VOLUME  »1  (BD-1  -  BD-7)


DRAFT BACKGROUND DOCUMENTS
RESOURCE CONSERVATION AND  RECOVERY  ACT
SUBTITLE C - HAZARDOUS WASTE MANAGEMENT
SECTION 3001 - IDENTIFICATION AND LISTING  OF
               HAZARDOUS WASTES
SECTION 250.13 - HAZARDOUS WASTE CHARACTERISTICS

BD-1 - IGNITABILITY

BD-2 - CORROSIVENESS

BD-3 - REACTIVITY

BD-4 - TOXICITY'
     •

SECTION 250.14 - HAZARDOUS WASTE LISTS

BD-5

BD-6 - RADIOACTIVE WASTE

BD-7 - INFECTIOUS WASTE

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BD-1
                          DRAFT
                   BACKGROUND DOCUMENT
         RESOURCE CONSERVATION AND RECOVERY ACT
         SUBTITLE C -  HAZARDOUS WASTE MANAGEMENT
      SECTION 3001 - IDENTIFICATION AND LISTING OF
                     HAZARDOUS WASTE
    SECTION 250.13 - HAZARDOUS WASTE CHARACTERISTICS
                      IGNITABILITY
                                        DECEMBER 15, 1978
          U.S. ENVIRONMENTAL PROTECTION AGENCY
                 OFFICE OF SOLID WASTE

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     This document provides background information and
support for regulations which have been designed to identify
and list hazardous waste pursuant to Section 3001 of the
Resource Conservation and Recovery Act of 1976.  It is being
made available as a draft to support the proposed regulations.
As new information is obtained, changes may be made in the
background information and used as support for the regulations
when promulgated.
     This document was first drafted many months ago and has
been revised to reflect information received and Agency
decisions made since then.  EPA made some changes in the
proposed regulations shortly before their publication in the
Federal Register.  We have tried to ensure that all of those
decisions are reflected in this document.  If there are any
inconsistencies between the proposal (the preamble and the
regulation) and this background document, however, the
proposal is controlling.
     Comments in writing may be made to:
          Alan S. Corson
          Hazardous Waste Management Division  (WH-565)
          Office of Solid Waste
          U. S. Environmental Protection Agency
          Washington, D.C.  20460

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                       IGNITABLE WASTE
                     BACKGROUND DOCUMENT
1.1  Introduction
     This background document strives to establish that an
important identifying characteristic of hazardous waste is
ignitability.  Test methods and quantitative limits were
evaluated so that identification of ignitable waste could be
a simple, economical procedure with reproducible results.
In some cases, available test methods were judged to be
inadequate, so prose definitions were used to define a
particular characteristic until these tests are improved.
     Analyzing past waste management, sometimes mismanagement,
of ignitable substances revealed incidents of landfill fires.
These fires directly of indirectly contributed to the
degradation of the environment.  Most of the fires could easily
have been averted by properly identifying the ignitable waste.
When a waste is known to be hazardous, greater care in handling
and disposal is required.

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1.2  Solid Waste/Characteristic Relationship
     Ignitability is one characteristic for defining a waste
as hazardous.  The mismanagement of ignitable waste may
result in fire that will cause damage directly from heat
and smoke production or may provide a vector by which other
hazardous wastes can be dispersed.  An example of this would
be the creation of convection currents that could transport
toxic particles.  A fire may also cause otherwise benign
wastes to become hazardous.  This could happen when plastics
are incinerated propagating noxious fumes.
     During and after the disposal of an ignitable waste/
there are many available external and internal energy sources
which can provide an impetus for combustion, raising
temperatures of waste to their flash points.  Electrical
energy in the form of sparks generated by landfill machinery,
and thermal energy resulting from the heat of neutralization
(pH change) of from the decomposition of organic waste, are
examples of potentially problematic heat sources.
     Past management of ignitable waste has resulted in many
landfill fires.  Some examples of fires and explosions in
landfills and treatment facilities can be found in Appendix A,
Only recently has there been incentive to perform post-fire
investigations at landfills.

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     Landfill fires are presently being investigated to
determine if a particular waste or substance can be identified
as having initiated the fires.  Also, fires occurring during
transportation that involve substances with flash points r~
greater than 100°F are being researched.   (It has been argued
that EPA should remain consistent with the Department of
Transportation (DOT) which defines flammability with a flash
point limit of 100°F.)
     Conflagrations — large, destructive fires — should
continue to be studied to determine what particular waste
initiated the fires, the flash points of the initiating
ignitable waste, and the source of the igniting energy.
Wastes that compound the fire problem — for example, those
whichemit noxious fumes or further propagate the flames —
canbe studied at the same time.  In this manner, a data base
can be developed to aid further in the justification of a
selected flash point limit and in the further identification
of those wastes which should be separated from ignitable
waste.
     For these reasons, it is desirable to identify wastes
that are ignitable so that they can receive proper handling
by way of the Resource Conservation and Recovery Act,
Subtitle C, regulatory control sustem.

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1.3  Alternative Approaches
     While most states, agencies, and organizations that
define ignitability use flash point as their limiting criteria,
there exists no consensus regarding what that limit should
be, what type of categorization system is best, or what
terminology is appropriate.  For example, DOT defines flash
points less than 37.8°C(100°F) as flammable, and flash points
greater than 37.8°C but less than 93.3°C(200°F) as combustible*;
in comparison, Ohio defines flash points less than 79.4°C(175°F)
as flammable and does not recognize the combustible category
at all .  The criteria vary greatly from state to agency to
organization.  Each has developed defining criteria that attempts
to solve its own immediate problems.  A major effort made by
DOT to establish its regulations as standard has affected
many public and private institutions, as is evident from
the examples listed in the subsections(1.3.a and 1.3.b)
below showing the multiple occurence of the 100°F flash point
limit.
      Reference 1
      Reference 4

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     In some of the alternative approaches, the defining
criteria is based upon a classification system in which degrees
of hazard are established (for example, extremely hazardous
and hazardous).  EPA's strategy, however, is to make use of
tests that give a definitive answer as to whether a waste
is hazardous or not, rather than indicate degree of hazard.
Harry A. Wray*, wHen commenting on an earlier ignitability
background document, suggested a classification system based
on a combination of the NFPA Code , DOT and DOL  regulations.
This classification system solves one of the major problems
encountered when defining an ignitable waste.  EPA would
remain consistent with DOT's terminology and flash point
limits; and at the same time regulate ignitable waste with
flash points below 140°F(60°C), this limit is discussed
later.  The proposed classifying limits are:

  Flammable             FPilOOfT             Class I
   extremely flammable  FP £ 20 F     .        Class IA
                        FP i 73°F,BP*100°C    Class IIA
                        FP 1 73°F,BPS100°C    Class IB
                        FP >73°F             Class 1C
  Combustible           FP 100to200°F        Class II
   ignitable   .         FP 100tol40°F        Class IIA
                        FP 140to200°F        Class IIB
      Chairman, American Society  for Testing Materials  (ASTM)
Committee  on Flash Point Methology  and Government  Response.
Reference  8, Nov. ]7,  1978.
      "•"National Fire  Protection Association, reference 9.
      * Department of  Labor
                               7

