United States
                      Environmental Protection
                      Agency
Prepared by the Office of
Water Regulations and Standards
and the Office of Solid Waste and
Emergency Response in conjunction
with the Dioxin Strategy Task Force
November 28, 1983
Washington, DC 20460
&EPA          Dioxin  Strategy

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      United States Environmental Protection Agency
                     DIOXIN STRATEGY
Prepared by the Office of Water Regulations and Standards
   and the Office of Solid Waste and Emergency Response
    in conjunction with the Dioxin Strategy Task Force
                    November 28, 1983
                  Washington, DC  20460

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                      EPA's DIOXIN STRATEGY




                        November 28, 1983
TABLE OF CONTENTS








EXECUTIVE SUMMARY



Part 1 - Introduction	  1



Part 2 - EPA1 s Dioxin Strategy	  6



     Study Tiers	  6



     Implementation of the Strategy	  7



     Field Sampling	 12



     Analytical Issues	 13



     Assessment of Data	 16



     Regulatory Initiatives	 18



     Remedial Actions at Contaminated Sites	 19



     Health and Environmental Effects of 2378-TCDD	 20



     Other Dioxins and Dioxin-like Compounds	 22



     Coordination	 24



     Community Relations	 24



Part 3 - Interim Guidance for Tiers 1 and 2	 26

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                        EXECUTIVE SUMMARY

   The strategy presented  here  provides a  framework  under which
the U.S.  Environmental Protection  Agency  (EPA)   will  1)  study
the extent  of  dioxin  contamination  and the associated  risks to
humans and  the environment,  2)  implement   or  compel  necessary
clean-up actions at  contaminated sites, and 3)  further evaluate
regulatory alternatives to prevent  future contamination,  as well
as disposal alternatives to alleviate current problems.

   EPA will be  investigating  and taking appropriate  response or
enforcement actions at production, disposal, and processing sites
where pesticides (including herbicides)  contaminated  with dioxin
were or  are being  handled.    In addition,  the  Agency  will  be
sampling other possibly contaminated sites as well as the ambient
environment throughout  the United  States  for the  presence  of
dioxin.  This  overall  investigation is  in  response  to  concerns
raised by the  increasing  number of  instances  when environmental
contamination by chlorinated  dioxins  has  been documented.   EPA
will also continue  its  evaluations of human health risks associated
with exposure to chlorinated  dioxins and of  disposal and destruc-
tion methods.

   Although there are  75 different  chlorinated  dioxins,  2,3,7,8-
tetrachlorodibenzo-p-dioxin (2378-TCDD)  is   the   one  of  primary
concern because  it  is the most  toxic dioxin  isomer,  with  the
potential of presenting  significant  health  and disposal  issues.

   The 2378-TCDD isomer  is known to be a  contaminant  of 2,4,5-
trichlorophenol (2,4,5-TCP) when  2,4,5-TCP   is  made  from tetra-
chlorobenzene.   2,4,5-TCP  is  used  in the manufacture  of  various
phenoxy herbicides,  including   2,4,5-trichlorophenoxyacetic  acid
(2,4,5-T) and Agent Orange, a defoliant  herbicide used in Vietnam.
The emphasis on  2,4,5-TCP and  its derivatives is based  on  the
fact that in nearly every place  where  2378-TCDD   has  been  found
in the  environment,  it can  be  associated,  if not  definitively
linked, to 2,4,5-TCP production or disposal  sites.

   To facilitate implementation of  the  strategy,  EPA has defined
the following  study  tiers based  on  decreasing  potential  for
2378-TCDD contamination:

    Tier 1 -   2,4,5-TCP production  sites  and  associated  waste
              disposal sites.

    Tier 2 -   Sites  (and  associated waste  disposal  sites)  where
              2,4,5-TCP was used as  a precursor to make pesticidal
              products.

    Tier 3 -   Sites  (and  associated waste  disposal  sites)  where
              2,4,5-TCP and its derivatives  were  formulated into
              pesticidal products.

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    Tier 4 -  Combustion sources.

    Tier 5 -  Sites where  pesticides  derived from 2,4,5-TCP have
              been and  are being  used  on  a  commercial  basis.

    Tier 6 -  Certain organic  chemical and pesticide manufacturing
              facilities where improper quality control on certain
              production processes  could  have  resulted   in  the
              formation of 2378-TCDD  contaminated products waste
              streams.

    Tier 7 -  Control sites where contamination from 2378-TCDD is
              not suspected.

   The strategy calls  for  investigating  and taking any necessary
response or enforcement actions  at  tier  1  sites  and, eventually,
at tier  2  sites.   Sites  in  tiers  3-6 will also be  studied  to
determine the  probability of contamination  at   these types  of
sites.  Sampling at sites  in  tiers  1-6  will initially  consist  of
a screening of  areas  most  likely to be contaminated to determine
if 2378-TCDD is present at the site.   If  it is,  further sampling
may include all media  (air,  water,  soil,  stream sediments,  fish
tissue) which are appropriate  to define the  extent of contamination
and health risk. Sampling in tier 7 will be  done in two phases.  In
the first phase, EPA will collect  multi-media samples at  a number of
control areas  (e.g.,   towns,  sections  of  cities,  rural  areas)
selected throughout the United  States.  During  the  second phase
EPA will  sample fish  (and other aquatic organisms) at  selected
stations throughout the United  States.   All sampling  done under
this strategy will follow prescribed analytical protocols.

   Another important  aspect of  the  strategy is  to determine the
potential health and environmental risks from exposure to 2378-TCDD
in different media.   EPA,  in  conjunction with other appropriate
federal agencies such as the Veteran's Administration (VA) and the
various constituent agencies of the Department of Health and Human
Services (HHS),  (e.g.,  the Centers for  Disease  Control  (CDC),
the Food and Drug Administration (FDA), and the National  Institutes
for Occupational  Safety  and   Health  (NIOSH)),   will   undertake
research to understand more fully the specific  effects  of 2378-
TCDD on humans  and other  species,  and  to  develop techniques  to
determine actual  risk given  different  levels  of  environmental
contamination.

   While investigations  into   the  extent   of  human  health  and
environmental risks  from  contamination  by  2378-TCDD  proceed,
EPA will also be evaluating different alternatives for  containing
and eventually  disposing  of   soils  and  wastes contaminated  with
2378-TCDD.  These alternatives include various methods of securing
contaminated soil and  preventing  leachate  runoff or percolation,
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extraction of dioxin  from soils, and  incineration  or photolysis
for destruction of dioxins.

   Finally, the  strategy lists  a  number of  research activities
to define  the  potential human  health  and  environmental  risks
from dioxin  isomers  other  than  2378-TCDD  and  other  "dioxin-
like" chemicals.   These  activities  include  1)  assessing  the
toxicity of  the  other  isomers,  2)  determining  their  specific
sources, 3)  evaluating  their  environmental  fate and  transport
properties, 4)  developing exposure  and  risk  assessments  based
on the above information, and 5) recommending appropriate control
measures.  To  assist   in  these  activities,  the  sampling  program
for 2378-TCDD  includes  provisions  to analyze  for  other  dioxin
isomers and  "dioxin-like"  chemicals  when  appropriate  to  the
situation or the sampling site.

Regulatory Activities

   EPA's efforts to  regulate  dioxin in the  environment  began in
1973 when the Agency instituted proceedings to cancel the
registration of  the  pesticide  2,4,5-T,   based  primarily   on  its
contamination by  2378-TCDD.    (Earlier,  the  U.S. Department  of
Agriculture had  limited   uses  of  2,4,5-T on  food  crops.)   EPA
terminated the  cancellation  proceedings  in  1974,  partly  because
the analytical  chemistry techniques  available  at the time  were
not capable of  measuring 2378-TCDD  in food or the environment at
the low levels  which  could pose a  hazard.   The  Agency  has since
significantly improved   its  analytical  capabilities.   In  1978,
EPA initiated  the  Rebuttable   Presumption  Against  Registration
(RPAR) process  against  pesticide  products  with  2,4,5-T.   In
1979, based  on a  study  of  miscarriage  rates  in Alsea,  Oregon
(where 2,4,5-T  had  been  sprayed on  forest  land) and  extensive
laboratory data demonstrating that  2,4,5-T,  silvex,  and/or 2378-
TCDD cause cancer and adverse reproductive effects  in test animals,
EPA ordered an  emergency suspension  of  2,4,5-T  and  silvex  use on
forests, rights-of-way,  pastures, home gardens,  turf, and aquatic
vegetation.  Other  uses   were   still  being  evaluated under  the
RPAR process.   Dow  Chemical  Company  appealed the  suspension in
federal court  and  lost.  In   1980,  an  EPA administrative  law
judge began consolidated cancellation hearings  on  the  suspended
and nonsuspended  uses  of 2,4,5-T  and  silvex.   These  hearings
were postponed  in  1981  to  allow Dow and  EPA  to concentrate  on
settlement discussions.

   Other programs have also been involved  in regulatory activities
related to dioxin.   Under the  Clean  Water Act  (CWA),  2378-TCDD
is listed as  one of  the 65 compounds  and  classes  of  compounds
which EPA  is  required to control  in  industrial effluents.   To
date, no  national discharge  regulations  have   been issued  for
2378-TCDD, primarily because it has not been detected  in effluents.
The only time  it  has  been measured  in effluents was when EPA's
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 Region  5  personnel measured  it  at the  50  parts per  quadrillion
 level  in  the Dow  effluent.   (Analytical problems may be one  of
 the  reasons  why 2378-TCDD  was not otherwise  detected.)   EPA  is
 working with the  State of Michigan on developing limitations  for
 Dow's  permit.  Under the Clean Air Act,  EPA  is  currently assessing
 the  health  impacts of 2378-TCDD  as  a  hazardous  air pollutant.

   As  an  interim  step  to control the disposal of any  wastes  con-
 taining 2378-TCDD  (defined as wastes resulting  from the production
 of 2,4,5-TCP or its pesticide  derivatives,  or  substances  produced
 on equipment that was  previously used for the production of 2,4,5-
 TCP  or  its pesticide derivatives),  EPA  in 1980 promulgated a  rule
 under  the Toxic Substances  Control Act (TSCA)  which  requires  any
 persons intending  to  move  or otherwise dispose  of  these  wastes
 to notify EPA of its plans 60 days prior to  initiating any action.
 This allows  EPA to review  the plans and ensure that the  wastes
 are  properly managed.   In 1983,  EPA  proposed  to regulate  wastes
 containing any  tetra-,  penta-,   and  hexachlorodibenzo-p-dioxins
 under  the  Resource Conservation  and Recovery Act  (RCRA).   This
 action  will  cover a  wider  range  of wastes  and is  designed  to
 ensure  that  no  future  sites are contaminated  with dioxin  wastes.

   As  this   dioxin  strategy   is  implemented  and  the data   are
 assembled, analyzed,   and  reviewed,  various  regulatory   options
 to prevent   or  control  future 2378-TCDD  contamination  will  be
 evaluated.   Control  options  will  include   new   applications  of
 existing regulations as well as  development  of  new  regulations.
 Such actions as RCRA waste stream listings, CWA  Section 307(a)(2)
•listings, TSCA  Section  6  rules,  and  Clean  Air Act hazardous
 pollutant listings,  and  alternative  management options  (e.g.,
 prohibiting  certain dioxin-containing wastes from land disposal),
 will be evaluated  and  recommendations  to  initiate regulatory
 actions will  be made  by appropriate program  offices.   Programs
 initiating regulatory  actions should  use  the  Dioxin Management
 Task Force as a  steering  committee  for  regulatory  development.

 Management and  Implementation  of  the  Strategy

   The  Assistant  Administrator   (AA)   for  the  Office of Solid
 Waste  and  Emergency Response  (OSWER) under the  direction of  the
 Deputy  Administrator is responsible for  implementing  the  strategy
 including the  periodic  reporting  of progress  to  EPA's  Deputy
 Administrator.  OSWER  will  directly  manage  the  investigations
 and  responses  for sites  in  tiers 1 and 2.  The  Office  of Water
 (OW) has been delegated responsibility for  the overall management
 of the  studies within tiers 3-7.  Within  tiers 3-7, individual
 program offices  will   be  responsible  for developing   study plans
 relating to  their  programs;  for example, the Office of Air, Noise
 and  Radiation  (OANR)   will  prepare the  study plan   for  tier  4.
 The  AA  for OSWER  will  have review and approval authority  for  any
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policy or plans developed by other EPA offices that are implementing
delegated portions of  the strategy.  OSWERwill also have oversight
responsibility for  the  preparation  of  external  correspondence,
testimony and public statements.

   This strategy  reflects  what  is currently  known  about dioxins
and presents  a  general plan  for implementation.    Specific  work
plans for the various elements of the strategy are to be prepared
by the  appropriate  program  officers   in  conjunction  with  the
Regions.  The  actual  detailed  sampling  plans for sites in tiers
3-7 (exclusive of tier 4)  will be prepared by the Regional offices
in conjunction with the States and will  be reviewed  by the appro-
priate program office.   Sampling plans  for sites in  tiers 1 and
2 will  be  prepared by the  Regional  offices in conjunction  with
the States, CDC  and NIOSH  when  appropriate.   The  individual  work
plans are to  be  more  specific than  the  strategy and the detailed
sampling plans are, by nature,  unique to  each  sampled' site;  they
reflect what  is  known at the time  of  their preparation  and the
availability of  resources.  As  time goes  on  and more information
is developed, the  work plans and the  sampling plans  are expected
to reflect  the assimilation of new  information  and go  through
perhaps several changes.   Thus, the strategy  and  the  elements of
implementation (e.g., work plans, sampling plans,  disposal
guidance) will  evolve  as  new  information  becomes  available.

   OSWER has  issued  detailed  interim  guidance (see Part  3  of
this document) to the regional  offices on  how to proceed  with
investigations of  the tier 1  and tier  2  sites.   This guidance
differentiates between the  actual  production sites (tiers 1 and
2) and  the associated  transportation,   treatment,  storage,  and
disposal sites (referred  to as tiers 1A and  2A  in the guidance).
The basic approach  outlined in  the  guidance is first to collect
detailed information  on  each  of the  sites from  EPA  and. State
data bases  and,   if   necessary,  from  site  visits  and  employee
interviews.  Initially, any new field  investigations  (screening)
will be  limited  to tier  1  sites; new  sampling  work  at sites in
tiers 1A,  2,   and  2A  will  be  initiated  after the  information
being collected  has  been  evaluated by OSWER.    Where  the  need
for a clean-up response  is  identified,  initial  efforts  are to be
directed at  getting  potentially  responsible  parties   to  take
appropriate action.   If  prompt  and  appropriate clean-up  is not
assured by  responsible  parties,  EPA will  respond   in   a  manner
consistent with  the  National  Contingency  Plan  and  the Regional
work plans  or  seek to compel response.  The priority for taking
either enforcement  or response  actions at  dioxin sites  will be
determined by  evaluating  the  seriousness  of  the  problem  at the
site relative  to the problem  at all  other  sites  whether  they
include dioxin or not.

