tetrachloroethylene
Trichlorobenzene
13
120
150
12000
1000
26000
400
1000
1000
500
(55kg/yr>
10 ppn/0.55 g
10 ppn/0.55 g
10 ppn/0.55 g
10 ppn/0.55 g
10 ppn/0.55 g
10 ppn/0.55 g
10 ppn/0.55 g
10 ppn/0.55 g
10 ppa/0.55 g
10 ppn/0.55 g
(1100 kg/yr)
10 ppn/11 g
10 ppn/11 g
10 ppn/11 g
10 ppn/11 g
10 ppn/11 g
10 ppn/11 g
10 ppn/11 g
10 ppn/11 g
10 ppn/11 g
10 ppn/11 g
kg/yr)
2 ppn/3.4 g
1.2 ppn/2.0 g
14 ppn/23.8 g
342 ppn/581.4 g
59 ppn/100.3 g
780.8 ppn/1327 g
300 ppm/510 g
1742.2 ppn/2962 g
1345.3 ppn/2287 g
67 ppn/113.9 g
water (3300 kg/yr)
no data/ 0.0
no data/ 0.0
0.019 ppn/0.063 g
0.007 ppn/0.023 g
no data/ 0.0
1.079 ppn/3.6 g
0.318 ppn/1.05 g
no data/ 0.0
0.018 ppn/0.059 g
0.003 ppn/0.010 g
Total Contam- Total
inant in waste Annual
g/yre Quantity
g
14.95
13.55
35.41
615.95
111.85
1342.15
522.60
2973.55
2298.61
125.46
27.95
133.55
185.41
12615.95
1111.85
27342.15
922.60
3973.55
3298.61
625.46
-------
a) list of chemicals compiled from information supplied by EPA: Winter (03/07/86); Dobbs (03/03/86); Lichtenberg (03/06/86); LLchtenberg and Winter
(02/28/86).
b) Quantities taken fron information received in a) above and from: liberick (02/28/86); Winter (01730/86). Where liquid volumes vere given, an average
density of 5 kg/gallon vas assameri. Maximum estimate of quantity was used when a range was given.
c) Concentrations in contaminated liquids and solids, waste oils and solvents, and leachates taken from Blackman et al. (1984).
d) Concentrations for industrial process waters, municipal wastewaters, and industrial wastewaters taken from USEPA (1986a) and SAIC (1985).
e) No data were found on levels of subject chemicals in sea water (1650 kg/yr handled at the FCF). Concentrations were therefore assumed to be zero.
-------
(see the following section - Exposure Assessment), ECAO agreed that the
American Conference of Governmental Industrial Hygienists (ACGIH) Short-Term
Exposure Limits (STELs) may be appropriately used. ECAO suggested that the
STELs be modified by an uncertainty factor of 10 to account for interhuman
variability to the toxicity of the chemical in lieu of chemical-specific data.
When STEL values were not available, ECAO advised that*the new ACGIH excursion
limit recommendations should be adopted for evaluating short-term exposures
(ACGIH 1986/87). The ACGIH excursion limit recommendation is defined as 3
times the TLV (Threshold Limit Value) for no more than a total of 30 minutes
during the work day and under no circumstances more than 5 times the TLV. In
the FCF EIS, 3 tim<;s the TLV was chosen as the most conservative measure.
Further, this value was modified (i.e.; divided) by an uncertainty factor of
10 (as was similarly done for the available STEL values)'to reflect interhuman
variability to the toxicity of the chemical in lieu of chemical-specific data.
The modified toxicity endpoints for the selected subject compounds are
presented in Table 4-9.
Exposure Assessment
The exposure assessment for the short-term catastrophic release scenario
consists of three major components: (1) developing estimates of release rates
!
associated with an explosion at the FCF; <2) selection and application of
atmospheric transport models to estimate ambient environmental levels of the
subject compounds; and (3) quantification of maximum short-term exposure
levels.
For the catastrophic release scenario, it has been assumed that the total
quantities of the subject compounds present at the FCF are released to, and
entrained in the atmosphere following an explosion. For the purposes of
transport modeling (discussed below), release rates must be defined in terms
of mass emitted to the atmosphere each second over a one-hour period. We have
therefore apportioned the total quantity of subject chemical present at the
facility (Table 4-8) over a one-hour period (3600 seconds) to derive an
estimate of grams released/second. The explosion is not treated in an
absolute sense as an instantaneous release, but in essence, a large scale,
total loss of contaminants over a one-hour period. The release rates are
summarized in Table 4-10.
4-32
-------
TABLE 4-9. TOXICITY ENDPOINTS FOR SUBJECT COMPOUND-
SHORT-TERM, CATASTROPHIC RELEASE
Modified Toxicity Endpoint'
Toxicity Endpoint* (Uncertainty Factor of 10)
Chemical (ug/m ) (ug/m )
Aldrin
Beryllium Compounds
Cadmium Powder
Carbon Tetrachloride
Hexachlorocyclopentadiene
Methylene Chloride
Potassium Cyanide
Styrene
Tetrachloroethylene
Trichlorobenzene
750
6
150
9 x 104
300
1.74 x 106
1.5 x 104
4.25 x 105b
1.34 x 106b
1.2 x 105
75
0.6
15
9 x 10
30
1.74 x
1.5 x
4.25 x
1.34 x
1.2 x
3
105
103
104
105
10"
"American Conference of Governmental Industrial Hygenists 1986/87 (ACGIH) new
excursion limit recommendations for short-term exposure is 3 x TLV for no
more than a total of 30 minutes during the work day and under no
circumstances more than 5 x TLV. When toxicological data are available to
establish a Short Term Exposure Limit (STEL - 15-minute time-weight average
not to be exceeded at any time during work day), this value takes precedence
over the excursion limit. Values present are excursion limits calculated as
3 x TLV except for chemicals so noted.
bSTEL: ACGIH Short-Term Exposure Limits 1986/87.
cModified Toxicity Endpoint: Toxicity Endpoint/10 to reflect interhuman
variability in response to exposure to toxicants in lieu of chemical-specific
data.
4-33
-------
Air dispersion modeling for the short-term, catastrophic release was
conducted using PTPLU (USEPA 1984a), an EPA-approved screening level air
quality model. PTPLU is an improved version of PTMAX, a steady-state/
straight-line Gaussian plume model that predicts maximum short-term
atmospheric concentrations from a single point source as a function of
atmospheric stability and wind speed. Using PTPLU, one-hour X/Q estimates
(the ratio of concentration over emission rate in units of sec/m ) may be
determined using both constant wind speed with height and wind speed profile
exponents. PTPLU may therefore be used to evaluate ground-level ambient
atmospheric concentrations under worst-case meteorological conditions. PTPLU
is a flat, terrain model, but its use can be justified because maximum exposure
concentrations are shown to occur very close to the source of release (see
discussion below), where terrain variations are minor.
The PTPLU model was used to model a hypothetical explosion at the FCF.
Only rough estimates are available of the exit conditions associated with an
explosion of sufficient force to penetrate the exterior of the proposed FCF.
Three cases have been considered, and the PTPLU model was run using input from
each of these, to determine the worst-case maximum exposure levels. The three
cases differ in the extent of structure penetration (i.e., the width of the
exit fracture and height of the lofting of the contaminants/plume) and in the
temperature and velocity of the blast emission.
Case 1; 15-meter effective stack height, 3-meter stack (fracture)
width, 1000°K temperature, 20-meter/second exit velocity
Case 2; 20-meter effective stack height, 3-meter stack width, 1000°K
temperature, and 20-meter/second exit velocity
Case 3; 30-meter effective stack height, 5-meter stack width, 2000°K
temperature, and 30-meter/second exit velocity.
In addition to these three cases, PTPLU was run three times to simulate
summer, winter, and annual average meteorological conditions (variations in
mixing height and ambient temperature).
The results of the air dispersion model using PTPLU (at a set emission
rate of 1 g/sec) indicated that the maximum X/Q values were associated with
4-34
-------
TABLE 4-10. RELEASE RATES AND MAXIMUM EXPOSURE LEVELS-
SHORT-TERM, CATASTROPHIC RELEASE
Chemical
Aldrin
Beryllium
Cadmium
Carbon Tetrachloride
Hexachlorocyclopentadiene
Methylene Chloride
Potassium Cyanide
Styrene
Tetrachloroethylene
Trichlorobenzene
Release Rate
(g/sec)
7.8 x 10"3
3.7 x 10~2
5.2 x 10~2
3.5
3.1 x 10'1
7.6
2.6 x 10"1
1.1
9.2 x 10"1
1.7 x 10'1
Maximum One Hour*
Exposure Level (ug/m )
0.03
0.14
0.19
12.95
1.15
28.12
0.96
4.07
3.40
0.63
*At a distance of 0.27 km from the point of release. Worst-case conditions;
15 m effective stack height, stability class 3, wind speed 16.3 m/sec,
summer.
4-35
-------
Case 1 above, during summer conditions. Table 4-11.presents the results of
this run. As shown, the maximum X/Q value was 3.7 x 10~6 at a distance of
approximately 0.3 kilometers from the source of release. This ambient concen-
tration is associated with a wind speed of 16.3 meters/second; and an
atmospheric stability class 3. In order to determine the exposure
concentration for each subject chemical, this X/Q value is simply multiplied
by the release rate for each compound under investigation.
PTPLU models one-hour exposure concentrations following a one-hour period
of release. As noted previously, in order to generate release rates for the
subject chemicals, the total quantity of a given contaminant at the facility
was assumed to be released over a one-hour period following the hypothetical
explosion at the FCF. The release rates presented in Table 4-10 were thus
multiplied by the X/Q value of 3.7 x 10~6 to yield the estimate of maximum
exposure concentration.
Risk Characterization
Characterization of noncarcinogenic risks of exposure to toxicants is
accomplished by comparing estimated exposure levels to a selected acceptable
toxicity limit for the compound under consideration (USEPA 1986c). This
method, often referred to as the quotient method, is based on the assumption
that, for noncarcinogenic effects, there is a threshold exposure level below
which adverse toxicological effects are not anticipated to occur. Risk of
noncarcinogenic effects is characterized as follows:
R = E/AI (2)
where E = expected exposure and
AI = an acceptable toxicity limit.
The factor R is not a probabilistic estimate of the likelihood of adverse
V"
health effects (as is the case for the assessment of carcinogens). In this
case, the value of R will vary from <1 to >1. If R is >1, then adverse health
effects in exposed receptor groups may be anticipated. It is important to
recognize that, depending upon the selection of the acceptable limits, risk
4-36
-------
FTPLU VERSION 80021, TOM PIERCE AND BRUCE TURNER : ENVIRONMENTAL OPERATIONS BRANCH
EPA CINCINNATI SUMMER CONDITIONS ONE-HOUR RELEASE
OPTIONS 1=YES USE THE OPTION 0=NO DO NOT USE THE OPTION
IOPT(1) = 1 (COMPUTE GRADUAL PLUME RISE) AMBIENT AIR TEMP = 303.00 (DEC, K)
IOPT(2) = 1 (COMPUTE STACK DOWNWASH) WIND EXPONENTS = 0.10 0.15 0.20 0.25 0.30 0.30
IOPT(3) = 1 (COMPUTE INITIAL PLUME SIZE) ANEMOMETER HT = 10.00 (METERS)
IF = 1 USE PASQUILLS RECOMMENDATION
-P-
i
U)
EMISSION RATE =1.00 (G/SEC)
STACK TEMP = 1000.00 (DEG.K)
STACK DIAM =3.00 (METERS)
MIXING HT = 1700.0 (METERS)
SOURCE PARAMETERS
PHYSICAL STACK HEIGHT =15.00 (METERS)
STACK EXIT VELOCITY =20.00 (M/SEC)
VOLUME FLOW = (141.37 (CU M/SEC)
RECEPTOR HT = 0.00 (METERS)
TABLE 4-11. MAXIMUM ONE-HOUR EXPOSURE LEVELS -
ANALYSIS OF CONCENTRATION AS A FUNCTION OF STABILITY AND WIND SPEED
****EXTRAPOLATED WINDS****
IILITY WIND SPEED MAX CONG
(M/SEC) (G/CU M)
1
1
1
1
1
1
1
2
2
0.50
0.80
1.00
1.50
2.00
2.50
3.00
0.50
0.80
2.4124E-07
5.1865E-07
4.7275E-07
4.8964E-07
7.2327E-07
9.5285E-07
1.1728E-06
2.3989E-07
2.2640E-07
DIST OF MAX
(KM)
0.011
1.805
1.736
1.000
0.826
0.716
0.639
0.011
8.809
PLUME RISE
(M)
115.3
1519.9(2)
1218.9(2)
735.5(2)
490.0(2)
360.4(2)
281.8(2)
115.3
1519.9(2)
WIND SPEED MAX CONC DIST OF MAX
(M/SEC) (G/CU M) (KM)
0.52
0.83
1.04
1.56
2.08
2.60
3.12
0.53
0.85
2.3199E-07
5.1034E-07
4.6467E-07
5.1852E-07
7.6176E-07
9.9925E-07
1.2255E-06
2.2622E-07
2.1595E-07
0.011
1.797
1.715
0.973
0.805
0.698
0.623
0.012
8.680
PLUME RISE
(M)
111.3
1460.1(2)
1171.1(2)
694.4(2)
463.4(2)
341.1(2)
266.9(2)
115.5
1431.1(2)
-------
TABLE 4-11. MAXIMUM ONE-HOUR EXPOSURE LEVELS -
ANALYSIS OF CONCENTRATION A3 A JUNCTION OF STABILITY AND WIND SPEED (continued)
****EXTRAPOLATED WINDS****
STABILITY WIND SPEED MAX CONC
(M/SEC) (G/CU M)
2
2
2
2
2
2
2
3
3
i
U)
oo 3
3
3
3
3
3
3
4
4
4
1.00
1.50
2.00
2.50
3.00
4.00
5.00
2.00
2.50
3.00
4.00
5.00
7.00
10.00
12.00
15.00
0.50
0.80
1.00
1.9534E-07
2.2671E-07
2.8439E-07
3.3830E-07
3.8905E-07
4.8285E-07
6.8256E-07
1.9738E-07
2.4245E-07
2.8630E-07
3.7051E-07
4.5040E-07
5.9833E-07
1.3413E-06
1.9554E-06
3.1244E-06
2.3796E-07
1.4985E-07
1.2085E-07
DIST OF MAX
(KM)
7.861
4.465
3.437
2.814
2.393
1.859
0.537
7.603
6.000
4.953
3.670
2.920
2.083
0.400
0.360
0.296
0.011
0.022
0.030
PLUME RISE
(M)
1218.9(2)
817.6(2)
616.9(2)
496.6(2)
416.3(2)
316.0(2)
157.5
616.9(2)
496.6(2)
416.3(2)
316.0(2)
255.8(2)
187.0
73.5
60.5
45.9
115.3
117-8
116.9
WIND SPEED MAX CONC DIST OF MAX
(M/SEC) (G/CU M) (KM)
1.06
1.59
2.13
2.66
3.19
4.25
5.31
2.17
2.71
3.25
4.34
5.42
7.59
10.84
13.01
16.27
0.55
0.89
1.11
1.9122E-07
2.3786E-07
2.9824E-07
3.5452E-07
4.0743E-07
5.0499E-07
7.8999E-07
2.1275E-07
2.6112E-07
3.0806E-07
3.9797E-07
4.8292E-07
6.8387E-07
1.5980E-06
2.2672E-06
3.7356E-06
2.1512E-07
1.3583E-07
1.0980E-07
7.284
4.221
3.254
2.666
2.268
1.763
0.510
6.973
5.507
4.549
3.376
2.690
0.455
0.382
0.343
0.271
0.012
0.025
0.035
PLUME RISE
(M)
1147.9(2)
770.2(2)
581.4(2)
468.1(2)
392.6(2)
298.2(2)
144.6
570.1(2)
459.0(2)
385.0(2)
292.5(2)
237.0(2)
99.0
67.3
55.6
41.1
111.5
116.5
117.4
-------
TABLE 4-11. MAXIMUM ONE-HOUR EXPOSURE LEVELS -
ANALYSIS OF CONCENTRATION AS A FUNCTION OF STABILITY AND WIND SPEED (continued)
****EXTRAPOLATED WINDS****
STABILITY WIND SPEED MAX CONG
(M/SEC) (G/CU M)
4
4
4
4
4
4
4
4
f 4
Ld
4
4
5
5
5
5
5
6
6
6
6
1.50
2.00
2.50
3.00
4.00
5.00
7.00
10.00
12.00
15.00
20.00
2.00
2.50
3.00
4.00
5.00
1.00
1.50
2.00
2.50
8.3329E-08
6.6100E-08
6.8598E-08
8.9315E-08
1.3478E-07
1.8420E-07
2.8287E-07
4.3569E-07
5.3636E-07
7.4524E-07
1.7902E-06
6.6911E-07
6.4862E-07
6.2796E-07
5.9478E-07
5.6932E-07
4.8927E-07
5.0545E-07
5.1547E-07
5.1894E-07
DIST OF MAX
(KM)
0.056
0.087
29.998
22.189
13.758
10.001
6.133
3.681
2.993
0.548
0.410
10.979
10.000
9.456
8.030
7.108
25.239
18.169
15.000
15.000
PLUME RISE
(M)
119.1
120.2
496.6(2)
416.3(2)
316.0(2)
255.8(2)
187.0
135.4
115.3
62.2
41.8
176.0
164.5
155.7
142.8
133.6
183.4
162.1
148.6
139.0
WIND SPEED MAX CONG DIST OF MAX
(M/SEC) (G/CU M) (KM)
1.66
2.21
2.77
3.32
4.43
5.53
7.75
11.07
13.28
16.60
22.13
2.26
2.82
3.39
4.52
5.65
1.13
1.69
2.26
2.82
7.6458E-08
6.1639E-08
7 . 9459E-08
1.0333E-07
1.5552E-07
2 . 1000E-07
3.2068E-07
4.8996E-07
5.9572E-07
1.0319E-06
2.3480E-06
6.5821E-07
6.3501E-07
6.1388E-07
5.8087E-07
5.5554E-07
4.9434E-07
5.0987E-07
5.1811E-07
5.1820E-07
0.066
1.102
25.418
18.719
11.648
8.694
5.291
3.198
2.630
0.496
0.369
10.186
9.783
8.829
7.511
6.645
22.819
16.538
15.000
15.000
PLUME RISE
(M)
120.2
120.8
450.1(2)
377.6(2)
287.0(2)
232.6(2)
170.4
123.8
105.7
53.9
36.5
169.6
158.5
150.1
137.7
128.9
176.7
156.2
143.3
134.1
-------
TABLE 4-11. MAXIMUM ONE-HOUR EXPOSURE LEVELS -
ANALYSIS OF CONCENTRATION AS A FUNCTION OF STABILITY AND WIND SPEED (continued)
****EXTRAPOLATED VTNDS****
STABILITY WIND SPEED MAX CONC DIST OF MAX PLUME RISE WIND SPEED MAX CONG DIST OF MAX PLUME RISE
(M/SEC) (G/CU M) (KM) (M) (M/SEC) (G/CU M) (KM) (M)
6 3.00 5.1709E-07
6 4.00 5.0510E-07
6 5.00 4.9202E-07
15.000
14.668
12.726
131.71
121.1
113.5
3.39
4.52
5.65
5.1337E-07
4.9805E-07
4.8464E-07
15.000
13.580
11.788
127.1
116.8
109.5
*-
o
(1) NO COMPUTATION WAS ATTEMPTED, AS THE DISTANCE TO THE POINT OF MAXIMUM CONCENTRATION IS SO GREAT THAT
THE SAME STABILITY IS NOT LIKELY TO PERSIST LONG ENOUGH FOR THE PLUME TO TRAVEL THIS FAR.
(2) THE PLUME IS OF SUFFICIENT HEIGHT THAT EXTREME CAUTION SHOULD BE USED IN INTERPRETING THIS
COMPUTATION, AS THIS STABILITY TYPE MAY NOT EXIST AT THIS HEIGHT. ALSO, WIND SPEED VARIATIONS
WITH HEIGHT MAY EXERT A DOMINATING INFLUENCE.
(3) NO COMPUTATION WAS ATTEMPTED FOR THIS HEIGHT, .AS THE POINT OF MAXIMUM CONCENTRATION IS GREATER THAN
100 KILOMETERS FROM THE SOURCE.
-------
characterization using equation (2) above may be used to evaluate a full
spectrum of health effects ranging from eye/throat irritation, to central
nervous system effects, to mortality.
In the assessment of the FCF, we have selected very conservative toxicity
limits for use in risk characterization. As discussed in the section on
toxicity assessment, STEL or ACGIH excursion limit recommendations were
chosen. These toxicity endpoints, when exceeded for a short period of time,
would be associated with minor, reversible health effects in exposed
individualsfor example, eye, nose, or throat irritation, dizziness, mild
nausea. These limits should thus be considered as "trigger levels" indicating
concern for potential adverse effects. Taking the advice of ECAO, these
limits, which already incorporate safety factors, were reduced further, by a
factor of 10 to account for the uncertainty/interhuman variability.
Table 4-12 summarizes the risks of short-term, catastrophic release of
contaminants for the FCF. As shown, the toxicity limits were not exceeded
(R < 1) for any of the subject compounds. The significance of this result is
discussed in the section that follows.
4.1.2.1.A Interpretation of the Results of the Risk Assessment
Before discussing the results of the risk characterization for long-term,
low-level release, and short-term catastrophic release of contaminants, it is
important to review the key assumptions made in this study.
Assumptions Concerning Release of Contaminants for the FCF - Long-Term,
Low-Level Release
The total quantity of a given compound present at the FCF on a yearly
basis was estimated using EPA information on amounts present as
reagent, solvent, standards, and projected quantities present in waste
samples (see Appendix A).
The total annual quantity of subject chemicals present at the FCF as
reagent, solvent, or contaminant in waste samples is the amount
released to the air filtering system over a one-year period (i.e.,
none of the subject chemicals end up in liquid wastes).
The air filtering system (HEPA and HEGA filters) removes none (0.0
percent) of the contaminants present in the exhaust air.
4-41
-------
TABLE 4-12. RISK CHARACTERIZATION - SHORT-TERM, CATASTROPHIC RELEASE
Chemical
Maximum One
Hour Exposure
Level (ug/m )
Modified
Toxicity
Endpoint
(ug/m3)
Risk
Characterization
Exposure/
Toxicity Limit
Exceeds
Toxicity
Limits
Aldrin
Beryllium Compounds
Cadmium Powder
Carbon Tetrachloride
Hexachlorocyclopentadiene
Methylene Chloride
Potassium Cyanide
Styrene
Tetrachloroethylene
Trichlorobenzene
0.03
0.14
0.19
12.95
1.15
28.12
0.96
4.07
3.40
0.63
75
0.6
15
9 x 103
30
1.74 x 105
1.5 x 103
4.25 x 104
1.34 x 105
1.2 x 104
0.0004
0.233
0.013
0.001
0.038
0.0002
0.0006
<0.0001
<0.0001
<0.0001
No
No
No
No
No
No
No
No
No
No
4-42
-------
Release from the FCF is constant and continuous occurring 24 hours a
day, 365 days a year, for 70 years.
Assumptions Concerning Release of Contaminants from the FCF - Catastrophic
Release ~~ "
The total quantity of the subject chemicals present at the FCF as
reagent, solvent, or contaminant in waste samples is the amount
released following an explosion at the facility.
This release occurs over a one-hour period.
The hypothetical explosion in the roof of the FCF creates an opening
(fracture) 3 meters in diameter and carries a "cloud" of contaminants
to a height of 15 meters above ground level (the effective stack
height).
The exit temperature and velocity were 1000°K and 20 meters/second,
respectively.
Assumptions Relating to Exposure Assessment
Once released to the atmosphere, the subject chemicals remain aloft/
entrained in the air while atmospheric dispersion occurs; that is, no
settling or wash-out of contaminants is assumed.
All subject chemicals are treated as conservative; that is, no
physical, chemical, or biological transformation occurs.
The exposure levels of concern in this public health assessment are
the ground-level, ambient atmospheric concentrations experienced by
the maximally exposed individual. In order to conduct a worst-case
assessment, these values were chosen even though the maximum exposure
levels are clearly "out-liers" and the range of estimated values span
more than an order of magnitude.
For the long-term, low-level release scenario, dose was characterized
for the adult male by converting the maximum exposure level to an
average daily lifetime dose, assuming 70 kilograms body weight, and a
breathing rate of 20 cubic meters a day. The maximally exposed
individual was assumed to experience the average daily lifetime dose
for 70 years (lifetime).
In the short-term, catastrophic release scenario, maximum one-hour
exposure concentrations were determined for each subject chemical, and
these values were used in assessing noncarcinogenic risks. It was not
necessary to determine dose here, because risk characterization
consists of comparison with acceptable exposure levels.
Assumption Relating to Toxicity Assessment and Risk Characterization
The selection of subject compounds as the focus of the public health
assessment (i.e., a subset of universe of chemicals handled at the
FCF) is an adequate basis for characterizing risks associated with
operation of the FCF.
4-43
-------
It is clear from the above assumptions that the focus of the assessment
is a worst-case evaluation of potential risks to human health. Limitations in
the data available to characterize (1) the activities at the FCF, (2) the
substances handled (nature and quantity), (3) the loss of chemicals to the air
filtering system, (4) the influence of the HEPA and HEGA filters over time on
contaminant pass through, and (5) the release of chemicals to the atmosphere,
justify the use of worst-case assessment. If this assessment demonstrates
that the risks to human health are acceptable, then no further evaluation need
be conducted.
Risk characterization of long-term, low-level release of the subject
carcinogens indicated a total maximum individual lifetime risk estimate of 1.0
x 10~4. This can be viewed as an increased probability of 1 in 10,000 that an
individual will get cancer following exposure over a 70-year period
(lifetime). The magnitude of this value is "driven" by the risk estimates for
three of the subject carcinogens: TCDD (dioxin), PCBs, and chromium VI (the
total maximum individual lifetime risk for the other eight chemicals is 1.4 x
10~6). There is no demonstrably safe level of exposure to carcinogens, that
is, an exposure level carrying no risk of cancer. In the EPA Superfund
Program, the 10" risk level is recommended as a target level for public
health assessment with a range of 10~7 to 10~4 considered acceptable in the
selection of remedial action alternatives of hazardous waste sites (Zamuda et
al. 1986). Ultimately, the decision of acceptability rests with the public
and the responsible regulatory agency. Given the assumptions made in
conducting the worst-case assessment, however, the results of analysis for the
FCF indicate no substantial increase in cancer risks for the maximally exposed
individual living in the vicinity of the facility.
The finding of no substantial increase in cancer risks due to long-term,
low-level release of chemicals from the FCF is based upon a number of
considerations. First, the maximum individual lifetime risk estimates are
based upon the single highest predicted ground-level atmospheric concentration
in the vicinity of the facility (i.e., at 70 meters north-northeast). The
concentrations of chemicals released are anticipated to decrease, however, by
more than 80 percent within a distance of 250 meters (approximately 820 feet)
from the FCF. Further, all the chemicals projected to be released from the
4-44
-------
facility were treated as conservative, that is, that physical/chemical trans-
formation processes would remove none of the compounds from the ambient air.
Finally, and of greatest importance are the assumptions that the total annual
quantity of the subject chemicals present within the FCF would be released to
the air filtering system over a one-year period and that there is no removal
(0 percent) of contaminants from the exhaust air stream.
The assumption that a given chemical used within the FCF would be
completely lost to the filtering system is unrealistic for all but the most
highly volatile compounds. The argument can be made for compounds with a high
vapor pressure such as methylene chloride, chloroform, benzene, carbon
tetrachloride, trichloroethylene, and tetrachloroethylene (vapor pressures of
362.4, 150.5, 95.2, 90, 57.9, and 14 mmHg, respectively). But for PCBs,
chromium metal, and TCDD (vapor pressures 10~3 to 10~5, <10~5, and 7.4 x 10~10
mmHg, respectively), this assumption is very unrealistic. In laboratory use,
TCDD will readily adsorb to particulate matter, and the only substantial
movement of the compound through the air would be on the surface of
particulates. The same applies to PCBs and chromium, although a small
percentage of the total amount of chromium metal may be released to the
atmosphere as metal fume from analytical instrumentation.