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     It has been suggested that flash points be standardized
to a particular atmospheric pressure, since barometric
pressure does vary with different locations, and with time
at the same location.  One might assume that if the barometer
drops appreciably after a flash point determination is made,
what was tested as a nonignitable substance at the higher
reading may be ignitable at the new pressure, or vice versa.
However, this is an unrealistic assumption since, according
to the National Oceanic and Atmospheric Administration, the
largest barometric deviation in a single day is less than
20mm Hg which changes the flash point at any temperature
only 1.2°F, and the barometric pressure difference between
elevation changes could be as large as 150mm Hg which changes
the flash point by 9°F.  Even if these changes were important,
the proposed standard measures of test incorporate pressure
correction .
                 F =F +0.06{760-P )
                  CO           O
                 reconverted flash point
                 F * observed reading
                 P »observed reading, pressure
                  o
     *
      ASTM D-93, ASTM D3278

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1. 3. a  .States



California (Reference 1)



     Flammable, (a) "Flammable means:



     (1)  A liquid which has a flash point at or below



          37.8 degrees centigrade  (100 degrees fahrenheit)



          -as defined by procedures described in Title 49,'



          Code of Federal Regulations, Section 173.115.



     (2)  A gas for which a mixture of 13 percent or less,



          by volume, with air forms a flammable mixture at



          atmospheric pressure or the flammable range with



          air at atmospheric pressure is wider than 12 percent



          regardless of the lower limits.  Testing me-th'bds



          described in Title 49, Code of Federal Regulations,



          Section 173.115, shall be used.

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     (3)   A solid which is likely to cause fires due to
          friction, retained heat from processing or which
          can be ignited under normal temperature conditions
          and when ignited burns so as to create a serious
          threat to public health and safety.  Normal temperature
          conditions means temperatures normally encountered
          in the handling, treatment, storage and disposal
          of hazardous wastes.
     (4)   A gas, liquid, sludge or solid which ignites
          spontaneously in dry or moist air at or below
          54.3 degrees Centigrade (130 degrees Fahrenheit)
          or upon exposure to water.
     (5)   A strong oxidizer.  Section 60415 "Strong Oxidizer"
          means a substance that can supply oxygen to a
          reaction and cause a violent reaction, or sustain
          a fire when in contact with a flammable or combustible:
          material in the absence of air.
Minnesota (Reference 2)
     Explosive material:  a material that has the property
either to envolve large volumes of gas that are dissipated
in a shock wave or to heat the surrounding air so as to cause
a high pressure gas that is dissipated in a shock wave.
Explosive materials include, but are not limited to, explosives
as defined in 49 C.F.R. S173.50  (1976) and compressed gases
as Defined in 49 C.F.R. S173.300 (1976).

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Flammable material:  any material that:
     a.   has a flash point below 20QOF (93.3°C), except the
          following:
          (1)  a material comprised of miscible components
               having one or more components with a flash
               point of 2000F (93.30C), or higher, that make
               up at least 99% of the total volume of the
               mixture;
          (2)  A material that has a flash point greater
               than 100°F  (37.8QC) and that when heated to
               200°F  (93.3°C) will not support combustion
               beyond the flash;
          (3)  An explosive material; or
     b.   may ingite without application of flame or spark
 .  	   including, but not limited to, nitro cellulose,
          certain metal hydrides, alkali metals, some oily
          fabrics,  processed meals, and acidic anhydrides.
 Flash  point:  the minimum temperature  at which a material
 gives  off vapor within  a test vessel in sufficient concentration
 to form  an  ignitable mixture with air  near  the surface of the
 material.
 Oxidative material:   any material with the  property  to
 readily  supply oxygen  to a  reaction in the  absence of air.
 Oxidative materials include, but are not  limited to, oxides,
 organic  and inorganic  peroxides,  permanganates,
 chlorates,  perchlorates, persulfates,  nitric  acid, organic
                             11

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and inorganic nitrates, iodates, periodates, bromates,
perselenates, perbromates,  chromates, dichromates, ozone,
and perborates.  Bromine, chlorine, fluorine, and iodine
react similarly to oxygen under some conditions and are
therefore also oxidative materials.
Flammable materials:  Whenever the flash point of a waste is
to be determined, one of the following test procedures shall
be used.  The test chosen shall be appropriate for the
characteristics of the waste that is tested.
      (a)  Standard Method of Test for Flash Point by Tag
          Closed Tester  (ASTM D56-70).
      (b)  Standard Method of Test for Flash Point of Aviation
          Turbine Fuels by Setaflash Closed Tester  (ASTM
          D3243-73).
      (c)  Standard Methods of Test for Flash Point of Liquids
          by Setaflash Closed Tester  (ASTM D3278-73).
      (d)  Standard Method of Test for Flash Point by Pensky-
          Martens Closed Tester  (ASTM D93-73) or alternate
          tests authorized in this standard.
      For any waste containing components with different
volatilities and flash points and having a flash point
higher  than  200°F  (93.3°C) according to the test procedure
employed, a  second  test  shall be conducted on a sample of
the  liquid portion  of  the material that remains after evaporatioj
in an open beaker  (or  similar container), under ambient
                             \1

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pressure and temperature (20 to 25°C) conditions, to 90
percent of original volume or for a period of four hours,
whichever occurs first, with the lower flash point of the
two tests being the flash point of the material.
Oregon (Reference 3)
     Flammability is defined as:
          (a)  material which is readily ignited under
               ambient temperatures
          (b)  material which on amount of its physical
               form or environmental conditions can form
               explosive- mixtures with air and which is readily
               dispersed in air, such as dusts of combustible
               solids and mists of flammable or combustible
               liquids
          (c)  material which burns with extreme rapidity,
               usually by reason of self-contained oxygen,
               materials which ignite spontaneously when
               exposed to air
          Cd)  liquids, solid or gaseous material having
               a flash point below 100°F (38°C)
Ohio (Reference 4)
     Plash points below 17SOP
     Very volatile flammable liquids, very flammable liquids
     and gases, and substances that, in the form of dusts
     or mists readily form explosive mixtures when dispersed
     in air.

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Washington (Reference 6)
     Explosives:  subs-tances capable of producing an explosion,
which are not regulated by chapter 296-52 WAG and which:
     (a)  evolve heat or gas when heated to 40°6'(100°F) ; or
     (b)  evolve gas or heat when mixed with water at
          4QOC  (100°F); or
     (c)  contain oxidizers, that is, substances that yield
          oxygen readily
     Flammable:  substances which have a flash point at or
below 40°C (100°F),  as determined by the Tagliafcue open cup
tester, or other suitable method.
1.3.6 Agencies and Organizations
Department of Transportation (Reference 5)
     (1)  flammable liquids are those having flash points
          below 100°F.
     (2)  Combustible liquids are those having flash points
          above 100°F and below 200°F.
     (3)  a flammable solid is any solid material other
          than one classifed as an explosive, which, under
          conditions normally incidental to transportation
          is liable to cause fires through friction, retained
          heat from manufacturing or processing, or which
          can be ignited readily and when ignited burns so
          vigorously and persistently as to create a serious
          transportation hazard.  See Appendix B for details
          and test methods.