   Funding for investigations and  response actions  for sites in
tiers 1  and  2  will  come  from  the Comprehensive  Environmental
Response, Compensation, and Liability Act (CERCLA),  while funding

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for studies  related  to  tiers   3-7   will   come   from  a  special
appropriation for  what  is  referred  to  as  "The  National  Dioxin
Study".  If  contamination  is  detected  at  sites  in tiers  3-7,
the data will  be forwarded to  OSWER for further  evaluation,  in
accordance with the interim guidance.

   Implementation of  the  strategy  will require  close  coordi-
nation with  a  number  of  other  federal  agencies,  including  FDA,
CDC, NIOSH,  and  others.   OSWER is responsible  for ensuring that
proper coordination takes place.  One of the key issues requiring
interagency coordination: is  health  and  environmental  effects
research.  OSWER,  in  conjunction  with  EPA's  Office  of  Research
and Development  (ORD),  is responsible for  developing  an initial
list of research needs.

Background - Toxicology

   Most of  the   available  toxicological  information on  dioxins
is for the  2378-TCDD  isomer,  which has caused lethal and toxico-
logical effects  in  laboratory  animals  at  lower  levels  than
any other man-made chemical.   However,  both  the lethal dose levels
and the  toxicological effects vary  considerably  among  different
animal species.  EPA's Cancer Assessment Group  regards 2378-TCDD
as both  an  initiator  and a promoter of  cancer;  this declaration
is based on  animal  studies rather than  data  from humans.   Based
on its carcinogenic potency,  EP.A estimates  that  cancer  risks  to
individuals exposed to  soils  or  fish contaminated  by  2378-TCDD
could be significant under  certain exposure conditions  which are
probably not widespread.   Thus, estimates  of  national  aggregate
risks cannot be  made with any degree of accuracy until more data
on exposure are collected.

Background - Sources

   A number  of  the dioxins,  including  2378-TCDD, are  formed  as
inadvertent byproducts during the  manufacture  of  certain organic
chemicals, particularly  chlorinated phenols.  The 2378-TCDD
isomer is  formed  during the  production  of  2,4,5-trichlorophenol
(2,4,5-TCP), which  is  a  basic  chemical  feedstock  used to  make
several pesticide products including 2,4,5-trichlorophenoxyacetic
acid (2,4,5-T),  silvex,  hexachlorophene  (a germicide),  ronnel,
and erbon.   EPA  scientists  estimate  that 80 to  95 percent  of the
2378-TCDD which is formed during the  production of these chemicals
ends up  in  the  waste  still bottoms from the toluene distillation
step of  2,4,5-TCP production.   Most  manufacturers  disposed  of
these wastes by  placing  them  in landfills  or  incinerating them;
however, some of  the  still bottoms  may  have been  injected  into
disposal wells or transported for disposal by contractors.   Other
possible releases to the environment  of 2378-TCDD from the  2,4,5-
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TCP manufacturing process include wastewaters generated by contact
cooling and product  separation,  and air emissions  caused  by the
venting of reaction vessels.

   In addition,  the  2,4,5-TCP  product  itself  could have  been
contaminated with 2378-TCDD,  particularly  if  it was manufactured
prior to  the  mid  1970's when  reaction conditions began  to  be
more carefully  controlled.   Product  contamination,  therefore,
implicates sites  where  2,4,5-TCP  was  used   to  make  pesticide
products and,  to  a  lesser  extent,  sites  where  those  pesticide
products were  formulated for final  uses.   Finally,  sites  where
these pesticide products were used  could  also  be  contaminated.

   At the  present  time  there  are no  known  producers of  2,4,5-
TCP in the  United  States; however, more than  a dozen facilities
have produced  it in the  past  and  may  still be  using contaminated
equipment.  A  somewhat larger number  of  facilities  were  involved
in manufacturing 2,4,5-TCP based pesticides,  and perhaps  hundreds
of facilities  were  involved   in   formulating   these  pesticides.
(Part of  EPA's strategy  will be  to  refine  the inventories  of
these facilities.)   Finally,  although past uses  were more  wide-
spread, current uses  of  these  pesticides  are  limited  primarily
to Arkansas and Louisiana rice fields, western rangeland, sugarcane
fields in  Florida,  and  certain rights-of-way as  a  result  of the
1979 suspensions.   However, it is difficult to predict the extent
of future  use  of  2,-4,5-T  and  silvex  even  in  light of  the 1979
suspensions.

   Combustion sources  such  as  municipal  and  industrial  waste
incinerators and accidental  transformer fires  (where  the  trans-
formers contained  a mixture  of  PCBs  and  chlorobenzenes)  have
been implicated  as  sources  of  2378-TCDD  and  other  dioxins.
Generally, levels  of  the. 2378-TCDD  isomer  from  these  sources
have been  relatively  low;  however,  there  is  a  potential  for
increased risk to populations  in  the vicinity  of these  sources.
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                              PART 1

                           INTRODUCTION

Overview

   This strategy  provides  a  framework  for actions  that  EPA, in
coordination with  other  Federal  and  State   agencies,  will  be
taking in  response  to concerns about health  risks  from exposure
to dioxin  contamination  in .the  United   States.    Since  dioxin
contamination may exist in soil, water, and air, several programs
within EPA,  at  both  the  headquarters  and regional  levels,  are
involved in this strategy; States are likewise actively involved.

   There are two primary reasons which have led to the development
of this strategy:  (1)  to  provide a systematic technical approach
in the investigation of sites,  including both chemical production
facilities and waste  sites,  suspected of  beitjg contaminated with
dioxin; and (2)  to determine the extent of environmental contami-
nation pursuant to  an  FY  84  congressional appropriation specifi-
cally earmarked to  conduct  a  "National Dioxin  Study".   Without
this strategy,  EPA's  response  to dioxin  issues might  possibly
become "piecemeal," uncoordinated, and inconsistent, with
priorities being  established by  special  interest  groups  rather
than from  a perspective  which  considers  the  total  situation.

   There are  75  different  chlorinated  dioxins,  divided  into
8 homologues (groups),  each  with different physical and chemical
properties depending on the  number  and  location  of  chlorine atom
substitutions.  One  of  22  isomers  with  four  chlorine  atoms,
2,3,1i8-tetrachlorodibenzo-p-dioxin (2378-TCDD),  is  of  primary
concern because of its extreme toxicity in animals.

   Much information has already been collected on dioxins.  Infor-
mation is  still  being collected, and  response  efforts are being
ta.ken to  reduce  human  exposure  to  dioxins.   However,  unless
these efforts are part of  a systematic national plan, inconsistent
actions could occur,  and information  collected  for  one  purpose
might not be available to others who need it.

   The EPA  dioxin  strategy  provides  for  intensive  study  of
locations potentially  contaminated with  the  most  toxic  of  the
dioxin isomers,  2378-TCDD  (about which the most is  known,  both
on toxicology and  sources).   The other dioxin  isomers will also
be evaluated to determine  whether they merit the same intensive
investigation.  As a  first step in this process, much incidental
information will  be  collected  on these  isomers  as part  of  the
2378-TCDD effort.

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   In addition  to  the  investigation  and  response  activities
called for in the strategy, the 2378-TCDD study will address five
questions:  1)  Where  does  it  come from?   2)  Where does  it  go?
3) What  are  the levels of  concern?  4) Once  it is  in  a medium
at levels  of  concern, what  can be done  about it?   and  5)  What
can be done to prevent -it from getting into the media?

   This strategy  does not  suggest that  2378-TCDD  is the  only
toxic pollutant  the  Agency  must   address.   It may  not  even  be
the most  critical in  terms  of environmental  and  human health
effects.  Therefore,   it is  important  that  the individual program
offices and  the  Regions   implementing  this  strategy  carefully
recognize that  their  efforts  on   this  contaminant  may  impact
resources available for other problems and that resource decisions
affecting this  strategy are to be made jointly  with the program
offices and the Regions.

Approach

   To implement  this  strategy, EPA has  established  seven  cate-
gories (or  tiers)  for  investigation  and/or  study  ranging  from
the most  probable tier  of  contamination   (2,4,5-TCP  production
and waste  sites)  to  the  least.   The  functional  components  of
implementation include:

   a.  a  comprehensive  investigation  leading to  clean-up at the
       most contaminated sites;

   b.  a  national  study  to  learn more   about  the  extent  of
       environmental  contamination; and

   c.  prevention -"of  future  contamination through  development
       of control actions and regulations.

   This strategy addresses  the  most toxic  of the dioxin isomers,
2378-TCDD, and lays out a plan to evaluate the other dioxin isomers
to determine whether the same  type of  intensive  investigation is
necessary.  Some initial screening for other isomers will be done
at some of the sites, including control sites, being investigated
for 2378-TCDD.

   One of  the  most  important  elements  of  this  strategy  is  that
it be  coordinated  with other  Federal  agencies  and  with  States,
as well as  within  EPA.   The dioxin problem  cannot  be adequately
addressed without active  coordination  of all these  groups.   For
example, FDA sets action levels and consumption advisories  for fish
and other consumables, CDC issues health advisories under CERCLA,
and NIOSH sets limits on exposure  in the workplace.  In addition,
the Federal  Emergency Management  Agency  (FEMA)   coordinates  the
relocation of people  during response  actions  under  CERCLA,  and
VA has  developed  a  large  body  of expertise  from dealing  with
veterans on the Agent Orange issue.

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   States in conjunction with  the  Regional  offices will continue
to have  a  major  responsibility in investigating  and  responding
to individual  sites  in tiers  1 and 2  as  they do  under CERCLA.

   The Agency  hopes  to  involve  each   of  these  groups so  that
everyone can  benefit  from  the others'  experience,  knowledge,
expertise, and resources.

2378-TCDD Questions

    1.  Where does it come from?  and 2.  Where does it go?

   For these  two  questions,   EPA  has   set  up  seven  categories
(or tiers)  for  study.   These  include  former production  sites,
waste disposal  sites,   incineration  sites,  formulation  sites,
etc.  Under the  overall direction  of the Assistant Administrator
for Solid Waste and Emergency Response  (OSWER), individual offices
will evaluate  the sources with  which  they   have  the  greatest
familiarity.

    3.  What are the levels of concern?

   National criteria  or action levels  for  2378-TCDD  have  not
yet been established.   The  respective program offices are currently
reviewing three dioxin hazard assessment documents (ambient water
quality criteria  for  2378-TCD.D; health -assessment document  for
dioxins; and health and environmental effects profile for tetra-,
penta-, and hexachlorodibenzo-p-dioxins)  being  prepared by  ORD
to determine the  implications  these  documents have on the dioxin
strategy.  Site-specific assessments have been  made  (the  1  ppb
action level for  soil  at Times Beach,  Mo.), however,  despite the
lack of  national  criteria  in order to  assess the potential risk
to humans at contaminated sites.  In addition, the FDA has estab-
lished a "level of concern" for 2378-TCDD in fish.

   Until such time that further action  levels  are developed, EPA's
OSWER, in conjunction  with ORD, is responsible  for developing a
list of health and environmental effects research needs.  Included
among these needs are standardization of hazard assessment  infor-
mation, establishment  of exposure  scenarios,  and  development  of
a nomograph for converting  from 2378-TCDD levels of contamination
in all  environmental  media  to estimates  of  upper risk  limits
for a variety  of exposure  scenarios.   This  type  of  information
is imperative for the development  of action levels.
                              - 3 -

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    4.  Once it is in a medium at levels of concern, what can
        be done about it?

   Available techniques  are  quite  limited  at this  time.   EPA's
OSWER, in  conjunct ion. with ORD  and the Dioxin Disposal .Advisory
Group, will  be  responsible for  pilot  testing  the  more promising
disposal/destruction techniques.

    5.  What can be done to prevent it getting into the
        environment?

   Since there is no known current production of 2,4,5-TCP in the
United States,  future  production  of   2378-TCDD  is likely  to be
limited to much smaller quantities from such sources as hazardous
waste incinerators,  transformer  fires,  and  possibly  municipal
incinerators.  These assumptions will  be tested during the study.
Under the appropriate regulations (FIFRA, TSCA), EPA will collect
information on any future  production  of 2,4,5-TCP  or its deriva-
tives that are used for pesticidal purposes.  EPA  is committed to
regulatory actions that go beyond existing controls if the results
of this  strategy  indicate that  additional  controls  are  needed.

Other Dioxin isomers

   The Office of  Solid Waste  (OSW) has the. lead  -responsibility
for developing a  program  to  assess the  other  dioxin isomers and
"dioxin-like" compounds.  Activities to be defined in the program
include:  1)  determining the  specific sources  of other  dioxin
isomers,  2) assessing their toxicity,  3) evaluating their environ-
mental fate and transport  properties,  4)  developing  exposure and
risk assessments  based  on the  above   information,  and  5)  recom-
mending appropriate  control  actions.   Implementation  of  this
program is contingent upon available resources.

Comparison of Risks

   In comparing  the  risks posed  by  2378-TCDD with the  risks
attributed to other  pollutants,  it is  important to  identify and
understand the  components  of  risk.   Simply  stated,  risk  is  a
function of  exposure  to a chemical  and  the  likelihood of  some
kind of harmful  effect.  One of the harmful  effects can be cancer
if it  can be demonstrated that  the   chemical  causes cancer in
either laboratory animals  or  humans.   The risk  from  carcinogens
is usually  expressed  in  quantitative  terms  as  a  probability
value based  on  an  exposure  level.    Other harmful  effects  may
include,  for  example,   heart  disease  and   emphysema,  although
quantitative risk estimates  for these  kinds  of effects  are  not
usually expressed in probabilistic terms.

   It is  also  important to discern between individual  risks and
aggregate (population)   risks.   Concern  about  individual  risk
focuses on the  effect  of  a  pollutant on increasing  the  risk to

                              - 4 -

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particular individuals, without regard to the number of individuals
involved.  Concern about aggregrate risk couples individual risks
with the number of  individuals involved -,  and thus deals with the
number of cancer cases which can be prevented.