Thus, only a fraction of the total amount of TCDD, PCBs, and chromium VI
present at the FCF is likely to be lost to the air filtering system, and this
would be as particulates. The HEPA filter in the proposed FCF is indicated to
be 99.99 percent efficient (USEPA 1985a, 1986a or b). Therefore, the final
quantity of TCDD, PCBs, and chromium VI on particulates that might be released
to the atmosphere would be further reduced to a great extent. If we estimate
that only one percent of the total annual quantity of TCDD, PCBs, and chromium
VI present at the FCF is lost to the air filtering system, and that only one
percent of this amount passes through the HEPA filter (both conservative
assumptions), then atmospheric release rates and subsequent individual risk
estimates would be reduced by four orders of magnitudes. The combined maximum
individual lifetime risk estimate for TCDD, PCBs, and chromium VI would be
approximately 1 x 10~ .
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For the purpose of comparison, it is helpful to examine "background"
inhalation cancer risks associated with the urban environment. EPA recently
completed a study of airborne carcinogens and the magnitude and nature of the
air toxics problem in the United States. It was found that, in urban areas,
the additive lifetime individual cancer risk attributable to simultaneous
exposure to 10 to 15 pollutants ranged from 10~3 to 10~4 (Berry 1986). These
EPA estimates were determined using actual monitoring data. They are not
source-specific but represent a portion of the total risk associated with the
complex mixture of contaminants typical of urban ambient air.
In evaluating noncarcinogenic risks to human health associated with the
catastrophic release of chemicals, the results of analysis indicate that none
of the predicted maximum worst-case one-hour exposure levels was found to
exceed the very conservative, modified toxicity endpoints selected [i.e.,
STEL/10 or (3 x TLV)/10]. Given this result, the noncarcinogenic risks to
human health associated with catastrophic release of contaminants from the FCF
are considered acceptable.
4.1.2.2 Land Use/Demography
Once the FCF is built, operation of the facility is not anticipated to
result in any measurable impacts on surrounding land uses, development, or
population characteristics. Overall, a maximum of only 6 to 15 new staff
would join AWBERC in order to work at the FCF. However, most of the antic-
ipated new FCF staff already work in other parts of AWBERC. No secondary land
use or demographic effects are expected as a result of operating the FCF. It
would not result in any significant change in overall land use in the area,
since the university-medical complex already contains numerous laboratories of
various kinds.
A. 1.2.3 Transportation
Because of the small number of people expected to work at the FCF, no
significant transportation impacts are anticipated due to staff commuting
needs. Sufficient parking for any new personnel is available on the AWBERC
grounds.
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Based on the EPA estimates of the total amounts of material that will be
transported to the facility (see Section 4.1.2.1.1 on Hazardous Identifica-
tion, above), no noticeable impacts on local traffic patterns are anticipated.
EPA expects that samples delivered to the FCF will arrive from many sources,
in particular from Greater Cincinnati Airport (by van or other small delivery
vehicle) via 1-75 and 1-71. It is unlikely that more than one or two samples
or chemical deliveries destined for the FCF would take place on any given
working day.
The small samples of hazardous and toxic materials, as well as toxic or
hazardous laboratory chemicals, would be packed to minimize the potential of
any toxic release to environment during transportation to the FCF. Packing
and labelling will comply with Federal Department of Transportation and EPA
requirements, described in 49 CFR Parts 100 to 179 and 40 CFR part 263. These
packing requirements provide protection against release of transported
compounds in the event of accidents during transport. In addition, shipping,
packing, and other handling would comply with rules of any common carriers or
courier services delivering materials to the AWBERC facility.
All available measures would be taken to minimize the potential for a
toxic release to the environment resulting from an accident. Mitigation
measures are described in Section 4.2.2 below.
4.2 MITIGATION OF ADVERSE IMPACTS
4.2.1 Mitigation of Construction Impacts
Standard mitigation practices will be implemented during the construction
phase, including erosion and noise control measures, visual barriers, and
construction traffic control.
4.2.2 Mitigation of Operational Impacts
In this section, potential environmental impacts resulting from the
operation of the EPA Hazardous Waste Engineering Laboratory will be discussed.
Alternative strategies will be proposed for mitigation of operational impacts.
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The potential environmental impacts resulting from the operation of the EPA
laboratory have been delineated as follows:
Potential impacts to public health - release of toxic substances to
the atmosphere
Potential impacts to human health and aquatic life - release of toxic
substances to the Mill Creek POTW
Potential impacts to laboratory workers - hazardous waste storage
accidents
Potential impacts to laboratory workers - chemical storage accidents.
4.2.2.1 Potential Impacts to Public Health - Release of Toxic Substances to
the Atmosphere
Potential impacts to public health has been discussed in Section 4.1.2.1.
EPA will implement procedures outlined in the Toxic Substance Control Manual
(USEPA 1982) to mitigate potential exposure.
4.2.2.2 Potential Impacts to Human Health and Aquatic Life - Release of Toxic
Substances to the Mill Creek POTW
As the proposed EPA laboratory will have laboratory sinks directly
connected to the Cincinnati sewer system, the possibility exists for labora-
tory chemicals to be accidentally discharged to that system. Such spills
could have potential adverse impacts on the city's sewage collection system,
operation of the city's Mill Creek POTW, water quality of the Mill Creek
POTW's receiving stream (Ohio River), and the quality of the sludge generated
by the POTW's treatment processes.
It is not anticipated that laboratory chemicals could be accidentally
spilled into laboratory sinks in sufficient quantities to cause explosive
and/or toxic levels to accumulate in the city sewer. Risk to city sewer
workers are therefore minimal.
The Cincinnati Mill Creek POTW is a conventional secondary wastewater
plant designed to receive 120 MGD of wastewater. Owing to design limitations
for sludge handling, however, full secondary treatment is only provided for
20 to 25 MGD. The remainder presently receives primary treatment only. The
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Mill Creek POTW discharges all treated wastewaters to the Ohio River. Sludge
wastes from the POTW's sludge return line is subjected to anaerobic digestion,
heat treatment, vacuum filtration, and incineration, in sequence.
Given the effect of dilution (to 120 MGD), it is expected that discharges
of small amounts of toxic substances by the EPA laboratory would not be
detectable at the Mill Creek POTW or its receiving stream, nor would any
discernable impact to biological treatment systems be expected.
4.2.2.3 Potential Impacts to Laboratory Workers - Hazardous Waste Storage
Accidents
The proposed practice of hazardous waste storage within the laboratory
itself does pose certain risks to laboratory workers. Chemicals of high
toxicity, reactivity, flammability, and/or explosivity may be stored for
extended periods of time in the laboratory's hazardous waste storage area.
Development of safety procedures for handling and working around these
hazardous wastes will be difficult, as exact compositional data for these
wastes will not be available.
4.2.2.4 Potential Impacts to Laboratory Workers - Chemical Storage Accidents
The chemical storage area proposed for the laboratory facility appears
quite small in Figure 2-2. It is possible, therefore, that reactive chemicals
may be stored in close proximity to each other within the storeroom, enhancing
the possibility of accidental spills, fires, and explosions. To the extent
feasible within the physical constraints of the facility, reactive chemicals
should be stored in a secure manner. Oxidants should not be stored next to
reductants acids should be kept away from bases, and so on. Reactive chemical
liquids such as sulfuric acid should be stored on lower shelves within the
storeroom, and the higher shelves should be reserved for more inert chemicals.
4.2.2.5 Potential Impacts to Populations Along Transportation Routes
Based on information provided by the City of Cincinnati's Planning
Department and Ohio-Kentucky-Indiana Regional Council of Governments (OKI), it
appears that the routes from the airport and from interstate highways shown in
Figure 3-5 are, in fact, the routes that would minimize the potential for
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accidental release of toxic materials to the environment (Larry Annett,
Cincinnati City Planning Department, March 1986; Ann Gordon, OKI, March 1986).
It is important to note that any toxic or hazardous samples being transported
to the FCF will be in extremely small quantities. Environmental samples in
55-gallon quantities such as sea water, surface water, groundwater, and
industrial or municipal wastewater will be received biannually. All samples
will be packed and handled according to standard methods designed to minimize
container breakage and contain any leakage within the package to be delivered
to the FCF. These methods are specified in DOT and EPA requirements for
packaging and transporting hazardous materials. All packages will also be
labelled to facilitate cleanup in the event that packaging is severely
damaged. Required packaging should be able to withstand most vehicular
collisions but may result in some release if exposed to a protracted fire or
explosion on the road.
In the event of a vehicular accident along the route, exposure of
populations to toxic or hazardous materials would be minimized by the use of
the interstate highway system whenever possible, rather than other arteries or
secondary roads through surrounding communities. Hazardous spill response
teams along the interstates are better able to deal with potentially toxic
spills than are the local fire units or hazardous material units outside the
City of Cincinnati (Ann Gordon, OKI, March 1986).
The City of Cincinnati's Fire Department maintains specialized units,
including "Squad 52," to respond to hazardous materials accidents. The city's
Hazardous Materials Team (although stationed within the city) is available to
respond anywhere in Hamilton County, through agreements with other communi-
ties. In addition, several corporations and the Lunken Airport crash unit may
be able to assist in responding to spills of materials with which they are
familiar (Ann Gordon, OKI, March 1986; David Roger, Cincinnati Safety
Department, March 1986). It should be noted, however, that safety procedures
among common carriers and carrier services vary, and their delivery routes may
not be those that minimize the chances of accident or exposure.
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4.3 UNAVOIDABLE ADVERSE IMPACTS
Some impacts associated with the implementation of any of the alterna-
tives cannot be avoided. The free FCF standing alternatives would have the
following adverse impacts:
o Short-term construction dust, noise, and traffic nuisance
o Erosion and siltation during construction.
4.4 IRRETRIEVABLE AND IRREVERSIBLE RESOURCE COMMITMENTS
The major type and amounts of resources that would be committed through
the implementation of any of the alternatives are presented in Section 4.1.
Each of the alternatives would include some or all of the following resource
commitments.
o Fossil fuel, electrical energy, and human labor for facilities
construction and operation
. o Chemicals for FCF operation
o Tax dollars for construction and operation
o Some unsalvageable construction materials.
There is a finite consumption of resources involving construction of the
FCF with no feasible means of recovery. Thus, nonrecoverable resources would
be foregone for the provision of the proposed facility. However, construction
would not result in the irretrievable consumption of critical materials in
limited supply or other resources of local or national significance.
4.5 EIS RECOMMENDED ACTION
The recommended action for this EIS is construction of a free-standing
full containment research facility (FCF) adjacent to the Andrew W. Breidenbach
Environmental Research Center. The issue of greatest concern in this
assessment is the potential risks to human health of release of chemicals from
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the FCF. As discussed in Chapter 4, the results of the risk assessment
indicates that no substantial increase in risks to public health is antic-
ipated due to operation of the FCF. This conclusion is based on projections
as to the nature and quantity of hazardous materials likely to be present at
the FCF and the assumption that recommended laboratory operating and safety
procedures be followed (USEPA 1982 - Toxic Substance Control Manual),.
It is not possible to anticipate all hazardous materials (their nature
and quantity) likely to be handled at the FCF over the lifetime of the
facility. In order to ensure that day-to-day operations at the FCF continue
to pose no significant risks to human health, it is recommended that a
monitoring program be adopted to evaluate the loss of chemicals to the air
filtering system to quantify the release of these compounds to the ambient
environment. The parameters selected for assessment should reflect the
ongoing activities at the FCF.
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5. RESPONSES TO COMMENTS ON THE DRAFT EIS
Comments on the Draft Environmental Impact Statement (DEIS) were received
at the Public Hearing held February 23, 1987 at the Andrew W. Breidenbach
Environmental Research Center (AWBERC) and were also received by mail.
Comments and questions received at the Public Hearing were documented in a
Hearing Transcript and responses to those comments are provided in this
chapter. Responses to Public Hearing comments are presented in Section 5.1.
Written comments on the DEIS were received from a total of three public
agencies and two private citizens (Appendix C). Responses to these written
comments are presented in Section 5.2 through 5.4.
5.1 RESPONSE TO COMMENTS FROM THE PUBLIC HEARING
Dr. Debdas Muckerjee
(1) Comments: How tall will the exhaust stack from the Full Containment
Facility be and how will both sewer and stack discharges such as those
containing dioxin or PCB's be treated before discharge? At what
temperature will stack discharges be treated?
Response: The exhaust stack will be 7 ft. 3 in. above the precast
concrete roof and the velocity of the exhaust plume will be 3,000 ft. per
minute. Any liquid hazardous waste material will be specially packaged
and disposed of by a hazardous waste disposal contractor. The air from
the FCF will not be incinerated but will be filtered through a special
filter arrangement prior to release into the atmosphere. No hazardous
material will be discharged to the sewer system.
Lawrence Horowitz
(2) Comment: How will the hazardous wastes and other hazardous materials be
delivered to, and received by the Facility?
Response: The materials will be received by truck and hazardous material
will be packaged in accordance with the Department of Transportation
specifications.
Tom Donnelly
(3) Comments: Will the holding tanks originally planned to prevent spilled
materials from being discharged directly to the sewer system still be
employed? What is their exact function? How will they alleviate
problems from spills? Is there a way to "trap" hazardous materials
before they can enter the sewer system? Are there better ways to deal
with small spills in lab sinks? What will be the function of the lab
sinks? What types of materials will be going down lab sinks? What are
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some examples? Are there any standard notification procedures (to
appropriate authorities and to the public) in the event of an accident
while hazardous materials are being transported to the Facility,
especially those that might pose a potential emergency? Who would make
the decision as to whether there would be any public notification and to
what level a danger would have to rise before the public would be
notified?
Response: No large holding tanks are planned for the FCF. All work with
hazardous materials will be performed in fume hoods. Each fume hood has
a small cup sink at the work surface level that will drain into a special
container below the individual fume hood. Should an accidental spill
occur it will be collected in this container. The laboratory sinks will
be used for materials other than hazardous or toxic materials. No
hazardous materials will be discharged into the sewer system. The sinks
would be used to wash glassware, etc. In the event of discharge of
hazardous waste during transportation the transporter must take immediate
action to protect human health and the environment (e.g. notify local
officials, dike the discharge area, etc.) Local officials, usually the
police and fire department, notify the public, when appropriate.
Mr. Hall
(4) Comments: What type of containers would hazardous materials be
transported in, and are there "outside" regulations that govern the
tranportation of hazardous materials or would the EPA be policing itself?
Would hazardous wastes ever be transported from the Facility to the
present AWBERC building?
Response: All of the chemicals, samples or other hazardous materials
which are shipped to or from the AWBERC or the proposed Full Containment
Facility (FCF) by a commercial carrier are strictly regulated by the
Department of Transportation (DOT). The DOT regulations are designed to
insure the proper and safe transportation of materials by shippers and
carriers. The DOT also has i he responsibility of enforcing these
regulations. The packaging and containers for hazardous materials that
are to be shipped are also strictly regulated by the DOT. Data and
results will, of course be transmitted from the Facility to the AWBERC
building, however no hazardous wastes will be carried from one building
to the other.
Lawrence Coffen
(5) Comments: Why should this Facility be built in the midst of a population
center rather than in a remote area? Wouldn't it be just as efficient to
build the Facility in a remote area and then to transmit research data
and results by phone to the present AWBERC?
Response: The work to be carried out in the new Facility will be in
direct support of the research programs which have been assigned to the
EPA Laboratories here in Cincinnati. The Facility has been designed
specifically to meet this need. Much, if not all of the work to be
conducted within the Facility will be parts of broader projects being
conducted by AWBERC researchers within the AWBERC building itself. In
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fact, the researchers who will work in the new Facility will, by and
large,, spend only part of their time within the Facility and will spend
the rest of their time in the AWBERC building. The work to be conducted
in the Facility will not, therefore, be independent. It will be closely
interlinked with other research within the AWBERC building and will be
carried out by the same researchers.
It would not, therefore be feasible, logistically or economically, to
locate the Facility at a remote site separate from the AWBERC building.
Moreover, since the risk analyses presented within the draft EIS have
shown that the Facility can be constructed and operated safely at the
proposed location, a remote location for the Facility is not necessary.
Chris Grubach
(6) Comment: Will there be procedures for monitoring for leakage through or
around the filters to be used to prevent emissions of hazardous compounds
from the exhaust stack?
Response: We will follow the procedures that have been established by
the filter manufacturers for testing filters for leakage.
Morgan Williams
(7) Comment: Who will determine what hazardous materials will be brought into
the Facility and in what quantities?
Response: The types and quantities of hazardous materials to be brought
into the Facility will be determined by the specific projects scheduled
to be carried out at the AWBERC. The planning for such activities is
done by local Laboratory management here in Cincinnati, within the
context of the AWBERC's mission within EPA and, of course, subject to
approval and funding for planned work from EPA Headquarters in
Washington.
As a matter of policy, every single project proposed to be conducted
within the Facility will have a specific "safety plan" which will include
a definition of the types and amounts of hazardous or toxic materials
required for the work. The amounts will be the minimum amounts necessary
and the handling procedures will have to be approved in advance so that
each project can be conducted safely, both with respect to the individual
researchers involved and with respect to the safety of the Facility
itself.
Arnold Pollock
(8) Comments: Why wasn't there more and earlier publicity regarding EPA's
intentions to build this Facility and regarding this meeting? Will
activities now conducted by EPA at other locations around the country be
moved here as a result of this Facility? What are several examples of
projects to be conducted within the new Facility? What is the potential
for spill or explosion from trucks or tanks containing hazardous
materials located outside and next to the Facility? Will there be fumes
discharged into the area? What is the potential for an explosion? Will
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there be any nuisance (noise, inconvenience) associated with the
Facility?
Response: Articles regarding the Full Containment Facility have appeared
in the Cincinnati newspapers since August 27, 1985. On January 20, 198/
the Enquirer printed an article regarding the proposed Full Containment
Facility arid also mentioned the Public Hearing. There is no plan at
present to move activities from other EPA locations to this Facility.
Toxic treatability studies on various treatment technologies; studies on
the characterization, destruction and detoxifiation of hazardous
materials; and the preparation of quality assurance samples for use by
various regulatory agency laboratories are all projects that will be
conducted in the FCF. There is no potential for spills or explosions
from tanks located outside the building since there will not be any tanks
outside the building. Any gaseous discharge to the environment will be
through a filtering system. The risk assessment in the EIS indicates no
substantial increase in the risk of adverse health effects to the
surrounding environment even if the day-to-day operation were conducted
assuming the air filtering system did not remove any of the contaminants
and even if there were an explosion in the FCF releasing toxic chemicals
to the environment.
We do not anticipate any noise, inconvenience, etc. associated with
the FCF other than the usual activity connected with the construction of
any building.
5.2 CORRESPONDENCE FROM FEDERAL AGENCIES
U. S. Department of Transportation; (23 February 1987)
(9) Comment: The DEIS has been reviewed and we have no comment.
Response,: Comment noted.
U. S. Department of the Interior; (3 March 1987)
(10) Comment: The final statement should present sufficient information to
support the finding that the proposed site will not be subject to a
landslide hazard. Develop an action plan to contain spills outside the
building.
Response: Comment noted.
5.3 CORRESPONDENCE FROM PRIVATE CITIZENS
Mr. Rick Navaro, Coldwell Banker Real Estate Ser.; (4 February 1987)
(11) Comment: Exchange the presently proposed site for a site on Jefferson
Avenue
Response: The Jefferson Avenue site is in a more densely populated
residential area than the proposed site.
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Mr. Raymond J. Dobos (23 June 1986)
(12) Comment: Cincinnati is a leading producer of carcinogenic pollutants and
has a leading cancer mortality rate. The FCF should be isolated on a
site away from a populous area. The EPA intends to have mustard gas at
the FCF.
Response: There are no data to substantiate that Cincinnati is a leading
producer of carcinogenic pollutants. The risk assessment in the DEIS
indicates no substantial increase in the risk of adverse health effects
in the day-to-day operation of the FCF or in a catastrophic release
scenario. There is no intention now or ever to house mustard gas in the
FCF.
5.4 CORRESPONDENCE FROM STATE AGENCIES
Ohio Historical Society; (18 February 1987)
(13) Comment: Requested a street map showing the location of the project
boundaries and front and rear elevation photographs of any standing
structures over fifty years old which will be affected by the proposed
facility to assess whether any are on the National Register of Historic
Places.
Response: A drawing showing the location of the proposed FCF was
provided as was a statement that no standing structures over fifty years
old would be affected.
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6. LIST OF PREPARERS
The Draft Environmental Statement (DBS) was prepared by the McLean,
Virginia office of Science Applications International Corporation (SAIC) under
contract to USEPA Region V. The USEPA Project Officers and the SAIC staff
involved in the preparation of the DBS included:
USEPA
Catherine G. Garra
Bill Spaulding
Russell Kulp (HQ)
Joe Castelli (AWBERC)
Project Officer
Project Monitor
Project Coordinator
AWBERC Contact
SAIC
Geoffrey Kay
Cindy V. Hughes
Fred Zafran
Roger Claff
Hunter Loftin
Judee Mayer
Ann Witzig
Karen Taylor
Dennis Borum
Holly Wootten
Project Administrator
Project Manager/Biologist
Environmental Scientist
Engineer
Engineer
Socioeconomist
Biologist
Biologist
Biologist
Environmental Scientist
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7. GLOSSARY OF TECHNICAL TERMS
Activated sludge process. A method of secondary wastewater treatment to
biologically treat wastes whereby microorganisms suspended in an aerated
treatment basin stabilize the waste, followed by settling of solids and
recycling of microorganisms back into the treatment process.
Advanced secondary treatment. Biological wastewater treatment whereby waste
is stabilized to a greater degree than in secondary treatment, but not to
advanced waste treatment levels.
Advanced waste treatment. Vastewater treatment to treatment levels that
provide for maximum monthly average BOD^ and SS concentrations less than
10 mg/1 and/or total nitrogen removal of greater than 50 percent (total
nitrogen removal = TKN + nitrite and nitrate).
Atomic Absorption. A laboratory method for determining the concentration of
trace quantities of elements especially dissolved metals in water through
the measurement of a decrease in the intensity of light of a particular
wavelength.
BODS. Biochemical oxygen demand exerted in a 5-day period. It is a measure
of biological degradability.
Carcinogen. A substarce capable of causing cancer.
Combined sewer. A sewer that carries domestic wastewater as well as
stormwater runoff.
DES. Draft Environmental Statement.
Effluent. Wastewater or other liquid, partially or completely treated, or in
its natural state, flowing out of a reservoir, basin, treatment plant, or
industrial treatment plant, or part thereof.
EIS. Environmental Impact Statement.
Exposure. Manner of contact between the chemical or physical form of a
substance and a receptor organism. Characteristics of exposure are
related to time and frequency, route, and dose delivered.
Fragipan. Soil term to describe a layer of very low permeability material,
which is usually 1-2 feet thick and occurs naturally.
Full Containment Facility. A building designed to physically confine and
control hazardous and toxic substances, and any facility effluents
through the observation and implementation of good laboratory practices,
installation of properly designed laboratory containment equipment, and
inclusion of special design features to prevent the escape of any
hazardous and toxic substance to the surrounding environment.
Gas Chromatograhy (GC). A laboratory method for analysis entailing the
vaporization of a liquid sample followed by the separation of various
gaseous components formed so they can be individually identified and
quantitatively measured.
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Gas Chromatography/Mass Spectrophotometry (GC/MS). The method described above
used in conjunction with a mass spectrometer gives positive
identification and quantification for a large number of individual
organic compounds present in water and wastewater. A mass spectrometer
is an instrument that will sort out charged gas molecules or ions
according to their masses.
Hazardous waste. Generally, a solid waste or combination of wastes that
because of quantity, concentration, or physical, chemical or inspections
characteristics, may cause or contribute to increased mortality, serious
irreversible, or incapacitating reversible illness, or pose a substantial
hazard to human health or the environment if improperly stored, trans-
ported or disposed of; or elements or compounds other than oil which when
discharged in any quantity into the navigable waters of the U.S. present
an imminent and substantial danger to public health or welfare.
High Performance Liquid Chromatography (HPLC). An analytical method by which
compounds may be separated in the liquid phase through the use of
solvents and application of high pressure.
Inflow. The water discharged into a wastewater collection system and service
connections from such sources as, but not limited to, roof leaders,
cellars, yard and area drains, foundation drains, cooling water
discharges, drains from springs and swampy areas, manhole covers,
cross-connections from storm sewers and combined sewers, catch basins,
stormwaters, surface runoff, street wash waters or drainage. Inflow does
not include, and is distinguished from, infiltration.
Influent. Water, wastewater, or other liquid flowing into a reservoir, basin,
or treatment facility, or any unit thereof.
LD50. (See Lethality).
Leachate. Solution formed when water percolates through solid wastes, soil or
other materials and extracts soluble or suspendable substances from the
materials.
Lethality. An index of toxicity, e.g., the maximal dose at which some deaths
occur or the smallest dose at which 50 percent (LD50) or 100 percent
(LD100) mortality occurs.
Loam. The textural class name for soil having a moderate amount of sand,
silt, and clay. Loam soils contain 7 to 27 percent clay, 28 to 50
percent silt, and less than 52 percent sand.
Milligram per liter (mg/1). A concentration of 1/1000 gram of a substance in
1 liter of water. Because 1 liter of pure water weighs 1,000 grams, the
concentration also can be stated as 1 ppm (parts per million, by weight).
Used to measure and report the concentrations of most substances that
commonly occur in natural and polluted waters.
Mitigation. Clean-up of soil or groundwater, by decreasing the concentration
of, or removing contaminants.
Ordinance. A municipal or county regulation.
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ppb. Parts per billion; weight/weight for water, and volume for volume in
air.
ppm. Parts per million; weight/weight for water, and volume for volume in
air.
pH. A measure of the acidity or alkalinity of a material, liquid or solid.
pH is represented on a scale of 0 to 14 with 7 being a neutral state;
0, most acid; and 14, most alkaline.
Point source. In regard to water, any pipe, ditch, channel, conduit, tunnel,
well, discrete operation, vessel or other floating craft, or other
confined and discrete conveyance from which a substance considered to be
a pollutant is, or may be, discharged into a body of water.
POTW. Publicly Owned Treatment Works.
Primary treatment. The first stage in wastewater treatment, in which
substantially all floating or settleable solids are'mechanically removed
by screening and sedimentation.
Risk. The probability of injury, disease, or death over a defined time period
usually expressed in numerical terms, taking values of 0 (absolute
certainty that harm will not occur) to 1 (absolute certainty that harm
will o~cur).
Sanitary sewer. Underground pipes that carry out domestic or commercial
wastewater, not stormwater.
Secondary treatment. The second stage in the treatment of wastewater in which
bacteria are utilized to aerobically decompose the organic matter in
sewage. This step is commonly accomplished by introducing the sewage
into a trickling filter or an activated sludge process. Effective
secondary treatment processes remove virtually all floating solids and
settleable solids, as well as 90 percent of the BOD and suspended solids.
USEPA regulations define secondary treatment as 30 mg/1 BOD, 30 mg/1 SS,
or 85 percent removal of these substances.
Sewage. Domestic wastewater.
Sewerage System. System of sewer pipes used to carry wastewater.
Sewer, storm. A conduit that collects and transports stormwater runoff. In
many sewerage systems, storm sewers are separate from those carrying
sanitary or industrial wastewater.
Slope. The incline of the surface of the land. It is usually expressed as a
percent (%) of slope that, equals the number of feet of fall per 100 feet
of horizontal distance.
Sludge. The accumulated solids that have been separated from liquids
containing suspended solids such as wastewater.
SS. Suspended solids.
7-3
-------
Thermistor. A semiconductor whose electrical resistance varies sharply and in
a known manner with temperature.