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Consumer Product Safety Commission (Reference 7)
     (1)  the term "extremely flammable" shall apply to
          any substance which has a flash point at or below
          20°F as determined by the Tagliabue Open Cup
          Tester
     (2)  the term "flammable" shall apply to any substance
          which has a flash point above 20°F, to and including
          80°F, as determined by the tester mentioned above
     (3)  "Extremely flammable solid" means a solid substance
          that ignites and burns at an ambient  temperature
          of 80°F or less when subjected to friction,
          percussion, or electrical spark
     (4)  "Flammable solid" means a solid  substance that
          when tested by the method described in Section
          1500.44, ignites and burns with  a self-sustained
          flame at a rate greater than one-tenth of an  inch
          per  second along its major axis.
 Environmental  Protection Agency  (Title  40  (Pesticides),
 C.F.R.,  Part 162)
     The proposed rulemaking  includes  flammability  labeling
 requirements.   "Extremely flammable" and  "flammable"  categories
 correspond  to  those  found in  Title  15,  U.S.  Code,  Sec.  1261.
      (I) extremely  flammable -  a  flash point less  than 20°F
      (2) Flammable  -  a  flash point greater  than  20°F and
          less than  80°F
      (3) Combustible  -  a  flash  point  greater than 80°F
          and  less  than  150°F.

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National Academy of Sciences  (Ad - 782 476):

     Rating                        Definition

     0 - Insignificant hazard      Not Combustible

     1 - Slightly hazardous        Flash point larger than
                                   140°F (60°C)

     2 - Hazardous                 Flash point from 100°F
                                   to 140°F  (37 to 60°C)

     3 - Highly hazardous          Flash point less than 100°F
                                   and boiling point greater
                                   than 100°F

     4 - Extremely hazardous       Flash point less than 100°F
                                   and boiling point less than
                                   100°F

National Fire Protection Association

     Flammable Liquid shall mean a liquid having a flash

     point below 100°F (37.8°C) and having a vapor pressure

     not exceeding 40 pounds per square inch (absolute)

     at 100°F (37.80C) and shall be known as a Class I liquid.

     Class I liquids shall be subdivided as follows:

     Class IA shall include those having flash points below

     73°F (22.8°C)  and having a boiling point at or below

     100°F (37.80C)  Class IB shall include those having

     flash points below 73°F (22.8°C)  and having a boiling

     point at or above 100°F (37.8QC).  Class 1C shall include

     those having flash points at or above 73°  (22.8°C)

     and having flash point at or above 73°F (22.8°C)  and

     below 10QOF C37.80C).

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     Combustible Liquids  shall  be  subdivided as follows:

     Class II  liquids  shall include those having flash

     points at or above 100°F (37.8°C)  and below 140°F

     (60°C).

     Class IIIA Liquids shall include those having flash

     points at or above 140°F (60°F)  and above 200°F

     (93.4QC).

     Class IIIB Liquids shall include those having flash

     points at or above 200°F (93.4°C).

Booz-Allen Research, Inc., EPA, 1973 (PB-221-464):

     A material is flammable if it has a flash point that

     is less than 100°F and a boiling point less than 1QQ°F;

     spontaneous combustion and/or explosive reaction.

Department of the -Navy:

     Hazard Level                  Criteria

          4 .                  Flash point less than 73°F and
                              boiling point less than 1QO°F.

          3                   Fp less -than 73° and Bp greater
                              than 73°F and less than 100°F

          2                   Fp greater than 100°F and less
                              than 200°F

          1                   Fp greater than 200°F

          0                   Material will not burn
                         n

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1^4  Selected Approach



     The problem in writing regulations that define an



ignitable solid, liquid, or gas is the choice of a hazardous



characteristic that best quantifies the waste.  A quick,



economical, and re-p'c\rfducible test method must be available



to minimize errors in lab and field testing which can end



in disaster for facility owners and/or operators.



     There are several established methods for measuring



the ignitability of liquid waste  (that is, pure liquids,



solutions, sludges^.or solids).  These ignitability characteristl



are defined in Subsection 1.4b.



     The most attractive of these alternatives is the use of



flash point as an indicator of ignitability.  Use of this



indicator offers the public better protection from fires



than the others do.  Plash point testing can provide reproducib



results.  Almost all governmen-t agencies and professional



organizations recognize flash point as the primary indicator



of ignitability.  For these reasons, flash point testing sho.uld



be used as an indicator of ignitable liquids.



     Autoignition temperature testing is a possible second



choice.  However, autoignition temperatures are generally



quite high, and it is unlikely that wastes would be exposed

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to energy sources of the magnitude needed to heat them to
their autoignition point.  The autoignition temperature
cannot be disregarded entirely, though, as internal combustion
is a definite problem at disposal sites given the available
internal energy sources.  Currently available autoignition
test methods were judged inadequate for use as an identifier
of ignitable waste.
     Flash points tend to be much lower than autoignition
temperatures.  Flash point is defined as the lowest temperature,
corrected to a pressure of 101.3 kPa (1013 millibars), of a
substance at which application of an ignition source causes
the vapors above the substance to ignite under specified
conditions of test.  Various sources of direct ignition can
be present at a land disposal site, such as hot tailpipes,
uncontrolled smoking, or sparks from compaction machinery..  In
such a situation, waste with low flash points are of more
concern than those with low autoignition points.
     Most companies responding to the Advance Notice of
Proposed Rulemaking  (ANPR) on Section 3001, distributed to
them by EPA, commented that they would like the flash point
limit to be 100°F, which would be consistent with DOT.*  This
limit is used in regulating hazardous waste during disposal.
The only basis for the argumented advocating the 100°F flash
point limit was to maintain consistency with DOT, therefore
 'Reference 8

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eliminating confusion in handling wastes.  While  it is
recognized that consistency in rulemaking is important,
nevertheless it is believed that flash points greater than
100°F pose a human health and environmental threat.
     The DOT flash point limit of 100°F that defines a
flammable substance was chosen with the rationale that 100°F
is about as hot as a shipment of a liquid material would get
while being transported in the United States.  However, this
limit does not take into account all of the heat sources
available to waste during transit, storage, and ultimate
disposal.  Joseph M. Kuchta recommendation on page eight of
their report *:
          It is recommended that a flammable liquid be
          defined as one with a flash point below 140°F,
          as determined in a Tag Closed Cup, and having
          a vapor pressure not exceeding 40 psia at 100°F.
          the 140° break point is suggested because ambient
          temperatures of this order can be encountered during
          shipment, particularly in hot climates; this break
          point is also consistent with the NFPA and IMCO
          classification systems and that proposed by IOTTSG.
     The EPA has chosen to use a flash point limit of 60°C
(140°F) or lower for defining an ignitable hazardous waste.
It should also be mentioned that to avoid confusion between
a DOT flammable liquid and an EPA flammable liquid, the Agency
has decided to use the term ignitable liquid.
     Conditions at present, given available landfill capacity,
are such that a higher flash point limit than 60°C (140°F)
would generate waste (s)  which could conceivably strain existing
*Reference 10
                      2.0

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hazardous Waste facilities and result in mismanagement of
these wastes.  Waste disposal companies, in their comments
on previous draft regulations, recommended flash point
limits be set between 140 and 200°F.  The available sources
of ignition at landfill sites (that is, unregulated smoking,
sparks from gasoline combustion engines, hot exhaust systems,
and improper mixing of wastes) causes a«degree of hazard in
handling waste.  It is this degree of hazard the EPA wishes
to minimize. .