   The derivation of  cancer risks requires  an  assessment  of the
chemical's potency and  the amount of  the  chemical to  which the
animal is exposed.   Thus,  understanding or  quantifying exposure
is a necessary component in defining risk.   Comparing the quanti-
tative risks associated  with  2378-TCDD with other  chemicals  is
confounded because of the  lack  of  good  exposure information.  We
are, therefore, left with  a  comparison  that  is  qualitative based
on relative  carinogenic  potency,  the amount estimated to  be  in
the environment, and its behavior.

   The quantities of 2378-TCDD produced  and  released  are  much
smaller than other pollutants of concern.   On the other hand, its
toxicity and carcinogenic  potency are  much  greater.   Thus,  for
example, the release  of  2678-TCDD *in past years  is  estimated  to
be about  30,000,000  times less  than  the   release  of  benzene,
4,000,000 times less than carbon tetrachloride,  and 130,000 times
less than PCBs.  On the other hand, carcinogenic potency of 2378-
TCDD, based  on  animal data, is estimated to be 17,000,000 times
greater than benzene, 5,000,000  times greater than carbon tetra-
chloride, and  100,000  times greater  than  PCBs.   The  bioaccumu-
lation potential of  2378-TCDD  is  20,000 times  greater than that
of benzene,  6,000  times greater  than  carbon tetrachloride,  and
4 times greater than PCBs.   Also,  compared to benzene, 2378-TCDD
is very persistent in the environment.

   Based on  what  is- known  about  2378-TCDD  release  and behavior
(i.e., low  levels  of  release,  very persistent,  and  extremely
potent), it  is  believed that  -risks  to some individuals  may  be
significant; however, the  risks may  not  be   widespread.   Conse-
quently, the  aggregate   risk  to  2378-TCDD  would  probably  not
match that of such a  ubiquitous pollutant as benzene  (from gaso-
line) , a pollutant  with  a  large  level of  release  and  a  high
potential for  widespread  human  exposure,   which  is  not  very
persistent and is not a  very potent  carcinogen when  compared  to
2378-TCDD.   -
                              - 5 -

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                              PART 2

                      EPA'S DIOXIN STRATEGY
Study Tiers

    1.  The following tiers (or categories of sources) are hereby
defined based on  a decreasing potential  for  2378-TCDD  contami-
nation; th6y will  be  addressed by this strategy  as  described in
the succeeding sections:

    Tier 1 -  Current   (if  any)  and  former  sites  of  2,4,5-TCP
              production including sites  where wastes were  dis-
              posed.  The  number  of  tier  1 production  sites is
              estimated to  be about   20;   the  total  number  of
              sites to  be  investigated   (production  sites  plus
              was£e disposal sites)  is not presently known.

    Tier 2 -   Sites  (current  and  former)   where 2,4,5-TCP  was
              used as a precursor to make another chemical product
              (e.g., hexachlorophene   production   sites,  2,4,5-T,
              and silvex) including  sites where wastes were
              disposed.  The  number  of tier  2 production  sites
              is estimated  to  be  about  30,  exclusive  of  sites
              where wastes were disposed.

    Tier 3 -  Sites (current and former)  where  2,4,5-TCP and its
              derivatives (e.g.,  silvex)  were formulated  into 'a
              pesticidal product.   An  example  would  be  a  site
              where 2,4-D  and  2,4,5-T were mixed to make  Agent
  *            Orange. - Tier 3  also  includes  sites where  formu-
              lating wastes were  disposed.

    Tier 4 - Combustion sources such as: incineration of hazardous
              and muncipal waste (including sewage  sludge);  wire
              reclamation facilities;  internal combustion engines;
              home heating  units  (e.g.,  wood  burning  stoves);
              industrial, fossil-fuel  fired boilers;  and  inadver-
              tent combustion   sources  such  as  PCB-transformer
              fires.  The number of potential  sites  in this tier
              is estimated to  be  in  the millions.

    Tier 5 -  Sites where  2378-TCDD contaminated  pesticides  have
              been used or are being used  on  a  commercial basis.
              These areas  include  certain  rights-of-way,  rice
              fields of  Arkansas   and  Louisiana,  pastures   and
              and western rangeland,  sugarcane  fields in Florida
              and Louisiana,  certain  aquatic sites,  and  forests
              (e.g., Pacific  northwest).    In addition,   animals
                              - 6 -

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             animals which  have  been grazed  on  treated land and
             fish from treated  waterbodies may contain 2378-TCDD
             residues.

   Tier 6 -   Sites  where  production  of  certain  other  .organic
             chemicals or  pesticides may  have  resulted,  through
             improper quality control,  in  the formation of 2378-
             TCDD.  The total number of production sites in this
             tier is probably less than one hundred.

   Tier 7 -  Control  sites  selected to  evaluate  the  extent  of
             dioxin contamination  in  areas   where  manufacturing
             or extensive use of 2378-TCDD contaminated chemicals
             has not occurred,  information from  these sites will
             be used: (a)  to  compare with  sites  where 2378-TCDD
             is a known  contaminant  and (b)  to  establish "back-
             ground" levels of 2378-TCDD.

Implementation of the Strategy

   Management and Funding

   2.  The AA for OSWER is responsible for implementing the over-
all strategy; he will report directly to the Deputy Administrator
for purposes of this strategy.

   3.  The AA  for OSWER  will be assisted by  three coordinating
groups: (1) the Dioxin Management Task Force (DMTF) ,  (2)  the Dioxin
Chlorinated Dioxin Work  Group (CDWG) and  (3)  its sub-group, the
Disposal Advisory Group   (DDAG)   formerly  called  the  Dioxin Task
Force.  Membership on groups (2)  and  (3) is currently set;  member-
ship on" the  DMTF  shall  be Office Director (OD) level individuals
from Headquarters and  Division   Director  level  individuals  from
the Regions.

   4.  The extent of Headquarters  and  Regional membership on the
DMTF shall be determined by the  AA for OSWER.

   5.  The Dioxin  Management  Task Force  will assist the  AA for
OSWER in  implementing  the  overall  strategy  and  function  as  a
steering committee dealing with  policy  and resource issues.  The
Chlorinated Dioxin Work Group will  continue to provide technical
expertise as necessary  and  the Dioxin  Disposal Advisory  Group
will continue to make technical recommendations about site-specific
clean-up and disposal/destruction options.

   6.  Efforts  conducted in tiers 1 and  2 will be managed directly
by OSWER and funded under CERCLA authority.
                              - 7 -

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    7.  Efforts  conducted  in tiers 3 thru  7  have been delegated
to OW,  in  conjunction  with  appropriate  program  offices.   In
particular, OANR-will  manage the  development  of  a study plan for
tier 4.

    8.  Management of tiers 1 and  2 will result in a comprehensive
assessment of  sites under  CERCLA  authority  leading  possibly to
identification of  responsible parties,  enforcement  actions  and
site clean-up.
                             «
    9.  The program  in tiers 3 thru  7  constitutes  "The National
Dioxin Study" ; it is a  study to learn  more about  the nature of the
problem by sampling  respresentative facilities  and  sites.   It is
'not as comprehensive an investigation as that planned for tiers
1 and  2  which are  thought to represent  over 80 percent  of  the
problem in terms of  levels of contamination.

    10.  Implementation  of  efforts  in  these  seven   tiers  will
proceed in  a   concurrent,  parallel  fashion.   While  the  initial
efforts in tiers  3  thru  7  will take two  years,  the  comprehensive
assessment of sites in  tiers 1 and 2 will  extend beyond two years,
particularly at  sites   where  enforcement  actions  and  clean-up
options are complex.   In addition,  any necessary followup actions
at sites  in  tiers  3  thru 7  where  contamination  is  found  are
likely to extend beyond two years.

    Tiers 1 and 2

    11.  Sites  (both  manufacturing  facilities   and   waste  dis-
posal sites)  in tiers  1  and  2 will be investigated  following the
attached guidance  (Part 3 of this document)  issued by  OSWER.
                    «
    12.  The  interim  guidance  subdivides  tiers  1  and 2  into:
tier 1A  and  tier  2A  which  include  the  transport,  treatment,
storage,  and  disposal  handlers or  sites  used by  tier. 1  and tier
2 facilities.   A primary objective  of the interim guidance is to
set forth a  process for defining the dimension  of  the  universe
to be investigated in these tiers.

    13.  A second  objective of this  interim  guidance  is  to make
certain that the Agency's limited  sampling resources are initially
focused on the most serious sites.   Regions are therefore directed
to place primary emphasis  on tier 1 sites,  and  later, on tier 1A
sites.  New  sampling  at  tiers  1A,  2,  and  2A  sites should  be
delayed,  where  it is  not   inconsistent  with prior  commitments,
until the  size of  the  universe  for  both  tiers (1  and  2)  are
better defined.
                              - 8 -

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   14.  The interim guidance  directs  Regional activities through
several phases: an information collection phase, a field investi-
gation phase and a  response  phase.   Also included in the interim
guidance are sections  which  provide guidance  on community rela-
tions, enforcement  procedures,  and  guidance  on  disposal  alter-
natives.

   Tiers 3 thru 6

   15.  Because of  the large number of  sites to be investigated
for 2378-TCDD  in  these  tiers,  sampling at  every  site  is  not
practicable.  One of the first steps will be to list, using avail-
able-data,  all  facilities/sites  in   these   tiers.   Preliminary
lists for tiers 3 and  6 have  been  developed  by OW in conjunction
with the  other program  offices  and  the  Regions.  These  lists
cannot be completed  in final form  until the  results from infor-
mation collection  forms have  been  received  and  all  facilities
can be assigned to their proper tier.

   16.  The  field  investigations to  be done  at, tiers   3  thru  6
over the  next  two  years (FY  84  and 85)  will be  from  a  selected
sample of  sites based on a sample  frame  developed  by  OW,  in
conjunction with the   Regional  offices  and  EPA  program offices
(e.g., OANR).  The development  of  the sampling  frame  for tier 4
— combustion sources — will be managed by OANR, with assistance
from ORD.   They  will  be  supported by  OSWER for  designing  the
sampling frame  for  hazardous  waste  incinerators  and   OPTS  for
evaluating municipal waste incinerators.

   17.  The initial  sampling to be done at  tiers 3 thru  6  will
be funded through an FY 84 appropriation of  $4 million which has
commonly been  referred to  as  "The  National   Dioxin  Study";  "this
appropriation is directed  to OW,  which will  allocate  resources
to the Regions and program offices  based on  anticipated  sampling
requirements.

   18.  OW,  in  conjunction  with the  other  program offices  and
the Regions, has  prepared  a  preliminary work plan  availble  for
review for  the  "The   National  Dioxin  Study".   This  plan  will
describe the "universe" of sites in each of  the tiers,  the basis
for site  selection,  tentative  schedules,  and  arrangements  for
sample control.
                              - 9 -

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   19.   In developing the  sampling  plan  for tiers 3, 5 and  6,  it
 is anticipated that multi-media  samples  will be taken at  sampled
 sites,  including samples of water, aquatic sediments, fish, soils,
 groundwater, vegetation, air, and waste  streams  (liquid, gaseous,
 solid)  as  appropriate.   Once  the preliminary  sampling  plan has
•been  reviewed,  the Regions  will then develop  detailed  sampling
 plans  (e.g., number  of  samples  per media)  for  the  initial  sites
 to be  sampled  by  March 1,  1984.  Once  the detailed  plans are
 reviewed by  the  appropriate  program office, the  Regions  will  be
 responsible  for  initiating field  sampling.

   20.   Sampling at facilities in tier 4  —  combustion sources  —
 will  include  source  sampling  for air emissions  and ambient air
 and will draw  upon  information  'already  available   from previous
 sampling efforts (e.g., OPTS source sampling of municipal  incine-
 rators).  Ambient  samples of other media  (e.g., fish, vegetation,
 and soil) may  be taken  as needed.  OANR in conjunction with the
 Regions  is responsible  for developing the sampling plan at tier 4
 facilities.

   21.   Funds available for "The  National Dioxin  Study" are  to  be
 used  primarily to  establish  whether sites  in  tiers  3 thru  6 are
 contaminated with  2378-TCDD.   The  object   of  the  study  is  to
 learn more about 2378-TCDD contamination  at  sites in these tiers.
 If 2378-TCDD  is  detected  at  a  site  during the  study,  the  data
 will  be  forwarded  to. OSWER for  further•evaluation.   Also,  there
 may be  reasons,  such as public  requests  and requests from  state
 governments, to  sample  sites  in tiers  3  thru 6 that are not  part
 of the  sample  design.  Any  activity  at   these  sites will  be  in
 accordance with  the  interim  guidance and   coordinated  with the
 appropriate program office.

   22.   It must  be emphasized  that,  although sites "found to  be
 contaminated in  tiers   3  thru  6  will  be  referred  to OSWER for
 possible CERCLA  action,  such referrals  do  not  necessarily  imply
 immediate response, remedial actions or  enforcement.  These
 referrals will have to  be  considered  along  with all  of the  sites
 in tiers 1 and  2  based on  a  schedule for  response  developed  by
 OSWER.

   23.  While the  Office  of  Water has been delegated the overall
 lead  in  implementing  "The National Dioxin  Study",  the interpre-
 tation  of  results  and decision  to  take  actions  (e.g.,  remedies,
 and control  actions)  is  the  responsibility  of  the respective
 program offices.
                              - 10 -

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   Tier 7 - Control Sites

   24.  Tiers 1  thru 6  represent  sites or areas  where contami-
nation with 2378-TCDD is either known or suspected.  A portion of
the samples to be taken at these tiers will be ambient samples of
suspected contaminated media,  such as  aquatic  sediments,  soils,
fish, vegetation and  groundwater.   These samples  will  be useful
in establishing the extent of outward migration of 2378-TCDD from
a source that is shown to be contaminated.

   25.  EPA believes it is equally important to assess the extent
of environmental  contamination of  2378-TCDD  by   taking  ambient
samples at  sites  not suspected  of being directly influenced  by
known sources of  2378-TCDD.   This may  be considered  an attempt
to establish  what  many  call  a  "background"   concentration,  and
also serves to  provide  discrete data  which address  the  general
perception that  2378-TCDD  contamination  may  be more  widespread
than previously documented.  A portion of the special appropriation
for "The  National  Dioxin  Study"   is  specifically  earmarked  for
this work.