Topography. The three-dimensional shape of a surface area including its
relief, or relative depressions or raised areas and the position of its
natural and manmade features.
Trickling Filter. Secondary wastewater treatment process whereby wastewater
is trickled over rocks covered with a biological slime.
Wastewater. Water carrying dissolved or suspended solids from homes, farms,
businesses, and industries to a treatment plant for treatment prior to
discharge to streams and other surface waters.
Water quality. The relative condition of a body of water, as judged by a
comparison between comtemporary ambient values and objective standard
values for biological, chemical, and/or physical characteristics. The
standard values are usually either set by law or are selected based on
specific intended uses, and may vary as the intended uses vary.
WWTP- Wastewater Treatment Plant.
7-4
-------
8. LITERATURE CITED
ACGIH. 1985. Threshold limit values for chemical substances and physical
agents in the work environment with intended changes for 1985-1986.
American Conference of Governmental Industrial Hygienists, Cincinnati, OH.
ACGIH. 1986/87. Threshold limit values and biological exposure indices for
1976-1986, American Conference of Governmental Industrial Hygienists.
ISBN: 0-936712-69-4.
Annett, L. 1986. Cincinnati City Planning Department (March). Personal
Communication.
Berry, D. 1986. Air toxics: What is the problem and how do we deal with it.
Office of Air Quality Planning and Standards, Environ. Science and
Technology 20(7)647-651.
Bjorklund, J., and J. Bowers. 1982. User's Instructions for the SHORTZ and
LONGZ Computer Programs: Volume 1. PB83-146100, H.E. Cramer Company,
Inc. Salt Lake City, UT.
Blackman, W., R. Garnas, J. Preston, and C. Swibas. 1984. Chemical
Composition of Drum Samples from Hazardous Waste Sites, U.S.
Environmental Protection Agency, National Enforcement Investigations
Center, Denver, CO.
Castelli, J. 1986. Memorandum: Use of the containment facility by the
Hazardous Waste Engineering Research Laboratory. U.S. Environmental
Protection Agency, Cincinnati, OH.
Castelli, J. 1986. USEPA, Cincinnati, OH. Personal Communication.
Cincinnati Business Courier. August 20, 1984. Deaconess Hospital Data.
City of Cincinnati, City Planning Department. 1981. Residential Populations
of Census Tracks, 1980 Census.
City of Cincinnati, City Planning Department, Cincinnati Census Tract Map.
1980.
City of Cincinnati, Planning Commission, Data Services, 1980. R.L. Polk
Detailed Listing of Business.
City of Cincinnati, City Planning Department and Neighborhood Housing and
Conservation, Clifton Community Plan. 1982.
City of Cincinnati, City Planning Department, Draft Clifton Heights,
University Heights, and Fairview Community Plan. 1984.
City of Cincinnati, City Planning Department, Preliminary Reconnaissance
Uptown Today. 1986.
8-1
-------
City of Cincinnati, City Planning Department Survey for Uptown Task Force,
provided 1986,.
City of Cincinnati Zoning Ordinance. 1985 (June).
Dobbs, R. 1986. Memorandum to J.A. Castelli, Facilities Management and
Services Division, March 3, 1986. U.S. Environmental Protection Agency,
Cincinnati, OH.
Dourson, M. August 1986. Personal Communication.
Fischer, K. 1986. National Enforcement Investigation Center, Denver,
Colorado; Wayne Craine, EPA Las Vegas Laboratory; and Jewell Morris, EPA
Laboratory, Research Triangle Park, North Carolina. (July). Personal
Communications.
Fischer, K. 1986. NEIC-Denver and W. Crane, EPA-LV. (June 30). Personal
Communication.
Gordon, A. 1986. Ohio-Kentucky Indiana (OKI) Regional Council of
Governments. (March). Personal Communication.
Hamilton County Soil Survey. Undated. Obtained from Cincinnati City Planning
Office. No citation provided.
Hayden, P. 1986. University of Cincinnati Residence Hall Administration.
Koerber, M., USEPA. Personal Communications. November and December 1986.
KZF Incorporated. 1986. Concept Development Plan for a Full Containment
Facility. Prepared for U.S. Environmental Protection Agency, AWBERC,
Cincinnati, OH, Contract No. 68-03-1755.
Lee, R., USEPA. Personal Communications. November 1986,
Liberick, W. 1986. Memorandum to J.A. Castelli, Facility Management and
Services Division, February 28, 1986. U.S. Environmental Protection
Agency, Cincinnati, OH.
Lichtenberg, J. 1986. Memorandum to J.A. Castelli, Facility Management and
Services Division, May 29, 1986. U.S. Environmental Protection Agency,
Cincinnati, OH.
Lichtenberg, J., and J. Winter. 1986. Memorandum to J.A. Castelli, Facility
Management and Services Division, February 28, 1986. U.S. Environmental
Protection Agency, Cincinnati, OH.
Mabey, W., J. Smith, R. Podoll, H. Johnson, T. Mill, T. Chou, J. Gates, J.
Partridge, and D. Vandenberg. 1981. Aquatic fate process data for
organic priority pollutants. U.S. Environmental Protection Agency,
Office of Water Regulations and Standards, Washington, DC.
Podol, R., H. Jaber, and T. Mill. 1986. Tetrachlorodibenzodioxin: Rates of
volatilization and photolysis in the environment. Environmental Science*
and Technology 20(5)490-492.
8-2
-------
Roger, D. 1986. Cincinnati Safety Department. (March). Personal
Communication.
SAIC. 1985a. Environmental Assessment for Full Containment Facility at
AWBERC, Cincinnati, Ohio. Prepared for U.S. Environmental Protection
Agency, Region V. Contract No. 68-04-5035.
SAIC. 1985b. Background Material for EPA OW and OSWER Briefings on Phase I
of the Domestic Sewage Study, prepared by Science Applications
International Corporation for USEPA Office of Analysis and Evaluation,
Washington, DC.
Sittig, M. 1981. Handbook of Toxic and Hazardous Chemicals. Noyer
Publications, Park Ridge, NJ.
Southwestern Ohio Air Pollution Control Agency. 1985. Air Quality Data Sheet.
Thurnau, R. 1986. Memorandum to J.A. Castelli, Facility Management and
Services Division, May 15, 1986. USEPA, Cincinnati, OH.
Thurnau, R. May 15 and 19, 1986 and June 26, 1986. Facility Management and
Services Division, USEPA, Cincinnati, OH. Personal Communications.
USEPA. 1982. Toxic Substance Control Manual. Policies and Regulations for
Control of Toxic Substances in the Laboratory. Andrew W. Breidenbach
Environmental Research Center. Cincinnati, OH.
USEPA. 1984b. Guidelines on air quality models (revised). U.S.
Environmental Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, NC.
USEPA. 1985a. Concept Development for a Full Containment Facility. Prepared
by KZF Inc., for the U.S. Environmental Protection Agency.
USEPA. 1985b. Superfund public health assessment manual. U.S. Environmental
Protection Agency, Office of Emergency and Remedial Response, Washington,
DC.
USEPA. 1985c. Guidance on remedial investigations and feasibility studies
under CERCLA. U.S. Environmental Protection Agency, Office of Solid
Waste and Emergency Response.
USEPA. 1985d. Health Assessment Document for Polychlorinated Dibenzo-p-
Dioxins. Office of Health and Environmental Assessment. U.S.
Environmental Protection Agency, Washington, DC. EPA/600/8-84/014F-
USEPA. 1986a. Report to Congress on the Discharge of Hazardous Wastes to
Publicly Owned Treatment Works. U.S. Environmental Protection Agency,
Office of Water Regulations and Standards, Washington, DC.
USEPA. 1986b. Guidelines for carcinogenic risk assessment. U.S.
Environmental Protection Agency. Federal Register 51 (125) 33992-34003.
8-3
-------
USEPA. 1986c. Guideline on Air Quality Models (Revised). U.S Environmental
Protection Agency. Research Triangle Park, NC, 450/2-78-027R.
USEPA. 1986d. Industrial Source Complex (ISC). Dispersion Model User's
Guide - Second Edition: Volume 1. U.S. Environmental Protection Agency,
Research Triangle Park, NC, 450/4/86-0059.
USEPA. 1986e. Guidelines for health risk assessment of chemical mixtures.
U.S. Environmental Protection Agency. Federal Register 51 34015-34025.
Wilson, R., USEPA. Personal Communications. November and December 1986.
Winter, J. 1986. Memorandum to J.A. Castelli, Facility Management and
Services Division, January 30, 1986. U.S. Environmental Protection
Agency, Cincinnati, OH.
Zamuder, C., J. Lounsbury, and D. Cooper. 1986. Superfund risk assessment:
The process and its application to uncontrolled hazardous waste sites.
U.S. Environmental Protection Agency and FCF-Clemen't. Proceedings of the
7th National Conference on Management of Uncontrolled Hazardous Waste
Sites. Washington, DC. December 1-3, 1986.
8-4
-------
9. ACRONYMS
AA - Atomic absorption
ACGIH - American Conference of Governmental Industrial Hygenists
ADI - Acceptable daily intake
AI - Acceptable Intake
AWBERC - Andrew W. Breedenbach Environmental Research Center
BOD - Biochemical oxygen demand
CAG - Carcinogen Assessment Group
CEO - Council on Environmental Quality
CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act
DBS - Draft Environmental Statement
EA - Environmental assessment
ECAO - Environmental Criteria and Assessment Office of the EPA Office of
Research and Development
EIS - Environmental Impact Statement
EMSL - Environmental Monitoring and Support Laboratory
ES - Environmental Statement
FCF - Full containment facility
FNSI - Findings of no significant impact
9-1
-------
GC - Gas chromatography
HEGA - High-efficiency gas absorption
HEPA - High-efficiency particulate absorption
HPLC - High performance liquid chromatography
HWERL - Hazardous Waste Engineering Research Laboratory
ISCLT - Industrial Source Complex Long Term
kg - Kilogram
mg - Milligram
MS - Mass spectrophotometry
NEIC - National Enforcement Investigations Center
NEPA - National Environmental Policy Act 1969
PAH - Polycyclic aromatic hydrocarbons
PCB - Polychlorinated biphenyl
POTW - Publicly owned treatment works
PPM - Parts per million
PTPLU & PTMAX - EPA Air Quality Model
RCRA - Resource Conservation and Recovery Act
SS - Suspended solids
9-2
-------
STEL - Short Term Exposure Limits
TCDD - Tetrachlorodibenzodioxin (or dioxin)
UCR - Unit cancer risk factor
USEPA - U.S. Environmental Protection Agency
WERL - Water Engineering Research Laboratory
9-3
-------
10. INDEX
Access Control 2-6
Acute Toxiclty 4-3
Aesthetics/Landscaping 1-1
Air Disperson Modeling 4-20, 4-34
Air Quality 1-1, 1-3, 2-6, 3-1
Analytical Instrumentation 2-4, 2-7
Balance Room 2-1
Biota 3-6, 3-7
Building Code 3-9
Burnet Woods Lake 3-6, 3-9
Business 3-15
Carcinogenic Potency Factor 4-15, 4-26
Catastrophic Release 4-27
Clay 3-3
Colleges 3-7, 3-9, 3-11, 3-16
Combined Sewer 3-6, 3-22
Construction Operations 1-1
Council on Environmental Quality 1-2
Decontamination 2-8
Detoxification 2-5, 3-21, 3-22
Disposal 2-9, 2-10, 3-20, 3-21, 3-22
Draft Environmental Statement 1-1
EMSL 2-1, 2-5, 4-8
Environmental Impact Statement 1-2, 1-3
Exposure Assessment 4-16, 4-32, 4-43
Exposure Estimates 4-32, 4-35
Finding of No Significant Impact 1-2
Floodplains 3-7
10-1
-------
Fume Hood 2-4, 2-5, 2-6, 3-20, 3-21, 4-4
Gas Chromatograph/Mass Spectrophotometer 2-4
Genetic Engineering 1-3, 2-5
Glovebox 2-1, 2-4, 2-5, 4-5
Groundwater 3-3, 4-1
Hazard Identification 4-8, 4-29
Hazardous Materials 1-3
HEPA/HEGA filters 4-5, 4-7, 4-18
Hospitals 3-7, 3-9, 3-15
Housekeeping 2-8 .
HWERL 2-1, 2-5, 4-8
Indicator Compounds 4-11
Inorganics Laboratory 2-1
Internal Waste Handling 1-1, 3-17, 3-20, 3-21
ISGLT
Laboratory Transport 2-8, 2-9
Land Use 3-7, 3-10, 4-46
Mitigation 4-47, 4-51
National Environmental Policy Act 1-2
Noise 1-1
Organics Laboratory 2-1, 2-4
Parking 1-1
Permeability 3-3
Pollution Control Programs 1-1
Pollution Standards Index 3-1, 3-2
Population 2-10, 3-10, 3-11, 3-12, 3-13, 3-15
Primary Containment Equipment 2-7, 3-20
Public Health Risk Assessment 4-3
Public Participation 1-2, 1-3
10-2
-------
Public Water Supply 3-6
Quantities of Chemicals Handled/Present 4-10, 4-12, 4-30
Records 2-7
Release Rates 4-35
Respirators/Personal Protection 2-5, 2-6, 2-7
Risk Characterization 4-28, 4-42, 4-43
Sample Storage 2-1, 2-4, 3-20
Sanitary Sewer 4-5
Shower/Locker 2-1, 2-6, 3-20, 3-21, 3-22
Site Geography 3-1, 3-3, 3-4, 3-5
Site Geology 3-3
Soils 2-5, 3-3
Solid Wastes 1-1, 3-20
Source Term Estimates 4-21
Spills 3-20
Storage Inventory 2-7
Streams 3-6
Study Area 1-1, 3-1, 3-3, 3-7, 3-9
Toxic Materials 1-3
Toxicity Assessment 4-14, 4-29, 4-43
Traffic 1-1, 1-3, 3-17, 3-18, 3-19, 4-3, 4-46
Vacuum Lines 2-8
Waste Samples 2-1, 2-11, 3-17, 3-20, 4-11
Wastewater 1-1, 2-4, 3-17, 3-20, 3-21, 3-22
Water Resources 1-1, 3-3
WERL 2-1, 2-4, 4-8
Wetlands 3-7
Work Area Identification 2-6
Work Surfaces 2-7, 3-20
10-3
-------
Working Quantities 2-8
Zoning 3-9
10-4
-------
APPENDIX A
AWBERC-PROVIDED MATERIAL
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RESEARCH AND DEVELOPMENT
HAZARDOUS WASTE ENGINEERING RESEARCH LABORATORY
CINCINNATI, OHIO 45268
DATE: February 28, 1986
SUBJECT: EIS for Full Containment Facility
FROM: Walter W. liberick, Jr., Chief
Technical Support Staff, OPO
TO: Joseph A. Castelli, Director
Facilities Managemejnt^ &
THRU: William A. Cawle
Acting Director,
Research Laboratory
The following is HWERL's response to your memo dated February 20,
asking for information about volume and nature of explosives, and volume,
nature, and delivery frequency of hazardous materials to be imported to the
containment facility. Obviously the information provided is our best
estimate at this time. Changes in program priorities could significantly
alter these estimates.
Current Estimates
0 Volume and nature of explosives - no significant quantities known
at this time. Small quantities of flammable solvents (1 liter or
less) may be brought to the facility for leaching or analytical
work.
0 Volume, frequency, and nature of incoming hazardous materials -
1. Soils contaminated with PCB's, dioxins, furans, or PCP's -
2 to 10 pounds, once per month.
2. Organic contaminated water - 1 gallon, once per month.
3. Oils and solvents contaminated with dioxins or PCB's -
1 gallon, 1 to 5 times per month.
4. Unknown samples from hazardous waste sites for characterization
in sample quantities may be shipped in on an undefinable schedule.
Again, let me reemphasize that these are our best estimates at this
time.
cc: J. Martin
H. Pahren
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RESEARCH AND DEVELOPMENT
WATER ENGINEERING RESEARCH LABORATORY
CINCINNATI, OHIO 45268
DATE:
SUBJECT:
FROM:
TO:
March 3, 1986
Revised Information for Environmental Impact Statement (EIS)
for Full Containment Facility (FCF)
Richard A. Dobbs, Research Chemist
Toxic Research & Analytical Support Staff
Joseph A. Castelli, Director
Facilities Management & Services Staff
Revised information
as follows:
needed for the EIS for the FCF is estimated to be
1. Volume and nature of explosives:
WERL does not have research plans which call for the use of explo-
sive materials at the present time.
2. Volume, frequency and nature of incoming hazardous materials:
Small quantities of hazardous chemicals may be used in treatability
studies in the FCF. The Chemicals are listed in the following table with
estimated quantities on hand and frequency of delivery:
Chemical Name Quantity
2-Aceetylaminoflourene 10 gm
Acrylonitrile 10 gm
4-Aminodiphenyl 10 gm
Asbestos 10 gm
Benzidine 100 gm
Bis-Chloromethyl ether 100 gm
3,3'-Dichlorobenzidine (and salts) 10 gm
4-Dimethylaminoazobenzene 10 gm
Ethyleneimine 10 gm
Methyl -chloromethyl ether 100 gm
4,4'-Methylene bis (2-chloroaniline) 10 gm
a-Naphthylamine 100 gm
B-Naphthylamine 100 gm
4-Nitrobiphenyl 10 gm
M-Nitrosodimethylamine 10 gm
3-Propiolactone 10 gm
Vinyl Chloride 100 gm
Frequency
annually
annually
annually
annually
annually
annually
annually
annually
annually
annually
annually
annually
annually
annually
annually
annually
annually
Environmental samples may be used on an irregular basis and may be
needed in 55 gallon quantities or more. Estimated use of environmental
samples is as follows:
-z-
-------
- 2 -
Environmental Sample
Seawater
Surface water
Ground water
Leachate
Industrial process water
Municipal wastewater
Indistrial wastewater
Quantity
55 gallons
55 gallons
55 gallons
110 gallons
55 gallons
55 gallons
110 gallons
Frequency
Bimonthly
Biannually
Biannually
Biannually
Biannually
Bimonthly
Biannually
The above reflect the best estimate of our anticipated use of the FCF.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RESEARCH AND DEVELOPMENT
ENVIRONMENTAL MONITORING AND SUPPORT LABORATORY
CINCINNATI, OHIO 45268
DATE: February 28, 1986
SUBJECT: Input to Environmental Impact Statement (EIS)
FROM: James J. Lichtenberg, Chief v^<>
Physical and Chemical Methods Branch
John A. Winter, Chief
Quality Assurance Branch
TO: Joseph Castelll, Director
Facilities Management and Services Division
This 1s written In response to your February 20 memorandum requesting
Information on planned presence and/or use of explosives and hazardous wastes
In the Containment Facility:
1. Explosives - There are no plans to procure, store or utilize explosives in
the Containment Facility.
Hazardous Wastes - As part of the method development and quality assurance
support provided to the Solid Waste, Superfund, and Toxics Programs,
Environmental Monitoring and Support Laboratory - Cincinnati
(EMSL-C1nc1nnat1) will irregularly over time (estimated at once/month),
obtain 1 quart - 5 gallon amounts of liquid to solid wastes containing
parts-per-billion to low percentage concentrations of an estimated five to
twenty organlcs or Inorganic compounds such as found on the priority
pollutant 11st of the Clean Water Act regulations, the Appendix VIII 11st
of the Research Conservation and Recovery Act (RCRA), or the Appendix A
list of the Comprehensive Environmental Response Compensation and
Liability Act (CERCLA). These wastes will be analyzed and disposed of or
prepared as small replicate subsamples for evaluation of USEPA, State and
USEPA contract laboratories. Any residual amounts of these wastes will be
disposed of under the current Andrew W. Breldenbach Environmental Research
Center (AWBERC) generator No. OHD 6800 30929.
Ref: 6519C
-------
w,
5SSJ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
'""i mot*-0 OFFICE OF RESEARCH AND DEVELOPMENT
ENVIRONMENTAL MONITORING AND SUPPORT LABORATORY
CINCINNATI, OHIO 45268
DATE: March 6, 1986
SUBJECT: Chemicals Related to Environmental Impact Statement (EIS)
"
FROM: James J. Llchtenberg,
Physical and Chemical Methods Branch
TO: Joseph A. CastelH, Director
Facilities Management and Services Division
The attached lists are being provided to you as requested for
consideration 1n developing an EIS for the Containment Facility. The lists
represent chemicals 1n the quantities that can be expected to be on hand for
use as reagents, solvents, and reference standards 1n performing analyses of
samples 1n the facility. These lists complement and, 1n some cases,
duplicate the lists provided by John Winter.
List 1 - Inorganic Chemicals
List 2 - Organic Chemicals
Please note List 3 - Repository Standards of John Winter's memorandum.
These chemicals would be ordered from the U. S. Environmental Protection
Agency (USEPA) Repository for Toxic and Hazardous Materials or other
sources, on a variable and selective basis only, as required for analyses.
That is, a few or a number of these standards may be on hand at different
times. These standards are prepared 1n small volumes of 1.5 mL each, in
sealed glass ampuls and shipped by U. S. mall.
Attachments (2):
As Stated
cc: Robert Booth with attachments
Thomas Clark with attachments
John Winter with attachments
-------
I
INORGANIC ANALYSES
CONTAINMENT FACILITY
REORDER
COMPOUND _ AMOUNT REQUIRED _ FREQUENCY
Calcium Hypochlorite 500 mL IX per year for all
Sodium Hydroxide 800 g
Ascorbic Acid 25 g
Lead Acetate 500 g
Sodium Dihydrogenphosphate 200 g
4-Dimethylaminobenzal Rhodanine 5 g
Chloramine - T 250 g
Barbituric Acid 100 g
Pyridine 500 mL
3-Methyl-l-Phenyl-2-Pyrazolin-5-one lOOg
3,3'-Dimethyl-l-r, Diphenyl-
(4-4 Bi-2 Pyrazoline) 5-5'-Dione 25 g
Magnesium Chloride 1000 g
Sulfamic Acid 100 g
Potassium Cyanide 100 g
Potassium Hydroxide 500 g
Acetic Acid 2 1/2 L
Phosphoric Acid 85% 1000 mL
Hypophosphorous Acid 500 mL
Potassium Dihydrogen Phosphate 500 g
Sodium Phosphate (dibasic) 100 g
Hydrochloric Acid 5 L
Potassium Iodide 100 g
Iodine 100 g
Phenylarsine Oxide Solution 1 L
Starch Indicator 1 L
N,N-Dimethyl-p~phenylenedianine Oxalate 25 g
Ferric Chloride 100 g
Sulfuric Acid 5 L
Diammmonium Hydrogen Phosphate 500 g
Methylene Blue 25 g
Sodium Sulfide 500 g
-------
-2-
COMPOUND
Thyodene
Potassium lodate
Sodium Bicarbonate
Ethyl enedi ami ne Tetraacetic Acid
Aluminum Metal Ingot
Antimony Potassium Tartrate
Arsenic (III) Oxide
Barium Chloride
Beryllium Sulfate
Boric Acid
Cadmium Metal
Calcium Carbonate
Chromium Tri oxide
Cobaltous Chloride
Copper Metal Rod
Iron Metal Rod
Leac1 Nitrate
Magnesium Sulfate
Manganese Metal - pieces
Molybdenum Trioxide
Nickel Metal Rod
Potassium Chloride
Selenous Acid
Silicon
Silver Nitrate
Sodium Chloride
Thallium Bar
Vandium Pentoxide
Zinc Oxide
Gold Metal
REORDER
AMOUNT REQUIRED FREQUENCY
100 g IX per year for all
500 g
500 g
500 g
10 g
25 g
5 g
5 9
50 g
25 g
50 g
25 g
25 g
20 g
25 g
5 g
50 g
25 g
250 g
5 g
26 g
50 g
25 g
500 ml
75 g
20 g
225 g
25 g
25 g
21 g
-7-
-------
-3-
REORDER
COMPOUND AMOUNT REQUIRED FREQUENCY
Cerium Oxide 10 g
Lithium Carbonate 10 g
Mercury 500 ml IX per year for all
Tin Metal 10 g
Strontium Chloride 25 g
Titanium Metal 5 g
Yttrium Oxide 5 g
Nitric Acid 2 1/2 L
-------
Livr z
ORGANIC ANALYSES
CONTAINMENT FACILITY
COMPOUND AMOUNT REQUIRED
Ethyl ether
Methyl -t-butyl ether
Hexane
Acetone
Dichloromethane
Toluene
Methyl ethyl ketone
Chloroform
Acetonitrile
Pentane
Dioxane
1 , 1 ,2-Tri chl oro-tri f 1 uoromethane
Ethyl alcohol
Methyl alcohol
Cyclohexane
n-Butanol
Petroleum ether
N ,N-Dimethy 1 f ormami de
Acetic anhydride
Lindane
4 L
4 L
8 L
8 L
4 L
8 L
4 L
4 L
4 L
4 L
4 L
4 L
2 L
8 L
4 L
4 L
4 L
4 L
100 g
< 10 mg
REORDER
FREQUENCY
2 X per year
1 X per year
2 X per year
2 X per year
5 X per year
1 X per year
"
»
"
»
»
»
3 X per year
"
1 X per year
"
»
"
"
1 X per year
Aldrin
Heptachlor
Heptachlor epoxide
Dieldrin
Polychlorinated biphenyls
(Aroclors and individual isomers)
Toxaphene
Hexachlorobenzene
Di bromoch1oropropane
DDT
DDE
" (each)
or as needed
-------
-2-
COMPOUND
AMOUNT REQUIRED
REORDER
FREQUENCY
2,4-D
2,4-D mixed esters
2,4-DR
?,4-DB mixed esters
2,4,5-T
2,4,5-T mixed esters
Silvex
Alachor
Metolachlor
Butachlor
Chloropyrifos
Chloropyrifos, methyl
Dichlorofenthion
Dichlorovos
Trichloroate
< 50 mg
< 200 mg
1 X per year
or as needed
Hydroquinone 500 g
2,4,6-Trichlorophenol 1 kg
Phenyl hydrazine 250 g
2-Phenoxyethanol 1 kg
Anthracene 5 g
Phenanthrene 10 g
N-Methyl-N-nitroso-p-toluene sulfmamide 100 g
1,2,3,4-Tetrahydronaphthalene 1 pt
Formaldehyde 1 pt
2,4-Dinitrophenol 1 kg
Diethanolamine 500 g
Methoxyacetonitrile 25 g
2-Nitrophenol 500 g
2,5-Dichlorophenyl hydrazine 25 g
Diphenylamine 100 g
-IP-
-------
-3-
COMPOUND
AMOUNT REQUIRED
REORDER
FREQUENCY
Benzene
Trlchloroethylene
Carbon tetrachloride
Chloroform
Dichloromethane
Ethyl chloride
Methyl bromide
Vinyl chloride
Hydrazobenzene
3,3'-Di methoxybenzene
Aldicarb sulfone
Dicapthon
Acrylonitrile
Diphenylhydrazine
Strobane
Hexabromobiphenyl
Hexachloroethane
Beta-chloronapthalene
2,4-Dichlorophenol
1,2,4,5-Tetrachlorobenzene
p-Chlorophenol
o-Chlorophenol
Tetrahydronapthalene
Dimethyl naphthalene
Benzonitrile
Hexachlorocyclopentadiene
1,2,3-Trichlorobenzene
2,3,7,8-Tetrachlorodibenzo-p-dioxin
and other isomers
dibenzofurans (isomers)
100 ml
1 L
7.6 L
3.8 L
3.8 L
1 X per year
or as needed
small gas cylinders
500 g
500 ml
10 g
10 g
500 g
100 g
100 g
20 g
100 g
10 g
100 g
25 g
100 g
100 g
25 ml
25 ml
25 ml
600 mL
500 g
< 1 g each
< 1 g each
r H -
-------
ISSEj UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
'* OFFICE OF RESEARCH AND DEVELOPMENT
ENVIRONMENTAL MONITORING AND SUPPORT LABORATORY
CINCINNATI, OHIO 45268
DATE: March 7, 1986
SUBJECT: Environmental Impact Statement (EIS)
FROM: John A. Winter, Chief
Quality Assurance Branch
TO: Joseph A. Castelll, Director
Facilities Management and Services Division
These lists are being provided to you as discussed on February 28, 1986.