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1.4.a  Solids, Gases, and Oxidizera
     Solids and oxidizers are not easily tested.  DOT, in its
regulations, uses prose definitions to identify each  .
Studies have been initiated by DOT in the past that evaluate
existing test methods and proposed quantitative limits.
However, for various reasons, they were judged inadequate
for regulatory purposes.  EPA and DOT are presently working
together in the hope that the problems of testing solids and
oxidirers can be resolved.
     EPA will use DOT'S present regulation to identify
ignitable gases,.  These regulations combine a prose definition
with test methods organized by the Association of American
Railroads .  Any gas that when ignited propagates and sustains
combustion under ambient conditions is hazardous and must
be handled in a safe manner.  EPA will regulate the future
disposal of contained gases, not allowing large pressurized
vessels to be placed in landfills when they are ignitable
compressed gases as defined in 49 CPR 173.300(b).
     *solid - 49CFR173.150; oxidizer - 49CFR173.151
      Reference 11, see Appendix C
                          22.

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1.4.b  Definitions

Autoignition (n) -the spontaneous ignition (without an
     external ignition source)  of a material as the result
     of heat liberation from an exothermic reaction.

Burning Velocity (standard) -fundamental velocity of a
     combustion wave measured normal to the flame front.

Combustible (adj) -capable of undergoing combustion.

Combustion (n)  -a rapid exothermic oxidiation process
     accompanied by continuous evolution of heat and usually
     light.

Deflagration -combustion which propagates into the reacting
     medium at a subsonic velocity.

Detonability Limits -the maximum and minimum concentrations
     of a combustible in an oxidant, e.g., air, which will
     propagate a detonation when initiated at a specified
     temperature and pressure.

Detonation -combustion or other reaction which propagates into
     the reacting medium at a supersonic velocity.

Fire (n) -the phenomenon of combustion.

Fire Point (n) -the minimum temperature to which a material
     must be heated in an open vessel to sustain combustion
     for a specified period of time after ignition by an
     external source.

Flame  (n) -a zone of gas or particulate matter or both  in
     gaseous suspension that is undergoing combustion,  as
     avidence by the evolution of both heat and usually
     light.

Flame  Temperature -the temperature of the product species in
     flaming combustion.

Flame  Speed -velocity of a combustion wave measured relative
     to a stationary observer.

Flash  Point  (n)  -the lowest temperature, corrected  to a
     pressure of 101.3 kPa  (1013 millibars), of a substance
     at which application  of an ignition source causes  the
     vapors above the substance to ignite under the specified
     conditions  of  test.

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Ignite (v) -to initiate combustion.

Lower Flammable Limit -the lowest concentration of a
     combustible substance that is capable of propagating a
     flame through a homogenous mixture of combustible
     substance and a gaseous oxidizer under specified
     conditions of test.

Lower Temperature Limits -the lowest temperature at which a
     combustible substance will produce a vapor concertration
     equal to the lower flammable limit under specified condition
     of test.

Minimum Oxygen Concertration -the minimum concentration of
     oxygen required to sustain burning or flame propagation.

Temperature  (h) -the thermal state of matter as measured on
     a defined scale.

Upper Flammable Limit -the maximum concentration of a combustible
     substance that is capable of propagating a flame through
     a homogenous mixture of combustible substance and a
     gaseous oxidizer under specified conditions of test.

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maid - (flamraability Regulations) - a  substance  that has a definite
Lome but no definite forte exgept such  given by its  container.  It has
viscosity of 1 x 1Q~"3 to 1 x 10   stokes  (1 x 10~7  to 1.x 10-1 ra2 s^1)
 104 F (4Q°C) or an equivalent viscosity  at agreed  upon temperature.
his does not include powders and granular materials).
      Liquids are divided into two classes:
      CLASS A (low viscosity) a liquid having a  viscosity of 1 x 10.""
 25.00 stokes (1 x 10"7 to 25.00 x Ifl"*4 m2 Sf1}  at  104°F  (40°C)
 an equivalent viscosity at an agreed  upon temperature. .
      CLASS B (high viscosity ) - a  liquid having a viscosity of 25.01
1 x 1Q3 stokes  (25;01 x 10~4 to 1 x  Ifl"1  m2 s"1} at 1Q4°F  C40°C)
 an equivalent, viscosity at an agreed  upon temperature.
                                    ^^^^iu^i^c^.^Ha^^^S-i'vis^cafslts
                                       »«.^TV«... .  	•-—^i*—-• —'' ^' ~~~-"- -  , --•• 	—    -fc
eater than  1 x  103  stokas- (1 x 10~  m2 s"1)  at 104°F (40°C) or an
uivalent viscosity  at aa agreed upon, temperature.  (This includes
wders and granular  materials).

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1.5  Test Methods
     There are several common methods used in determining the
flash point of a liquid.  All methods require that the sample
be placed in the sample cup and be heated at a slow and
constant rate. . There are two basic types of apparatus used
for testing the flash point of liquids:  open cup and closed
cup testers.  In a closed cup tester, the test flame is
inserted into a vapor/air mixture within the cup and over
the liquid.  In an open cup, the test flame is passed over
the vapor/air mixture  just  above the liquid.
     A  liquid tested in a closed tester generally  flashes
at a lower  temperature than the  same liquid tested in  an open
cup apparatus.  The  liquid  will  flash at the  same  concentration
of vapor and air  (lower flammability limits)  in  both cups.
In the  open cup,  the temperature must be raised  to a greater
degree  than in  the closed cup  to achieve the  lower flammable
 limits  above the liquid.   This is  due  to the  vapor being
 confined in the closed space above the liquid in a closed
 cup,  while the vapor is allowed to diffuse into the atmosphere
 above the liquid in a open cup*.  The closed cup tester simulates
 the most danerous type of hazardous waste situation (that is,
 gases from volatile liquids when confined tend to accumulate
 quicker, expediting ignition).  Therefore, it is recommended
 that this  type be used in  the determination of flash points.
      'Harry A. Wray, November 17,  1978,Ref.  8

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    There are  two  types  of  temperature baths:  liquid and



air baths.   Since the  purpose  of  these temperature baths is



to ensure uniform temperature  around the entire sample,  a



liquid bath  is  superior to an  air bath due to the better thermal



transport properties of liquids compared to air.



    It makes no difference  in the test whether the apparatus



has a gas or electric  burner.  Both are equally accurate at



the low temperatures of concern.



    Another optional  feature  available is a mixing device.



If the sample to be tested is  very viscous, tends to skin



over, or contains suspended  solids, a stirrer should be



incorporated into the  apparatus.   By agitating the sample,



it can prevent  local temperature  variations.  Since a test



of a pure nonviscous liquid  can be run on either type of



apparatus, it is recommended that the apparatus with a stirrer



be used as standard test  equipment.