   26.  Pursuant to  this, the  Office  of  Water,   in  conjunction
with Regions  and  Headquarters  program   offices,  will  develop  a
sampling plan  designed   to   determine   the  extent  of  2378-TCDD
contamination at various control sites.

   27.  The  sampling in  tier  7  will  include  two phases.   The
first phase will be  to  collect  a number of  soil,  fish and stream
sediment samples at  about  20  control  areas.   These  areas  could
be towns, sections  of cities,  or  rural  areas.  These sites will
fall into  five  categories:   1)  chemical production areas  (other
than areas in tiers  1-6), 2) other industrial areas, 3) commercial/
residential areas,   4)  agricultural  areas,  and   5)  undisturbed
areas.  The initial candidate list of sites will  be developed  by
OW based, in part,  on recommendations by the  Regions.   Once  the
actual sites have  been  chosen, detailed sampling plans  will  be
developed by the Regions in conjunction with the States.

   28.  The second phase of  sampling  in tier  7  will be to sample
organisms in streams  located throughout the United States,  open
waters of the Great  Lakes,  and estuarine waters.   Stations  will
be selected which characterize  conditions throughout the drainage
basins.  A  preliminary  list of  stations  has been  sent to  the
Regions for their  review.   After  review  and  final selection  of
stations, the  Regions  will  be  responsible  for   collecting  the
specimens. Initial sampling will be whole  fish composites  of  the
same species, preferably bottom feeders.  If significant contami-
nation is detected, analyses of fillets  and stream sediments  may
be warranted.
                              - 11 -

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   29.  Detailed  guidance   (e.g.,  site  selection,   sampling  and
preservation methods) for  tier 7  sampling  will be  issued  by OW
after the "National Dioxin  Study"  plan has  been reviewed.   It is
anticipated that this guidance will  be  available by December 31,
1983.

   30.  Control  sites  which  show  2378-TCDD contamination  will
be evaluated by the Office of Water and the Regions to establish,
if possible, the source of  contamination.   The  data  will also be
forwarded to OSWER for additional evaluation.

   31.  This strategy  acknowledges the current  proposal  by OPTS
to measure  dioxin  (and furan)  levels  in  human  adipose tissue,
although at this  time  this effort is judged  to be  outside the
scope of  sampling  and  funding  pursuant  to  "The National  Dioxin
Study".  Nonetheless, EPA  recognizes  the  value  of this proposal,
therefore appropriate funding mechanisms  will  be investigated by
OPTS.

Field Sampling

   32.  Field  sampling  for  all tiers,  except  tier  4,  will  be
implemented through the EPA Regional offices.

   33.  Field  investigations  at  sites  in  tiers 1  and  2  shall
continue to use, as  necessary,  the Superfund contractors as well
as the  Technical  Enforcement  Support  (TES) contract.   Wherever
possible, responsible  parties  may  be  involved  in  conducting
field investigations at the direction of the Regional  Office in
conjunction with States.

   34.  Field  investigations  at  sites  in  tiers  3.,  5,  6,  and  7
will be conducted by the Regional Offices employing those
mechanisms they deem appropriate.   For example,  Regions  may use
contractors, their  own  Regional  personnel, or may  arrange  for
the States  to  perform the field  sampling.   Whatever choice  is
made, the individual sampling  plans to be developed by the Regions
for tiers  3,  5, 6,  and  7  are  to  indicate  the  arrangements for
field sampling.

   35.  Sampling at  sites  in tier  4  shall  be  arranged  by  OANR.
They may  use   contractors  or  a  combination  of  contractors  and
Regional/State personnel.

   36.  Whenever it is judged to be necessary,  appropriate health
and safety precautions shall be used during field sampling.   This
may require the use of  personal  respirators  and other  similar
equipment.  The individual  sampling plans, prepared by the Regions,
should indicate the need for such equipment.
                              - 12 -

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   37.  Arrangements for  laboratory  analyses  will be coordinated
through the  "Dioxin- Sample  Control  Center".   This  center,  for
purposes of  this  strategy,  will  combine  some  of  the  functions
currently being  provided  by  OSWER's  Sample  Management  Office
(SMO) and OW1s Sample  Control  Center.  The Dioxin Sample Control
Center will  also be  responsible  for: (1) providing documentation
of the analytical methods including  procedures for quality control
and quality assurance and (2) entering the results into a central
data system  after   they  have  been   checked  by  the  Regions  and
States.  Specific details on these*arrangements will be available
for review by January 15, 1983.

   38.,  This  strategy  reflects  what  is  currently  known  about
dioxins and presents a general plan for implementation.  Specific
work plans  for  the  various  elements of  the  strategy are  to be
prepared by  the appropriate  program offices in  conjunction with
the Regions.  In turn, the Regions will prepare detailed sampling
plans unique to each sampling site.   Both work plans and sampling
plans will reflect  what is known at  the time of their preparation
and the  availability of  resources.   As  time  goes  on  and  more
information is developed,  the  work  plans  and the  sampling plans
are expected to reflect  the  assimilation  of  new information and
go through perhaps  several  changes.   Thus, the  strategy  and the
elements of  implementation (e.g., work  plans  and sampling plans)
will evolve as new information becomes available.

Analytical Issues.

  ' Sampled Media
   39.
in tiers
soil, stream
        Generally,  multi-media  sampling  will be  done at  sites
        i  1  thru  7,  including,  but  not  limited  to,  samples  of
	,  __ream sediments, groundwater,  surface  water,  ambient air,
wastewater discharges, air emissions,  fish,  and  other biological
specimens (e.g., vegetation)  as  appropriate for the site.

   40.  The  specific  media  to  be  sampled will,  of  course,  be
dictated by the  type  of facility  or  site in  a  particular tier.
For example, sampling of waste  sites  associated  with tiers 1 and
2 (tiers 1A and  2A) will likely be limited to soils, groundwater
(if the  site  is  near  an  aquifer  currently  used  as  a  drinking
water supply), and  surface  water,  if  nearby.  Specific  sampling
plans, developed  by  the  Regions in  conjunction  with  the  States
whenever appropriate,  will  spell   out  the types of  media  to  be
sampled.

   41.  In  certain  circumstances  it may  be prudent  to composite
or pool  samples  in order  to  increase the sampling  area  without
substantially increasing the  number of  samples  to  be analyzed.
Compositing and  pooling  can, however,  dilute the  concentration
in the  pooled  or  composited  sample,  therefore,   care  must  be
used in making this decision.
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   Detection Limits

   42.  Soil  samples  collected  during  screening   at  sites  in
tiers 1, 2,  3,  4,  and 6 will be  analytically  measured for 2378-
TCDD using methods that will  result  in a parts per billion (ppb)
detection level.   In  certain  cases  sub-ppb  detection  limits  can
be achieved  depending  on  the  sample  volume and  the  extraction
efficiency.  Follow-up  investigations  at contaminated  sites  may
require soil analyses  at  the parts  per trillion (ppt) detection
limit, depending on the circumstances of contamination and
potential for -human exposure.

   43.  Soil samples collected at tiers 5 and 7 will be
analytically measured  for  2378-TCDD  using  methods  that  will
result in  a  ppt detection level.   Since  these  tiers represent
areas where "background" levels of 2378-TCDD are being evaluated,
ppt level of detection is judged to be necessary.
                                                          «.
   44.  Samples  of  stream  sediments,  fish,   other  biological
specimens (e.g., vegetation) and  waste streams (liquid, gaseous,
solid) will be  analytically measured  for 2378-TCDD using methods
that will result in detection levels in the ppt range.

   45.  Samples  of surface water,  groundwater,  and ambient  air
shall be of  sufficient volume  to permit  parts  per quadrillion
(ppq) level of detection.   '

   Laboratory Resources

   46.  EPA1s  ORD  and OPTS  will  provide  analytical  services
for all  samples collected  in  tiers  3  thru  7;  control  of these
samples will be  accomplished through OW s  Sample Control Center.
The analytical  services  will be  managed by EPA's  Environmental
Research Laboratory in  Duluth,  MN,  and  will provide analyses  of
150 samples per  month  for  two  years,  the length of the "National
Dioxin Study".  .  Requirements for  ppt  and ppq analyses  beyond the
two years should be fulfilled by  a  sufficient  number of contract
laboratories that  are  anticipated to be in  a  position  to  do  the
required work by that  time.

   47.  ORD  will  select   appropriate  sampling  and  analytical
methods and  QA/QC  specifications for  2378-TCDD  analyses  in  all
tiers.  These methods  will be  documented by  the  Dioxin  Sample
Control Center  and circulated  for  review by  January  15,  1983.
Interim analytical  methods and  QA/QC  procedures  for  2378-TCDD
analyses are described  in  an ORD document  dated July  27,  1983.
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   48.  EPA's  OSWER  will begin  to develop the  requirements for
low detection  level   dioxin  analyses,   including  the  necessary
arrangements to  certify/qualify  contract  laboratories  and  to
provide for  contractual mechanisms  in  order  that  Regions  and
States can have samples processed at the ppt and ppq level beyond
the two-year life of  the ORD analytical commitment.

   49.  The  Regions/States   can  continue  to  use  the  National
Contract Lab Program  as described in the  Interim  Guidance (Part
3 of this document)  for sampling  conducted  at  tiers 1 and  2 or
they may use the  ORD/OPTS  analytical services for  samples to be
processed at the ppt  or lower detection limits.   Samples destined
for a  contract lab  should   be  controlled  through OSWER1s  SMO.
During screening investigations,  soils  are  to be measured at the
ppb level of detection, and other samples (e.g., fish,  sediments)
are to be measured at the ppt level of detection.

   50.  Because of the large number  of samples to  be  collected
from tiers  1 through 7, the  priorities for analytical work may
at some point  become an issue.   The basic  goal  and  the function
of the  Dioxin   Sample  Control  Center   is  to make certain  that
sampling episodes  will be  consistent  with the analytical  pace
and capacity so that  samples  are processed  as  quickly  as  they
are collected.   In the  event  a  backlog  occurs,  samples from the
lower numbered  tiers  (tiers  1, 2, and 3) take priority.

   51.  This  strategy  recognizes  that  because.'.the  number  of
potentially contaminated sites has not been enumerated,  the total
number of samples to  be processed cannot be accurately estimated.
Thus, samples  collected from all  seven tiers could  conceivable
outstrip current analytical  capacity.   It is important, therefore,
to understand  that if  this  happens,  increasing  laboratory capa-
bility may require additional resources and time.

   Analyses for Other Chemicals

   52.  Analyses for  other chemicals  (e.g., other dioxins,  furans,
PCB's, chlorophenols) in addition to 2378-TCDD may be appropriate
at certain  sites,  including control  sites  (tier 7).   While the
National Dioxin Study  principally  focuses  on  2378-TCDD, sampling
and analyses for  other chemicals may  be reasonable in order to
make cost-effective use of field and laboratory resources.

   53.  The decision  to analyze for  other  chemicals  will  be made
on a case-by-case basis  by  OSWER for sites in tiers 1  and 2 and
the Office  of  Water  in tiers 3  thru 7.  Decisions will  be  made
in conjunction   with   the Regions and   coordinated  through  the
respective offices.  All analytical extracts processed under this
strategy will  be held  for possible subsequent analysis  for other
chemicals and other dioxin isomers.
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   54.  The  analytical  service  to  be provided  by  ORD  of  150
samples per month is based  on  a scheme whereby tetra-class  dioxins
are initially analyzed.  Should  there  be  the need to analyze for
other dioxins or other chemicals, the need must first be approved
by the appropriate  program office  since analyses  for other than
tetra-class dioxins  will reduce the  sample capacity of  the ORD
laboratories.  For  this  reason, sufficient sample  volumes will
be taken  to  allow   for  subsequent  analyses  of  other  dioxins,
furans, or other chemicals as appropriate.

   55.  The sampling plan  to  be  developed  by OSWER for the other
dioxin isomers may  include some of  the  same sites  that  will  be
sampled during the  National  Dioxin Study.   Until  such  time that
the sampling  plan   for  the  other  dioxin  isomers  is developed,
duplicate samples should be  collected from  the  sampled  sites of
the National  Dioxin  Study.  One sample will be  measured for the
tetra-class dioxin isomers and the other sample held  for possible
inclusion in  the  scheme  to  study   the   other  dioxin  isomers.

Assessment of Data

   56.  The data  obtained  from  sites  sampled in tiers  1  thru  7
(exclusive of tier 4) will  be assembled by  the respective Regions.
The Regions,  in  conjunction  with the program  offices,  will then
prepare a report for each sampled site which summarizes available
information including the  analytical  results;  analytical results
will be  sent  directly  to  the  Regions from the  Sample  Control
Center.  This  report,  to  be  completed  within  one month  from
receipt of all the analytical data, should also contain recommen-
dations from the Regions on follow-up activities.

   57.  Reports on  sites in tiers 1  and  2  will  be  forwarded to
OSWER for review, comment, and assessment  of  follow-up actions.

   58.  Reports on  sites  in  tiers  3 thru  7  will  be  forwarded to
OW and OSWER  for review  and  comment.   Reports on  sites in tier 4
— combustion sources — will be prepared by OANR with assistance
from the Regions where the  combustion sites were sampled.

   59.  Sites in all tiers that are determined to be contaminated
with 2378-TCDD will  be further  evaluated  by OSWER  to  determine
the need  for  further sampling and/or  response.   As  stated pre-
viously and emphasized again, referring a  site to OSWER does not
necessarily imply immediate response,  remedial actions or enforce-
ment.   The timing of  actions  must  be consistent  with the degree
of contamination and potential  health  risk  of  the  site  when
compared to other contaminated sites.
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   60.  Whenever  it  is  determined  that  there  is  sufficient
sampling to demonstrate  that  2378-TCDD contamination constitutes
a potential public  risk, the Regions In  conjunction  with OSWER,
as described  in the  Interim Guidance,  will  immediately notify
the appropriate officials  including,  but  not necessarily limited
to, State  officials  (particularly  health  officials)   and  CDC.

   61.  CDC  and FEMA  will  continue  to  work through  the  OSWER
program office  as  defined  in  the  Executive Order  pursuant  to
.CERCLA and redelegation  agreements pursuant thereto.

   62.  The  Regions  are  initially  responsible  for   compiling
and reporting the data  which will be  collected  pursuant to this
dioxin strategy.  To  effectively manage  the  data  and facilitate
the review by the Regions and the program offices, centralization
of the data  is  essential.   Pursuant  to  this  need,  EPA's STORET
system will be  used to  store and retrieve  the dioxin data  which
will be  collected  from  all  tiers.   The  Dioxin  Sample Control
Center will,  after   first  reporting  the  analytical  results  to
the Regions, enter  the  results into  STORET.   Access  to the data
will be  limited  based   on  guidelines  developed  by  the  Sample
Control Center  in  conjunction  with- the Regions and  the program
offices.