Now that the term, "hazardous materials," has been translated to "chemical
compounds," we are pleased to provide the following lists as representative of
what might be expected to be procured and used 1n the development and analyses
of quality control (QC) and performance evaluation (PE) samples 1n the
containment facility:
List 1 - Inorganic Chemicals
List 2 - Organic Chemicals
List 3 - Repository Standards
Please note that List 3 - Repository Standards would be ordered from the
U.S. Environmental Protection Agency (USEPA) Repository for Toxic and
Hazardous Materials or other sources, on a variable and selective basis only,
as required for analyses. That Is, few or a number of these standards may be
on hand at different times. These standards are prepared In small volumes of
1.5 mL each, in sealed glass ampuls and shipped by U.S. mall.
We believe this completes the requested response for the EIS.
cc: Robert Booth
Thomas Clark
Ref: 6530C
-------
CHEMICAL
Ammonium Persulfate
Ammonium Phosphate (dibasic)
Ammonium Molybdate
Ammonium Chloride
Barium Nitrate
Boric Add
Calcium Chloride
Calcium Nitrate
Calcium Carbonate
Cadmium Nitrate
Cobalt Nitrate
Ferric Nitrate
Ferric Ammonium Sulfate
Ferric Chloride
Hydrazlne Sulfate
Hydroxylamlne Hydrochlorlde
Hydroxylamine Sulfate
Lanthanum Chloride
Lead Carbonate
Lead Nitrate
Magnesium Chloride
Mercuric Nitrate
Nickel Nitrate
Potassium Chloride
Potassium Dlchromate
Potassium Ferrfcyanlde
Potassium Bllodate
Potassium Cyanide
Potassium Iodide
Potassium lodate
Potassium Hydroxide
Potassium Permanganate
Potassium Persulfate
Potassium Phosphate (monobasic)
-13-
LIST 1
INORGANICS
AMOUNT
ON HAND
2 pounds
FREQUENCY OF RE-ORDER
1-2 years (as needed)
2
3
1
550 grams
600 "
2500 "
1 pound
500 grams
500 "
100 "
1 pound
600 grams
1 pound
400 grams
90
400 "
500 "
300 "
3.5 Kg
90 grams
1000 "
10 "
3 pounds
1 "
500 grams
100 "
300 M
2.5 pounds
1 pound
6 pounds
1800 "
2.5 pounds
700 grams
H
H
H
N
H
n
N
M
n
N
n
N
a
H
N
n
H
n
a
n
u
n
n
n
H
M
H
H
N
II
H
H
U
M
H
H
H
II
I*
II
II
II
II
II
II
If
II
H
n
it
H
II
n
H
H
it
it
a
n
n
H
-------
LIST 1 - INORGANICS (continued)
CHEMICAL
Potassium Phosphate (dibasic)
Potosslum Sulfate
Sodium Arsenate
Sodium Bicarbonate
Sodium Borate (Borax)
Sodium Carbonate
Sodium Chloride
Sodium Fluoride
Sodium Hydroxide
Sodium Iodide
Sodium Nitrate
Sodium Phosphate (dibasic)
Sodium Phosphate (trfbaslc)
Sodium Sulfate
Sodium Phosphate (monobasic)
Sodium Thlosulfate
Sodium Lauryl Sulfate
Antimony (sponge)
Antimony (powder)
Antimony Trichloride
Antimony tartrate
Arsenic Tr1 oxide
Barium Chloride
Beryllium (flake)
Boric Acid
Calcium Carbonate
Cadmium (powder)
Chromium (VI) tr1 oxide
Cobalt (sponge)
Copper (powder)
Lanthanum oxide
AMOUNT
ON HAND
400 grams
2.5 pounds
100 grams
1 pound
200 grams
30 "
2.5 pounds
1 pound
8100 grams
50 grams
1 pound
300 grams
2 pounds
500 grams
1 pound
3 "
1 a
50 grams
10 "
20 "
1 pound
60 grams
70 "
70 "
500 "
20 "
100 M
100 "
120 "
35 "
50 "
FREQUENCY
1-2 years
H
II
H
H
II
H
II
H
II
II
II
II
II
II
H
H
H
II
II
II
II
II
II
II
II
II
II
II
II
II
OF RE-ORDPR
(as needed)
H
H
H
H
H
N
II
H
II
II
II
II
It
H
II
H
II
II
II
II
H
H
II
H
n
n
n
n.
N
n
-------
LIST 1 - INORGANICS (continued)
CHEMICAL
Lead Nitrate
Mercuric Chloride
Potassium Carbonate
Potassium Chloride
Potassium Nitrate
Potassium D1hydrogen Phosphate
Magnesium (rods)
Magnesium (chips)
Magnesium (pieces)
Magnesium Oxide
Molybdenum Tr1oxide
Ammonium Molybdate
Nickel (sponge)
Selenium IV dioxide
Silver Nitrate
Strontium Nitrate
Tin (rod)
Tin (30 mesh)
Thallium Nitrate
Titanium (sponge)
Titanium (wire)
Vanadium Pentoxlde
Yttrium Oxide
Zinc Oxide
Chromium Trloxide
AMOUNT
ON HAND
200 grams
20 grams
10 "
100 "
50 "
10 "
100 "
500 "
100 "
20 "
10 grams
10 "
200 "
100 "
30 "
80 "
6mm x 160mm
500 grams
55 "
100 "
.75mm x 30cm
250 grams
60 "
140 "
200 "
FREQUENCY OF RE-ORPER
1-2 years (as needed)
M H
N
H
II
n
H
H
n
H
II
II
n
M
n
n
n
n
M
M
II
II
H
II
II
n
H
M
N
H
II
H
N
H
II
n
II
n
II
n
-------
LIST 1 - INORGANICS (continued)
CHEMICAL
Glydne
L-G1utam1c Acid
Magnesium Nitrate
Magnesium Chloride
Mercuric Chloride
Potassium Carbonate
Potassium Fluoride
Potassium Hydrogen Phthai ate
Potassium Iodide
AMOUNT
ON HAND
2000 grams
500 grams
1000 "
100 "
100 "
1 pound
100 grams
2 pounds
FREQUENCY OF RE-ORDER
1-2 years (as needed)
N
H
H
H
H
N
II
Potassium Phosphate (monobasic) 1 pound
Potassium Phosphate (dibasic) 1 "
Potassium Nitrate 1 "
Sodium Arsenate 500 grams
Sodium Borate 1 pound
Sodium Bicarbonate 2 pounds
Sodium Phosphate (monobasic) 3 pounds
Sodium Phosphate (dibasic) 400 grams
Sodium Sulfate 1 Kg
Lead Acetate 500 grams
Cupferron 1 pound
Dowex 50 WX-8 400 grams
Dextrose 2 pounds
Glutamlc Add 2 "
H
H
U
II
n
n
n
H
H
n
H
H
n
-------
LIST 1 - INORGANICS (continued)
CHEMICAL
Methyl ene Blue
Potassium Add Ph thai ate
Antimony Potassium Tartrate
THAM
EHochrome black T
Bromo Phenyl Blue
Methyl Thymol Blue
2,4 -Den1trophenyl-Hydraz1ne
Thymol Blue
AMOUNT
ON HAND
200 grams
100 grams
1 pound
100 grams
35 '"
5
7
20 "
5
FREQUENCY OF RE-ORDER
1-2 years (as needed)
n
n
N II
H l>
H H
n
N
it n
-------
LIST 2
ORGANICS
CHEMICAL
Acetone
Methanol
I sooctane
Freon
Isopropyl alcohol
p-xylene
l,2-d1chloroethane
1-propanol
Acetonltrfle
1 ,2, 4- trlchl orobenzene
Dlchlorome thane
Pentane
Hexane
Benzene
To! uene
Glycerin
Vegetable oil
Paraffin oil
Phenol
1 ,2-dlchloropropane
m-d1chl orobenzene
trlchl oroethyl ene
ethyl benzene
o-xylene
hexachloro-1 ,3-butad1ene
p- d1 chl orobenzene
1,1-dlchloroethane
Hexachl orocycl opentadl ene
m-xylene
AMOUNT
ON HAND
2 gallons
2
1
2
1
1 Kg
1 gallon
1
1
1
2 quarts
1 gallon
1 "
1 "
1 "
2 pint
1
1 gallon
500 grams
1 quart
100 grams
1 pint
1 Kg
100 grams
1 Kg
100 grams
10 nt
1 Kg
1 Kg
FREQUENCY
1-2 Years
H
n
n
N
H
n
H
n
H
»
n
n
H
n
n
n
H
H
H
n
n
n
n
n
n
n
n
n
OF RE-ORDER
(as needed)
H
II
II
II
II
II
II
N
II
II
II
II
II
II
II
n
n
u
H
n
u
n
n
n
n
H
n
-------
List 2 Organic* (continued)
CHEMICAL
1 ,1 ,1 -trlchl oroethyl ene
Tetrachl oroethyl ene
CarbontetrachloHde
Trlchl oroethyl ene
1,2-dichloroethane
Styrene
Chlorofonn
Bromochl orome thane
Chlorobenzene
D1chl orome thane
1,2-d1chloropropane
2-chl oroethyl vinyl ether
1 ,2-d1bromo-3-chloropropane
o-dfchlorobenzene
ds l,2-d1chl oroethyl ene
Chi orobenzene
1 ,1 ,2,2-tetrachloroethane
Trlchl orof 1 uorome thane
trans 1 ,2-d1chl oroethyl ene
Vinyl chloride 1n N2 (1410 ppm)
Aldrln
Chlordane
DDT
D1eldr1n
Heptachlor
AMOUNT
ON HAND
200 ill
500 mL
500 id
1 liter
1 Kg
1 Kg
500 ml
§00 grams
1 Kg
500 mL
1 Kg
500 mL
200 grams
500 nt
50 grams
250 mL
250 mL
250 mL
250 mL
4 lecture btls.
3 grams
2 "
2 "
2 "
1
FREQUENCY
1-2 years
N
tt
N
N
H
II
M
II
II
N
U
II
II
M
n
M
H
n
H
H
H
n
«
u
OF RE-ORDER
(as needed)
n
n
n
n
H
n
H
n
M
n
M
n
»
n
n
n
H
n
ii
n
n
n
u
n
-------
List 2 - Organlcs (continued)
CHEMICAL
Hexachlorobenzene
Hexacnlorobutadlene
BHC Isomers
Sllvex
2,4-D
Toxaphene
V1nyl1dene chloride
Heptachlor
Heptachlor epoxlde
DDE
DDD
Endrln
EndHn aldehyde
Endnn ketone
Methoxychlor
Endosulfan 1
Endosulfan 2
Endosulfan sulfate
o-chl orotol uene
p-chl orotol uene
m-chl orotol uene
4-chl orobenzotrl f 1 uorl de
2-chl orobenzotrl f 1 uorl de
2,4,5-trlchlorophenol
1 ,2,3,4-tetrachlorobenzene
Mesitylene
2 ,4-d1chl orophenol
AMOUNT
ON HAND
500 grams
1 liter
14 grams
2 grams
2 "
9.5 _"
500 "
2 "
2.5 "
1.5
1 "
2 "
0.2 "
0.1
1 "
1
1 "
2 "
100 "
100 "
100 "
100 "
100 "
1 "
25 "
500 "
100 "
FREQUENCY OF RE-ORDER
1-2 years (as needed)
H
II H
* N
N
H
H n
H II
H N
H n
H
H H
H H
II
H N
H
H II
N n
II
n
H
H
H
N
H
a
n
30
-------
List 2 Organ1cs (continued)
CHEMICAL
Dimethyl phthalate
D1-octyl phthalate
01 -ethyl hexyl phthalate
01 butyl phthalate
Butyl benzyl phthalate
01 ethyl phthalate
Bromochl orome thane
1 ,2,3-tr1chloropropane
Octadecane
Hexachloroe thane
1 , 2, 4- trl me thy! benzene
4-chloroan1l1ne
4-bromod1phenyl ether
2 ,6- tetrachl orotol uene
l,4-d1chlorobutane
Fluorobenzene
n-butyl benzene
n-propyl benzene
1 ,3,5-trfchlorobenzene
1 ,2,3,5-tetrachlorobenzene
1 , 2, 3- trl methyl benzene
AMOUNT
ON HAND
500 grams
250
500
500
250
100
500
100
100
100
0.5 Kg
100 grams
25
100
250
100
25 . "
25
100
100
100
FREQUENCY OF RE-ORDER
1-2 years (as needed)
« it
" «
H
H
H
H
H
« M
N N
H
H
N
H
H
M
n
N
n
n
n
-------
List 3 Tht USEPA Repository for Toxic and Hazardous Materials
EMSt-C1nc1nnat1 maintains the USEPA Repository for Toxic and Hazardous
Materials to provide a continuing source of calibration materials, standard*,
reverence compounds, spiking solutions for all trace organic* of Interest to the
Agency. The Repository provides support for Ambient Monitoring, Drinking Water,
NPDES/PHorlty Pollutants, Hazardous Waste/Solid Waste, Toxics and Superfund
Programs.
Compounds are prepared Individually as 1.5 ml solutions In water-misclble
solvents sealed 1n all-glass ampuls. A data sheet with each ampul contains
general chemical data, solution specifications, storage and preservation
recommendations, Information on purity and health hazards, and safe handling
Instructions.
Three grades of materials will be distributed:
Quality Assurance Standards (QAS) > 99 percent purity
Quality Assurance Reagents (QAR) 95-98 percent purity
Quality Assurance Technical Materials (QAT) < 95 percent purity
The Repository will move as many compounds as possible from the QAT and QAR
categories Into the QAS category by use of purification techniques. Exceptions are
nultlcomponent materials such as PCBs, toxaphene, ehlordane and halowaxes which will
be categorized as QAR or QAT and will not be purified further. The current IJst of
the Repository materials distributed 1s given 1n the following table: 1
-------
Hit 3 Continued Th« (JStM MootUcry for Tosle and
Hflt*f1«1i
Concentration! irt 5,000 ug of QAS«purt compound ptr «(.
of methanol solvent unlesi otherwise notad.
C001 Aesnaphth«ns
£002 Aero1«1n**
£003 Aery Ion Urns (10,000 ug/iH)
£004 Bcnztna (10,000 ug/nH.)
EOOS B«nz1d1nt
E006 Chlorobfnztne (10,000 ug/flt)
£007 1,2,4-TMchlorobinztne
EOOS Htxaehlorobenzene (1000 ug/mL)*
E009 1,2-01ch1orb«thane (10,000 ug/ml)
E010 1,1,1-TMchloroethane
(10,000 ugMMQM)
E011 Hexachloroethanc
£012 1,1-01eh1oroethane (10,000 ug/ml)
£013 1,1,2-TMchloroethane
(10,000 ug/mL)(QAR)
£014 1,1,2,2-Tetrachloroethane
(10,000 ug/mL)(QAR)
E015 Chlorotthant (11,000 ug/mL)***
E016 b1s(2-Ch1oroethy1) ether
EOT7 2-Chloroethyl vinyl ether (QAR)
£018 2-Chloronaphthalene
£019 2,4,6-Trlchlorophenol
£020 p-Chloro-m»creso1
£021 Chloroform (10,000 ug/ni)
£022 2-Chlorophenol
£023 1,2-01chlorobenzene
£025 1,4-01chlorobenzene
£026 3,3>-01ch1orobenz1d1ne
£028 trans-1,2-01chloroethylene
(11,500 ug/ml)
£029 2,4-Olchlorophenol
£030 1,2-01chloropropane (10,000 ug/mL)
£033 2,4-01n1troto1uene
£034 2,6-01n1trotoluene
£036 Ethyl benzene (10,000 ug/mL)
£037 Fluoranthane
£038 4-Chlorophenyl phenyl ether
£039 4-8romopheny1 phenyl ether
£040 b1s(2-Ch1@ro1sopropy1) ether (QAR)
£041 b1s(2-Ch1oroethoxy) methane (QAft)
£042 Hethylene chloride (10,000 uq/mL)
£043 Methyl chloride (4,500 ug/mL)***
£044 Methyl bromide (9940 ug/raL)***
£046 Dlchlorobromomethane (10.000 ug/mL)
£050 Hexachlorobutadlene (QAR)
£051 Hexachlorocyclopentadlene
£052 Isophorone
£053 Naphthalene
£054 Nitrobenzene
£055 2-N1tropheno1
£056 4-N1tropheno1
£057 2,4-01n1trophenol (QAR)
£058
EOS9
£060 N-l
£061 M-N1trosod1-fl-propy1tffl1nt
E062
£053
£064 b1«(2-£thy1 hexyl) phthalate
£065 Butyl benzyl phthalate
£066 01-n-toutyl phthalati
£067 01-n-octyl phthalate
£063 01ethyl phthalatt
£069 Dimethyl
£070 Benzo
£071 Benzo
£072 Benzo
£073 Benzo
anthracene (1,000 ug/mL)
pyrtne (1,000 ug/mLHQAfi)1
fluoranthene
fluoranthene
£074 Chrysene (1,000 ug/aL
2,500 ug/mL)*
1,000 ug/mL)*
£075 Acenaphthylene (QAR)
£076 Anthracene (1,000 ug/nt)*
£077 Benzo(g,h,1)pery1ene (1,000 ug/nt)**
£078 Fluorene (QAR)
£079 Phenanthrene
£081 Indeno(1,2,3-c,d)pyrene (500 ug/mL)*
£082 Pyrene (1,000 ugM)
£083 Tetrachloroethylene (10,000 ug/mL)
£084 Toluene (10,000 ugM)
£085 Tr1 chl oroethylene (10,000 ug/ml)
£088 Oleldrln
£089 Chlordane (QAT)
£091 4,4'-DOE
£092 4,4'-000
£093 alpha-Endosulfan**
£094 beta-Entio$ylfin**
£095 Endosulfan sulfate (QAR)
£096 EndHn (QAR)
£097 EndHn aldehyde
£098 Heptachlor
E099 Heptachloj* epoxlde
£100 alpha-BHC (2,500 ugM)
£101 beta-BHC (2,500 ugM)*
£102 gama-BHC (Llndane)
£103 delta-BHC (1000 ygM)
£104 PC8«Aroclor 1242 (QAT)
£105 PCB-Aroclor 1254 (QAT)
£107 PCB-Aroclor 1232 (QAT
£108 PCB-Aroclor 1248 (QAT
£109 PCB-Aroclor 1260 (QAT
£110 PCB-Aroclor 1016 (QAT)
El11 Toxaphene (QAT)
£124 4,4'-DOT (QAR)
£126 PCB-Aroclor 1221 (QAT)
£130 PCB-Aroelor 1262 (QAT)
*In Acetone **In para-Oloxane
+ln Methylent chloHde
***In 2-Propanol ****in AcetonltrUe
-------
Hit 3 Continued The
Heoo*Uory for Toatc me murdou* Hater Uli
Concentration! are 5,000
of nethanol to1 vent un1e»i
ug of QAS-pure compound per nil
otherwlte noted, (continued)
£150
£151
£152
'131 PCI-Aroclor 12M (2,500 ugM)* OAT)
136 Broflwchloronwthane (10,000 ugM)
SI 49 2,4-01ch1oroto1uene
2«Ch1oroto1uene
3-CH1oroto1uene
4-Chlorotoluene (QAM)
El 53 4-Ch1orobenzetr1f1uor1de
El 56 Pentachloronltrobettiene
El 68 alpha, alpha, 2, 6-Tetrachlorotoluene
E169 Benzyl chloride (QAR)****
El 70 2,3-01ch1oro-1-propy1ene
(10,000 ugM)
E171 1,2-01brontoethane (EDB) (10,000 ug/mL)
E173 c1$-l,2-01ch1oroethy1«ne
(10,000 ua/mL)(QAR)
2,3-Trlchlorobenzene
3,5-Trlchlorobinzene
1,2,4,5-Tetrachlorobenzene
(2,500 ugMKQAR)*
E175
E176
El 77
1,
1
El 79 2,4,5-Trlchlorophenol (QAR)
El 80 2,4,6-Tr1ch1oroan111ne
E182 3-Chlorophenol
£183 4-Chlorophenol
£200 Chlorodlbromomethane
(10,000 ug/mL)(QAR)
E201 ortho-Xylene
^202 meta-Xylene
£203 para-Xylene
£212 Bromoform (10,000 ug/mL)(QAR)
£21 4 1 , 3-01 ch 1 orobenzene
£218 els & trans 1,3-01 eh loropropylene (QAR)
£219 M1rex (1,000 ug/mL)*
£220 Aldrln
E222 2,3,5-Trlchlorophenol (OAR)
£224 2, 4-01methyl phenol (QAR)
£225 1,2,3,4-Tetrachlorobenzene (2,500 ug/mL
£231 01b«nzo(a,h)anthracene (1,000 ug/mL)**
E236 n-Oecane
£237 n-Undecane
£238 n-Oodecane
E239 n«Tr1decane
£240 n-Tetradecane
£241 n-Pentadecane
£242 n-Heptadecane (2,500 ug/mL)
E244 n-Nonad«einc (1,000 ug/mL)
C246 n-Tttracoiant (500 ugM)
E250 ortho-Cruol (OM)
E2S1 mta-Crtsol (QAft)
E252 para-Crtsol
£255 Olbutyl flthtr
I2S7 Styrtn*
E2S8 Eplchlor-ohydrln****
E260 Ptntachlorobtnzena (2,500 ugM)
£261 01b«nzofuran
E262 Olpherryl «th«r
£263 01pheny1an1ne
£270 Aery 1 amide (10,000 ugM)
£271 PyHdlnt (10,000 ugM)
E282 OUsodecyl phthalate
£284 Acetone
£285 Dfethyl ether (4,500 ugM)
£286 1,2-Epoxybutarie****
£305 4-Ch1oroan111ne
E311 Methyl ethyl ketone (10,000 ugM)
£324 o-N1troan111ne
£325 m-N1troan111ne
£330 2,4-01chlorophenoxyacet1c add
(2,4-0)****
£342 p-N1troanH1ne
£360 Carbon tetrachloHde (10,000 ugM)
£368 1,2,3-THchloropropane
£470 PCN Halowax 1099 (QAT
E471 PCN Halowax 1001 (QAT
£472 PCN Halowax 1000 QAT
£480 para-01oxane (10,000 ugM)
£536 Vinyl chloride (4,500 ugM)
£542 Aniline
£548 N,N-01nethylformam1de
£552 2,4,5-TP (Sllvex) (QAR)
) £662 3-NUrophenol
£713 Pic lor am (1000 ugM)
£715 Carbofuran
£952 p,p'-Methoxychlor
£954 Aldlcarb (1,000 ugM)
£993 1,2-01bromo-3-ch1oropropane
£995 Aldlcarb sulfone (1,000 ugM)
£996 Aldlcarb sulfoxide (1,000 ugM)
*In Acetone **In para-01oxane
*Methylene chloride
***In 2-Propanol ****Aceton1tr11e
-a*-
-------
Hit 3 Continue The USEPA Repository for To<1c and Maiardom Hit«f1i1t
Concentratloni are 5(000 ug of QAS-purt coapound ptr «H.
of methanol lolvent unless otherwise noted, (continued)
PCSi at 1,000 ug/ol In 3.5 ml Isooctant
E125 PC8-Aroc1or 1010 (QAT) £132 PCB-Aroclor 1242 (QAT)
£129 PCB-Aroclor 1260 (QAT) E135 PCB-Aroclor 12S4 (QAT)
Surrogate and Inttrntl Standard for USEPA 6C/MS Xtthods 624 tnd 625
E188 Phcnanthrtnt - dio (150 ug/mL) £196 1 ,4-01ch1orobuUn«-dg (150 ug/mL) *
El 89 Phenol - dc (100 ug/fll)* E197 2-Bromo-l-ch1oropropan«-d« (150ua/mL)(QAT)
El 90 2,4-01methy1 phenol -3,5,6-d3 E198 BromochloroMthane-djJISO ug/mL)
(QAR)(100 ugM)* £199 Benzo(g,h(1)perylene-13c]2(loO ug/mL)*
E191 Pentachlorophenol-^C* (100 ug/mL)* £232 Fluorobenzene (150 ug/mL)
£192 Dimethyl phthalate - d« (150 ug/mL)* £233 4.Bromof1uorobenzene (150 ug/mL)
£193 2-F1uoropheno1 (QAR) (100 ug/mL)* £234 4,4-Olbromooctafluoroblphenyl (100 ug/mL)*
£194 2-Fluorob1pheny1 (100 ug/mL)* £776 1,2-01ch1orobenzene-d4 -(ISO-ug/mL)
£195 1-F1uoronaphtha1ene (100 ug/mL)*
*In Acetone **In para-Oloxane ***In 2-Propanol ****Aceton1tr11e
*In Methyl Chorlde
-------
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-------
N-SERIES STANDARD CONSTRUCTION FEATURES
SUGGESTED SPECIFICATIONS
The filter housing shall be a N-Series Bag-In/Bag-Out housing and shall be man-
ufactured from 14 gauge T-409 stainless steel unpainted (14 gauge T-304 stainless
steel unpainted is also available). The housing shall be adequately reinforced to
withstand a negative or positive pressure of 10" water gauge. The housing shall
be side access for filter installation and change-out. Housing design and filter ar-
rangement shall allow air to enter and exit housing without changing direction.
Housing shall accommodate standard gasketed HEPA filters, or carbon adsorbers,
that do not require special attachments or devices to function properly in the
housing.
All weld joints and seams shall be continuously welded. All weld joints shall be vis-
ually inspected for cracks, underfill, incomplete fusion, overlaps, surface porosity,
gas pockets, crevices, crater pits and depressions. All joints and seams shall be
ground smooth and all burrs and sharp edges shall be removed. All welding procedures,
welders and welder operators shall be qualified in accordance with ASME Boiler and
Pressure Vessel Code, Section IX.
All hardware on the housing and mechanical components of the filter clamping mechan-
ism are 300 series stainless steel except for the threaded nuts, which are brass, and
the access door knobs which are cast aluminum. Each tier of filters is fitted with a
filter clamping mechanism that is operated from outside the housing. The filter clamp-
ing mechanism shall include pressure bars with pre-loaded springs that exert a mini-
mum sealing force of 1,200 Ibs. per filter, applied as an even, uniform load along at
least 80% of the top and bottom of each filter frame.
Housings with more than one (1) filter shall have a filter removal rod to draw the fil-
ters to the change-out position. The filter removal rod shall be designed in a manner
that allows the housing to be rotated 180° on its' airflow axis and serve as a left hand
access unit or a right hand access unit at the users discretion. The removal rod shall
operate from inside the change-out bag. Each housing shall have a bagging ring a-
round the access port that is sealed by a removable, gasketed access door. The bag-
ging ring shall have two (2) continuous ribs to secure the plastic change-out bag and
each ring is hemmed on its outer edge to prevent the bag from tearing.
One (1) PVC change-out bag shall be furnished with each access port. Bags shall be
8 mil thick and amber in color. Bags have a translucent, matte finish and a 1/4" dia.
elastic shock cord hemmed into the mouth of the bag so when stretched around the
bagging ring it is a secure, snug fit. Bag shall include approximately 12" of transpar-
ent PVC at the mouth of the bag and shall have three (3) glove sleeves built into the bag
to assist in the filter change-out. "To prevent the bag from sliding off the bagging'
ring during the change-out operation, one (1) nylon security strap with a neoprene
rubber gasket sewn on the inside shall be provided with each access port.