    In Table I there  is  a comparison of different types of



flash point  testers offered  by two venders, Fishers and



Sargent.  The Setaflash Closed Cup Tester is not included



because of the  relative newness of the device.  The price



of the Setaflash is between  800 and 1000 dollars.  The Pensky-



Martens Closed  Cup  Tester is EPA's first choice followed by



the Setaflash Closed Cup  Tester.   There will follow a discussion



on the Setaflash Closed Cup  Tester.

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TABLE 1-Comparison of Plash Point Tester Types

Type
Pensky-Martens (Fischer)
Pensky-Martens (Fischer)
Tagliague (Fischer)
Tagliague (Fischer)
Cleveland (Fischer)
Cleveland (Sargent)
Cleveland (Sargent)
Pensky-Martens (Fischer)
Pensky-Martens (Fischer)
Sample Cup
Closed
Closed
Open
Closed
Open
Open
Open
Closed
Closed
Stirrer
No
Yes
No
No
No
No
No
No
Yes
Bath
Air
Air
Liquid
Liquid
None
None
None
Air
Air
Type of Terao Control
Electric
Electric
Electric
Electric
Gas
Gas
Electric .
Gas
Gas
Cost(1974)
$395
$470
$200
$300
$265
$120
$240
$330
$400

* Reference

12








^
C
                                                                         o

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1.5.a  Comparison of Flash Point Test Methods*
     Several test methods are recommended by the American
Society for Testing and Materials for determining the flash
points of petroleum products and other flammable liquids.
Four of the most common types used in this country are listed
in Table II.  Of the four testers listed, the Cleveland open
cup is the least reliable one.  The poor reproducibility of
data by the least reliable one.  The poor reproducibility of
data by this tester is attributed partly to the prescribed
high testing rate and the poor temperature control that
results from the use of an open flame for heating the cup;
the presence of air convection currents can also affect the
results noticeably.  Although the Tag open cup uses a
temperature bath and a low heating rate, its precision is
still not quite as high as that of the Tag closed cup.
Regardless of the precision of the testers, it is important
to examine the great differences that are frequently obtained
for the flash point of a material by the use of the open and
closed cup methods.
      This section and Table II were taken from a report by
J.M.Kuchta and David Burgess, reference 10.

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     Generally, the flash points of flammable liquids are lower
by the closed cup than by the open cup method.  The amount of
the difference will vary with the compositions of the liquids
and the models of testers used.
     According to the available data in the literature, the
Tag closed cup is suitable for determining flash points of
liquids over a temperature range from about 220°F down to at
least 0°F.  Although it is currently recommended for determ-
minations up to only 174°F, ASTM Committees (D-2 and F-27)
are presently proposing that the maximum temperature be
increased to 200 or 220°F for use with liquids having a 'viscosit
of 4 centipoise or less at 100°F.  For liquids of higher
viscosity or higher flash points, the Pensky-Martens closed
cup is recommended.  However, one can also extend the use of
the Tag .tester to the higher viscosity liquids by employing
a lower heating rate than presently specified.  A heating
rate of less than 0.5°F/min or a maximum temperature difference
of 5°F between the bath and sample have been found suitable for
extending the applicability of this tester to thickened fuels
and other highly viscous materials.
                             3o

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                              Table 2-ASTM Specifications and Measured  1Q
                             Performance for Several Flash Point Testers
Tester
Cleveland
Open Cup
Tag Open Cup

Tag Closed Cup

Pensky-Martens
Closed Cup
ASTM Designation
D 92-66

D 1310-67

D 56-64

D 93-66
D 93-73
Temp. Range F
175

0-200
201-325
55
lSr-175
220
220
Heating Rate F/min
9-11

2
2
2
2
9-11
9-11
Repeatability F
15
i
4
9
2
2-
4
10
Reproduclbility F
30

7
12
6
4
6
15

    10 Kuchta, J,M. and D.  Burgess.   Recommendation of  Flash Point Method  for  Evaluation of  Flamraability
Hazard in the Transportation pf Flammable Liquids,   Safety  Research Center,  Bureau  of  Mines,  Report
054131,  April 29, 1970,                    1

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l.S.b  Pure Liquids and Solutions
     A pure liquid or solution with a flash point less than
60°C (140°F) is a hazardous waste.  The 60°C breakpoint is
suggested because ambient temperatures of this order can be
encountered during the disposal of waste, particularly in hot
climates.  Heats of chemical reaction, solar radiation, or
organic degradation can elevate ground temperature well above
DOT'S 100°F.
     Testing of pure liquids with the apparatus recommended
above is a reasonably simple process described in the American
Society for Testing and Materials (ASTM) guidelines*.
     Agitation of the liquid is necessary if it has a
viscosity of 45 S.U.S. or more at 37.8°C (100°F), or if..it
contains suspended solids or has a tendency to form a
surface film while under testing.  It is recommended that
the agitation device be used in all tests to simplify testing
procedures.
      ASTM D93-72
     "•" S.U.S. means Saybolt Universal Seconds as determined by
the Standard Method for Saybolt Viscosity  (ASTM D88-56) and
may be determined by the use of the S.U.S. conversion tables
specified in ASTM test D2161-66 following determination of
viscosity in accordance with the procedures specified in the
Standard Method for Transparent and Opaque Liquids  (ASTM D445-6S
                            32-

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l.S.c Sludges

     Sludges are the most prevalent form of waste and are quite
difficult to test.  Stratification is one of the physical
peculiarities of sludges which might affect flash point testing.

     If the sludge is stratified, x^hich is likely due to the
differing densities of most substances/ then the upper layers
will inhibit evaporation of the lower layers.  The evaporation
of the lower layers will occur at the normal rate only when
they are in direct contact with the atmosphere by either
thermally or mechanically produced holes.

     This problem can be overcome by taking two test samples
that represent the two extreme situations.  These situations
are:   (1)  no mechanical or thermal agitation is present,
allowing only the least dense  (top) layer to be in contact
with the .atmosphere enabling it to evaporate;   (2)  there
is vigorous agitation and all  components of the sample come
into contact with the atmosphere and evaporate.

-------
     If flash points of the two samples representing these

extremes are taken and neither results in an ignitable

solution/ then any linear combination of the two situations

will also be nonignitable .  However, if either one of these

samples has a flash point below 60°C  (140°F) then the sludge.

is a hazardous waste.

     The Pensky-Martens Closed Cup Tester is recommended

because of the incorporation of a stirring device to handle

simply the testing procedure of sludges and slurries.  With

very viscous materials the Setaflash Closed Cup Tester can

be used with greater success.
      The theoretical rationale for the the evaporation-
inhibiting effect of layer stratification is as follows:
At any given temperature the molicular motion of a sample
can be statistically described.  Only those molecules with
a kinetic energy above a certain level have enough energy to
escape the attractive forces of the other molecules in the
liquid in the liquid phase.  Obviously, those molecules for
below the surface have a very small chance of reaching the
surface with this minimum kinetic energy intact, since they
are constantly being involved in elastic collisions and
will, on the average, loseenergy in these exchanges since
they are themselves above the mean in energy.

-------
l.S.d Solids

     The testing of solid waste samples also must be considered.
In the burning of most substances, the actual carabustion takes
place only after the substance has been vaporizer1 or decomposed
by heat to produce a gas.  Most solids have lower vapor pressures
than liquids due usually to the stronger intermolecular forces
existing in solids.  For this reason, they are less likely to
be ignitable since it takes more energy (a higher temperature)
to volatize them.