   63.  The  development  of   site-specific  response  actions  or
enforcement at  contaminated  sites will be  managed  by  OSWER  in
conjunction with respective Regions and other Federal/State
agencies involved with the site.  If appropriate, the Chlorinated
Dioxin Work -Group and  its  subgroup,  the Dioxin Disposal Advisory
Group shall  review  disposal/destruction   related  activities  at
these sites.

   64.  OW  in   conjunction  with  the  other  program  offices  and
the Regions  will  assess  the extent  of  2378-TCDD  contamination
in tiers 3  thru  6.   The basis for this assessment  will  be  developed
from the information  collected  at the  sampled sites  and must  be
consistent with the overall sampling frame.

   65.  OW  will  also  evaluate  the  data  collected   at tier  7
sites.  This information, plus  the site specific information from
sampling tiers  1  thru 6, will  be the  basis  for determining the
extent of environmental contamination of 2378-TCDD.  This overall
determination shall be made jointly by OSWER  and  OW in conjunction
with those  program  offices  that  have  major  assignments in  the
strategy and the Regional Offices.
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   66.  Pursuant to the  special appropriation  for  "The National
Dioxin Study," OSWER and OW in conjunction with the other program
offices and  the  Regions  will  prepare  a  report  which  documents
the extent of environmental contamination  based  on the information
obtained pursuant to this strategy.  This report shall be forwarded
to the Deputy  Administrator and made available to  the  public by
December 31, 1985.

Regulatory Initiatives

   67.  As  stated  previously,  this  strategy is  being  developed
to study the extent of  dioxin  contamination, implement  necessary
remedial actions  at  hazardous  sites,  and  evaluate  regulatory
actions to  prevent  future  contamination.   EPA  has  a  strong
commitment to  regulatory  actions  if  necessary  to  ameliorate
existing problems or to prevent  future  ones.   The  very  nature of
2378-TCDD, however, makes  regulatory  development  an  especially
difficult process.      „

   68.  EPA  is committed  to publishing the three  dioxin  hazard
assessment documents recently  reviewed  by a  peer  group  of  scien-
tists in Cincinnati, OH.   While  the documents  are  not  regulatory
actions per  se,  they can have  regulatory implications for  the
affected program offices.   The  affected offices are to  carefully
evaluate these criteria documents and develop, where appropriate,
regulatory initiatives  that  are  consistent  with  this  dioxin
strategy.

   69.  As the data are  assembled,  analyzed,  and reviewed, various
regulatory options to  prevent or control future  2378-TCDD contami-
nation will  be evaluated.   Such  actions as  RCRA  waste  stream
listings, CWA Section 307(a)(2) action, TSCA Section 6 rules, and
Clean Air Act  hazardous pollutant  listings,  for example,  will be
evaluated and  recommendations   to  initiate  regulatory  actions
will be made by appropriate program offices where the da-ta justify
regulations.  Equally important will be the evaluation of current
permit authorities (e.g.,  underground  injection,  ocean  disposal)
to assess whether changes are necessary.  The Agency will explore
utilizing the Dioxin Management Task Force as a steering committee
for regulatory development related to dioxin.

   70.  On  April  4,  1983,  EPA  through  its  RCRA program  has
proposed adding  the  following  waste  streams  to  EPA's list  of
hazardous wastes:

   (a)  The production and  manufacturing  use of tri-,  tetra-, or
        pentachlorophenol and intermediates used to produce their
        derivatives;
                              - 18 -

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   (b)  The manufacturing  use of tetra-,  penta-,  or hexachloro-
        benzenes under alkaline conditions;

   (c)  The production of  materials  on equipment previously used
        for the  production  or  manufacturing  use  of  materials
        listed under (a)  and (b) above; and

   (d)  Discarded  unused  formulations  containing  tri-,  tetra-,
        or pentachlorophenols,  or  discarded unused formulations
        containing compounds  derived  from these  chlorophenols.

   Under RCRA,  the  Agency  has broad  authority  to  regulate  all
aspects of hazardous  waste management  (i.e.,  generation;  trans-
portation; treatment/storage/disposal).   The  proposed  rule  for
active facilities will impact  the  response by the  Agency  to the
contamination sources in each of the tiers.

Remedial Actions at Contaminated Sites                   .

   71.  Based on the information obtained and analyzed from sites
sampled in tiers 1 thru 7,  short  and  long-term clean-up strategies
will be implemented or compelled at those sites where dioxin con-
tamination is judged  to  warrant action.  This judgment  shall be
made by OSWER with technical assistance from CDC, the Chlorinated
Dioxin Work Group, ORD, the Regions and the affected States.  Clean-
up activities w.ill proceed in accordance with the interim guidance
and the  National  Contingency  Plan.   The  priority  for  taking
either enforcement  or  response actions at  dioxin   sites will  be
determined by evaluating  the seriousness  of the problem  at that
site relative to the  problem  at all  other  sites   whether  they
include dioxin or not.

   72.  Presently, alternatives which  appear to  be  most  suitable
for uncontrolled sites are listed below:

   A.   Secure soil in place — in situ soil fixation, subsurface
        perimeter grout  curtain,  impermeable  cap,  diversion  of
        surface runoff,  resident  relocation from  immediate  area
        and monitoring.

   B.   Consolidate and secure soil — removal of soil to secure
        landfill; or  containment of  soil  in  a  concrete  vault,
        possibly on-site.

   C.   Incineration — following excavation and  transportation,
        a size reduction process is required before incineration.

   D.   Solvent Extraction — solvents would be used to extract
        dioxin from  the   soil  into  a  soluble   form.   Several
        different technologies  could  then be  used  to  destroy
        the dioxin.
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   73.  OSWER,  in  conjunction  with  ORD and  the  Dioxin Disposal
Advisory Group  (DDAG),  will  be responsible for pilot testing  the
'more promising disposal/destruction techniques.  A specific
research agenda shall be developed by December 20, 1984.

   74.  Several important  questions  need to be addressed through
pilot studies  before  these alternatives can  be  fully  evaluated.
For example,  to destroy  dioxin,  the  treatment  technology  must
first break the dioxin/soil particle  bond.   In doing so, partially
treated residues, or contaminated materials which may be released
during processing,  have the  potential   to  spread contamination.
Therefore, ORD will consider including a  sorption/desorption study
on contaminated soils as part of its research agenda to determine
dioxin release  rates.   While  these  treatment  technologies  may
present the  ultimate  solution to  contaminated media,  they could
present significant health risks during  processing.  Thus, during
the pilot testing  phase,  the potential  for further contamination
must be assessed.

   75.  Based upon  the  success of  the pilot testing phase, OSWER
staff in conjunction  with ORD  and the   DDAG  will  recommend  full
field validation projects to the AA for  OSWER.  Upon approval, ORD
will implement  the  full field validation  studies in conjunction
with the Region where testing is to occur.  Full field validation
work should commence by July 1985.

   76.  The  results of pilot  testing  and  full  field  validation
will be reported to OSWER.  These  results will be used to support
specific guidance concerning  the alternatives for clean-up given
specific conditions of contamination and exposure.  This guidance
will be used  in deciding  upon  final  clean-up options at specific
contaminated sites.

Health and Environmental Effects of 2378-TCDD

   77.  EPA  realizes  that  much remains  to be discovered  about
the effects of 2378-TCDD on both human health and the environment.
The development of  specific  action  levels  is  hindered  by  this
fact.  This strategy recognizes that additional work must be done
in this area and the information integrated into an authoritative
view of the risks,  including development of action levels associ-
ated with exposure  to  2378-TCDD.   Delaying the  implementation of
this strategy until final action  levels are developed, however,
is not believed to  be in the best public interest.
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   78.  Some  of  the  studies  to be  conducted are  short-term in
nature and appropriately managed  by EPA; other  types  of studies
are longer-term and  are  beyond  the  purview  of EPA.  Thus, inter-
agency coordination  in  this  area is essential.   For purposes of
intra-agency coordination, OSWER, in conjunction with ORD and the
program offices,  will develop  a list  by  February  15,  1984  of
specific health  and  environmental  effects  research  needs  that
will assist  EPA  in implementing the  elements of  this strategy.
This list will also  be  used to  assist  in coordination with other
Federal agencies.

   79.  The  following short-term activities  are  to  be conducted
by ORD with assistance from CDC and the affected program offices:

        A.   Using best data at hand (carcinogenicity and repro-
             ductive  effects)   ORD  will  continue to  coordinate
             hazard assessment  techniques  used by EPA in making
             site-specific risk assessments.

        B.   ORD in conjunction with the CDWG will establish
             exposure scenarios to estimate exposure under
             various  conditions likely to be encountered at
             tiers 1  thru  6.   A report  is  to  be  completed  by
             July 1984.

        C.   ORD will'develop a nomograph for converting from
             2378-TCDD levels of  contamination- in environmental
             media to estimates of upper risk  limits for a variety
             of exposure  scenarios;  a  final  product  will  be
             completed by July  1984.   ORD  will  provide guidance
             to the Regions and States on use of exposure
             nomographs; this  guidance  will   also be  available
             by July  1984.

   80.  The  respective  offices  will   review the  three  dioxin
hazard assessment  documents  being  prepared by  ORD and determine
the implications  these  documents have  on  the  elements  of  this
strategy.  This review is to be completed by January 1, 1984.  In
addition, OW  and  OPTS will work  with  the  FDA and the U.S.  Fish
and Wildlife  Service  in assessing  the  relationship  between the
FDA action levels  for 2378-TCDD in  fish and the proposed ambient
water quality  criteria.   Any conflicts  between  the  two  numbers
are to be identified  and resolved, if possible, by March 1, 1984.

   81.  EPA's  ORD  will  study   the  bioavailability   and  uptake
mechanism of  sorbed  2378-TCDD.   ORD will  also  investigate  the
transport and transformation processes  (bioaccumulation and  bio-
magnification) of  2378-TCDD  in  fish,  sediments, and  plants  for
use in food  chain  models  and  establishment of acceptable levels.
ORD will develop  a time frame  for  these  activities  and identify
resource needs by February 1, 1984.
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   82.  The  following  research  items are judged to be  of suffi-
cient importance to the strategy that they should be specifically
identified in  any  inter-agency  meetings that  are conducted  to
initiate health research:

        A.   Understanding the pharmacokinetic mechanism of
             2378-TCDD induced toxicity  to  determine  differences
             between species in response to 2378-TCDD.

        B.   Understanding and developing the toxicological
             and analytical relationship between 2378-TCDD
             and "2378-TCDD equivalents" in complex mixtures
             for more  rapid  and  less   expensive  determinations
             of 2378-TCDD levels and effects.

        C.   Conducting epidemiological studies at contaminated
             sites to  provide better  information  of   risks  for
             regulatory decisions.  This work will help establish
             the cause/effect relationship of 2378-TCDD to
             human disease.

Other Dioxins and Dioxin-like Compounds

   83.  A number of  halogenated  compounds  related to  dioxins are
thought to be  almost  as  toxic as 2378-TCDD.  They therefore have
the potential for causing significant exposure and risk problems.
Among these  compounds,  the halogenated  dioxins  and  furans  with
chlorine or bromine  atoms  at  positions  2,3,7,  and 8,  and with at
least one hydrogen atom on  the dioxin or furan  structure, are  of
special concern.   These   halogenated dioxins  and  dibenzofurans
are inadvertent by-products  of  a number  of production processes
involving halogenated phenols, and are thought also to be created
in the course of combustion  of a variety of halogenated aromatics.
The production  and  use  of pentachlorophenol, and  of  other halo-
phenols and of  their derivates,  and  of  polybrominated  biphenyls
and biphenylethers, are also of concern.  In addition, combustion
of these compounds could, under certain conditions, create
"dioxin-like" compounds.

   84.  As part of  this  strategy's  approach to dioxin the Dioxin
Management Task Force, in conjunction with the Chlorinated Dioxin
Work Group will develop by January 15, 1984, a work plan to study
the other dioxin  isomers  and  "dioxin-like"  compounds.   The acti-
vities to be  included in the  work  plan are:  1)  determining the
specific sources of other dioxin isomers  and dioxin-like compounds,
2) assessing  their toxicity,  3)  evaluating their  environmental
fate and  transport properties,  4)  developing  exposure  and  risk
assessments based  on  the  above information, and  5)  recommending
appropriate control  actions.   Implementation  of  the   work  plan
will be dependent on resource availability.
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   85.  Existing  information,  and  chemical  structure  analysis,
will be  used  to  investigate  the  sources  of  these  compounds.
First priority  will  be  given  to investigating the  contribution
from combustion and  chemical  manufacturing  sources.   Following
source identification,  a  sampling   plan  will  be  developed  to
evaluate these suspected sources. The  sampling plan will identify
the processes  which  are  also  sources  of  2378-TCDD; thus,  much
dual sampling will be avoided.

   86.  In order  to  take advantage  of  the  sampling  effort being
conducted for  2378-TCDD,  the  Regions  will  collect  sufficient
sample volumes  to analyze  for both 2378-TCDD  and  the  "dioxin-
like" compounds at  those  sites   sampled in  tiers  1 through  7.

   87.  As part  of  the  development  of  an  inter-agency  program,
EPA's ORD  will coordinate  with  the   other  Federal   agencies  in
developing a  research  program  by April  1984  which  addresses the
toxicology of  the other dioxin  isomers  and the  "dioxin-like"
chemicals.  Additional  toxicity  data  are  needed,  especially for
possible carcinogenic, reproductive, and teratogenic effects, and
bioavailability of  the  halogenated dioxins  and  dibenzofurans.

   88.  During FY 84,  ORD will work with CDC, the U.S.  Fish and
Wildlife Service,  and other Federal agencies to develop analytical
protocols to measure  "dioxin-like" chemicals in biological tissues,
waste emissions, and environmental media.  Interim protocols will
be completed by September 1984.

   89.   ORD will  explore the development and validation of bio-
analytical techniques  for  estimating   the  toxicity  of  complex
mixtures containing  2378-TCDD  and  "dioxin-like"  compounds.   It
is expected that such methods will reduce  the need for  the expensive
and resource-intensive  isomer-specific analysis  of  the  mixtures
associated with combustion and chemical processes.