The filter housing shall.be manufactured under a quality assurance program that address-
es the requirements of ANSI N45.2, "Quality Assurance Program Requirements for Nuclear
Power Plants". Housing shall be tested for filter fit, operation of the filter clamping mech-
anism and leak tightness before leaving the factory. Both the filter sealing surface and
the complete assembly pressure boundary shall be leak tested by the "pressure decay meth-
od" in accordance with ANSI/ASME N510-1980, "Testing of Nuclear Air-Cleaning Systems"
paragraph 6 & 7 and guaranteed to meet the leak tightness requirements of ANSI/ASME
N509-1980, "Nuclear Power Plant Air-Cleaning Units and Components", Table 4-4 "Maximum
Unit Leakage Rates" for ESF, leakage Class 1.
-a;-
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FILTER TRAINS CMODULAR WELDING IN SERIES]
In many cases more than one bank.of filters are required to do the complete
filtration job, (for example, when both contaminated participates and gases
must be filtered from the same air stream, or when the application requires
a greater residence time than one bank of carbon adsorbers can provide). In
such cases, the type and number of filters to go in each bank is determined,
the appropriate modules (housings) are constructed and are then welded in
series one behind the other to create a filter train. Filter trains can be made
from any of the standard housings offered by CSC.
HCFA 01 High
Elficl.ncy Filt.l
Doufhint Filter
ruin
A typical 2,000 CFM Filter Train consisting of: Roughing Filter, HEPA, Carbon
(1/8 second residence time/bank = 1/4 second residence time total), HEPA. The
door-side filters are shown outside the housings for identification of the filters.
Filter trains like this one can be made up from any model size N-Series Bag-In/
Bag-Out Housings, standard prefilters, HEPA or high efficiency filters, and
Type I (V-Bed) carbon adsorbers.
Small Filter Train
(nominal 1000 CFM)
Prefilter-HEPA /Carbon
Large Filter Train
(nominal 6000 CFM) ,
Prefilter-HEPA /Carbon /Carbon /HEPA
-------
FILTER TRAINS {MODULAR WELDING IN SERIES!
BAG-IN/BAG-OUT FILTER TRAIN
(WITH OR WITHOUT BUOWBRS, TRANSITION, BTCJ
,OOO CFM PREFILTBR,
fEPA/CARBON/CARBON/
HEPA SELF-CONTAINED
1AG-IN/BAG-QUT FILTRATION
SYSTEM
DESCRIPTION:
CSC can design and manufacture complete self-contained filter systems. These
systems usually include a prefilter, HEPA filter, carbon adsorber(s), housings
to contain these components, and a blower to provide the necessary airflow.
These self-contained units can be sized from very low flows to many thousand
CFM. These units are designed to connect to existing ductwork to provide a
high efficiency filter system for existing fume hoods, glove boxes, or any other
process air exhaust system that has dangerous effluents. CSC's self-contained
filter system has many features not found in other designs. These features in-
clude the following:
CSC can supply entire prepackaged, pretested units.
Detailed engineering to assure compatibility between housing, its components,
and blower.
« Minimize installation problems.
Quick delivery.
Ready to connect to existing ductwork.
Ready to be wired to existing electrical system.
FOR COMPLETE INFORMATION ON CSC'S CUSTOM AND SELF-CONTAINED
SYSTEMS, CALL OR WRITE FOR CSC BULLETIN No. 483E.
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INTRODUCTION TO HBQA
WHAT IS A HECA?
In order to be called a High Efficiency Gas Adsorber (i.e., HECA). the adsorber must
exhibit a minimum *mechanical efficiency of 99.9% when tested in accordance with IES
Designation: RP-8, "Gas Phase Adsorber Cell", which supercedes IES (AACC) CS-8.
In additior, the adsorber must be designed, built, filled, and packaged in accordance
with the intent of this standard. Since HECA filters are manufactured In several dif-
ferent sizes and of several different materials, this standard is not always followed to
the letter, but it is the intent of the standard and the resulting performance of these
adsorbers that is important. This type of adsorber is not intended to be used in odor
control systems. However, if the user needed a very efficient odor control system, and
could justify the higher initial and operating cost, then this type of adsorber would do
an excellent job. The following comparison between an odor control type adsorber vs. a
HECA may help:
An odor control type adsorber compared to a HECA is like comparing an
ASHRAE type particulate filter to a HEPA. The odor control type adsorber
(like the ASHRAE type particulate filter) has a low efficiency, low pres-
sure drop, and low cost. On the other hand, the HECA (like the HEPA)
has a higher efficiency, higher pressure drop, and higher cost. Both ad-
sorbers have their place in industry, but because of these major differ-
ences they are not usually interchangeable.
WHERE ARE HEGA'S USED?
HECA's are most often used in "containment" air filtration systems. Containment air
filtration systems are very high efficiency systems, used to filter out and contain
dangerous particulate and/or gaseous contaminants. Containment systems are most often
designed to treat exhaust air from contaminated spaces, but occasionally are used in
supply and recirculated air systems. Examples of facilities using these systems are:
Nuclear Power Plants
Cancer Research Laboratories
Toxicology Laboratories
Animal Disease Research Laboratories
Chemical Agent Research Facilities
Bomb Shelters (CBR)
Radiopharmaceutical Plants
Laboratories using Chemical Carcinogens
Chemical Agent Munitions Disposal
Facilities
HOW DOES A HECA WORK?
A HECA filters gaseous contaminants from an airstream by adsorbing these contaminants
(see page 14 for explanation of "Types of Adsorption"). With a properly designed system
(i.e., selection of the proper adsorber, adsorbent and residence time) any adsorbable
contaminant can be filtered and contained (see page 10 for "Carbon Specifications" and
page 1.5 for explanation of "Residence Time").
* See "Efficiency vs. Penetration" on page 14.
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HBGA SELECTION
The following will assist the designer by answering questions that should be nrMressed
when designing a system requiring HEGA's.
1. Should I use a Type I or Type II HECA?
(see pages 12 & 13)
2. Which type of carbon do I need?
(see page 10)
3. What residence time do I need?
(see pages 4 & 15)
H. Do I need samplers and how can I tell when to change HEGA's?
(see pages 11 & 16)
5. What materials should I specify for the HEGA frame? Stainless Steel? Plastic?
(see pages 4-9)
DESIGN CONSIDERATIONS
The following items should be considered when designing the filtration system:
- Any system filtering dangerous contaminants should use Bag-In/Bag-Out housings
to contain the contaminated filters and protect maintenance personnel during filter
change-out.
- High Efficiency or HEPA filters should be provided upstream of HEGA filters to
prevent the adsorber from trapping particulates and thereby increasing the adsor-
ber's pressure drop.
- In systems where both particulates and gaseous filtration is required, high efficiency
or HEPA filters should also be located, downstream of the adsorber to collect any fines
(which might be contaminated) released from the adsorbent material and to act as a
back-up in case the first particulate filter should fail.
- Filter trains can be easily constructed with any combination of roughing filters, high
efficiency filters, HEPA filters and adsorbers (see pages 12 6 13 for examples).
- An in-place test of both adsorbers and HEPA filters is required for nuclear systems
and is becoming a more frequent requirement in many critical non-nuclear systems.
The in-place test, if required, should be discussed with a factory representative
prior to the selection of equipment so that the system will be correctly designed to
facilitate the test. In-place test equipment and service personnel are available from
CSC to assist in the original installation and testing.
- The filtration system should be manufactured under a good quality assurance pro-
gram such as one that addresses the requirements of ANSI N45.2 "Quality Assurance
Program Requirements for Nuclear Power Plants".
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TYPES OF ADSORPTION
There are three types of adsorption that concern us: (1) Kinetic, (2) Isotopic Exchange
and (3) Complexing or Chemisorption.
KINETIC: Kinetic adsorption of a gas molecule or elemental vapor is the physical attrac-
tion of the molecule to the carbon granule by electrostatic forces. These forces, as they
apply to small particles, are governed by Van der Walls theories, and these attraction
forces are termed Van der Walls forces. Since these forces are physical in nature, the
forces can be undone by physical effort. Thus, high temperature, high humidity, or
other natural causes may cause an adsorbed contaminant to desorb.
Generally, the higher the boiling point and the larger the molecule size, and the lower
the melting temperature is, the easier the molecule is to kinetically adsorb, and the more
permanently it is held once it is adsorbed.
ISOTOPIC EXCHANGE: A second adsorption is isotopic exchange. Radioactive materials
usually have a family of isotopes. If a stable isotope is adsorbed on the carbon initially,
an unstable isotopic compound will, when it comes into close proximity to the stable form
of the element, exchange the isotopes. The stable form is now on the airborne molecule,
and the radioactive is on the molecular structure of the impregnant. An example of this
is to impregnate carbon with KI3. The radioactive form of iodine in the organic form...
CH.I..., will isotopically exchange with the iodine on the carbon. This exchange is non-
directional, which means the adsorbed (exchanged) radioactive'species of iodine may
very well exchange again, and the result will be a different airborne radioactive methyl
iodide molecule. This new radioactive molecule may again isotopically exchange with stable
iodines on the carbon in the KI3 impregnant, and so on, until the radioactive iodine is
delayed long enough to decay into stable xenon.
COMPLEXINC OR CHEMISORPTION: A third capture mechanism is chemisorption. This is
the actual complexing, or attaching chemically, of a radioactive iodine species to a stable
impregnant that has the ability to share electrons. Once the iodine is complexed, it does
NOT desorb similar to the isotopic exchange. However, it may desorb similar to the kinet-
ic adsorption discussed. But if it does, the entire impregnant desorbs from the carbon,
not just the iodine. An example of this is to impregnate the carbon with Tri-ethylene-di-
amine (TEDA) or some other tertiary amine product.
To take advantage of both impregnates and capture mechanisms, carbon can be co-impreg-
nated. This allows the carbon to be used as a kinetic adsorber, an isotopic exchange me-
dium, and a complexing agent. As long as the, operating conditions are kept within nor-
mal bounds, the carbon will perform as required. It will perform under high humidity
conditions and undar high temperature conditions better than a single impregnate. How-
ever, some data indicate that the iodine of the KI3 impregnate has a tendency to migrate
to the molecule of the TEDA impregnate. CSC is not sure of the implications of this action.
CSC recommends a co-impregnated carbon until some adverse action is clearly documented.
EFFICIENCY VS. PENETRATION
There is often confusion between "efficiency" and "penetration" of contaminants thru a
carbon bed.
Efficiency is the ability of the carbon to remove a desired contaminant. Methyl Iodide ef-
ficiency, for example, is determined by challenging the carbon with an actual methyl io-
dide vapor. The amount of the contaminant upstream of the carbon is known, and the
amount that is collected on "back-up" beds is measured. The efficiency of that carbon
sample to remove methyl iodide is easily calculated by comparing the counts of the carbon
sample to the counts on the back-up beds. Test parameters such as temperature and re-
lative humidity greatly affect the efficiency.
Penetration, on the other hand, is a term used to indicate the degree of leak tightness
for installed carbon systems. The installed system is subjected to a test gas that is easily
adsorbed, such as Freon 11*. The penetration, or by-pass of the Freon is measured
downstream of the filter, and that amount is compared to the amount measured upstream
of the filter. A penetration value in percent is easily calculated from the collected data.
This is also termed mechanical efficiency.
*FREON is a registered trademark of Dupont.
-------
RESIDENCE TIME
Residence time is the term given to the time that a gas stream contacts a carbon bed,
For example, if a carbon bed were a foot thick, and the air stream moved at one foot
per minute, the residence time would be one minute. It would take one minute for a
gas molecule to move through the bed.
Typically, the carbon bed is one inch thick, and the air velocity is 40 feet per minute.
What would the residence time be in that situation? The residence time c
-------
DECONTAMINATION r-xo i m-i
The Decontamination Factor is the ratio of the concentration of a contaminant in the un-
treated air to the concentration of the contaminant in the treated air.
if anyone ask what the Decontamination Factor (DF) of a filter is, the answer can be ob
tained by calculating the RECIPROCAL of the penetration expressed as a fraction, or
EXAMPLE: What is DF of a filter whose penetration is H0%?
DF = cL. ; DF = -Ij ; DF = 2.5
(1) 0.1%? ; DF = 7rLrr ; DF = 1.000
(2) 50%? ; DF = -^ ; DF = 2
FILTERING CHEMICAL CARCINOGENS
At the time of this writing, to the best of CSC's knowledge, there is no written standard
establishing the best filter system design for removing chemical carcinogens. However; it
is generally acknowledged that a properly designed filtration system to remove these con-
taminants should be as follows:
1. HEPA filters should be used to trap dangerous particulates and protect the
carbon filters from collecting particulates and thereby increasing the ad-
sorber's pressure drop.
2. Carbon filters must:
- Exhibit a minimum mechanical efficiency of 99.9% (i.e., HEGA)
- Use high quality coconut shell activated carbon
- Be sized for approximately 0.125 second residence time
3. All filters should be installed in "Bag-In/Bag-Out" Housings to
protect maintenance personnel and the environment .
4. Filtration system designs should have provisions for pulling sam-
ples of air or carbon for laboratory analysis (to assist in determin-
ing when carbon adsorbers need changing).
5. The disposal of hazardous waste (i.e., spent HEPA and HEGA filters)
should also be considered. Hazardous waste incinerators are becoming
very popular for this purpose.
6. The filtration system should be manufactured under a good quality
assurance program such as one that addresses the requirements of
ANSI N45.2 "Quality Assurance Program Requirements for Nuclear
Power Plants".
-------
SOME RANDOM THOUGHTS ON CARBON
AND ADSORPTION OF MATERIALS
The following are some random thoughts that will help you to form a general idea of the
carbon filter technology. These comments are to be considered as general axioms, and the
reader should be able to "fill" in some of the unknown factors when strange situations a-
rlse. However, there Is no substitute for expert advise and opinion, and the reader is
urged to contact CSC for any technical problem beyond the ability of the reader.
1. Elemental iodine is adsorbed by attraction of the iodine to the carbon. This is called
kinetic adsorption.
2. Methyl iodide, which comes from elemental iodine (1131) combining with methane must
be adsorbed by chemisorption, usually in the form of isotopic exchange when Kl car-
bon is used, or complexing when TEOA carbon is used.
3. The recommended design velocity for methyl iodide is 0.25 seconds residence time per
two inch bed. Recent tests have shown that the carbon will perform as required at
twice that velocity.. .or half that residence time, for a limited time period.
4. As the humidity increases, the ability of the carbon to perform is adversely affected.
However, the carbon must perform at 95% relative humidity In order to meet ANSI
N509 Table 5-1 requirements. (See Table on Page 2).
5. As the temperature decreases, the carbon is adversely affected to a small degree.
However, the carbon must perform as required at 30°C. It will perform better at 80°C
since many of the easily adsorbed materials, such as moisture, are driven off the
carbon at that temperature.
6. The heavier the molecular weight of a material, the easier it is to adsorb.
7. The higher the boiling temperature of a material, the easier to adsorb.
8. The converse of 6 & 7 is true.
9. One gram of 60% active carbon (as measured by carbon tetrachloride) has a surface
area of about 1,000 square meters.
10. The adsorption coefficient of carbon is the amount, by weight, that the carbon will
adsorb of a given material. For example, the adsorption coefficient of Freon 11 is
about 20-25%. That is, 100 pounds of carbon will hold 20-25 pounds of Freon 11.
11. Some hard to adsorb materials can be dislodged by easier to adsorb materials. For
example. Acetic anhydride may drive off acetone. Acetone may drive off acetalhyde,
and acetalhyde may drive off acetylene.
12. The lower the concentration of a material, the harder to achieve a high removal per-
centage.
13. One gram of carbon will adsorb one milligram of iodine. The total inventory of iodine
in any system is very small.
14. Since carbon will adsorb anything adsorbable, it can be "poisoned" by harmless mater-
ials, and not be able to adsorb the material that it was designed to control. That is
why the carbon should always be protected from fumes that will harm it.
15. Shelf life of carbon in properly packaged drums or in filters having a vapor barrier
of some kind, can be as long as five (5) years. CSC recommends that the carbon
over three years old be retested to assure that it continues to meet the efficiency
requirements of the original specifications.
16. Methyl iodide adsorbs-desorbs-adsorbs thru the bed, exchanging iodine at each junc-
ture. That is, methyl iodide can be radioactive-stable-radioactive-stable until it de-
cays into harmless xenon.
17. Elemental iodine, once adsorbed, usually stays adsorbed due to the different adsorp-
tion mechanism.
18. Ideal partical size distribution of 8x16 mesh carbon will produce a 0.88 in. w.g. pressure
drop at 40 ft./mln. in a 2H bed; 6x14 mesh carbon will produce a 0.66 in. w.g. pressure
drop under the same conditions.
-------
APPENDIX B
TOXIC SUBSTANCE CONTROL MANUAL
-------
TOXIC SUBSTANCES CONTROL MANUAL
POLICIES AND REGULATIONS FOR CONTROL
OF TOXIC SUBSTANCES IN THE LABORATORY
A. W. BREIDENBACH ENVIRONMENTAL RESEARCH CENTER
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RESEARCH AND DEVELOPMENT
CINCINNATI, OHIO 45268
August 1982
-------
FOREWORD
This manual was prepared by the Hazardous Materials Handling Guide-
lines Task Group of the Hazardous Materials Subcommittee to provide
laboratory personnel and supervisors a positive control program for the
safe use of toxic chemicals.
Policies, regulations and recommendations are in compliance with
Chapter 8 of the Environmental Protection Agency's Occupational Health
and Safety Manual entitled Laboratory Use of Toxic Substances. In
addition, the Task Group used a document from the Environmental Monitor-
ing Systems Laboratory in Las Vegas as a source of additional information
for the present manual.
A basis for positive control of toxics is presented although no
attempt is made to present specific solutions to all the variety of
problems and conditions that may arise in laboratory situations. Never-
theless, sufficient information is presented to enable users to incorpo-
rate adequate safety into experiments with toxic materials.
For assistance and information regarding the acquisition, safe
handling, use, storage, and disposal of toxic substances, contact the
Chief Safety Officer, George A. Bodmer, Room 201, St. Clair Building,
Extension 7269.
Hazardous Materials Handing Guidelines Task Group Members:
//. ^Sfa-^fc&t^/ Richard A. Dobbs, Chairman
George A. Bodmer
Carl I. Rybak
l_ Stephen Billets
ii
-------
Concurrence by AWBERC Officials:
Gerald Berg, Ph.D., Chairman
Hazardous Materials Committee
William A. Cawley, Moderator
Occupational Health & Safety Committee
David G. Stephan, Ph.D.
Senior Official, ORD
William A. Benoit, Director
Office of Administration
Robert L. Booth
Acting Director, EMSL
Richard J. Bull, Ph.D..Director
Toxicology and Microbiology
Division, HERL
David G. Stephan, Ph.D.
Director, IERL
Francis T. Mayo
irector, MERL
L. A. Van Den Berg
Director, TSD
Jerry F. Stara, Ph.D.
Director, ECAO
Calvin 0. Lawrence
Director, CERI
m
-------
TABLE OF CONTENTS
Page
Foreword . ^ ]1
Concurrence iii
I. Policy and Responsibilities
Policy ^
Purpose 1
Background 1
Prime Responsibilities 4
II. Health and Safety Program
Safety Plan 11
Inventory Control 11
Medical Surveillance 13
Records . . . 14
Training 1.5
Audit . 17
III. Engineering Controls and Work Practices
Control Strategies 18
Requisitioning 23
Receiving 24
Packaging and Shipping 24
Disposal 25
Facility Requirements 26
Operational Practices 27
Personnel Practices 32
IV. Additional Requirements for Animal Experiments 37
iv
-------
TABLE OF CONTENTS (cont'd)
Page
V. Emergency Procedures
Minor Spills Involving Minimal Toxic Hazards to Personnel . . 39
Major Spills Involving Toxic Hazards to Personnel 40
Accidents Involving Dust, Mists, Fumes, Organic Vapors & Gases 41
Fires and Other Emergencies 42
First Aid 43
APPENDIX
A. Controlled Toxic Substances 45
1. NIOSH's Registry of Toxic Effects of Chemical
Substances 46
2. Carcinogen Assessment Group's List of Carcinogenicity . . 47
3. OHSA's List of Regulated Carcinogens 53
B. Toxic Substance Safety Plan 54
C. Occupational Health and Safety Staff, Laboratory Directors,
and Toxic Substances Committee Members . 58
D. Toxic Substance Chemical Inventory, Running Inventory
Sheets, and Toxic Chemical/Environmental Sample Log Sheet . . 60
E. Periodic Health Assessment 63
F. Location of Carcinogen Dilution Laboratory and
Limited Access Areas 65
G. Packaging, Marketing, Labeling, and Shipping of Toxic
Substances Used by Laboratories 66
H. Primary Containment Equipment 70
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TOXIC SUBSTANCES CONTROL MANUAL
I. POLICY AND RESPONSIBILITIES
A. POLICY
The U.S. Environmental Protection Agency is committed to providing
S6fe and healthful working conditions in laboratories where toxic sub-
stances are used. This Manual was prepared as part of a program to ensure
a safe and healthful work environment in areas where toxic substances are
used or stored. An additional objective is to prevent or minimize the
release of toxic substances to the environment.
B. PURPOSE
This Manual establishes policy, responsibilities, and procedures for
the conduct of the Agency occupational health and safety program for the
laboratory use of toxic substances. Specifically, (1) it defines the
responsibilities of all personnel involved in the use of toxic substances,
(2) it details health and safety program requirements, (3) it describes the
work practices and engineering controls that must be used in all labora-
tories, and (4) it provides guidelines necessary for carrying out these
responsibilities.
C. BACKGROUND
Executive Order 12196, 29 CFR 1960, and Chapter 8 of the EPA Occupa-
tional Health and Safety Manual requires the EPA to provide safe and
healthful working conditions for its employees. The EPA is responding to
this requirement with an adaptation of the U.S. Department of Health and
Human Services' Laboratory Use of Chemical Carcinogens, NIH Publication No.
81-2385, May 1981.
-------
-2-
An interagency subcommittee, which included an EPA representative,
developed the Department of Health and Human Services' Guidelines. The
control measures given in the Guidelines consist of the laboratory work
practices and engineering controls necessary to protect laboratory
workers from exposure to carcinogenic (or other highly toxic) substances.
In addition, the Guidelines provide alternative control measures which
are less demanding for low risk situations and more demanding for high
risk situations.
1. Basis of the Guidelines. The Guidelines are based on the
assumption that any exposure to a chemical carcinogen, regardless of how
small, carries some risk. While complete elimination of exposures is
the ideal objective, this is not always obtainable. However, the potential
for exposures must be reduced to the lowest practicable level.
The application of these Guidelines to a specific laboratory activ-
ity must be based on the judgment of the Principal Investigator, who is
responsible for the safety of his or her laboratory operations. No set
of guidelines can be applied uniformly to every situation. It is imper-
ative, therefore, that the Principal Investigator assess those variables
peculiar to each planned activity in establishing appropriate safeguards.
Variables that require specific attention include (1) toxicity, (2)
quantity of the toxic substance to be used, (3) physical and chemical
properties of the agent, and (4) the type of experimental procedures
in which the toxic substances will be used.
2. Substances Considered Toxic. A toxic substance is any material
which can produce injurious or lethal effects on contact with the body
and so present an environmental health hazard. Such substances may be
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-3-
solids, liquids, or gases, including fumes, mists, and vapors. Of
special concern are those substances that exhibit acute toxicity and
those that have known or suspected carcinogenic, mutagenic, or terato-
genic potential. Specifically included in the definition of toxic
substances are environmental samples containing, or suspected of con-
taining, any of these substances.
Toxicity is relative and refers to harmful effects on biological
mechanisms. The term relative toxicity is commonly used in comparing
the harmful effects of one chemical or physical agent with another.
Toxicity is the inherent potency of a material or combination of materials
to produce biological injury or harm. The hazard is the possibility
that the material will cause injury when a specific amount is used under
specific external conditions. Control of exposure still remains the
most effective means of preventing injury from hazardous chemicals.
Substances considered toxic for purposes of this Manual are listed
in Appendix A. The Appendix consists of three separate parts as described
below and includes substances exhibiting chronic and acute toxicity.
The ultimate criterion in this Manual for classifying a substance as
toxic is the degree of hazard that the substance may pose to the health
of laboratory employees. Since persons, in addition to the Director,
Occupational Health and Safety Staff (OHSS), may make this determination,
the Manual includes the sources of the lists and selection criteria for
reference. The lists, which may be added to locally, will be up-dated by
the Director, OHSS, at least annually. The three parts include:
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a. Selected compounds from the National Institute for
Occupational Safety and Health's Registry of Toxic
Effects of Chemical Substances.
b. Carcinogen Assessment Group's List of Carcinogens.
c. Occupational Safety and Health Administration's
List of Regulated Carcinogens.
D. PRIME RESPONSIBILITIES
The following are responsibilities imposed by Executive Order 12196,
29 CFR 1960, and Chapter 8 of the EPA Occupational Health and Safety Manual.
1. Assistant Administrators(AA) and Regional Admim'strators(RA)
Assistant and Regional Administrators are responsible for developing
and implementing a health and safety program for laboratories under their
organizational jurisdiction which use toxic substances. AA's and RA's
must coordinate the development of their health and safety program with
the Director, OHSS, and must submit their health and safety programs to
the Director for review to assure consistency of these programs throughout
the EPA.
The AA for the Office of Administration (OA), as the Designated
Agency Safety and Health Official, is responsible for administering the
EPA's health and safety programs for laboratory use of toxic substances.
The AA for OA must ensure the allocation of adequate resources in the
EPA's Zero Base Budget to support and monitor these programs and must
identify, with designated object class codes, the resources as required
by OMB Circular No. A-ll.
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2. Laboratory Directors
Each Laboratory Director is responsible for implementing the health
and safety program for the laboratory use of toxic substances at their
reporting unit. (See EPA Occupational Health and Safety Manual, Chapter
1, paragraph 5, for a detailed description of health and safety responsi-
bilities). The Laboratory Director is charged with assuring that any
Principal Investigator using toxic substances is qualified by training or
experience, has the equipment and facilities to handle the materials safe-
ly, and proposes a use which is safe to all concerned. The Laboratory
Director is also responsible for assuring the completion of semi-annual
program reviews and audits.
3. The Toxic Substances Committee
The Toxic Substances Committee by order of the Senior ORD official
(ref: see below) is responsible for aiding and advising the Laboratory
Directors on employee health and safety matters and policies and pro-
cedures for the Agency occupational health and safety program for handling
toxic substances in the laboratory. (See EPA Occupational Health and
Safety Manual, Chapter 5, paragraph 4, for a detailed description of the
health and safety responsibilities). The Committee should include or have
access to individuals who possess expertise in chemistry, toxicology,
medicine, engineering, and laboratory safety.
In managing the toxic substances program the Toxic Substances Committee:
a. Reviews and approves Safety Plans prepared by each Principal
Investigator and forwards plans and protocols to the Chief
Safety Officer.
(Memorandum dated January 11, 1978, "Occupational Health and Safety Committee.
D. G. Stephan and W. J. Benoit).
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b. Develops appropriate and timely policies and guidelines to assure
the safety of EPA personnel and protect the general public from
exposures to toxic substances. Such policies and guidelines are
designed on the premises that
. no unwarranted restrictions will be imposed on project operations
or on the selection and use of any type or amount of toxic substance(s);
and
. all means of preventing contamination of equipment and facilities
used in low level experiments will be taken.
c. Advises the Laboratory Directors on proposed use(s) of toxic
substances prior to the acquisition or use of such substances.
d. Acts as a Review Board in matters of health and safety as related
to use of toxic substances and advises the Laboratory Directors
on approval/disapproval of proposed projects in which these
materials are to be used.
e. Acts as a Board of Inquiry in toxic substances spills and
accidents that result in exposures. (The Committee may
investigate accidents irrespective of exposure potential.)
f. Advises the Laboratory Directors on specific programs for Health
Surveillance.