     It is rare for a solid to have a flash point in the normal
temperature range.(except for those solids having substantial
vapor pressure, like naphthalene).  Therefore, there is less
danger of fire from solids.  Since solids can exist in many
different "states"  (granular, amorphous, rigid, etc.), the
ignitability testing procedures must be very general with few
of the specific details  one 'has come to expect in standards.

-------
     There is another reason why solids  are more  difficult to

test for ignitability than liquids.   Solids are usually poorer

conductors of heat than liquids, and even among themselves

vary widely in thermal transport properties.   When a solid

is heated, heat build-up is intense  at the energy source,  due

to poor conductance.   Depending on the duration of heating

or the rate of change of heating, different ignition points or

flash points would be recorded for a solid.  For  example,  if

it were heated slowly, a lower flash point would  be observed

than if it were heated quickly, due  to the inability of solids

to quickly reach thermal equilibrium.


     For reasons such as these, and  where a standard testing

procedure is not applicable, a prose definition may be warrante

in the case of solids.  Such a definition might be similar to

the one incorporated in Minnesota's  hazardous waste regulations

It reads:


        A flammable solid is any solid material other than
        one classified as an explosive;  (1) that  under
        conditions incident to its management, is liable
        to cause fires through friction, absorption of
        moisture, spontaneous chemical changes, retained
        heat from manufacturing or processing, or (2) that
        can be ignited, and when ignited burns so vigorously
        and persistently as to create a hazard during its
        management.  Examples of flammable solids include,
        but are not limited to certain metal hydrides,
        metallic sodium and potassium, certain oily fabrics,
        processed metals, and nitrocellulose products.
                              3C,

-------
     As mentioned earlier in_ this document,  the largest problem

associated with solids seems to be in writing standards for
                            'S
the proper sampling techniques, since each particular "type"

of solid state demands a different sampling technique.  In a.
                                                   jfc
report that was done by the Bureau of Mines for DOT  ', there

were established two criteria for testing the flamrnability of

solids, ignitability and flame spread behavior.


     The report, Classification Test Methods for Flammable

Solids, proposes that given the described procedures, most

of the ignitable solids can be classified.  Three classes of

flammable solids were recommended for the transportation.

regulations:            '                        .


        Class  1:  Flammable solids which may ignite when
        exposed to flame, such as a butane torch, but which
        propagates flame horizontally at rates less than
        10 in/min by the proposed method.

        Class  2:  Flammable solids which are rated highly
        flammable either because of their great ease of
        ignition when exposed  to flame such as a butane
        torch, or because of their ability to propagate
        flame  at rates  greater than 10 in/min.   (Solids
        which  ignite in less than 1 second by the proposed
        flame  exposure  test would be  included in this  class)
                             37

-------
          Class 3:  Extremely flammable solids which may
          ignite  spontaneously in dry or moist air at
          ambient temperatures equal to or less than 130°F.
           (Solids which react to produce flame or tempera-
          ture rises over SOQOp by the proposed pyrophori-
          city test would be included in this class).
     In order to provide a more enforceable regulation, EPA
needs to develop and introduce an acceptable test method for
solids.  The policy of the Agency has been toy     "criteria
                                             /
that best quantify each hazardous characteristic.  The 60°C
(140°P) flash point will identify ignitable liquids? and
possibly ignitability and flame spread at some determined
quantitative limit will identify ignitable solids at some
future time.
     It may be pointed out that some polymeric materials may
be classed as solids but may have residual momomens present
which will flash such as polystyrene.  Furthermore, waste
material may come from a concentrator with absorbed and adsorbed
liquids having a low flash point.  The Setaflash Close Cup Tested
may be used to determine the flash point of these materials.

-------
l.S.e  Gases and Oxidizers

     As mentioned earlier in this document, hazardous gases and
oxidizers will be defined using a prose definition.  There is
no available test method that adequately evaluates the danger
involved in handling either gases or oxidizers in a waste form
that may be mixed with other wastes.
     Definitions of ignitable gases and oxidizers were selected
from DOT'S regulations 49 CFR 173.300 and 49 CFR 173.151,
respectively.

-------
                         References

1.   California.  Environmental Health.  Title 22.
          Register 77, No. 42-10/15/77.  Chapter 2.
          Minimum Standards for Management of Hazardous
          and Extremely Hazardous Wastes.  Article 1.
          Definitions.  Section 60112.
2.   Minnesota.  Minnesota Pollution Control Agency.
          HW-1 General Applicability, Definitions,
          Abbreviations, Incorporations, Severability,
          and Variances.  HW-2 Classification, Evaluation,
          and Certification of Waste.  Draft Document.
          June 3, 1977.
3.   Oregon.  Proposed Regulations on Hazardous Waste Disposal.
          63-015(1)(C).  Sept. 4, 1975.
4.   Ohio.  Ohio Revised Code.  3734.  EP-20-01.
5.   Department of Transportation.  Hazard Materials Regulations
          Code of Federal Regulations.  Title 49. Part 171-177.
          Federal Register Part IV.  Monday, September 27, 1976.
6.   Washington.  Washington State Department of Ecology.
          Washington Administrative Code (WAG).  Hazardous
          Waste Regulations.  Chapter 173-302 WAC.
          January 27, 1978.
7.   Consumer Product Safety Commission.  Title 16.   (Commercial
          Practices).  Code of Federal Regulations.  Part 1500.

-------
8.    3001 Docket.   Hazardous Waste Management Division  (WW-565).
          U.S. Environmental Protection Agency.  401 M St., S.W.
          Washington, D.C.  20460.
9.    National Fire Protection Association.  Fire Protection
          Handbook.  National Fire Protection Association
          International.  60 Batterymarch Street, Boston 10,
          Mass.  U.S.A.  Chapter 11, Fire Hazard Properties
          of Flammable and Combustible Liquids.
10.  Kuchta, J.M.  and David Burgess.  Recommendation of Flash
          Point Method of Evaluation of Flammability Hazard
          in Transportation of Flammable Liquids.  April 29, 1970.
          11 p..  Available from National Technical Information
          Service, 5258 Port Royal Road, Springfield, Va.  22151.
          PB-193077.
11.  Testing protocol is available at the Bureau of Explosives.
          Association of American Railroads.  Washington, D.C.
          20036.  202/293/4048.
12.  Walter W. Kovalick, Volatility of Hazardous Waste  (Information)
          Memo to John P. Lehman.  Hazardous Waste Management
          Division.  EPA.  Aug. 15, 1975.
13.  Kovalick, J.M. and A.F. Smith.  Classification Test Methods
          for Flammable Solids.  Report of Investigation 7593*
          Pittsburg, Mining and Safety Research Center.  Bureau
          of Mines.  Pittsburg, Pa.  1972.
                             4|

-------
                        Bibliography
National Fire Protection Association.
Fire Protection Guide on Hazardous Materials.
6th Edition.
Boston, Massachusetts.  1975

National Fire Protection Association.
National Fire Codes.
Boston, Massachusetts.  1973.

Department of Transportation.
Hazardous Materials Regulations.
49 CFR Parts 171-177.
Federal Register Part IV.
Monday, September 27, 1976.