   90.  ORD,  in  conjunction   with  the  Chlorinated   Dioxin  Work
Group, will  develop   and  apply   methods  to  predict  the  fate,
persistence, and  bioaccumulation potential  of  dioxins  in  the
environment.  These efforts  will begin  in  FY 84  in  conjunction
with the  development  of  the   sampling  program  discussed  above.
The results  of  these analyses will  be combined  with the  source
asessments and toxicity  studies  to  provide interim  exposure and
risk assessments for  the  other dioxin isomers.  Interim assessments
will be available  by September 1986.

   91.  As sources of other dioxins and "dioxin-like"  compounds
are evaluated,  OSWER  will,  if appropriate,  develop  regulations
under RCRA in  order to  ensure  the proper disposal  of wastes from
such sources.   As a  first  priority   OSWER  will  promulgate  the
regulations proposed  on  April  4,  1983, for the  regulation  of
process wastes  containing  tetra-,   penta-,  or   hexachlorinated
dioxins and dibenzofurans, as appropriate.

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Coordination

   92.  Coordination  between  the various  agencies is  a  crucial
element necessary  to  answer   questions  that  have  been  raised
about dioxin exposure,  environmental  effects, and  risk.   In the
area of health research (toxicological studies and epidemiological
studies),  the  federal  health  and  safety  agencies  under  HHS
(e.g., CDC,  NIOSH,  and  FDA),  VA,  and  EPA  should work  closely
together.   The governments  of Canada  and Italy,  in  particular,
should also  be  involved in  the  coordination  of  efforts pursuant
to this strategy.   OSWER  will  have  overall responsibility for
coordination.

   93.  To  help  achieve  effective  inter-agency  coordination,
OSWER will  develop  a  plan  which  will  frame the  issues to  be
addressed  by the agencies and, in relationship to EPA's strategy,
investigate various mechanisms   (e.g.,  the  Department  of  Health
and Human  Services' committee to coordinate environmentally related
programs)  to -secure interagency  coordination.  This plan  will be
available  by March  1,  1984, for review by the Deputy Administrator.

   94.  EPA recognizes the importance of the States'in effectively
implementing this strategy.  Accordingly, the Regions are to coor-
dinate with the States in gathering  information on specific sites,
in developing  sampling  plans  and  collecting  samples,  and  in
devising the  appropriate response.   It  is especially  -important
to encourage States'  initiative  in  any  response  efforts that may
take place at a contaminated site, including direction of respon-
sible private  party .action.   Such  coordination  will  minimize
duplication and maximize resource availability.

   95.  It  is very   likely  that  the  results  of  EPA's  dioxin
strategy will point  out the  need  for  more work  in a  number of
areas, especially  in   the  area  of  source  characterization  and
control technologies  for the  other  dioxin isomers.   Since  funds
are not yet available  for additional work, requests for additional
funding should be developed  through the appropriate EPA and other
agency budget processes.

 Community Relations

   96.  EPA recognizes  the  importance of  dealing  with the public
on such a  sensitive  issue  as  dioxin.   Indeed, even  the sampling
at uncontaminated  sites  (tier  7)  will  likely  generate  local
apprehension and questions.   To  communicate effectively with the
public, each  Region  should  appoint  one  individual  to  handle
community  relations relative to this dioxin strategy.
                              - 24 -

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   97.  The  Regional  community  relations  official will  provide
updates, as needed, to local and  State  governments following the
community relations plan that  is  to  be  developed pursuant to the
OSWER interim guidance for tiers 1 and 2.

   98.  The  AA  for OSWER  or his  designate  in  conjunction  with
EPA's press  office  will  be the  focal point at  headquarters for
public relations.
                              - 25 -

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                              PART 3

                INTERIM GUIDANCE FOR TIERS 1 AND 2
EXECUTIVE SUMMARY

Introduction

   The Agency has been developing an overall strategy for
responding to  the -public  health  risks  associated  with  dioxin
contamination.  The major components are:

   1)  A national study  of  selected sites to estimate the extent
       of dioxin contamination (the "study" component);

   2)  Identification and coordination of research and regulatory
       initiatives to  prevent  contamination  (the  "regulatory"
       component); and

   3)  Development of  appropriate  response measures  at  contami-
       nated sites (the "cleanup" component).

   The EPA dioxin strategy provides for intensive  focus on the most
toxic of the  75  dioxin  isomers  —  2,3,7,8-tetrachlorodibenzo-p-
dioxin (2378-TCDD).   The other di'oxin isomers, which have different
physical and  chemical  properties,  will  be evaluated as  part of
the strategy to  determine whether  they merit the  same  intensive
investigation.

   This section  provides interim  guidance  on  the  third  major
component listed  above:   the identification of TCDD contaminated
sites and the development of appropriate response measures.

   For the  overall  strategy, the Agency has identified  a seven
tier hierarchy of sites based on an estimated decreasing potential
for 2378-TCDD contamination.  The focus  of the  cleanup component
will be  initially on the most  serious sites,  and this  guidance
sets up a controlled, structured approach for working down through
tiers 1  and  2  to identify  2378-TCDD  contaminated  sites.   The
national study  will  utilize  the  data  being  collected   in  the
cleanup component, but  will  focus its resources on tiers 3 through
7.  Of course, any site discovered to  be  contaminated  with 2378-
TCDD in  the national  study or  otherwise  will  be  referred  for
appropriate cleanup response.

   For the  cleanup  component,   the  2  tiers   of  concern  are:

   Tier 1  -  Current,  if  any,   and   former sites  of  2,4,5-TCP
   production.
                              - 26 -

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   Tier 1A -  Transport,  treatment, storage,  and disposal (TTSD)
   handlers or sites used by tier 1 facilities.

   Tier 2 - Sites,  where  2,4,5-TCP was or is used as a precursor
   to produce  another chemical  product  (e.g.,  hexachlorophene,
   2,4,5-T, silvex, etc.)

   Tier 2A -  Transport,  treatment, storage,  and disposal (TTSD)
   handlers or sites used by tier 2 facilities.

   Due to the  manufacturing  processes  involved,  it  is  estimated
that 80-95% of the  2378-TCDD produced  in  this  country is associ-
ated with  tiers  1  and  1A.    While  it  is  believed that  there
are approximately  20   facilities  in tier 1  and 30  in  tier  2,
there is no  accurate  count of handlers  or sites in  tiers  1A  or
2A.  Accordingly, a primary objective  of  this  guidance  is to set
forth a process  for defining  the  dimensions  of  the  universe  to
be investigated.

   A second objective  of  -this guidance  is  to see that the Agency's
limited sampling  resources  are  initially  focused   on   the  most
serious sites.   Regions  are directed  to place  primary  emphasis
on tier 1 sites,  and later on the other tiers (tier 2) consistent
with the Regions'  work  plan  and  with  the approval  of  the AA for
OSWER.

   Additionally,  it is  recognized  that some Regions  are already
sampling at sites  in  tier 2.   The demand that  this  sampling has
placed on the national lab capacity and  Superfund support contracts
is considerable.   In order to focus on the  potentially more serious
sites in tier  1A,  and to maintain resources for  other  Sxiperfund
work, the Agency has  made  a  decision that new  sampling  at tier 2
sites should be delayed,  where it  is  not  inconsistent with prior
commitments, until  the  size  of  the  universe  for both  tiers  is
better defined.  Then, the  Agency will make decisions  regarding
the best way  to  apportion laboratory capacity,  support' contracts
and technical resources.   This  interim  guidance  sets forth certain
other decisions  which  will  have  to be  coordinated  with  OSWER  in
order to maintain  a coherent Agency approach and to  control the
resource demands nationally.

Approach

   The Regions'  activities  at  the  sites  will  involve  several
phases.  The  basic  approach,  explained  in  more  detail  later  in
this interim guidance, is as follows:

   Information Collection

   1.  Consolidate Regional and Headquarters data bases to
       identify tier 1 and 2 sites.

                              - 27 -

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       Collect  information  for
       begin identification  of
       sites.
                known  tier
               tier  1A and
1  and   2  sites  to
 2A facilities  and
       Depending
       interviews,
       the field.
on the  results,  arrange  site  visits,  employee
  and  other  evidence  collection  necessary  in
   Field Investigation

   1.  Sampling at  tier 1  sites
       mation collection phase.
                should  begin  during the  infor-
   2.  No  new  sampling  should  be  initiated  at  tier  2  sites
       until the  results  of  the  information  collection process
       are analyzed,  and  the  Agency  determines  how  it  will
       proceed. The  same  is true for  transportation, treatment,
       storage and  disposal  handlers  or  sites  associated  with
       any of the 2 tiers.

   Response Acti-vities

   1.  If  2378-TCDD contamination  requiring  a  cleanup  response
       is identified,  direct  initial  efforts  at  getting  poten-
       tially responsible  parties  (PRPs)  to  take  appropriate
       action (e.g., remedial investigation, emergency response).

   2.  If necessary, develop a Superfund cleanup response.

Detailed Guidance

   Whenever possible, the Agency will work  closely with the States
and encourage them  to be the  lead  agency  as  it does throughout
the Superfund program.  After the Agency has conducted an initial
screening of the  sites,  it  will look  to  potentially responsible
parties (PRPs)  to undertake  Remedial  Investigations  (RI).   Due
to resource demands  placed  on the  Agency,  the  Agency^has  made a
management exception to current policy by allowing PRPs to under-
take Remedial Investigations.  The scope of any remedial investi-
gation conducted  by  a  PRP will be  incorporated  into an adminis-
trative order.

   Community Relations Plans.

   Community Relations  Plans  (CRPs)  must  be  developed  for  each
site in  accordance  with  the  guidance   issued  to the  Regions  on
May 9, 1983 with  modification as necessary for  consistency  with
this interim guidance.
                              - 28 -

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   Information Collection

   The Office  of Waste  Programs  Enforcement (OWPE)  is  in  the
process of identifying current and former 2,4,5-TCP manufacturing
sites (tier 1) and current and former manufacturers who purchased
2,4,5-TCP as  a  feedstock in pesticide production  (tier  2).  The
compliance monitoring staff of the Office of Pesticides and Toxic
Substances Enforcement  (OPTSE)  will  assist  OWPE  in  identifying
potential 2378-TCDD  dioxin  sites  by  providing accesss  to their
FATES computer  system from  which  information on  pesticide pro-
duction can be obtained.   Further,  OPTSE in  conjunction  with the
Regions (Air and Hazardous Materials Division) will summarize and
provide information  from the Toxic  Substances Control Act  (TSCA)
Section 6  dioxin inspections.    Various  program  and  enforcement
offices in Headquarters  are being  asked to  compile  information
and coordinate it through  OWPE.   The results  of  the  survey will
be made available to the Regions.
 •
   The Regional  Superfund program  and  enforcement offices  should
confer with  the  Regional  Pesticides,  Toxic  Substances   and  the
Resource Conservation and Recovery  Act  (RCRA)  program and enforce-
ment offices  to  obtain  information  on  production,  transport,
treatment, storage,   and disposal of  2,4,5-TCP wastes  from  facil-
ities identified  by  OWPE  and  other  facilities  the  Regions  may
identify.  The  Regions   should  notify  OWPE  of   the  results  of
their document  search by  September  6,  1983.  This  information
will be used by  OWPE to  complete its  categorization of sites and
facilities into  the  appropriate tiers.   OWPE will  provide this
"revised categorization" to  the  respective Regions  by September
19, 1983, and will update this information as necessary.

   In order to gain  more informaton  on  potentially contaminated
2378-TCDD sites  the  Regions  will   issue  CERCLA  S104/RCRA §3007
information request   letters  by  September  30  to  all  tier  1  and
tier 2 facilities identified by OWPE and the Regions.   Recipients
of the  letter  will   be  given  30  days to  respond.   The  letters
will request  information  on the amounts  of  waste  generated  and
disposed, current and past disposal practices, including  disposal
site locations and waste haulers, and other pertinent information
that may  be  needed   to  support  an  enforcement or  Fund-financed
response action.  Use of enforcement actions under RCRA §3008 for
inadequate responses to the information request letters should be
initiated when appropriate.

   The Regions are advised to  remain  firm  on  the  30-day  deadline
for responses to the information request letters.   Extensions, if
granted, should  only be  granted  for good cause shown and should
not exceed two weeks.
                              - 29 -

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   Most responses,  even  with a two  week  extension,  should be  in
the Regional  offices by  November  15, 1983.   The  Regions  should
review the  responses and provide to  OWPE,  by December 15, 1983,
the following:

   1)  List of  facilities that complied with  the request;

   2)  List of  facilities that failed  to  respond;

   3)  List of  additional sites", including transporters,
       treatment, storage,   and  disposal facilities   identified
       in the responses;  and
   •
   4)  A  Regional  plan   for  further  investigative  and  response
       activities for each site.

   After compilation  and  review of  all  available  information,
the Region  will  determine   if  additional  information gathering
through follow-up  site  inspections,  interviews  with current and
former site employees,  responsible  party searches,  and/or title
searches is  needed.  The  Regions   should also consider  the  use
of a  trained  investigator to  compile information  and assist  in
investigations.

.Preliminary Investigation Phase  (.Screening)

   This portion  of  the guidance  explains how to conduct a  syste-
matic investigation of facilities.   Tier  1 sites will  be  screened
first in order  to focus efforts on  sites  posing  (potentially) the
most urgent and widespread public  health concerns.   By  December
5, 1983,  the  Regions  -should  implement  and   provide  to  OWPE   a
screening program for  confirmed  tier 1 sites.  When OSWER  deter-
mines that  the  resources are  available   nationally, tier  1A,  2,
and 2A sites will be investigated following these same  procedures.

   During the preliminary investigation phase an initial screening
of tier 1 facilities shall be' conducted to determine if 2378-TCDD
is present at the site.  If  it  is present, further remedial  inves-
tigation or endangerment  assessments  shall  be conducted as  des-
cribed in the response phase of this guidance.  Initial screening
of tier 1 facilities will be conducted by EPA or States concurrent
with information gathering.

   Once the Region  has  identified  the tier 1  facilities  targeted
for preliminary  investigation, it will devise  a screening program
for collection  of a  limited number  of  environmental media samples
at these  sites.   In Regions where  several  tier 1 facilities are
to be screened,  an  inspection  scheme should be developed to  help
management set  priorities and schedule investigations.
                              - 30 -

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   In general,  where  currently  operating  facilities have  been
targeted for  sampling,  the  Region  should  look  to  FIFRA,  TSCA,
RCRA, and/or CERCLA for authorities to conduct record inspections
and/or collect  environmental media  samples.   In  addition,  the
Regions should  address  compliance  with all  applicable  rules and
regulations.