4. Chief Safety Officer
The Chief Safety Officer, appointed by the Director of Administration,
provides advice and assistance to the Laboratory Directors in developing,
organizing, directing, and evaluating their health and safety programs for
laboratory use of toxic substances. In addition, the Chief Safety Officer
must:
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a. Approve all requisitions for toxic materials and ensure that an
approved Toxic Substance Safety Plan is available and a Material
Safety Data Sheet accompanies the requisition.
b. Maintain inventories of specified toxic and hazardous materials.
c. Coordinate the reporting of any accident involving exposure
(inoculation, ingestion, dermal contact, or inhalation) to a
toxic substance, in accordance with the procedures detailed
in Chapter 3 of the Occupational Health and Safety Manual.
In addition, a copy of this type of accident report must be
incorporated in the employee's medical record.
d. Coordinate record keeping and medical monitoring programs.
e. Serve on Toxic Substances Committee.
f. Establish a system for safe disposal of toxic substances and
contaminated residues.
g. Keep Laboratory Safety Officers informed of bulletins and special
programs issued by the OHSS.
5. Laboratory Safety Officer
The Laboratory Safety Officer, appointed by the individual Laboratory
Directors, serves as a member of the Toxic Substances Committee and in
this capacity has the primary responsibility for carrying out the essential
features of the toxic substances control program at the laboratory level.
Thus, he:
a. Ensures overall safety in the handling and use of toxic substances.
b. Enforces regulations and policies in all matters pertaining to
toxic substances.
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c. Maintains records on inventory and history of all toxic sub-
stances from time of arrival to final disposition.
d. Supervises disposal of all toxic substances and wastes.
e. Directs and assists in survey and decontamination activities
required following an uncontrolled release or accident.
f. Maintains and posts current list of personnel authorized access
to controlled limited access areas.
g. Makes documented inspections of storage and working areas to
ensure compliance with established procedures.
h. Coordinates accident reporting and record keeping.
i. Distributes manuals, pamphlets, and memoranda to personnel as
required on toxic substances practice and procedures and main-
tains the timeliness of such information by referral to current
periodicals, Chemical/Environmental Log Sheets, and the literature.
6- Principal Investigator
The Principal Investigator on a project in which toxic substances
are used:
a. Prepares a written Safety Plan for all projects prior to the
use of toxic substances. (See Appendix B for details of the
Toxic Substance Safety Plan.)
b. Selects work practices and engineering controls for handling
toxic substances.
c. Submits the Safety Plan to the immediate Supervisor, Chief Safety
Officer, Laboratory Director, and Toxic Substances Committee for
approval.
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d. Makes available to program and support staff copies of the
appoved Safety Plan.
e. Assures that the program and support staff (including mainte-
nance and housekeeping personnel) are instructed in procedures
to avoid accidental exposure to toxic substances.
f. Supervises the safety performance of the staff to ensure that
the required laboratory practices and engineering controls are
emp1oyed.
g. Arranges for immediate medical attention and reports to the
Chief Safety Officer any accident that results in (1) inoculation
of toxic substances through cutaneous penetration, (2) ingestion
of toxic substances, (3) probable inhalation of toxic substances,
or (4) any incident causing overt exposure to personnel or danger
of environmental contamination by toxic substances.
h. Cooperates in the occupational program on medical surveillance
activities.
i. Reports to the Laboratory Safety Officer the location of work
areas where toxic substances will be used, provides a current
listing of personnel authorized to work in these areas, and
provides a current inventory of working quantities of toxic
substances that will be kept in these areas.
j. Assists the Chief Safety Officer in investigating accidents.
k. Investigates and reports in writing to the Chief Safety Officer
problems pertaining to operation and implementation of laboratory
practices and engineering controls.
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1. Corrects work errors and conditions that may result in the
release of toxic substances.
7. EPA Employees
Each employee is responsible for complying with the health and
safety program established by this Manual on the laboratory use of toxic
substances. Each employee shall report to his/her supervisor any unsafe
condition and all facts pertaining to accidents which result in employee
exposure to toxic substances.
8. Director, Division of Occupational Health and Safety
Under the supervision of the Assistant Administrator for Administration
the Director, OHSS, is responsible for reviewing and coordinating the
health and safety programs developed for laboratory use of toxic sub-
stances for consistency with this Manual. The Director also audits the
laboratories for compliance with their health and safety program, informs
the responsible EPA official of any problem areas, annually updates the
lists of toxic substances presented in Appendix A, provides technical
support, and approves training courses. The Director, OHSS, is the top
technical advisor for EPA on health and safety for laboratory use of
toxic substances.
9. Other Responsibilities
The individuals specified above, and other individuals, have
responsibilities for this program which are described in relevant sections
of the balance of this Manual. (See Appendix C for names of individuals
specified above.)
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II. HEALTH AND SAFETY PROGRAM
A. SAFETY PLAN
The Toxic Substance Safety Plan is a principal means of control in
the use and disposition of toxic substances.
1. Prior to any project or operation involving a toxic substance
the Principal Investigator must prepare a Toxic Substance
Safety Plan. A sample plan is included as Appendix B.
2. The Toxic Substance Safety Plan must be reviewed by the
Laboratory Safety Officer.
3. Approval of the Safety Plan by the immediate Supervisor,
Laboratory Director, Chief Safety Officer, and Toxic Substances
Committee is required.
4. The Chief Safety Officer must maintain the Safety Plan on file
and make it available for distribution. A copy must be provided
to each employee using the toxic substance and an information
copy must be forwarded to the Director, OHSS, Washington, D.C.
(PM-273).
B. INVENTORY CONTROL
1. The Chief Safety Officer must approve all purchase requisitions
for toxic substances. Whenever possible, existing inventories
must be used in order to maintain a minimum of toxic substances
in storage. The Laboratory Director, after consulting with the
Chief Safety Officer, may add to the list of toxic substances
presented in Appendix A for his/her reporting unit. The
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Chief Safety Officer subsequently monitors and records the receipt,
transport, storage, use, and disposal of the newly listed toxic
substances. The Chief Safety Officer must update the inventory
at least semi-annually, and must obtain, maintain, and distribute
safety data sheets and other information needed to use toxic
substances safely.
2. The Laboratory Safety Officer must maintain records, to be up-
dated semi-annually, indicating all types and amounts of toxic
substances in storage and in use for the reporting unit. Semi-
annual reports of the inventory will be provided to the Chief
Safety Officer as a basis for a semi-annual report to the OHSS
for all of EPA-Cincinnati.
3. The Principal Investigator or other authorized user of a toxic
substance must maintain a continuous and current record of each
controlled substance in his/her possession from the time of
acceptance to its final disposition or depletion.
a. The Chief Safety Officer in cooperation with the
Laboratory Safety Officers will use this information
to produce an automatic inventory listing or a manual
system, depending on the number of entries for distri-
bution to the user/storage areas. Appendix D shows a
sample Toxic Substance Chemical Inventory Sheet and a
Toxic Substance Running Inventory Usage Sheet. An
initial inventory is prepared by using the Toxic
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Substance Inventory Sheet for all compounds listed
in Appendix A. A separate Toxic Substance Running
Inventory Usage Sheet is filled out for each toxic
compound. Inventory records and reports are based
on the current amount on hand as listed in the last
column of the usage sheet.
C. MEDICAL SURVEILLANCE
1. Preassignment Health Assessment
The Laboratory Director must ensure that a baseline health assess-
ment is provided to all employees who work with toxic substances or who
are assigned duties in work areas where toxic substances are regularly
used. These health assessments are provided under the EPA Medical
Monitoring Guidelines. The Laboratory Director, after consultation
with an occupational physician, the Chief Safety Officer, and the medical
monitoring coordinator, must also determine the necessity of providing
preassignment health assessments for employees who may be assigned
duties in work areas where small quantities of toxic substances are
infrequently used.
The purpose of this preassignment assessment is to establish a
baseline health record and, if evidence of preexisting or predisposing
conditions is found, to inform and counsel the employee on the inadvisa-
bility of working in areas where toxic substances are used. The pre-
assignment assessment will include a work history, a medical history,
and a physical examination, which includes customary laboratory studies
and agent-specific studies when appropriate.
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2. Periodic Health Assessments
The Laboratory Director must ensure that periodic health assessments
are provided to all employees who work with toxic substances or who are
assigned duties in work areas where toxic substances are regularly
used. The periodicity and content of these assessments must be deter-
mined after consultation with an occupational physician, the medical
monitoring coordinator, and the Principal Investigator.
The assessments will include an updating of the employee's work
and medical histories, including occurrences of any accidental exposures
previously unreported. The following information must be included in
the employee's medical record: names of toxic substances to which the
employees may have been exposed, information on the probability, frequency,
and extent of exposures, and any environmental measurements relating
to toxic substances that may have been made. The periodic health
assessment may also include a physical examination, biochemical or
other surveillance of body fluids, and an evaluation of pertinent
functional systems of the body. (See Appendix E.)
D. RECORDS
The EPA-Cincinnati Medical Services Staff, selected by the Director
of Administration, will maintain health assessment records during the
tenure of the employee's service with the Agency.
1. Upon termination, including retirement or death, of the
employee, the medical records will be maintained for at least
thirty (30) years after the employee's last work with toxic
substances, and in a manner that will ensure ready access as
needed by the health program of the Agency.
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2. Records that cannot be maintained locally will be placed in
custody of the Medical Monitoring Project Officer, OHSS,
Washington, D.C.
E. TRAINING
The Laboratory Director must ensure that all employees subject to
potential exposure to toxic substances are provided adequate health
and safety instruction and training.
1. The Principal Investigator, with assistance from the Laboratory
Safety Officer, the Chief Safety Officer, and the Toxic Substances
Committee, will ensure that laboratory workers receive adequate training
(followed by appropriate refresher courses annually) in the following
topics as applicable:
a. The possible sources of exposure to toxic substances
b. Carcinogenic and other adverse health effects associated
with such exposure
c. Work practice and engineering controls to limit exposures
d. Methods used to monitor control procedures and the health
status of employees
e. Responsibilities in proper work practices to protect fellow
employees
f. Types and functions of monitoring equipment such as personal
samplers
g. Medical monitoring methods, especially unusual procedures
such as sputum cytology and biologic monitoring of metabolites
in the urine
h. Benefits to persons participating in environmental and
medical monitoring programs.
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2. The Chief Safety Officer must obtain the approval of the Director
OHSS, of the initial training and refresher courses and must issue a
certificate to employees upon completion of the courses.
3. The Chief Safety Officer and Principal Investigator (and, if
warranted, professional instructors on the subject) will train all
persons who work with or may be exposed to a specific toxic substance,
to enable them to work safely with and to understand the relative
significance of potential hazards as they relate personally. This
training will include:
a. The safe handling of the specific substance, including
emergency procedures
b. A non-technical summary of the nature and extent of
potential hazards, with periodic refresher review
c. ' A procedural review of an actual project in which the
discussed toxic substance will be used.
4. The Chief Safety Officer will instruct warehouse and stock-
room personnel in the safe handling of toxic substances, including:
a. Special handling of containers to avert damage by dropping,
improper stacking, or inadequate environmental controls.
b. The possibility and effects of exposures.
c. Segregating chemicals into safe groupings during storage.
5. The Laboratory Director must ensure that employees identified
to respond to emergencies involving toxic substances receive additional
training, repeated at least annually, which includes directing general
evacuation, decontamination of uncontrolled releases of toxic substances,,
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maintaining a respirator program at least equivalent to 29 CFR 1910.134,
using other personal protective equipment, first aid, and CPR.
6. 'The Chief Safety Officer must keep the Safety Plan, safety
data sheets, and other appropriate written information describing the
relevant toxic, physical, and chemical properties of toxic substances
used or stored in the laboratory, in a file that is continuously and
readily available to employees.
F. AUDIT
The Laboratory Director must ensure that semi-annual program reviews,
including inspections, of the health and safety program for laboratory
use of toxic substances are conducted by persons with appropriate back-
ground and training and that any deficiencies are corrected as soon as
possible (or immediately if the deficiency is an imminent hazard). The
Laboratory Director must forward a copy of the program review and abate-
ment actions to the Director, OHSS, for review. The Director, OHSS,
will conduct independent audits to evaluate compliance with the health
and safety program.
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III. ENGINEERING CONTROLS AND WORK PRACTICES
A, CONTROL STRATEGY
The purpose of this section is to describe situations in the
handling of toxic substances where different levels of safeguards are
specified to protect the laboratory worker. Any modification to the
laboratory practices and engineering controls described must be care-
fully considered and reviewed by the Principal Investigator, the Chief
Safety Officer, and the Toxic Substances Committee.
The hazard in working witHi toxic substances is a function of the
exposure potential and the toxicity of these substances. The risk of
exposure to a toxic substance is related, among other things, to the
quantity and physical properties of material used and the nature,
frequency, and complexity of the experimental procedure. There is a
greater risk of exposure when working with 100 mg of material than
with 1 mg of material. Similarly, the potential for exposure is greater
during blending, preparation of dry feed mixture, and in the manipulation
of powders than during the preparation of aliquots of stock solution.
The toxicity and carcinogenic potency are also important factors
in the selection of safeguards. For example, experimental data suggests
that the carcinogenic potency of aflatoxin Bl is magnitudes greater
than that of chloroform.
Based on the factors just discussed a three-level control system
will be used for laboratory operations at EPA-Cincinnati. Specific
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control practices for each laboratory operation will be spelled out in
detail in the individual Safety Plans submitted by the Principal Investi-
gator on a case-by-case basis. General guidelines which apply to all
projects for both use and storage of regulated substances will now be
defined for each list of compounds in Appendix A. The strategy for
control of specific toxic compounds is as follows:
COMPOUNDS RISK STORAGE USE
List 1 Low Low Laboratory Cabinet Unrestricted
I i<;t 7 TnfprmpdiatP I imitpH Arrpcc Arp;» ^ w/w Concentration
List i intermediate Limned Access Area Limit Jn Non.controlled
Area
List 3 High Carcinogen Dilution ,
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Stock quantities of compounds must be maintained in a secured and
appropriate storage area when not in use. Locked laboratory cabinets,
labeled with a sign bearing the legend: CAUTION - TOXIC SUBSTANCE, are
required. Compounds controlled at this level are those contained on List 1
entitled "NIOSH's Registry of Toxic Effects of Chemical Substances".
(See Appendix A.)
2. Intermediate Risk Situation
More stringent safeguards are required for certain research investi-
gations that present higher risk situations than those subject to the
general requirements. More stringent requirements may also be required
for research activities that involve highly potent toxic substances. The
toxic substances and laboratory activities for which additional controls
are required will now be described.
Any laboratory operation involving the use of a compound contained
on the Carcinogen Assessment Group's (CAG) List of Chemicals Having
Substantial Evidence of Carcinogenicity (see List 2, Appendix A) requires
additional engineering controls.
a. Stock quantities of compounds in this category must be stored
in a limited access area. All weighing and dilution procedures
necessary to provide daily working quantities must be done by a
qualified person under controlled conditions in the limited
access area. Limited access areas are specially designed modules
for storage and use of toxic substances. These modules must be
locked at all times. Upon entering or leaving a limited access
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area a sign-in/sign-out record book must be signed by each
user. In addition, the facility must provide the following:
a laboratory hood, glove box, sink, refrigerator (explosion-
proof preferred), locked storage cabinets, an analytical
balance, mechanical pipetting aids, disposable laboratory
coats, and plastic or latex gloves. Location of all limited
access areas are listed in Appendix F.
b. The maximum allowable concentration permitted in non-controlled
areas is 1.0% by weight or volume.
c. Organic solvents on the CAG list are permitted in normal
laboratory modules for experimental purposes but not for
storage. The level of written approval required is based on
the quantity needed for laboratory operations as follows:
Principal Investigator <_! Liter
Branch Chief <_5 Liters
Toxic Substances Committee <^5 Liters
d. The preparation of dilute solutions or the removal of small
amounts of a toxic substance from stock quantities must
always be performed within a laboratory fume hood or glove
box. The work surfaces of the hood must be covered with stain-
less steel or plastic trays, dry absorbent plastic-backed paper,
or other impervious material.
e. Each person using the "limited access area" must sign in and
sign out in a permanent log book posted inside the area.
f. Only persons with approved Safety Plans can use the "limited
access areas".
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3. High Risk Situations
All laboratory procedures that involve the use of an OHSA regulated
chemical carcinogen (see OSHA's List of Regulated Carcinogens, List 3,
Appendix A) require work practices and engineering controls in addition to
those previously discussed. These include: additional or more frequent
changes of protective clothing, shower facility and change room, use of
primary containment devices, work area access control, and monitoring for
environmental contamination resulting from certain laboratory operations.
Protective clothing such as disposable pants, shirts,.jumpsuits, shoe and
head covers, and plastic and latex gloves must be worn as appropriate.
Showers are recommended after each exit from the work area.
Special facilities are required for handling carcinogens. The module
for carcinogen handling must have a separate hood exhaust and a glove box or
other completely closed containment system. Work areas must be separated by
a. controlled access area from areas that are open to unrestricted traffic
flow. This controlled access area may be an anteroom, a change room, an air
lock, or any other door arrangement that separates the laboratory from areas
of unrestricted traffic flow. Areas which meet these requirements are
called Carcinogen Dilution Modules. EPA-Cincinnati has two modules that
meet the above requirements. (See Appendix F - Location of Carcinogen
Dilution Modules and Limited Access Areas). Laboratories which do not have
a Carcinogen Dilution Module must obtain permission from the appropriate
Laboratory Director for the use of the existing facilities or must construct
an equivalent facility of their own for laboratory operations that involve
the storage or handling of any OSHA regulated chemical carcinogens.
Additional requirements and considerations for the high risk situation
include the following:
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a. Stock quantities of toxic substances must be the minimum quantity
required for efficient use; the primary containers must be stored
in an unbreakable outer container. Containers may consist of
plastic-coated glass bottles with polypropylene caps, both of
which can satisfy a 4-foot drop test.
b. The maximum allowable concentration of these materials permitted
in a non-controlled area is 0.1% by weight or volume.
c. Environmental monitoring may be required in work areas where the
potential of exposure to a known potent toxic substance is great.
An example of such an area might be a dry feed mixing operation
where a large amount of the toxic substance is handled in an
activity that can produce significant'amounts of aerosol.
B. REQUISITIONING
The following procedures reflect Office of Research and Development
procedures and Toxic Substances Committee recommendations for controlling
toxics substances:
1. To requisition toxic chemicals, complete Standard Form EPA-
1900-8 (Rev. 12/80).
2. Prior to authorizing the requisition by signing the EPA-1900-8
form, the Principal Investigator will ensure that an approved
Safety Plan is available for using the chemical and that the
chemical is not available from existing inventories.
3. The Program Administrative Officer will forward the requisition
to the Chief Safety Officer for final approval before the chemical
is ordered. Existing inventories should be checked prior to approv-
ing any requisition for toxic substances. Receiving warehouse
personnel will be informed of special handling procedures to be
used when the substance arrives.
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C. RECEIVING
Receipt of all toxic substances and/or samples delivered to EPA-
Cincinnati must be recorded on the Toxic Chemical/Environmental S_ample
Log Sheet (see Appendix D). A copy of each Log Sheet will be forwarded
to the Chief Safety Officer at the end of each quarter.
1. Persons receiving or carrying toxic substances into the EPA-
Cincinnati facilities outside the normal shipping and mailing
channels will, immediately on arrival of such materials,
notify their Division Directors. The materi-al must not be
opened or handled until inspected and logged by the appropriate
Division Director or Branch Chief or an authorized representative.
2. Prior to delivery to the requisitioned any toxic substance
listed in Appendix A, must be inspected, logged, and approved
for dispersal by the Laboratory Safety Officer or designee.
a. Log-in entails recording the required information on the
Toxic Chemical/Environmental Sample Log Sheet.
b. Inspection entails removal of the toxic substance/sample(s)
from the shipping container, checking for evidence of
physical damage, leakage, or other possible external
contamination.
3. On release of the requested material, the material will be
placed in the proper storage area (as defined in Section III A).
D. PACKAGING AND SHIPPING
Toxic substances must be packaged to withstand shocks, pressure
changes, and any other conditions which might cause the leakage of
contents incident to ordinary handling during transportation.
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The transfer of any toxic substance or mixture of substances
from EPA-Cincinnati for any purpose shall meet the requirements for
monitoring, packaging and labeling of the U.S. Department of Transportation
(DOT), as described in Title 49, Code of Federal Regulations, and shall
be further in compliance with the regulations governing the shipment of
such materials as required by the Interstate Commerce Commission, Federal
Aviation Agency, Bureau of Explosives, U.S. Coast Guard, and as appro-
priate for the mode of transportation and recipient. For more extensive
detail see "Final National Guidance Package for Compliance with DOT
Regulations in the Shipment of Environmental Laboratory Samples" available
from Laboratory or Chief Safety Officer. (See Appendix G.)
E. DISPOSAL
All EPA-Cincinnati toxic wastes will be disposed of through a com-
mercial contract disposal agency.
1. Principal Investigators will arrange through the Laboratory
Safety Officer for disposal of toxic wastes resulting from
their projects. The Principal Investigator must:
a. Convert very hazardous wastes into lesser hazardous
substances, if possible, before placing them in
disposal containers. For example, oxidize strong
carcinogens in solution; neutralize acids; or moderate
reactions by dilution, cooling, or slow addition of a
neutralizing agent. For water-miscible materials,
pouring the reaction mixture onto a bed of ice can
often cool and dilute it.
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b. Promptly dispose of unlabeled containers and chemicals no
longer needed. We must not allow excess chemicals or
wastes to accumulate in the laboratory.
c. When a toxic substance listed in Appendix A, List 3, has
been used, decontaminate or dispose of all equipment,
residual labware, toweling, gloves, dishwater, and other
materials that have been in contact with the substance as
specified in the Safety Plan.
F. FACILITY REQUIREMENTS
1. Handwashing Facility. A handwashing facility must be available
within the work area. (This need not be a facility used exclusively for
handwashing). The use of liquid soap is recommended. In new facilities,
foot or elbow operated faucets should be provided.
2. Shower Facility. A shower facility, other than emergency drench
showers, must be located in the building in which toxic substances are
used. The shower facility must be available at all times. Shower
facilities adjacent to the work areas are highly recommended.
3. Eye Wash Facility. An emergency eye wash facility must be located
in each laboratory. The eye wash facility should be designed to wash
both eyes at the same time with a continuous stream of potable water.
4. Exhaust Air from Primary Containment Equipment. The exhaust air
from glove boxes must be treated by filtration, reaction, absorption,
adsorption, electrostatic precipitation or incineration, as appropriate,
depending on the nature of the compound. The need for, and type of,
treatment for other primary containment equipment, including laboratory
fume hoods and biological safety cabinets, must be determined by the
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Chief Safety Officer. Exhaust air treatment systems that remove toxic
substances from the exhaust air by collection mechanisms such as filtra-
tion, absorption,and adsorption must be serviced in a manner that avoids
direct contact with the collection medium. Trained maintenance employees
may remove the spent collection medium with a bag-in/bag-out collection
system or garbed in appropriate personal protective clothing and equip-
ment. All exhaust air from primary containment equipment must be dis-
charged by roof-mounted blowers to the outdoors so' that such air is
dispersed clear of occupied buildings and air intakes.
5. Exhaust Ventilation. A mechanical exhaust ventilation system
must be provided for controlling laboratory room air movement. The
movement of air must be from areas of lower contamination potential to
areas of higher contamination potential (i.e., from entry corridors to
the laboratory). This directional air flow may be achieved by a common
building exhaust system, provided that the exhaust air is not recirculated
to any other area of the building. The exhaust air from laboratory areas
must be discharged outdoors in a way that entry into a building's air
supply is minimized. Exhaust air from laboratory areas which is not
derived from primary containment equipment can be discharged to the out-
doors without being treated.
G. OPERATIONAL PRACTICES
1. Work Area Identification. Entrances to all work areas where
toxic substances are being used or stored must be posted with signs
bearing the legend: "CAUTION - TOXIC SUBSTANCE - Authorized Persons
Only", followed by the name of Principal Investigator.
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2. Access Control. Work areas where toxic substances are used or
stored may be entered only by persons authorized by the Principal Investi-
gator. Access doors to work areas must be kept closed while experiments
with toxic substances are in progress.
3. Work Surfaces. All work surfaces (bench tops, hood floors, etc.)
on which toxic substances are used must be covered with stainless steel or
plastic trays, dry absorbent plastic-backed paper, or other impervious
material. The protective surfaces must be examined for possible contami-
nation immediately after each procedure with a toxic substance has been
completed. Contaminated surfaces must be decontaminated or disposed of
as described in the Safety Plan.
4. Use of Primary Containment Equipment. Procedures involving
volatile toxic substances and those involving solid or liquid toxic sub-
stances that may result in the generation of aerosols must be conducted
in a laboratory fume hood, a glove box, or other containment equipment
approved for toxic substances by the Chief Safety Officer. Examples
of aerosol-producing procedures are: the opening of closed vessels,
transfer operations, weighing, preparation of feed mixtures, and the
application, injection or intubation of a toxic substance into experi-
mental animals. Tissue culture and other biological procedures involv-
ing toxic substances may be conducted in a Class II Type A or B bio-
logical safety cabinet when approved by the Toxic Substances Committee.
(Personnel protection factors for Class II biological safety cabinets
have not yet been established; however, when installed with total
exhaust, these devices are currently acceptable for tissue cultures
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-29-
and other biological procedures involving toxic substances.) The selection
and use of a Class II biological safety cabinet for procedures involving
toxic substances must be a joint decision of the Principal Investigator
and the Chief Safety Officer. Primary containment equipment used for con-
tainment of toxic substances must display a label bearing the legend:
CAUTION-TOXIC SUBSTANCE. All bidding documents and installation plans for
primary containment equipment must be reviewed by Facilities Management and
Services Division prior to procurement. (See Appendix H for additional
information on primary containment equipment).
5. Use of Analytical Instrumentation. Toxic vapors or aerosols pro-
duced by ana-lytical instruments must be captured through local exhaust
ventilation or appropriate trap at the site of their production. The
instruments may be placed entirely within a laboratory fume hood if this
will not impair hood performance (i.e., towards the back and raised on
legs to minimize turbulence of inflowing air). When a sample is removed
from the analytical instrument, it must be placed in a tightly stoppered
sample tube or otherwise safeguarded from contaminating the laboratory. In
the event that the analytical equipment becomes contaminated, it must be
labeled "CAUTION - TOXIC SUBSTANCE" until it has been completely decon-
taminated. This operational practice applies to analytical equipment even
when only infrequently used for toxic substances.
6. Use of Respirators as Personal Protective Devices. A respirator
use program must be provided for emergency and maintenance personnel who
enter areas where a potential for inhalation exposure to a toxic substance
is present. This program will meet the requirements of the OSHA General
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-30-
Industry Standards for respiratory protection as detailed in 29 CFR 1910.134.
The respirators must be certified in accordance with the requirements of
the National Institute for Occupational Safety and Health (NIOSH) under
the provisions of 30 CFR Part 11. The selection and use of respirators
must be approved by the Chief Safety Officer.
7. Storage Inventory and Identification. Stock quantities of toxic
substances must be stored in a specific storage area that is secured at
all times. The storage area must be posted with a sign bearing the legend:
CAUTION - TOXIC SUBSTANCE - Authorized Personnel Only. Principal Investi-
gators must maintain inventory records of toxic substances for which they
are individually responsible and must provide copies to the Chief Safety
Officer. The inventory records must include the quantities of toxic sub-
stances acquired and dates of acquisition and disposition. Storage vessels
containing stock quantities must be labeled: CAUTION - TOXIC SUBSTANCE.
Additional storage precautions may be required for compounds with properties
such as flammability, radioactivity, etc.
8. Working Quantities. Quantities of toxic substances present in
the work area must not exceed the amounts required for use in one week or
the limits set by III. A. This does not include amounts stored in a
specific toxic substance storage area or cabinet that is located within
the laboratory work area. Storage vessels containing working quantities
must be labeled: CAUTION - TOXIC SUBSTANCE.