U.S. Environmental Protection Agency.
Issue Analysis from Discussions at Fous Public Meetings.
Public Meetings Record  (SW-524).  December 1975.

Kuchta, J.M. and A.F. Smith.
Classification Test Methods for Flammable Solids.
Bureau of Mines Report of Investigation 7593.  1972.

Underwriters' Laboratories, Inc..
Tests for Comparative Flammability of Liquids.
Standard for Safety 340.
March 24, 1972.

Grumpier, Gene.
Development of a Working Definition for
Volatility of Potentially Hazardous Liquids and Solids.
OSW - Technology Assessment Program _ EPA.

Kohan, A.M..
A Summary of Hazardous Substances
Classification Systems.
U.S. EPA Report #SW-171.  1975.

Environmental Protection Agency
OSW Hazardous Waste Guidelines and Regulations.
Federal Register Part V Monday, May 2, 1977.

Electronic Industries Association.
Ignitability and Flammable Tests.
EIA RS-325  June 1966.

-------
ASTM.  Standard Method of Testing for
Ignition Properties of Plastics  D 1929-68.

ASTM.  Standard Method for Testing for
Vapor Pressure of Petroleum Products (Reid Method)
D 373-72.

ASTM.  Standard Method for Testing for
Vapor Pressure of Petroleum Products (Micro Method)
D2551-71.

ASTM.  Standard Method for Testing for
Flash Point by Pensky-Martens Closted Tester
D 93-73.

ASTM.  Standard Method for Testing for
Flash Point of Chemicals by Closed-Cup Methods
E 502-74.

ASTM.  Standard Method for Testing for
Flash Point of Liquids by Setaflash Closed Tester
D 3278-73.

ASTM.  Standard Method for Testing for
Flash Point bv Tag Closed Tester
D 56-70.

Kirk-Othmer.  Encyclopedia of Chemical Technology.
Second Edition  Interscience Publishers.

Chemical Rubber Company.
Handbook of Chemistry and Physics  56th Edition.
Litton Educational Publishing, Inc.  1968.

Department of Transportation.
Annual Report of the Secretary of Transportation on
Hazardous Materials Control.
Section 302, PL 91-458. 70, 71, 72, 73, 74, and 75.

Battelle Memorial Institute.
Program for the Management of Hazardous Waste,
EPA Office of Solid Waste Management Programs.
Contract #68-01-0762.  July 1973.

King, P.V. and A.H. Lasseigne.
Hazardous Classification of Oxidizing Materials and Flammable
Solids for Transportation - Evaluation of Test Methods.
Report No. TSA-20-72-6.
National Technical Information Service.

Department of Transportaiton.
Hazard Classification of Flammable and Oxidizing Materials for
Transportation - Evaluation of Test Methods, Phase II.
Report No. TES-20-73-1.
National Technical Information Service.


                              4-?

-------
Dale, Charles B.
Classification of Oxidizers and Flammable
Solids/ Phase III.
DOT - Office of Hazardous Materials
Report No. TES-20-75-2.
National Technical Information Service.
                            44

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        Appendix A







   Examples of Accidents



Involving Ignitable Wastes

-------
                           Alabama
               Anniston, Calhoun County 3/76
     Kevlar aramid waste from a Du Pont plant in Richmond,
Virginia, which had been brought to Alabama by Southern
Metal Processing Company (SMPC), was stockpiled at three
locations in Calhoun County.  SMPC failed to provide adequate
disposal and as a result the corrosive contents leaked onto
the ground.  There was a major fire at the main site, two
firemen become ill presumably due to inhalation of toxic fumes.
Du Pont paid $650,000 for clean-up of the sites.
                              Iowa
               Council Bluffs, Elias Burning Dump 71-76
     A gravel pit, located on private property, was filled with
rubble one year prior the start of a fire.  The fill material
consisted mainly of frame buildings taken from a urban renewal
area of the city.  The fire initated around 8/71 and continued
to burn till 7/76.  One attempt of the city to extinguish the
fire failed.  Noxious fumes and smoke was emitted during most
of the burning history.  County delays and lack of state regu-
lations hampered efforts to     control the fire.
                              Wisconsin
                    Wonewac, Junean County 2/74
     A fire was reported at Wonewac dump.  At the scene of the
fire 6 volt dry cell and single cell batteries were found with
the name Rav-0-Vac on them.  The fire was visable for three miles
and small explosions were observed.

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                              Texas
                    Austin,  Travis County 7/75
     An unlicensed waste hauler,  Rabor Enterprises,  stored
industrial waste at an unauthorized storage dump and left
the contents in steel drums, some of which, started  leaking.
These waste included acids,  heavymetals,  volatile liquids,
and waste oils.  Clean-up of the  site cost $76,825.75.
                              Ohio
                    Cincinnati, Elda Inc. Dump
     An employee of a private dump was burned over 50 percent
of his body when several containers of an unknown volatile
liquid caught fire and enveloped  his bulldozer.   Firemen had
to run their hoses more than a half mile to extinguish the
flames because the dump did not have hydrants.
                          Illinois
          East St. Louis, St. Clare County 8/73  & 4/74
     Two serious fires occured at the site during compaction
operations.  The fires burned for several days and involved
personal dangers.  The Mal-Milam  Landfill has accepted various
industrial waste for the past ten years.   Monitoring tests
have shown phenol concentrations  at 2500 ppb.
                         Illinois
                    Calumet, Cook County 9/75
     A landfill operator died from severe burns  when the com-
pacter that he was operating struck a 55-gallon  drum of ethyl*
acetate.  The incident occured after a scavenger/hauler had da-
posited a load at the Calumet Industrial Development Landfill
in the dark hours of the morning.

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                         Illinois



               Chicago,  Dan Ryan Expressway



     Several dozen barrels of chemical waste exploded in a



truck bin spewing barrels and flames over cars smarling rush



hour traffic.  The chemical, believed to be sodium nitrate,



was part of a load being carried by an industrial waste hauler.



Two policemen suffered eye injuries from the smoke.





                         Pennsylvania



                    Harrisburg, Dauphin County 1/75



     An explosion occured at the Harrisburg City incinerator



which resulted in building damages totalling approximately



$95,000.  The explosion resulted from the ignition of a drum



of spray adhesives delivered by the Rolance and Rolance Supply



Co.





                         Pennsylvania



               Harrisburg, Dauphin County.3/72



     Approximately 85 grates were burned out in the Harrisburg



City incinerator.  The damage resulted from the incineration



of magnesium filings delivered by TRW Systems Group.  Resultant



cost was $123,000.



                         Washington



               Everett, Snohomish County 9/74



     The N.W. Wire Rope Corp., cleaning off debris from the site



of a metal  reduction plant,  sent 200  cubic yards  to  a  landfill



near Siver  Lake.  The debris consisted of  aluminum dust,  magnesium



chips,  and  two broken drums of concentrated phosphorus.   Upon



dumping and compaction,  the material  ignited  and  developed  into

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a fire.  Water could not be applied to the waste and explosions



eliminated chances to obtain samples.