   Field Investigation Procedures

   The following  procedures  for  screening  sites  for  potential
2378-TCDD contamination  should  be instituted  for  tier  1  sites.

   1)  Develop  and  implement  an  initial  site  sampling  plan
       (screening program  using  the  protocols  and  procedures
       developed by EPA/ORD  and  the  Centers  for Disease Control
       (CDC) to  sample  the  most  probable  locations of  dioxin
       contamination at the  site  or  in the  immediate vicinity) .
       Site inspection  schemes  should  be  reviewed  with  OWPE
       Regional Coordinators -  Compliance  Branch.   During this
       round of sampling, limit the number of samples taken to
       only those which are necessary to determine  if dioxin is
       present.  States  should  be  advised  by  Regions  of  the
       site inspection  schemes.    For   active  industrial  sites,
       CDC should  be  contacted to  coordinate with  the  National
       Institute for Occupational  Safety  and Health  (NIOSH)  for
       further sampling  guidance.    If  there are  people  living
       in the  area,  the State  health  officials  and CDC  should
       review all  sampling  protocols  from the beginning.   CDC
       should be contacted through  its staff person  in  each EPA
       Regional Office.

   2)  Initial  field --investigations  must  employ  EPA  chain  of
       custody procedures,   document   control,   site   safety  plan
       procedures and Quality Assurance/Quality  Control
       procedures.*

   3)  Analysis  for  2378-TC.DD in  soil will  be conducted  using
       state-of-the-art low resolution GC mass spectrometry
       methodology and  appropriate  detection  limits.   Analysis
       for 2378-TCDD  will   be  performed  using  high  resolution
       GC mass  spectrometry methodology   in  enviormental  media
       other than  soil.   Qualitative   analytical  screening  for
       other dioxin  isomers  should  also  be considered by  the
       Regions at  sites where there  is  reason  to  believe  that
       other dioxin isomers  may  be present.  The  Regions  should
       contact the  National  Contract  Lab  Program  in   order  to
       schedule sample  analysis  as  early  as  possible.   These
       samples should be labelled as  tier 1 - 2378-TCDD
 * Guidance for QA/QC  is  available  from the Office of Research and
   Development.

                              - 31  -

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       samples in  addition  to  any  of  the  identifiers  used.
      ..(Coordination should be through the Regional Environmental
       Services Division (ESD) Directors).

   4)  If  the initial  sampling  results  indicate  2378-TCDD  is
       present, and  response  action  is  to  be   pursued  through
       either enforcement or Fund-financed activities, the proce-
       dures set  forth  in  the Response  Phase  of  this  guidance
       should be followed as appropriate.  All phases of response
       must be in accordance  with  the National Contingency Plan.
       The priority  for taking  either  enforcement  or  response
       actions at dioxin sites will be determined  by evaluating
       the seriousnes of  the  problem at  that  site  relative  to
       the problem at all other sites whether they  include dioxin
       or not.

   Regional Workplan

   The information obtained  from the  field investigations should
be used by each  Region  to  develop  a  Regional workplan for tier 1
sites which initially determines whether or not a contaminated site
will be addressed through Fund-financed activities  or enforcement
authorities,  and projects a schedule for further action.  Workplans
should be submitted to  OSWER  by  March 15, 1984.   These workplans
will be  reviewed  by  OSWER in light  of the  national  demand  for
resources and analytic  'laboratory  capacity.  OSWER will  consult
with the  Regional  Offices  on  any  adjustments  to  the  workplans
based on the dimensions of the national situation.

   Response Phase

   Response actions, which are consistent with the  Region's work-
plan and the  approval  of  the AA for  OSWER,  will  be initiated at
a site  when   the  analytical  results  of  the preliminary  field
investigation (screening)  confirm  the presence of  2378-TCDD  and
the Region_determines that the situation warrants  response.   In
evaluating'whether .or  not  to take a  response action at  a site,
the Agency will  consider  criteria  such as  the   following:  the
location of  the   site,   the  site's   use,  the  demography,  etc.

   If technical  assistance or  expenditure   of  funds from  other
Federal agencies is  needed, a Regional Response Team (RRT) meeting
should be  convened.  The  RRT  will  serve  as  the  coordinating
mechanism within  the Federal  government  and for  Federal/State
cooperation.   In addition,  because the  RRT  serves as the  coordi-
nator for  inter-agency  actions,  it  can also  become the  focal
point for communications  with the  local  citizens  and  the press
at a site.
                              - 32 -

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   Enforcement Procedures (See Figure 2)

   To support  possible  enforcement  response  actions  at  tier 1
sites where  2378-TCDD contamination  has  been  confirmed through
initial screening, additional information gathering may be needed
to supplement the material  gleaned from the  CERCLA 104  and RCRA
3007 information request letters and from FIFRA/TSCA inspections.
In the  Regions,  the  Air  and Hazardous Materials  Division  will
determine the  sufficiency  of  information  collected  and  have
primary responsibility  for  compiling  information  from'  local,
State, and Regional sources.  At the  Region's request,  OWPE will
compile information from  computer  systems  such as  FINDS  in the
Management Information Data Systems Division and from the various
program and enforcement  offices  to  support an enforcement response
action at a particular site.

   Once the  potentially  responsible  parties  (PRPs)  have  been
identified, notice  letters  will  be  issued  apprising PRPs  that
EPA has  conducted  or will  conduct planning  or  response actions
at the .site to determine both the nature and extent of the dioxin
contamination.  the  PRP  will  be   offered  the  opportunity  to
undertake the  necessary  assessment and response actions  at the
site, and  will  be  apprised of possible  liability  under  CERCLA
for injunctive  relief or  cost  recovery  in  the  event  Superfund
action is taken.   If  the  PRPs choose to  undertake  the  necessary
response actions at the  site, the  Region  should,  depending upon
the evidence available, issue an administrative  order  on consent
in order  to  gather additional  data  and  direct  the appropriate
response measures  (e.g.,  CERCLA §106,  RCRA §3013,  RCRA §7003).

   Where PRPs decline  to undertake  the necessary remedial investi-
gation activities  the  Region will  pursue,  aftfer  consultation
with the  Office of  Waste  Programs  Enforcement  (OWPE)  and the
Office of  Enforcement  Counsel  Waste   (OEC-Waste),  one  of  the
following options:
                                               •
   1)  Issuance of  a  unilateral  RCRA  §3013 or  CERCLA  §106 order
       to obtain the information necessary to conduct a
       feasibility study;

   2)  Initiation of a Fund-financed removal action;

   3)  Initiation  -of   a  Fund-financed   remedial  investigation/
       feasibility study (RI/FS);  or

   4)  Initiation of an enforcement-funded endangerment/
       alternatives assessment.

   The option selected  will be dependent upon  such variables as
the complexity of the  case, severity and imminence of hazard, the
number of  sites  needing  response action, availability of  Super-
fund and/or enforcement dollars,  and  availability  of  personnel.

                              - 33  -

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   If Option  1  above is  selected  and the PRP  complies with the
order, then EPA  will perform the feasibility  study.   If the PRP
chooses not to  comply  with  the  order,  then  the  Region  should
pursue Option 2, or  3,  or 4.  If option  2  is  chosen, the proce-
dures outlined  for  "removals"   in   the   Response   Section  below
should be  followed.   For option  4, an  endangerment assessment
must be performed  by the  Region.    In addition,  an  endangerment
assessment may also  be  necessary for  options  2 and  3  if  a cost
recovery action  is  to  be taken.   This  assessment will .examine
the nature and quantity of the dioxin or any hazardous materials,
exposure pathways,  human and animal populations exposed or poten-
tially exposed  and   the  actual   or  potential  risks  and effects
associated with  the  exposures  to   the  hazardous materials.   At
this point, CDC  should  be notified  of  the  information contained
in the endangerment  assessment  and  be asked for a health assess-
ment or advisory.   CDC  will coordinate  with  NIOSH   for  active
work-related situations.  The endangerment  assessment along witn
the subsequent  alternatives  assessment are  considered  to  be 'the
critical components of the enforcement strategy,  and are nece'ssary
to ensure  successful  prosecution  of  an enforcement action under
administrative or judicial statutory authorities.

   Upon completion of the  Fund-financed  RI/FS  or the  enforcement
financed assessments, the  Region  will have  60-120  days to nego-
tiate an agreement with the PRPs for response action.

   If an  agreement,  can  be  reached,  it  will  be embodied  in  an
administrative order or  a  consent  decree  pursuant to  §106  and/or
§7003.  If an  agreement  cannot be reached, the Region will pursue,
after consultation with  OWPE  and OEC-Waste,  one of the following
options:
                                                         *
   1)  issuance  of   a  unilateral  administrative order  pursuant
       to §106 and/or §7003; or

   2)  Initiation of a   judicial action  pursuant to  §106  and/or
       §7003;  or

   3)  Initiation  of a  Fund-financed  response action  followed
       by a §107 cost recovery action.

   If Option  3  is  selected, then   the  Region  will  initiate  a
cost recovery  action  pursuant   to  §107  for  reimbursement  of
expenditures under  Superfund  for  site planning  and  response and
other expenditures.   Cost  recovery  actions will  be  conducted  in
accordance with existing procedures and policies.

   Dioxin sites  identified  for action   by  States  may  require
Agency overview in the  form  of  technical  support for  enforcement
actions or  response   actions.   In   certain  cases,   actions  may
                              - 34 -

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involve joint  federal  EPA and  State  efforts.  Depending  on the
success of  State  enforcement action, direct  EPA  involvement may
be necessary.

   Fund-Financed Response             .

   If the initial  sampling  (i.e.,  the limited sampling performed
as step  #1  of  the Field  Investigation  Phase) results indicate
that dioxin  is present,  and  the  response  is to be Fund-financed,
then the Agency must  decide  if the situation  warrants  a removal
action.  Regions  must  recommend  removal  actions,  with required
documentation to  the  Assistant  Administrator for  OSWER.   CDC
should be consulted  in case  a  health assessment or  advisory is
needed.  If  EPA believes  temporary  relocation is  warranted, it
must ask the  Federal  Emergency Management  Agency (FEMA)  to make
such a determination.

   It is possible  that either  or both short-term  and  long-term
cleanup activities may be  necessary  at a site.   (If  the  site is
going to  need  long-term  or  "remedial"  work,  then  the  site
needs to be  scored .in accordance with the  Hazard Ranking  System
for ranking  and placed on  the National Priorities List  (NPL), if
appropriate.)

   Additional investigation,  planning  and design work  for  long-
term activities can be performed while short-term cleanup
activities are  being  performed.    If  work  other  than  removal
action Is  needed, the  following activities  should  take  place:

    1)  A more  detailed  sampling effort  should  be  conducted at
        the site,  setting  up  the sampling  locations   in  a  grid
        network extending beyond the facility boundaries.
        Environmental media other than soil should also be
        sampled when appropriate.   Once  again, CDC  and/or NIOSH
        should be  involved  in  this  process.  Sample  protocols
        and analysis  schedules  should be   reviewed  with  OERR.
        As noted  above,  the  Region  should  contact  the  Sample
        Management Office  of the National  Contract  Lab  Program
        in order to schedule all sample analyses and mark
        samples "Tier  1-TCDD".   Coordination  should be  through
        the Regional ESD Directors.

    2)  Once the  results from  this  second sampling  are  obtained,
       > EPA  should again request  a  health advisory  or  assessment
        from CDC.   Based  on  CDC's  recommendations,  EPA  must
        decide if  temporary  or  permanent  relocation  should  be
        considered for  persons  residing   in  the  vicinity.   As
        noted above,  FEMA  makes the  determination  for  temporary
        relocation during removal activities.  If temporary
        relocation is  contemplated  during  remedial  actions, EPA
        makes the  determination  (under a recent  redelegation of
        authority  from  FEMA)  that  it   is   necessary  and  FEMA


                              - 35 -

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        implements the determination.  EPA also has the responsi-
        bility for making  the  determination  concerning permanent
        relocation, and FEMA implements it.

    3)  If  further response  activities  are  warranted,  and the
        site has  been  proposed for inclusion on  the  NPL, feasi-
        bility study and design-work should be initiated,  followed
        by additional construction.

   Separate guidance  is  attached  concerning  the  short-term and
long-term technical  options  for  destruction  and  disposal  of
dioxin which  are  currently available  or  being   developed.   In
addition, information  is   included  regarding  the  notification
procedures to  be  followed  for   the  transport  or  disposal  of
dioxin.

Technical Assistance

   The Region should consider  using  their FIT and TAT as well as
FIFRA, TSCA, and Water inspection program resources in the infor-
mation collection  and  initial screening  phases.    The  Superfund
contractors' (REM/FIT and TAT)  as well as the technical enforcement
support (TES) contract  should be used to support  field  investi-
gations, data  analysis and development  of   feasibility  studies
for 2378-TCDD contaminated  sites.  Water quality program monitoring
resources may also  be  useful in  the investigative mode  for  fish
and water  sampling.    Environmental  media  samples taken during
the field investigations can be analyzed by the Superfund  contract
laboratory program.   if  the  capacity of these laboratories  is
exceeded, other  laboratories  available   to   the   Region  through
contractual arrangements, ORD or the Environmental Services
Division, may be employed after consultation with OERR's Technical
Support Division.

   Financial Assistance

   The States  can use  the  money allotted to  them  through the
CERCLA/RCRA 3012  program  to  investigate sites   thought to  be
contaminated with  2378-TCDD.  For  example,  if   the  State  has
targeted 100  site  inspections  in  their application,   and  now
wishes to  inspect  20  2378-TCDD  sites.    The  States  can  perform
activities at the 20 2378-TCDD sites as part of their established
goal.  This would  simply  reestablish priorities for  the  States.