9- Laboratory Transport. Storage vessels containing toxic sub-
stances must be placed first in an unbreakable outer container before
being transported to the laboratory work areas. Good standard transfer
practices must be used. Freight elevators must be used to transfer
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-31-
regulated substances from one floor to another. Plastic-coated glass
bottles with polypropylene caps, which can satisfy a 4-foot drop test,
are currently available and can serve as both the storage vessel and
the unbreakable outer container combined. Contaminated materials which
are transferred from work areas to disposal areas must first be placed in
a closed plastic bag or other suitable impermeable and sealed primary con-
tainer. The primary container must be placed in a durable outer container
before being transported. The outer container must be labeled with both
the name of the toxic substance and the warning: CAUTION - TOXIC SUBSTANCE.
10. Housekeeping. General housekeeping procedures which suppress
the formation of aerosols, such as the use of a wet mop or a vacuum cleaner
equipped with a High Efficiency Particulate Aerosol (HEPA) filter to remove
particulates, must be used. Dry sweeping and dry mopping are prohibited
because of the hazard of aerosol formation. Training of personnel in
appropriate cleaning techniques to avoid or minimize exposure is the
responsibility of the Principal Investigator. In those instances where
the toxic substance or contaminated material is spilled, special pro-
cedures developed for the individual compounds must be followed as
described in the approved Safety Plan.
11. Protection of Vacuum Lines. Each vacuum service, including
water aspirators, must be protected with an absorbent or liquid trap and a
HEPA filter to prevent entry of any toxic substance into the system. When
using a volatile toxic substance, a separate vacuum pump or other device
approved for toxic substances must be used.
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12. Decontamination. Contaminated materials must either be decon-
taminated by-procedures that decompose the toxic substance to produce a
safe product or be removed for subsequent disposal. Toxic substances
which have spilled out of a primary container so as to constitute a hazard
must be inactivated in situ or must be absorbed by appropriate means for
subsequent disposal. Adequacy of clean-up must be tested with wipe-test
or fluorescence tests or by other appropriate means as described in the
Safety Plan.
13. Handling and Disposal. Prior to the start-of any laboratory
activity involving a toxic substance, plans for the handling and ultimate
disposal of contaminated wastes and surplus amounts of the toxic sub-
stance must be completed. Principal Investigator and Chief Safety Officer
should jointly determine the best methods available that are in com-
pliance with Federal, State and Local codes and ordinances.
H. PERSONNEL PRACTICES
Each laboratory worker must observe the following rules:
1. Precautionary Considerations
a. Know the safety rules and procedures that apply to the
work you are doing; make note of the appropriate safety
precautions and potential hazards before beginning any
operation.
b. Review the applicable emergency procedures; know where the
emergency equipment is located in your area, how to use it,
and how to obtain help in an emergency.
c. Assure the availability of the proper protective equipment
and use the proper type for each operation.
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d. Be alert to unsafe conditions and actions and have them
promptly corrected. Someone else's accident can be as
dangerous to you as any you- might have.
e. Remain out of the area of a fire or personal injury
unless it is your responsibility to help meet tee
emergency.
2. Protective Clothing
A two-level control system for laboratory coats is required. A
fully fastened color-coded laboratory coat must be worn by all employees
working in laboratories with controlled toxic substances. These color-
coded laboratory coats must not be worn outside the toxics work area. A
fully fastened white laboratory coat must be worn by visitors (including
fellow employees) in laboratory areas where toxic substances are used or
stored. It is common for visitors to toxic work areas to accidentally
brush against presumedly decontaminated work benches or to unconsciously
rest against them. Since it is unlikely that visitors to toxic work
areas can be prevailed" upon to remove laboratory coats when leaving
toxic work areas and again to put them on each time they return, the
standard white laboratory coat may also be worn outside the toxic work
area. Thus, the white laboratory coat is protection for street clothes
in laboratory areas. Its major purpose is to reduce the probability of
taking contamination from the laboratory to the home environment. The
use of the white laboratory coat reflects an awareness by those respon-
sible for safety that such a coat in non-controlled areas no more suggests
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-34-
contamination than street clothes in the same areas suggests freedom
from contamination. The white laboratory coat should not be worn in the
cafeteria, library, conference rooms, auditorium or other common meeting
places.
Clothing contaminated by toxic substances must be decontaminated or
disposed of immediately after an obvious exposure. Contaminated clothing
must not be sent to the laundry until decontaminated. In situations
where decontamination is not feasible, clothing must be disposed of in an
appropriate manner. Gloves which are appropriate to the specific situ-
ation must be used when handling toxic substances. Disposable gloves may
be used only once and then must be discarded into a properly labeled con-
tainer. Such gloves must be discarded immediately after known contact
with a toxic substance.
3. Pipetting
Mechanical pipetting aids must be used for all pipetting procedures.
Oral pipetting is prohibited.
4. Eye Protection
Safety glasses must be worn by all workers and visitors in all
laboratory work areas. Contact lenses shall not be worn in any laboratory
work area.
a. It is the responsibility of the laboratory supervisor or
the Principal Investigator to determine what additional eye
protection may be required for a particular operation.
5. Personal Conduct
a. Personal hygiene must be maintained; fingernails must be short
and clean; hands and arms must be washed thoroughly before
handling any object that goes to the mouth, nose or eyes, and
before leaving the laboratory.
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b. Toxic materials may not be handled by personnel with a break in
the skin below the wrist, unless the wound is so protected that
no toxic material can gain access; the break must be covered with
adhesive tape and appropriate rubber or vinyl gloves must be
worn.
c. There must be no eating, drinking, chewing gum or tobacco,
smoking, and applying cosmetics while working in areas where
toxic substances are in use; refrigerators in such areas must
not be used for storing food or beverages.
d. Distracting or startling other workers must be avoided;
practical jokes or horseplay cannot be tolerated at any time
in the laboratory.
6. Housekeeping
a. Laboratories where toxics are handled must be kept neat
and clean; clean-up procedures are required upon completion
of each operation at the end of each day.
b. Work areas must be free of equipment and material not required
for the immediate operation.
c. All chemicals must be correctly and clearly labeled and stored;
warning signs are required when unusual hazards exist such as
radiation, laser operations, flammables, biological hazards,
or other special concerns.
d. Applicable waste disposal procedures must be followed; chemical
reactions may require traps or scrubbing devices to prevent
the escape of toxic gases.
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e. Exposure to toxic vapors, mists, gases, and dusts must be
minimized by preventing the escape of such materials into the
working atmosphere; adequate ventilation must be ensured by
use of exhaust hoods and other local ventilation.
f. Equipment must be used only for its designed purpose.
g. Reaction apparatus must be carefully positioned and clamped
to permit manipulation without the need to move the apparatus.
h. Reagents must be combined in appropriate order; avoid adding
solids to hot liquids.
7. Personal Monitoring
Each person is responsible for ensuring that his person, clothing,
shoes, laboratory equipment, and work area surfaces are kept free of
contamination. Before leaving the laboratory for even short periods,
contaminated clothing must be removed; showering will also be mandatory
before leaving the laboratory for lunch and at the end of the day when
highly toxic materials are being used by anyone in the laboratory. (When
in doubt concerning the degree of toxic substance hazard present, consult
the Chief Safety Officer for advice and assistance.)
8. Working Alone
Generally, it is prudent to avoid working in a laboratory building
alone. Arrangements should be made with persons working in nearby
laboratories to cross check periodically, especially during irregular
working hours. (The Security Guard can be asked to check on conditions
periodically.)
a. Experiments known to be hazardous should not be performed by an
unaccompanied laboratory worker.
b. The laboratory Supervisor or Principal Investigator is respon-
sible for determining when two or more persons are required.
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IV. ADDITIONAL REQUIREMENTS FOR ANIMAL EXPERIMENTATION
INVOLVING TOXIC SUBSTANCES
All work practice and engineering controls specified in this Manual
apply to animal experimentation when toxic substances are used. Addition-
ally, animal care personnel must wear a completely closed jumpsuit or
undergo a complete clothing change including laboratory-issue shoes or
booties, head cover, and gloves. Clean clothing must be provided daily or
/
more frequently when needed. Animal care personnel engaged in pro-
cedures where exposure to airborne particulates contaminated with toxic
substances could occur must use appropriate respiratory protection. The
selection and use of an appropriate respirator must be approved by the
Chief Safety Officer. The face mask or respirator must not be worn
outside the animal room. Used filters must be disposed of, the respi-
rator housing must be decontaminated daily, and the respirator must be
stored in a clean location. Personnel required to wear respirators must
shower after completion of procedures that may result in the creation of
airborne contamination in the animal room.
Experimental animals must be housed in cage systems that confine
feed, feces, urine, and bedding within the enclosure. When a volatile
toxic substance is used, the cage must be appropriately sealed or venti-
lated to prevent evolution of contaminants. Alternative animal housing
methods must be approved by the Chief Safety Officer.
The Safety Plan prepared for animal studies must include descriptions
of the proposed animal housing methods, safeguards appropriate for dose
preparation and challenge procedures, procedures for bulk storage and
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-38-
disbursement of test material, waste management practice, and personnel
protection requirements. An operations manual must be prepared for
facilities in which large-scale animal studies and inhalation challenge
studies are conducted. Equipment use procedures for all inhalation
challenge studies must be described in detail.
All animal use must comply with the Animal Welfare Act, Public Law
89-544, 1966, amended in 1970 and 1976 (P. L. 91-579 and P. L. 94-279)
and must conform with the Guide for the care and use of Laboratory
Animals, DHEW No. 78-23, revised 1978 or succeeding editions.
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V. EMERGENCY PROCEDURES
Emergencies will generally be in the nature of spills, fires,, or
explosions, which may result in the spread of toxic material. Since it
is not possible to devise a set of rules or procedures to govern all
possible emergencies, the following considerations are presented only as
a guide to aid the user in establishing more specific emergency procedures
applicable to his working conditions.
NOTE
All employees are responsible for reporting any accidental
spill of a toxic substance and accidents involving potential
exposure (inoculation, ingestion, dermal contact, inhalation)
to the Chief Safety Officer and the Principal Investigator.
The Principal Investigator must follow up to ensure that the
Chief Safety Officer is notified. The Chief Safety Officer will
coordinate the accident-reporting requirements and the clean-up
procedures.
A. MINOR SPILLS INVOLVING MINIMAL TOXIC HAZARDS TO PERSONNEL
1. Notify all other persons in the room at once and, before proceeding
with the cleanup, notify the Chief Safety Officer.
2. Confine the spill immediately.
3. Permit into the area only the minimum number of persons
required to deal with the spill.
a. Liquid spills:
(1) wear protective gloves
(2) place absorbent paper on the spill
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b. Dry spills:
(1) wear protective gloves
(2) dampen spilled materials thoroughly taking care not
to spread the contamination: use caution in damp-
ening fine, dry particulate material so as not to
create an aerosol; where chemical reactions with
water are possible, use oil as an agent
(3) use wipe tests or fluorescence tests to assure
adequate cleanup
4. Establish a plan and begin decontamination.
5. Monitor all persons involved in the spill and cleanup operation.
6. Prepare and submit to the Chief Safety Officer a complete
description of any accident or spill involving a toxic
substance and subsequent remedial and protective actions taken.
B. MAJOR SPILLS INVOLVING TOXIC HAZARDS TO PERSONNEL
1. Anyone involved in a spill must notify all persons not involved
in the spill to vacate the area at once and limit the movement
of displaced persons to confine the spread of contamination.
2. If the spill is liquid, use a stick, tongs, or lever to place
the spill container upright; the hands may be used only if
protected or gloved appropriately. Spill kits are available
and are required for limited access areas and laboratory rooms.
3. If the spill is on the skin, wash the affected parts thoroughly
with water or appropriate solution.
4. If the spill is on clothing, remove and discard the contaminated
clothing immediately.
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5. Shut off the power to all fans and air circulators.
6. Vacate the room.
7. Notify the Chief Safety Officer as soon as possible and
include identification of material involved.
8. Decontaminate personnel involved; obtain medical aid if
necessary.
9. Decontaminate the area; personnel involved in decontamination
must be adequately qualified and protected.
10. Spills should be inactivated in situ or be absorbed by any
appropriate methods; check up with wipe tests or fluorescence
tests.
11. Monitor all persons involved in the spill and clean up.
12. Permit no one to resume work in the area without the approval
of the Chief Safety Officer.
13. Prepare and submit to the Toxic Substances Committee a
ccmplete history of the accident and subsequent remedial
actions.
C. ACCIDENTS INVOLVING DUST, MIST, FUMES, ORGANIC VAPORS AND GASES
1. Anyone involved in an accident must notify all other persons
to vacate the area immediately.
2. Refrain from breathing as much as possible; close the
escape valves on the continer leaking the contaminant.
Use a respirator if necessary.
3. Vacate the room and, if necessary, activate the fire
alarm to vacate the building.
4. Notify the Chief Safety Officer at once.
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5. Ascertain that all doors to the room are closed; post
conspicuous warnings or guards to prevent accidental
opening of the doors or entry.
6. Monitor all persons suspected of contamination.
7. Proceed with decontamination of personnel.
8. Report at once all known or suspected inhalations of toxic
materials.
9. Evaluate the hazard and the necessary safety devices for
safe re-entry.
10. Determine the cause of contamination and rectify the con-
dition prior to the start of any area decontamination
operations.
11. Establish a plan of operation and begin decontamination of
the area. Check adequacy of clean up with wipe tests or
fluorescence tests.
12. Perform an air survey of the area before permitting normal
work to be resumed.
13. Prepare and submit to the Toxic Substances Committee a complete
history of the accident and subsequent remedial actions.
D. FIRES OR OTHER MAJOR EMERGENCIES
1. Anyone involved in,a fire or other emergency must notify
all other persons in the room and building at once. If the
building must be evacuated, individuals we'aring protective
clothing must segregate themselves from others until the
clothing can be disposed of.
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2. Contact the Fire Department and safety personnel including
the Chief Safety Officer.
3. Extinguishing the fire may be attempted if a toxic hazard is
imminent.
4. Restrict firefighting and other emergency activities to
the guidelines and rules prescribed by the Chief Safety
Officer.
5. Monitor all persons, involved in combating the emergency.
6. Following the emergency, monitor the area- and determine
the protective devices required for safe decontamination.
7. Establish a plan of operation and begin decontamination
in the area.
8. Permit no one to return to work without the approval of
the Chief Safety Officer.
9. Prepare and submit to the Toxic Substances Committee and
the Chief Safety Officer a complete history of the
emergency and subsequent remedial or protective actions.
E. FIRST AID
Report all toxic material accidents with possible health effects,
wounds, ingestion, inhalation, etc., to a physician or other professional
medical person immediately; use extreme care in providing emergency
comfort or first aid treatment, so as to avoid aggravating the injury.
(Washing under running water may be attempted.)
1. For wounds:
a. Wash wound or affected area immediately under running
water, spreading the wound sufficiently to allow
good rinsing.
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b. Call or take the injured person to a physician or
other person qualified to treat toxic injuries.
c. Employ appropriate measures to prohibit the spread
of toxic material by the injured.
d. Permit no person injured by toxic substances to return
to work without the approval of the physician and the
Chief Safety Officer.
e. Prepare accident and injury reports as required for
the Chief Safety Officer and the Personnel Office.
f. Prepare and submit to the Chief Safety Officer and
Toxic Substances Committee a complete history of the
accident and subsequent actions.
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APPENDIX A
CONTROLLED TOXIC SUBSTANCES
Substances considered toxic are contained in the following three
lists.
List 1 was generated by searching the National Institute for
Occupational Safety and Health's Registry of Toxic Effects of Chemical
Substances. Compounds selected were those which met the following
criteria:
ACUTE TOXICITY
Dosage Method Type of Measure
Oral LD*0
Inhalation LD£O
Dermal LD^g
List 2 comprises the Carcinogen Assessment Group's "Chemicals Having
Substantial Evidence of Carcinogenicity."
List 3 comprises the Occupational Safety and Health Administration's
List of Regulated Carcinogens.
(List 1 will be added to the Manual when the selection criteria are
established and the printout obtained.)
*
To be established in cooperation with the Occupational Health
and Safety staff.
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LIST 1 *
NIOSH'S REGISTRY OF TOXIC EFFECTS
OF CHEMICAL SUBSTANCES
*To be established in cooperation with the Occupational Health and
Satety staff.
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LIST 2
CHEMICALS HAVING SUBSTANTIAL EVIDENCE OF CARCINOGENICITY
Compounds
Aflatoxins
Aldrin
Amitrole
Aramite
Arsenic and Arsenic Compounds
Auramine and the manufacture of Auramine
Azaserine
Benz(c)acridine
Benz(a)anthracene
Benzene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(j)fluoranthene
Beryllium and Beryllium Compounds
N,N-Bis(2-Chlorethyl)-2-Naphthylamine
(Chlornaphazene)
Cadmium and Cadmium Compounds
Carbon Tetrachloride
Chlorambucil
CAS No.
64365-29-3
309-00-2
61-82-5
140-57-8
39277-51-5
12237-78-4
115-02-6
225-51-4
56-66-3
54682-86-9
50-32-8
205-99-2
205-82-3
7440-41-7
494-03-1
7440-43-9
56-23-4
305-03-3
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Compounds CAS No.
Chloroalkyl Ethers
Bis(2-ch1oroethyl)ether 111-44-4
Bis(chloromethyl)ether 108-60-1
Chloromethyl methyl ether (CMME),
technical grade (IARC) 107-30-2
Chlordane 52002-35-4
Chlorinated Ethanes
1,2-Dichloroethane (Ethylene Chloride,
Ethylene Dichloride EDC) 52399-93-6
Hexachloroethane 67-72-1
1,1,2,2-Tetrachloroethane 1299-89-4
1,1,2-Trichloroethane 79-00-5
Chlorobenzilate 510-15-36
Chloroform 8013-54-5
Chromium Compounds, Hexavalent 18540-29-9
Chrysene 27274-05-1
Citrus Red No. 2 6358-53-8
Coal Tar and Soot (CAG, included in lARC's soots,
tars, and oils designation)
Creosote 8001-58-9
Cycasin 453-95-2
Cyclophosphamide 50-18-10
Daunomycin 20830-81-3
DDT (Dichlorodiphenyltrichloroethane) 50-29-3
Dial late 58904-04-4
Dibenz(a,h)acridine 226-36-8
Dibenz(a,j)acridine 224-42-0
Dibenz(a,h)anthracene 53-70-3
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-49-
Compounds CAS No.
7H-Dibenzo(c,g)carbazole 194-59-2
Dibenzo(a,e)pyrene 192-65-4
Dibenzo(a,h)pyrene 189-64-0
Dibenzo(a,i)pyrene 189-55-9
l,2-Dibromo-3-chloropropane 96-12-8
1,2-Dibromoethane 8003-07-4
Dieldrin 60-57-1
Diepoxybutane 1464-53-5
1,2-Diethylhydrazine 1615-80-1
Diethylstilbestrol 56-53-1
Dihydrosafrole 94-58-6
3,3'-Dimethoxybenzidine 119-90-4
7,12-Dimethylbenz(a)anthracene 57-97-6
3,3'-Dimethylbenzidine 119-93-7
Dimethylcarbamoyl Chloride 79-44-7
1,1-Dimethylhydrazine 57-14-7
1,2-Dimethylhydrazine 540-73-8
Dimethyl Sulfate 77-78-1
2,4-Dinitrotoluene 121-14-2
1,4-Dioxane 123-91-1
1,2-Diphenylhydrazine 122-66-7
Epichlorohydrin 106-89-8
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, -50-
Compound
Ethylene Bis Dithiocarbamate
Ethylene Oxide
Ethylenethiourea
Ethyl Methanesulfonate
Formaldehyde
Glycidalhehyde
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexach1orocyc1ohex ane
aHCH
BHCH
YHCH
Technical HCH
Hydrazine
Indeno(1,2,3-cd)pyrene
Iron Dextran
Isosafrole
Kepone
Lasiocarpine
Melphalan
Methapyrilene
3-Methylcholanthrene
Methyl Iodide
Methyl Methanesulfonate
N-Methyl-N'-nitro-N-nitrosoguanidine
CAS No.
142-59-6
19034-08-3
96-45-7
62-50-0
50-00-0
765-34-4
76-44-8
118-74-1
87-68-3
608-73-1
319-84-6
319-85-7
58-89-9
75013-58-0
193-39-5
9004-66-4
120-58-1
143-50-0
303-34-4
8057-25-8
91-80-5
56-49-5
74-88-4
66-27-3
70-25-7
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Compounds CAS No.
Methylthiouracil 56-04-2
Mitomycin C 7481-68-7
Mustard Gas 505-60-2
Nickel and Nickel Compounds 7440-02-0
Nitrogen Mustard and its hydrochloride 55-86-7
Nitrogen Mustard N-oxide and its hydrochloride 302-70-5
5-Nitro-o-toluidine 99-55-8
4-Nitroquinoline-l oxide 56-57-5
Nitrosamines
N-Nitrosodiethanolamine 1116-54-7
N-Nitrbsodiethylamine 55-18-5
N-Nitrosodi-n-butylamine 924-16-3
N-Nitrosodi-n-propylamine 621-64-7
N-Nitrosomethylethylamine 10595-95-6
N-Nitrosomethylvinylamine 4549-40-0
N-Nitroso-N-Ethylurea 2151-05-5
N-Nitroso-N-Methylurea 684-93-5
N-Nitroso-N-methylurethane 615-53-2
N-Nitrosomorpholine 59-89-2
N-Nitrosonornicotine 16543-55-8
N-Nitrosopiperidine 68374-62-9
N-Nitrosopyrrolidine 930-55-2
N-Nitrososarcosine 68374-66-3
Pentachloronitrobenzene 82-68-8
Phenacetine 62-44-2
Polychlorinated Biphenyls
Pronamide 23950-58-5
1,3-Propane Sultone 1120-71-4
Propylthiouracil 51-52-5
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-52-
Compounds CAS No.
Reserpine 50-55-5
Saccharin 474-91-9
Safrole 94-59-7
Selenium Sulfide 7446-34-6
Streptozotocin 18883-664-4
Tetrachloroethylene 127-18-4
Thioacetamide 1482-80-0
Thiourea 62-56-6
o-Toluidine Hydrochloride 636-21-5
Toxaphene 8001-35-2
Trlchloroethylene 79-01-6
2,4,6-Trichlorophenol 88-06-2
Tris(l-aziridinyl)phosphine sulfide 639-23-6
Tris(2,3-dibromopropyl)phosphate 126-72-7
Trypan Blue, commercial grade 72-57-1
Uracil Mustard 66-75-1
Urethane 51-79-6
Vinylidene Chloride 75-35-4
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-53-
LIST 3
OSHA'S LIST OF REGULATED CARCINOGENS
Compounds
2-Acetylaminofluorene
Acrylonitrile
4-Aminodiphenyl
Asbestos
Benzidine
Bis-Chloromethyl ether
3,3'-Dichlorobenzidine (and salts)
4-Dimethylaminoazobenzene
Dioxin (2,3,7,8-Tetrachlorodibenzo-p-dioxin)*
Ethyleneimine
Methyl-chloromethyl ether
4,4'-Methylene bis (2-chloroaniline)
ot-Naphthylamine
B-Naphthylamine
4-Nitrobiphenyl
N-Nitrosodimethylamine
B-Propiolactone
Vinyl Chloride
CAS No.
53963
29754-21-0
92671
92875
542881
91941
60117
1746016
151564
107302
101144
134327
91598
92933
62759
57578
75015
*0n List 3 because of extremely high toxicity.
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APPENDIX B
TOXIC SUBSTANCE SAFETY PLAN
Assistance in preparing the safety plan can be obtained from the
Laboratory Safety Officer.
USE CATEGORY
Routine Infrequent
REVIEW:
Laboratory Safety Officer
APPROVALS:
Supervisor of Principal Investigator
Laboratory Director
Chief Safety Officer
Toxic Substances Committee
PRINCIPAL INVESTIGATOR:
Laboratory or Branch
Building, Room i___
Phone
DATE OF PLAN PREPARATION:
TOXIC SUBSTANCE(S)
Name(s) CAS No(s).
Synonyms
Safety Data Sheet Available Yes No
Location of Use
Intended Use
Location of Storage
INVENTORY DATA
Date Toxic Substance Ordered or Synthesized
Quantity
Period of Use
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APPENDIX B (continued)
TOXIC SUBSTANCE SAFETY PLAN
DETAILED DESCRIPTION OF INTENDED USE OF TOXIC SUBSTANCE(S)
(Use additional sheets if necessary)
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APPENDIX B (continued)
TOXIC SUBSTANCE SAFETY PLAN
DECONTAMINATION AND DISPOSAL
Decontamination Procedures (contaminated surfaces, materials,
instruments, equipment, etc.)
Disposal Procedures (wastes and unused stock):
EMERGENCY PROCEDURES
In event of overt personnel exposure (inhalation, ingestion, dermal
contact, inoculation):
In event of environmental contamination (spill):
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APPENDIX B (continued)
TOXIC SUBSTANCE SAFETY PLAN
HAZARD ASSESSMENT (toxic and pharmacologic effects, reactivity, stability
flammability, and operational concerns - weighing,
mixing, etc):
MONITORING PROCEDURES (If required by the Chief Safety Officer)
Medical surveillance procedures for evidence of personnel exposure:
Personnel monitoring procedures:
Surveillance procedures for environmental contamination:
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APPENDIX B (continued)
TOXIC SUBSTANCE SAFETY PLAN
PERSONNEL POTENTIALLY EXPOSED TO TOXIC SUBSTANCES
Personnel Authorized to Use Toxic Substances:
i 4.
2. 5.
3. 6.
Other Personnel Assigned to Locations Where Toxic Substance is Used;
1. 4.
2. 5.
3. 6.
ALTERNATIVE WORK PRACTICE AND ENGINEERING CONTROLS (if Used)
(Describe alternative controls not specified in this Manual for the
Laboratory Use of Toxic Substances. Indicate controls specified
in the Manual for which proposed alternative controls will serve
as substitute methods).
READ AND UNDERSTOOD (Signatures of all Personnel Potentially Exposed).
1. 4.
2. 5.
3. 6.
LITERATURE CITATIONS
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APPENDIX C
OFFICE OF OCCUPATIONAL HEALTH AND SAFETY, LABORATORY DIRECTORS,
AND TOXIC SUBSTANCES COMMITTEE MEMBERS
Occupational Health and Safety Staff
Robert C. Magor, Director
Occupational Health and Safety Staff (PM-273)
Washington, D. C. 20460
(Telephone: 382-3640)
David Weitzman, Industrial Hygiene Program Manager
Occupational Health and Safety Staff (PM-273)
Washington, D. C. 20460
(Telephone: 382-3647)
Laboratory Directors
Robert L. Booth, Acting Director
Environmental Monitoring and Support Laboratory (EMSL)
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7301)
Richard J. Bull, Director
Toxicology and Microbiology Division
Health Effects Research Laboratory (HERL)
U. S. Environmental Protection Agency
26 West St. Clair Street
Cincinnati, Ohio 45268
(Telephone: 684-7401)
David G. Stephan, Director
Industrial Environmental Research Laboratory (IERL)
U. S. Environmental Protection Agency
5555 Ridge Avenue
Cincinnati, Ohio 45268
(Telephone: 684-4402)
Francis T. Mayo, Director
Municipal Environmental Research Laboratory (MERL)
U. S. Environmental Protection Agency
26 West St. Clair Street
Cincinnati, Ohio 45268
(Telephone: 684-7951)
L. A. Van Den Berg, Director
Technical Support Division (TSD)
U.S. Environmental Protection Agency
26 West St. Clair Street
Cincinnati, Ohio 45268
(Telephone: 684-7904)
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APRENDrX C (continued)
Toxic Substances Committee .Memb.ers
George A. Bodmer, Chief Safety Officer
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7269)
Gerald Berg, Chairman
Hazardous Materials Committee
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7357)
Stephen Billets, Laboratory Safety Officer
Environmental Monitoring and Support Laboratory (EMSL)
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7494)
Charles R. Feldman/Laboratory Safety Officer
Technical Support Division (TSD)
U. S. Environmental Protection Agency
26 W. St. Clair Street
Cincinnati, Ohio 45268
(Telephone: 684-7943)
Lawrence J. Kamphake, Laboratory Safety Officer .
Municipal Environmental Research Laboratory (MERL)
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7957)
Carl T. Rybak, Laboratory Safety Officer
Toxicology and Microbiology Division
Health Effects Research Laboratory (HERL)
U. S. Environmental Protection Agency
26.West St. Clair St.
Cincinnati, Ohio 45'268
(Telephone: 684-7457)
Donald G. Silvis, Laboratory Safety Officer
Industrial Environmental Research Laboratory (IERL)
U. S. Environmental Protection Agency
26 West St. Clair St.
Cincinnati, Ohio 45268
(Telephone: 684-7514)
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APPENDIX D
TOXIC SUBSTANCE CHEMICAL INVENTORY SHEET
Date:
Inventory Quantity,
No. Chemical Name CAS No. gms Bldg. Room User
-------
APPENDIX D (CONT'D)
TOXIC SUBSTANCE RUNNING INVENTORY USAGE SHEET
NAME OF MATERIAL:
DATE RECEIVED: QUANTITY RECEIVED:
CAS NUMBER:
ncc /AMTMAI TccTc rucM DCArTTnMC err \ AMOUNT WHERE AMOUNT
USE (ANIMAL TESTS. CHEM. REACTIONS, ETC.) USE[) USEQ REMAINING
O-i
ro
i
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APPENDIX D (CONT'D)
TOXIC CHEMICAL/ENVIRONMENTAL SAMPLE LOG SHEET
LOG SHEET CONTROL IDENTIFICATION NUMBER:
NAME OF MATERIAL:
BILL OF LADING OR PURCHASE ORDER NO.:
DATE OF RECEIPT: NAME OF RECEIVER:
QUANTITY: CONTAINER SIZE:
FORM OF SHIPMENT:(i.e. Federal Express,etc.)
CONDITION OF SHIPPING OR SAMPLE CONTAINER:
SAMPLE COLLECTION DATA:
EXACT LOCATION OF SAMPLING:
NEAREST TOWN: TIME: DATE:
SOURCE OF SAMPLE: (Drum,evaporative pond, stream,ground water,etc.)
MANUFACTURING/INDUSTRIAL PROCESSES IN AREA:
SUSPECTED CONTAMINANTS:
COLLECTED BY: ORGANIZATION: PHONE:
AUTHORIZED BY:
DISTRIBUTION OF MATERIAL: AMOUNT: BUILDING: _
ROOM NO.: NAME OF PRINCIPAL INVESTIGATOR:
DATE: SIGNATURE OF RECIPIENT:
EXACT STORAGE LOCATION:
MATERIAL SAFETY DATA SHEET AVAILABLE: YES NO
APPROVED SAFETY PLAN AVAILABLE: YES NO _
DISPOSAL: AMOUNT: DATE: PROGRAM:
DISPOSAL DATA:
HEALTH AND SAFETY IMPACT:
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APPENDIX E
PERIODIC HEALTH ASSESSMENT
The nature of a program for providing periodic health assessments is
complicated by several factors. Among these are (1) many laboratory
workers handle a variety of toxic substances so that the medical sur-
veillance should ideally seek evidence of adverse effects from all these
substances, (2) some toxic substances cause cancer but have li-ttle or no
toxicity other than the production of neoplasms, and (3) most tumors do not
become evident until many years (often 20-30) after ttie initiating events.
Medical monitoring will, therefore, sometimes for necessity and more
often for efficiency, usually concentrate on events likely to precede
overt evidence of serious health effects such as tumorigenesis. For
example, some carcinogens, such as dimethylnitrosamine, have high acute
toxicity, especially to the liver, and evidence of such acute toxicity
can be obtained within a few hours or days following exposure. Some
tumors, such as those induced by carbon tetrachloride, are normally pre-
ceded by marked changes in liver cells, usually detectable by clinical
tests. Others, e.g., angiosarcomas induced by such substances as vinyl
chloride, will often cause detectable cell changes in nearby tissue as
the probable result of space occupation. It should be noted that detec-
tion of such toxic changes does not necessarily presage tumor develop-
ment, but should nevertheless precipitate the instruction of corrective
work practices and improved engineering controls. The occupational
physician, to be effective, must have relevant information such as mode
and mechanism of toxic action, frequency and severity of exposure, and
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exposure concentrations, if known. Some of this information will be
available in individual safety data sheets. However, this information
should be supplemented by the Principal Investigator when appropriate.
Biologic monitoring is sometimes a useful method of detecting
exposure and, perhaps, of estimating the degree of exposure. Biologic
monitoring usually involves the analysis of body fluid or excreta
(usually urine, sometimes blood, rarely expired aiH for the toxic
substance or a biotransformation product. An example is the detection
of reaction products of biphenylamines in the urine samples of persons
absorbing benzidine or its derivatives. Even if exposure cannot be
quantified, as is sometimes the case, the rrere detection of the meta-
bolite, if its presence is specific to the individual toxic substance
or class, is sufficient to indicate the need for corrective action.
In some cases, especially with some less well known carcinogens,
those in the research laboratory will be better informed on possible
biologic monitoring procedures than will .the occupational physician.
In such cases, the investigators should discuss the possibilities with
the occupational physician. It may also be that specialized analytical
procedures and equipment will be needed for some of this monitoring.
Some procedures and equipment that may not be available to the medical
laboratory are available in the research laboratory. The investigators
should undertake such monitoring procedures themselves only with prior
approval of and in participation with the occupational physician.
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APPENDIX F
LOCATION OF CARCINOGEN DILUTION MODULES AND LIMITED ACCESS AREAS
*Carcinogen Dilution Module (EMSL) Sv. Clair Room 576
*Carcinogen Dilution Module (HERL) St. Clair Room 608
IERL St. Clair Room
MERL St. Clair Room 411
TSD St. Clair Room 411
**TMD (HERL) St. Clair Rooms 762-768
*Presently the only approved areas for storage and handling of neat
chemical carcinogens regulated by OSHA (List 3, Appendix A).
**These rooms have been set aside as the only rooms in which dosing of
animals can exceed the amounts prescribed for a non-controlled area.
Carcinogens are not to be stored in these rooms.
Personnel other than EMSL and HERL must obtain permission from
the appropriate Laboratory Director for use of Carcinogen Dilution
Laboratories.
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APPENDIX G
PACKAGING, MARKING, LABELING, AND SHIPPING OF TOXIC
SUBSTANCES USED BY LABORATORIES
1. GENERAL PROVISIONS
These procedures apply to substances considered toxic for this
Manual (identified in Appendix A) which are shipped between laboratories
or the field. Applicable laboratories include any EPA laboratory or
private laboratories under contract with EPA who handle these toxic
substances.
a. Most of the toxic substances identified in Appendix A are not
materials specifically identified in the Department of Trans-
portation (DOT) Hazardous Material Table (49 CFR 172.101). Any
material listed in the DOT Table should be transported accord-
ing to the Table or according to applicable DOT packaging
exemptions (e.g., a Poison B, n.o.s. can be packed in Label-
master, Inc.'s package #38, or Dow Chemical Co.'s Imbiber Pack
for shipment by United Parcel Service). Substances that are
judged to be environmental samples should be shipped according
to EPA national guidance (Compliance with Department of
Transportation Regulations in The Shipment of Environmental
Laboratory Samples, draft memo by water media DAA's, available
from Division of Occupational Health and Safety).
b. Toxic substances may be transported by rented or common carrier,
truck, bus, railroad, and by Federal Express Corporation*
*These procedures are designed to enable shipment by entities like Federal
Express and should not be construed as an endorsement by EPA of a particular
commercial carrier.
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(air cargo), but they may not be transported by any other
common carrier air transport or even by "cargo only" air-
craft other than Federal Express at this time.
c. If toxic substances are transported by any type of government-
owned vehicle, including aircraft, DOT regulations are not
applicable. However, EPA personnel must still use the pack-
aging procedures described below.
2. PRELIMINARY STEPS
The following procedures should be followed before toxic substances
are shipped:
a. Place a sufficient quantity of the toxic substance in glass
and/or polyethylene containers to determine whether it will
react with or substantially reduce the effectiveness of the
container.
b. Pack toxic substances according to "Packaging, Marking, and
Labeling Requirements for Toxic Substances Used by Laboratories."
3. PACKAGING, MARKING AND LABELING REQUIREMENTS FOR TOXIC SUBSTANCES
USED BY LABORATORIES'
a. Place the toxic substance in a 16-ounce* or smaller glass or
polyethylene container with nonmetallic, Teflon-lined screw
cap. Allow sufficient ullage (approximately 10% by volume)
so container is not liquid full at 130 °F. If an air space
in the innermost container cannot be tolerated in order to
maintain sample integrity, place the container within a
* Larger capacity containers, up to one gallon, may be used for toxic sub-
stances with a flash point of 73 °F or higher. In this case, such should
be marked on the outside container (carton, etc.) but only a single (one
gallon or less) bottle may be packed in an outside container. Ten percent
ullage and requirements 2, 5, 6, and 7 must also be followed. On the
shipping papers (if required) state that flash point is 73 °F or higher.
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second container which provides the required ullage. If
collecting a solid material, the container plus contents must
not exceed one pound net weight.
b. For toxic substances which are samples taken in the field,
attach properly completed sample identification tag to
sample container.
c. Seal the toxic substance container and place it in 2-mil-
thick (or thicker) polyethylene bag, one container per bag.
Plastic-coated glass bottles with polypropylene caps, which
can satisfy a 4-foot drop test, are currently available and
can serve as both the container and polyethylene bag.
(Labels and/or tags should be positioned to enable them
to be read).
d. Place sealed bag or plastic bottle inside a metal can with
incombustible, absorbent, cushioning material (e.g., vermic-
ulite, coarse grade to minimize dust), one bag or plastic
coated bottle per can. Pressure-close the can and use clips,
nylon reinforced tape, or other positive means to hold the
lid securely, tightly, and effectively.
e. Mark and label this can as indicated in 3. h. below.
f. Place one or more metal cans (or a single one-gallon bottle;
see footnote on previous page), surrounded with incombustible
packaging material for stability during transport, into a
strong outside container, such as a fiberboard box.
g. Mark and label the outside container and complete shipping
papers (if required) as described in 3. h. below.
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h. Place the following information on strong outside container,
either hand printed or in label form:
(Laboratory name and address)
Tosic Substance, not regulated by DOT, (chemical name):
EPA Laboratory Sample
Use abbreviations only where specified for DOT listed
hazardous materials. "THIS SIDE UP" or "THIS END UP" should
also be marked on the top of the outside container, and
upward pointing arrows should be placed on all four sides of
the exterior container.
i. Shipping papers are not required for toxic substances which
are not DOT listed hazardous materials. Regulations for
shipping papers for DOT listed hazardous materials are
presented in 49 CFR 172. 200-204.
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APPENDIX H
PRIMARY CONTAINMENT EQUIPMENT
1. PURPOSE
The purpose of primary containment equipment is to protect the
laboratory worker from exposure to vapors or aerosols of hazardous
materials that may be released by procedures performed within the
equipment. Primary containment equipment that is properly designed,
located, maintained, and operated can prevent or minimize the escape of
hazardous materials from the equipment into the laboratory. The labora-
tory fume hood, the biological safety cabinet, and the glove box are
the principal primary containment equipment upon which laboratory
workers depend for their protection while working with toxic substances.
2. LABORATORY FUME HOOD
The laboratory fume hood (a Class I device) is the primary hazard
control device that laboratory workers depend upon for their protection
while working with toxic or other hazardous materials. If-designed,
installed, operated, and maintained properly, the laboratory fume hood
will provide personnel with a high degree of protection and allow the
user to safely work with a wide range of potentially hazardous materials.
a. Hood Function The purpose of a laboratory fume hood is to
prevent or minimize the escape of contaminants from the hood
back into the laboratory. This is accomplished by drawing air
pest the operator through the zone of contaminant generation
and into the hood.
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b. Conditions Affecting Hood Performance.- The ability of a
laboratory hood to control contaminants generated in the hood
will depend on many factors. Of prime concern are the control
velocity at the hood face, air movement in the room, turbulence
within the hood working space, and hood location. It is the
proper selection and control of these factors as a group that
determines the performance of the hood from the standpoint of
hazard control.
(1) Face Velocity. Air flow rates, to provide protection
from operations performed in the hood, must provide
positive control of air movement against competing
influences. Control velocities required at the face
of the hood range from 80 FPM (ft. per minute) for
"ideal" laboratory conditions to 100 FPM for "good"
conditions.
(2) Operator Effect. The operator standing in front of the
hood has a significant effect on the air flow patterns.
The "eddies" formed around the -operator can carry
contaminants from the hood to the operator's breathing
zone. Proper use of make-up air at the hood face, with
emphasis on filling the void or minimizing the low
pressure area in front of the operator, is necessary for
optimum hood performance.
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(3) Air Movement in the Laboratory. Air movement within the
laboratory affects the performance of hoods and is influ-
enced by hood location and room air supply systems. Hood
locations must be away from doors, operable windows, and
pedestrian traffic. Air from these sources can attain
velocities several times greater than the hood face
velocity, creating potential for dragout or displacement
of contaminated air from the hood. Ceiling and wall
diffusers for distribution of make-up_ air are also
serious-potential sources of interference. Air from such
outlets should either be controlled to assist in the per-
formance of the hood or directed so that the energy is lost
before entering the zone of influence. Experience indicates
that air from make-up systems should not exceed 25 FPM in
the hood face areas (measured with hood exhaust "off").
Air drawn from adjacent areas (by the hood exhaust system)
must enter in a manner that does not create excessive
turbulence.
(4) Hood Turbulence. Upon entering the hood, the air is drawn
past equipment and sources of contamination toward the ex-
haust slots. Much of the air within the hood is in a tur-
bulent state. At air-flows greater than needed to provide
a good vector and contain the contaminant, the resulting
turbulence can be excessive causing a "rolling effect" in
the hood chamber. This increases the potential for greater
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-74-
mixing of contaminated air and room air at the hood face.
Often, a combination of poor hood arrangement and interior
turbulence will result in loss of contaminated air to the
room.
(5) Hood Location. Location of a hood at the end of room or
bay, where the operator is essentially the only one who
enters the; zone of influence, is the most desirable.
In any arnngement, pedestrian traffic past fume hoods
should be minimized. Hood location parameters are detailed
in subparagraph 2.C:
c. Hood Location Classification.
"Ideal" (1) End of room or bay, no nearby doors or windows.
(2) Essentially no pedestrian traffic, other than hood
operator.
(3) All of the required laboratory hood make-up air drawn
or induced to enhance over-all hood performance. For
example, a properly designed and located perforated
ceiling section or well designed auxiliary air hood
plenum.
(4) No other grilles or diffusers exist that produce air at
measurable velocities in the hood area.
"Good" (1) Not on a main aisle, no nearby doors or windows.
(2) Minimum traffic other than hood operator.
(3) Have air supplied to lab so velocity from diffusers or
grilles does not exceed 25 FPM in vicinity of hood.
"Poor" (1) Any one or more of the above conditions are not met.
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d. Additional Specification and Procedures. Additional specifica-
tion and performance evaluation procedures for laboratory
fume hoods can be found in:
(1) EPA Laboratory Fume Hood Specifications and Performance
Testing Requirements, available from the EPA OHSS.
(2) U.S. Environmental Protection Agency Facilities Safety
Handbook, Amendment No. 1., available from the EPA
Facilities Engineering and Real Property Management
Branch.
3. CLASS II BIOLOGICAL SAFETY CABINET.
The Class II biological safety cabinet is a primary containment
device designed to protect the laboratory work as well as the laboratory
worker.
a. Cabinet Function. The Class II biological safety cabinet
provides a blanket of clean air over the work, contains air
contaminants in the work area, and conveys the contaminated
air away from the operator. It accomplishes these functions
by combining recirculation with filtration and exhaust.
High Efficiency Particulate Aerosol (HEPA) filtered air
descends over the work surface and splits at the center.
A portion of the downflow air exits through a front air
intake grille, and the balance exits through a rear air
exhaust grille. The downflow air is reunified under the
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work surface and forced up through a rear or side positive
pressure plenum to the unit's top. Type A (30%) or Type B
(70%) of this air is filtered and exhausted and the balance
is filtered and forced down to blanket the work. The make-up
air (30% Type A or 70% Type B) enters from the room through
the front intake grille and sweeps by and protects the oper-
ator. Total exhaust Class II biological safety cabinets
which have recently become available presumably provide high
personnel protection factors.
b. Conditions Affecting Cabinet Performance. The conditions
that affect cabinet performance are essentially the same as
the conditions that affect laboratory hood performance which
were presented in detail above. The operator effect can be
particularly pronounced since the operator's arms interfere
with the recirculating downflow air vector.
c. Additional Specifications and Procedures. The OHSS is develop-
ing standards for these cabinets using the EPA laboratory
hood standard as a model. Meanwhile, equipment descriptions,
recommended specifications and certification procedures can
be found in the following documents:
(1) Laboratory Safety Monograph, A Supplement to the NIH
Guidelines for Recombinant DNA Research. U.S. Depart-
ment of Health, Education and Welfare, Public Health
Service, National Institutes of Health, January, 1979.
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(2) National Sanitation Foundation Standard No. 49.
National Sanitation Foundation, Ann Arbor, Michigan, 1976.
4. GLOVE BOX
a. The Glove Box, or Class III biological safety cabinet, is
a totally enclosed ventilated cabinet of gas-tight construction.
Operations within this equipment are conducted through attached
rubber gloves. When in use, the equipment is maintained under
negative air pressure of at least 0.5 inches water gage. A
small volume of supply air, to prevent contamination build-up,
is drawn into the equipment through a HEPA filter and the
exhaust air is treated to prevent the discharge of contaminants
into the environment. This equipment provides the highest
level of personnel and environmental protection.
b. The Glove Box is generally recommended for the isolation of
procedures involving stock quantities of toxic substances.
Worker protection can be compromised by puncture of the gloves
or accidents creating positive pressure. Flammable solvents
should not be used in this equipment unless a careful
evaluation has been made to determine that concentrations will
not reach dangerous explosive levels. When the use is deter-
mined safe, these materials should only be introduced into the
glove box in closed, nonbreakable containers. These materials
should not be stored in the glove box. Flammable gas should
not be piped to this equipment.
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APPENDIX C
Correspondence Received Pertaining to
Draft Environmental Impact Statement,
Full Containment Facility, Cincinnati, Ohio
-------
US Deportment
Of Transportation
..
Federal Highway
Administration
- Region 5
Illinois. Indiana. Michigan.
Minnesota. Ohio, Wisconsin
1 B209 Di*« Highway
Homewood. Illinois 60430
February 23, 1987
HPP-05
Mr. Russell N. Kulp, P.E. (PM-215)
U.S. Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460
Deaf Mr. Kulp:
The draft environmental impact statement for the Full Containment
Facility at the Andrew W. Breidenbach Environmental Research
Center in Cincinnati, Ohio, has been reviewed. As a result of
our review, we have no comments to offer on the draft document.
Sincerely yours,
Regional Administrator
By:
E. V. Heathcock
Director, Office of Planning
and Program Development
ccs:
Sec Rep
OST P-14
HEV-10
Ohio D/0
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7/107
United States Department of the Interior
OFFICE OF ENVIRONMENTAL PROJECT REVIEW
WASHINGTON, D.C. 20240
MAR 3 1987
Russell N. Kulp, P.E. (PM-215)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.G. 20460
Dear Mr. Kulp:
The Department of the Interior has reviewed the draft environmental statement for Full
Containment Facility, Andrew W. Breidenbach Environmental Research Center,
Cincinnati, Hamilton County, Ohio, and has the following comments.
The final statement should present sufficient geotechnical information to support the
finding that the proposed site will not be subject to a landslide hazard. Similarly, other
geotechnical issues are not addressed including foundation conditions, and other stability
considerations. Detailed site-specific geotechnical investigations should be conducted to
ensure that the design of the toxic and hazardous storage and containment facilities will
not be subject to any potential subsidence or slope stability hazards.
We recommend an action plan should be developed to contain accidental spills of
hazardous substances on the soil outside the building as the draft statement recognizes
the possibility of such spills.
We hope these comments will be helpful to you in the preparation of a final statement.
Sincerely,
Jlanchar^Director
Environmental Project Review
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COLDUieLL
February 4, 1987
COLOWELL BANKER
COMMERCIAL REAL ESTATE SERVICES
FIRST NATIONAL BANK CENTER
425 WALNUT STREET. 25TH FLOOR
CINCINNATI, OHIO 45202
Mr. Charles J. Luken, Mayor
City of Cincinnati
801 Plum Street, Room 150
Cincinnati, OH 45202
Dear Mr. Luken:
I want to bring an urgent matter to your attention which if not dealt with
immediately, would negatively affect the long term image of Carl H. Linder
Hall and the University of Cincirnati. I would also like to offer a
solution to the problem.
The Environmental Protection Ager cy is finalizing plans to build a
hazardous and toxic waste laboratory on its land, directly across the
street from the Carl H. Lindner Kail and U.C. student dormitories. The
EPA claims the lab has to be in close proximity to its existing St. Claire
Street facility and that the lab will be safe. It is my opinion that the
hazardous and toxic waste laboratory's high visibility location will
always be a perceived threat to the safety of those who go to school and
live directly across the street at the University of Cincinnati. It is
hard to calculate the harmful effect on UC if there ever was an accident.
I offer a solution. An alternative site is available on Jefferson
Avenue. The site is a short walking distance to the EPA, it is not
visible or contiguous to the University of Cincinnati, and has a
significantly lower accident exposure than the proposed location. The
site is zoned properly and ready for development. The owners of the
Jefferson Avenue site would sell, lease or exchange their land for a
comparable amount of the EPA's land. If the EPA agreed to exchange their
St. Claire Street land for the Jefferson Avenue land, then the University
might even consider purchasing this St. Claire Street land for additional
parking or future expansion.
For a short time the EPA is accepting the communities input regarding its
proposed lab. For a small amount of inconvenience for the EPA, the
community and U.C. can gain a great deal. As a real estate agent and a
concerned U.C. graduate I would like to see the EPA hazardous and toxic
waste lab facility moved to the Jefferson Avenue site. I solicit your
immediate and vocal efforts in having the EPA move the hazardous and toxic
waste lab from its proposed site to the Jefferson Avenue site.
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February 4, 1987
Page 2
As a starting point, I urge you to contact these two EPA officials who
would be instrumental in effecting the change in building sites:
1. Mr. Russ Kulp, Project Officer, (202) 382-2172
2. Mr. Joe Castelli, Director of Facilities, (513) 569-7251
I appreciate your efforts and would be pleased to discuss this urgent
matter with you at your convenience.
Sincerely,
Rick Navaro, CCIM
369-1325
RN/blb
c: Mr. Carl H. Lindner
Mr. Charles J. Luken
Dr. Joseph A. Steger
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PROPOSED
HAZARDOUS I TOXIC WSTE LAB
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COLDUIGLL
COMMERCIAL REAL ESTATE SERVICES
FOR SALE
The Only Undeveloped Land
Assemblage of its kind in Clifton
FIRST NATIONAL BANK CENTER
425 WALNUT STREET
25TH FLOOR
CINCINNATI. OHIO 45202 CHILDRCNS HOSPITAL
(513)369-1300 GENERAL HOSPITAL
V.A. HOSPITAL
UNIVERSITY
P*
CINCINNATI
Zoned B-4 - Retail, Office, Medical Office
Over 100,000 sq. ft. of undeveloped land
Centrally located less than:
3 miles to Downtown Cincinnati
2 miles to Interstates 75, 74, and 71
-1 mile from 9 major hospitals
l/2 mile from the University
of Cincinnati
Contact Rick Navaro, CCIM
or
Jay Holubeck
(513)369-1300
KENTUCKY
information contained herein has been obtained from the owrnw of the property or from other sources that we deem reliable
we have no reason to doubt it; accuracy but we do not guarantee it
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2401 Fairview Avenue
Cincinnati, Ohio 45219
January 28, 1987
Executive Board Members
CUF Community Council
2301 Chickasaw Street
Cincinnati, Ohio 45219
Ladies and Gentlemen,
I have recently reviewed the environmental impact statement by the
EPA concerning the proposed hazardous waste containment building to
be erected on their Clifton property. The book is quite thorough and
well-written and their reasons for wanting this building are
legitimate; however, their publication is somewhat vague as to the
effect on surrounding neighborhoods' air and water quality,
particularly through the sewer systems.
As you are probably aware, Cincinnati has a high concentration of
industries which use toxic and hazardous substances. On a national
level, we are a "leading producer" of carcinogenic pollutants.
Cincinnati also had one of the leading cancer mortality rates. I am
concerned that this proposed waste containment facility will only
make matters worse. What more do we want?
The Clifton area is densely populated and contains many hospitals,
colleges, a major university, and elementary and secondary schools,
along with other vital facilities. If a mishap should occur
associated with the new waste containment facility, approximately
40,000 to 50,000 residents would be affected, not to mention people
who use our hospitals and schools.
The proposed building should be isolated on a site away from any
populous area, especially since it is the first of its kind. It
would be presumptuous to assume that accidents would never occur *
Danger is imminent anywhere toxic wastes are .stored. For example,
one of the substances the EPA intends to house at this facility is
mustard gas, which is highly toxic, even in small amounts, and
historically has been used in chemical warfare. If an accident
should occur using this substance, it could create quite a
catastrophe! The price for this building may be too great in terms
of the health of our residents and others who frequent the Clifton
area.
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I firmly oppose the building of such a facility in our neighborhood
and feel that our community council should make a thorough
investigation of the EPA's proposal and insure the health and safety
of its residents by fighting against the erection of such a facility
Sincerel
/
Raymona J. Dg£0s
RJD:ar
Enclosures:
EPA Environmental Impact Statement
Pages 1-1, 3-21, 3-22, 6-1, 6-2, and
Abstract
cc: Senator Howard Metzenbaum
Congressman Thomas Luken
Mayor Charles Luken
Russell Kulp, P.E. (EPA)
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Ohio Historic Preservation Office
1985 Velma Avenue
Columbus. Ohio 43211
614/297-2470
February 18, 1987
OHIO
HISTORICAL
SOCIETY
SlNCb 1885
Russel N. Kulp, P.E. (PM-215)
U.S. Environmental Protection Agency
401 M Street, Swe Office
Washington, D.C. 20460
Dear Mr. Kulp:
Re: Draft EIS, Full Containment Facility,
Andrew H. Breidenbach Environmental Research Center
Cincinnati, Ohio
This letter Is In response to your correspondence dated January 13, 1987
concerning the project noted above. My staff has reviewed the Information
you have provided. However, additional Information Is necessary in order to
determine whether any properties have been Inventoried, listed or eligible
for the National Register of Historic Places. Please provide us with a
street map showing the location of the project boundaries. Front and rear
elevation photographs of any standing structures over fifty years old which
will be affected by the proposed facility would also be helpful.
If you need any further Information or clarification, please contact
Richard Bolsvert or Catherine Stroup at (614) 297-2470.
Slncerejjr,
W. Ray Luce'
State Historic Preservation Officer
WRL/CAS:Jk
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI. OHIO 45268
March 2, 1987
Mr. W. Ray Luce
State Historic Preservation Officer
Ohio Historical Society
1985 Velma Avenue
Columbus, OH 43211
Dear Mr. Luce:
This is in reply to your letter dated February 18,
1987, to Russell N. Kulp, P.E., regarding the additional
information you requested concerning the Draft EIS for
the Full Containment Facility.
Enclosed is a drawing which shows the location of
the proposed Full Containment Facility- As you can see
from the drawing, the proposed location is on the present
site of the Andrew W. Breidenbach Environmental Research
Center which is a U. S. Government owned facility.
There are no standing structures over fifty years
old which will be affected by the proposed facility. If
you need additional information, please contact me at
(513) 569-7251.
Sijncerely yours,
i
.Joseph A. Castelli
Director, Facilities Management
& Services Division
cc: Russell N. Kulp
William Spaulding
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