   The following  activities  can  be  funded   with  these  grants:
preliminary assessments, site inspections, responsible party
searches, discovery,  and  site  inspection  followup.   For  more
information about  this  source of funds,  you can refer  to the
Federal Register Notice of  February  7,  1983  and  the EPA guidance
issued on March 8, 1983.
                              - 36 -

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                                                FldUMe I
Review of local,.state
and federal files by
HQ, Region, and State
OWPE List Of 2,4,5-TCP
Manufacturers and 2,4,5-TCP
Pesticide Derivative
Manufacturers
wMMoml (MM
104/3007 Letters to
OUPE List of Facilities
                       TIER 1

                   Manufacturers of
     TIER la

TTSD facilities of
TIER l
                       TIER  2
                   Sites where 2,4,5-TCP
                   was used as a precursor
                   to produce another.
                   chemical product
                       TIER  2t

                   TTSD facilities of
                   TIER  2
                                                                                            FIFRA* Inspection
                                                                                                   or
                                                                                            TSCA Inspect ion/Sanplinj
                                                                                                   or
                                                                                            Superfund Screening
                                                  Superfund  Screening
                                                  Consult with OSHER
                                                  prior to  taking
                                                  further action
                                                            FIFRA Inspection
                                                                   or
                                                            TSCA Inspection/Sampling
                                                                   or
                                                            Superfund Screening
                                                  Superfund Screening
                                                                                                                          , 2,3,7.8-TCDD
                                                                                                                           present
                                                                                                                     Response Action  (see Fig.  2)
                                                                                                                          and
                                                                                                                     Additional  information
                                                                                                                     gathering  for enforcement
                                                                                                                     purposes,  e.g.,  files search,
                                                                                                                     interviews,  responsible  party
                                                                                                                     search
                                                                                , No 2,3,7.8-TCDD
                                                                                 Present
                                                                                                                                                   |Ho  Response  Action]
                                                                                            Consult with OSHER
                                                                                            prior  to taking
                                                                                            further action

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                                                                      FIGURE 2
                                       S3013  A.O.  for RI
                                                                    EPA  does FS
CO   NOTICE LETTER
.     FOR RI/FS/RD/RA
                                       S3013/106 A.O.  for
                                       RI/FS/RD/RA

                                             or

                                       S106  and/or S7003
                                       Consent Decree for
                                       RI/FS/RD/RA
 $3013 Unilateral A.O..
 for RI

       or
                       4

-Fund-Financed RI/FS
 and/or Removal
       or
                                       Enforcement-Financed
                                      -Endangerment/Alternatives
                                       Assessment
                                                                     r.r..  .     r.^
                                                                     EPA  does FS
F106 and/or  S7003 A.O.
or Consent Decree
                                                                                   unoooparaOv*
                                                                         negotiate RO/RA
                                                                                       irauocaeakl
                                                                         60-120 day*
   ^§106  and/or S7003 Unilateral
      .O.  for RD/RA

               or

     5106/7003 Civil Action    LITIGATION

               or

     Fund-financed RD/RA

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                           ATTACHMENT  I

DISPOSAL GUIDANCE

Background

   Although a  significant  amount of dioxin-related research  work
has been published, most is related to  the toxicity or  destruction
of dioxin in a solubilized form.   This  is  rarely  applicable  to the
conditions existing  at most  Superfund  sites.   These  sites  are
often characterized  by a  variety of contaminated  soils,  gravels,
and other materials,  for  which  there  is little available  infor-
mation to  use  in  developing a  technically  sound prediction  of
dioxin1s behavior  in  the environment,  its containment  efficiency,
or treatment effectiveness.

   Due to dioxin1s known  toxicity  and hazards to  personnel,  the
scientific community  has  been   reluctant to  conduct   controlled
investigations  of  dioxin1s environmental  behavior outside  of  the
laboratory.  These risks, plus the high cost of analytical  testing,
have also limited rigorous studies of uncontrolled  dioxin  releases
to a few instances.  Furthermore, only  at  Seveso, Italy, and Snytex
have significant   investigations  been  conducted  into treatment
alternatives for  dioxin-contaminated  soil.   At  these  and   the
other sites, the  contaminated soil was eventually  contained  in a
•landfill or is  .presently  in  an interim storage  facility,  awaiting
the development  of  technologies  related to dioxin-contaminated
soil.

   Remedial Action Alternatives  Considered

   Over 40 possible  treatment processes   and  over  500  sources  of
information were  considered  in  the initial screening of  alterna-
^ •! *» |*k O f f\ V*  V V"\ J-*l  £ S^ ^ f+ 4 \~\ •! 1 ^ 4- • T   r* t » 1 S^ * r  U •! *^ \f XX V / C* +• f*l lit  A 4 S^. ^f ^ f\  ft I ^ /-V  T F^
Missouri.
iiiLuirindi. ion wete cuns luerreu  in cue  iniciaj.  screening on aicei
tives for  the  feasibility  study  Minker/Stout  dioxin  site  in
M-i e o/-\i i v* i
   The treatment  processes  were  screened  on  the  basis  of  1)
state of  development,  2)  health  and  safety  risks,  3)  process
complexity and  constructability,  4)  reliability,  and  5)  cost.

   Six remedial  alternatives were selected  for  a detailed  eval-
uation.  Alternatives  A  through  C  rely  on the  principle  of
containment to reduce dioxin exposure  which,  due to  the  demon-
strated insoluble nature of dioxin in these  soils, centers around
immobilizing the  contaminated  soil  particles.    Alternatives  D
through F  rely on  the  principle  of treatment to reduce  dioxin
level, in  addition  to containment of  the treatment  residue.   In
reality, each  treatment  alternative   is  a two-stage  process,
involving soil  extraction  (thermal  or  solvent), followed  by  a
destruction process.  Contaminated soil has  several  unique
characteristics that make the application  of any  of  the  treatment
alternatives a  challenge.   Among  the  special  requirements  are:

                              -  39 -

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   0 The need to process  a  wide  range of contaminated materials,
     e.g., rocks,  clay,  roots,  and  other  materials  on-site.

   0 The requirement that the  remedial  alternative  be capable of
     processing all contaminated  material.   Combination of reme-
     dial alternatives  for  various  types  and  concentrations of
     contaminated material were not considered.

   0 The use  of Level C  or higher personnel  protection  for all
     soil handling and treatment activities.

   0 The potential listing of 2378-TCDD as a RCRA waste, which will
     significantly impact  storage,  transportation,  monitoring,
     and treatment  requirements.    If  residue tests  and  other
     limitations do not enable  a delisting of the treated residue,
     there would appear to  be  little cost incentive to treat the
     soil prior  to  containment  in  a  fully  permitted  secure
     landfill.

   The following  six   remedial alternatives   were  selected  for
a detailed evaluation  at  the Minker/Stout site.  Alternatives D,
E, F and  the  possible fixation portion  of  Alternatives A  and  C
have significant technical unknowns that warrant pilot testing to
better demonstrate their application to dioxin-contaminated soils.
Alternative B  and the  remainder  of Alternatives  A  and  C  are
highly site-specific  and  do not  .warrant pilot testing but  may
need additional site testing.

   Alternative A — Secure Soil In Place

   This alternative would secure the  soil  in  place  and prevent
public site access.  This would likely involve insitu soil fixation
and securing the site  with  a subsurface perimeter  grout curtain,
an impermeable  cap  over  the contaminated area, and diversion of
surface runoff.  Permanent resident relocation and house demolition
would be necessary within the  sites and for any additional house-
holds inside  an  undertermined buffer   zone.   A   longterm  site
monitoring and maintenance program would be necessary to monitoring
the ground water  and  conditions  in  the  surrounding environment.

   Alternative B — Consolidate Soil On-Site

   This alternative would  remove the contaminated soil and consoli-
date it  into  one  area at  the site.   Due  to  the  varying  soil
depths, unknown  site  hydrogeology,  and  the  need for  a positive
liner and leachate collection  system, a double-lined,  above-grade
concrete vault  would  be used  to  contain the  contaminated  soil.
Permanent resident  relocation   and  house  demolition  would  be
necessary within the  sites  and for  additional households  inside
a buffer  zone.   A long-term   site  monitoring  and  maintenance
program would also be required.
                              - 40 -

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   Alternative C — Secure  Soil Off-Site

   This alternative  would remove  and  transport the  contaminated
soil to  a  secure  hazardous  waste  landfill  for  disposal.    In
accordance with  the April 4,  1983,  Federal Register, the Agency
is currently  proposing  the  addition of dioxin wastes to the  RCRA
regulations.  If  this  proposed  rule  is  promulgated, the design
and operation of each landfill disposal facility would need to  be
thoroughly evaluated before dioxin could be added to the landfill's
permit.  The  removed  soil volume  and  up  to a foot of additional
fill would be added to  restore the site drainage and  to cover any
fugitive traces  of  contaminated  soil.   The site would be  reland-
scaped and  the   houses  rehabilitated  to  completely  restore the
area.

   Alternative D — Incineration

   This alternative  would involve the  direct thermal extraction
and destruction  of  the  2378-TCDD-contaminated  soil.   The contami-
nated soil would be stabilized on-site  or removed to a concrete
vault, or  other storage  facility,  where  it  would  remain while
the incineration  process  was  pilot  tested  and   developed  for
this particular  contaminated soil.  The  low  levels of soil  con-
tamination, required  high  destruction  and  removal  efficiency,
and widely  varying soil  characteristics will likely expand the
'state-of-the-art of incinerator technology.

   A significant  permitting effort  could  be  necessary  for the
pilot tests  and  for the  siting  of  a  full-scale  facility.   Fol-
lowing the permitting process  and the  construction of the facil-
ity, the  soil  would  be transported  to  a  size   reduction  and
handling process,  and  then  to  an  incinerator.   The incinerator
particulate and  soil  residue  would be  transported  to  a  secure
landfill site,  unless  extensive  testing  allowed  the residue  to
be delisted under RCRA.

   Alternative E — Solvent  Extraction

   This alternative  would extract the  dioxin  from the  soil  with
a solvent, concentrate  the  solvent, and  then destroy the dioxin
in the  solvent.   The contaminated soil would be  stabilized on-
site or removed  to a concrete vault where  it would  remain while
the solvent  extraction   process  as  pilot tested  and developed.

   A significant  permitting effort  could  also be  necessary for
the pilot bests and the  siting of a full-scale  facility.  Following
the permitting process  and  the construction of this  process, the
soil would be transported to a size reduction and handling process,
and then to the  solvent  extraction  process.  The resulting contami-
nated solvent would  be  concentrated, with the concentrate under-
                              - 41 -

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going degradation  and  incineration.   The incinerator particulate
and the  soil  residue  would  be  sent  to a  secure  landfill site,
unless extensive  testing  allowed  the  residue  to  be  delisted.

   Alternative F — Storage While Awaiting Development of
   Emerging Technology

   This alternative would  allow for  the development of emerging
technologies other than  incineration  and solvent extraction.  The
contaminated soil would  be  removed  and stored until such  time* as
emerging technologies  (such as  supercritical  water  reactors, wet-
air oxidation,  fluidwall  reactors,  and biological degradation)
could be  pilot  tested  and  evaluated  for  their  ability  to  be
competitive with existing  technology.  Today, these technologies
are not developed  sufficiently to be  used  commercially for this
type of hazardous  waste.   All  of these technologies have  several
major technical hurdles  to overcome before they can  be considered
viable.  There  is  a risk  that  these emerging  technologies  may
never become  cost  effective  for these  soils and,  therefore,  a
contingency .plan would be necessary,  should a research and devel-
opment program  not proceed as  quickly  as  planned  or  be unable
to demonstrate an acceptable alternate technology.

   Long and Short-Term Control Strategy

   Preliminary testing .indicates  that  three Minker/Stout  soil
samples subject- to EP toxicity tests all showed leachate containing
no 2378-TCDD above the  1-ppt 'detection limit.   In  its current soil
matrix, 2378-TCDD appears to be  water insoluble,  as well as non-
volatile and,  therefore,  soil  particle movement  is necessary to
spread the contamination.
                                                     <
   Containment technologies are  based on the  dioxin-soil  binding
characteristic and  focus upon the  restriction of  soil particle
movement.  These technologies can be used as  a short-term  interim
solution when  coupled   with  treatment  technologies for  future
processing, or as a long-term remedy.

   When dioxin  contamination  above 1  ppb  is  detected,  a  short-
term control  strategy   should   be   immediately  developed.   This
short-term strategy should  focus on  containing  the contaminated
soil and  preventing airborne  migration and   surface  stormwater
erosion.  Public access•to the  site  should  be limited.   Resident
relocation will  be based  on  health  advisories   or assessments
issued by the  Centers  for Disease Control  and  determinations  by
the Federal Emergency Management Agency or  EPA that  relocation is
necessary to protect public  health  in accordance  with  a  recent
redelegation of authority from FEMA.  A monitoring program should
be designed  to determine  the  extent  of surface  and  subsurface
migration.  If  the  site  cannot  be   controlled  on  a  short-term
basis, then excavation and temporary  storage will  be  required.
                              - 42 -

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   EPA has proposed the listing of a number of dioxins (including
2378-TCDD) as hazardous wastes  under the  RCRA regulations.  Cur-
rently, however,  the  disposal  of  2378-TCDD  contaminated  wastes
(including soils)  is  covered  by  TSCA  (40  CFR  775.197).   These
regulations have  governed  the  manner in  which  temporary storage
has been provided at several sites including:

     Denny Farm, Missouri
     Syntex Verona, Missouri
     Vertac Jacksonville, Arkansas
     Saugett, Illinois
     Love Canal/Hyde Park, New York

   Temporary storage may be  undertaken  by the responsible party,
or as a  Fund-financed  immediate  removal or as a remedial action.

   As sites are discovered  and actions planned, the TSCA mechanism
can be utilized  for  technical  review of  any  actions  which might
be taken.   For  further  information  contact  Dr.  Donald Barnes,
Chairman, Chlorinated Dioxin Work Group at 382-2897.

   Contaminated sites will  require extensive sampling  to  deter-
mine the  extent  and  severity  of  the  problem and to  assess  the
performance of short-term controls.

   The destruction of dioxin in soil will require the development
and pilot testing  of  technologies  and  should be  considered  as a
long-term (greater than two years)  control strategy.

   To destroy 2378-TCDD, treatment technologies must first vaporize
or solubilize the 2378-TCDD from soil thus breaking  the dioxin soil
bond.  In doing  so,  partially treated  residues,  or  contaminated
materials released during  processing, have the potential to spread
contamination via any one of the exposure routes (water, air,  and
soil) with highly mobile soluble,  volatile,  or  particulate forms
of 2378-TCDD.  While treatment technologies may be considered the
ultimate solution,  they  could  entail  significant health  risks
during processing.

   State-of-the-art methods  will   be  necessary  to mitigate  the
exposure hazard -to workers,  the public,  and  plants and wildlife.
The control of dust, treatment emissions,  water contact with  soil
or treatment  residue,  must  be an  integral  consideration  when
evaluating destruction technologies and  will have to be considered
as part of any future pilot testing program.
                              - 43 -

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