                            Minnesota



                  Minneapolis, Dakota County



     An employee of a Dakota County landfill was seriously



burned when the piece of equipment he was operating crushed



and ignited a container of flammable solvent which had been



illegally dumped at the landfill.   The employee suffered burns



over 85% of his body and spent 4*s months in the hospital.

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           Appendix B
Test Methods for Ignitable Waste

-------
                 Table of Contents

B-l,2 	  Aerosol Flame Projection Tests
B-3	  D93-72
B-4 	  D3278-73
B-5 	  Reference 13
                        51

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\TIONS AND MAINTENANCE DEPARTMENT  • • BUREAU OF EXPLOSIVES
'CAN RAILROADS BUILDING  •  WASHINGTON, D.C. 20038 •   202/293-4048
\nt

ZtANO
                  AEROSOL FLAME PROJECTION TESTS

        Section 173. SOOlb) subparagraphs (2), (3),  and (4) of Title 49 to
 the Code of Federal Regulations referenced The Bureau of Explosives'
 Flame Projection Apparatus, Open Drum Apparatus and  Closed Drum
 Apparatus to be used when examining aerosol products.

        The following are descriptions of the equipment and testing pro-
 cedures to be used when conducting the tests.  Any further questions
 relating to this testing should be addressed to the Director at the above
 address.

 FLAME PROJECTION TEST
                EQUIPMENT - The test equipment consists of a base
  four inches wide and two feet long.  A thirty inch rule (with inches marked)
  is supported horizontally on the side of the base and about six inches above
  it.  A plumber's candle of • such height that the top third of the flame is at
  the height of the horizontal rule is placed at the zero point  in the base.

                PROCEDURE  - The test is conducted in a draft-free area
  that can be  ventilated and the atmosphere cleared between each test.   The
  self-pressurized container is placed at a distance of six inches from the
  ignition source and the spray jetted into the top third of the flame with valve
 -opened fully for periods of 15 - 20 seconds.  The length of the flame pro-
 jection from the candle position is read on the horizontal scale.  Three or
  more readings are taken on each  sample and the average is taken  as the
  result.  Samples are also tested with valve in partially open positions to
  test for "burning back" to valve.
  DRUM TESTS

                EQUIPMENT-  The equipment consists of a 55 - gallon open-
  head steel drum or similar container which is placed on its side and fitted
  with a hinged cover over the open end that will open at a pressure of 5 p. s. i.
                                 sv

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The closed or solid end is equipped with one shuttered opening at the top.
This is for the introduction of the spray.   The opening is approximately
two inches from the edge of drum head.and is two inches in diameter,
There is a safety glass or plastic window six inches  square in che center
of the solid end.  A lighted plumber's candle is placed inside the drum or
the lower side and midway between the ends.

              PROCEDURE  - The tests are conducted in.the open and
when temperature is between 60°F and 80°F.
              	  OPEN DRUM  TEST 	'

              This test is conducted with hinged errd in a completely
open position and with the  shutter closed.  The spray from the dispenser,
with valve opened fully,  is directed into the upper half  of the open. en;l
and above the  ignition source for one minute.  Any significant propaga-
tion of flame through the vapor-air mixture away from the  ignition souro
shall be considered a positive result -- but — any minor and unsustained
burning in the immediate area of the ignition source shall not be considei
a positive result.
               •	  CLOSED DRUM TEST	

              This test is conducted with the hinged cover dropped into
position to rest freely against the end and to close the open end of the
drum to make a reasonably secure but  not necessarily a completely air-
tight seal.  The shutter is opened and the spray is jetted into th« drum
through this shutter with valve fully opened for one minute.  After clear1
ing the atomsphere in the drum,  the jetting is repeated similarly three
times.  Any explosion or  rapid burning of the vapor-air mixture
sufficient to cause the hinged cover to move  is considered a positive
result.
April, 1974
                              B-i

-------
         B-3 ASTM D93-72





Pensky-Martens Closed Cup Tester
               54-

-------
                                                                                    •to-
    ft  Designation: O 93 - 72
                       : 34/71
           AMERICAN SOCIETY FOR TESTING AND  MATERIALS
                                   $».. H»iU«tl»liia. "a, HIM
                                         W A5TM »!••>••* Ctnr**i ASTM
TVt
Standard Method  of T«»t tor
FLASH  POINT  BY PENSKY-MARTENS  CLOSED
TESTER1
            1*24: LAST kt«n*o. 1*71
  •f ifcc Air«nci« SocMy Far T«ttu| u
                                          Dvtll
                                          ». I** )**» »f U«
M UM jfu of tiM rc*pvr**«l Tha a itea • fLu4*r* W ckx Uuu»u of f»-
IP H Ta« taal (WBbtr n">| wl» ma» be
dcwrmiMd  Mi«f Method D O9J  ami  th« flu*
DOUM of toWai-iypc liquid  »«« may  b» deter-
•MMd uuif Method D M37.
  Non 2— Thti method may be  cnp4oycd  for
tfcc  ottcoton of ooaumimtioii of hibncatuif otb
by tmtfot MOMIIU of »oUuW materiaU
2. Applicable  Docvncirtt
  II ASTM Standard*
     D 56  Test for Rash Point by Tag Closed
       Teattf*                          _
     D 1310 Test  for Flaah Point of Liquid*
       by Ta$ Open-Cup Apparatus*
     D 1393 Test  for Flash Point of Drying
       Oil**
     D 1417 Test  for Flash Point of Solvent-
       Type Liquid Waxes'
    £  I Specification for ASTM Thermom-
       eters'

X Swwfttrr «f Method
  3.1 The sample is  heated at  a slow, con-
stant rale with continual stirring.  A small
fame is directed  inn the  -P ai r>  -'ar in
tenrali *ith simulu.i:ous i:..ertuption J. u.r-
ring. The  fb>h point is the lowest tempera-
ture at »hich application of  the test flame
cautes the vapor  above the sample  to ignite.
                                    4. Apparanu
                                     4.1  Pt«sJt>-Morte*s Closed FtasM Tester.
                                    as described in AppeadU Al.
                                     Nort J—Ta*rc arc automatic ftath point tcsicrs
                                    available aad i«  MM »hic!i may be aavaatagcous
                                    la UM  saruif of iruw| time, pcnrui the  avc of
                                    smaller vimpUa. aad h*»c ether factors »kich miy
                                    merit Utor mac. If aMomatic letters arc  used, the
                                    M*r NMM b» s«rc ikat all of the manufacturer's in-
                                    straetioaa he cal'brauof. arfjvtuag. aad operating
                                    tkc unmuBOM arc followed,  la aay cam of diiptiic.
                                    the  aath pout w diurmiaad maaually taaU be
                                    coaaidend the ref erw leu.
                                     4.2 Ttitrmomtttn—^Two  standard   ther-
                                    mometers  shall  be  used  with the ASTM
                                    Peasky-Marteas tester, as follows:
                                     4.2.1 For tests in whkh the indicated read-
                                    ing ftOs within  the limits 20 to 200  F (-7 to
                                    +93  Q.  bdusfve, aa ASTM  Pensky-Mar>
                                    teas Low  Range or Tag Closed Tester Ther-
                                    mometer  having a range from  20  to  230  F
                                    (—5 to +UO Q aad coo/orming to the re-
                                    quirements for Thermometers  9F (9O and
                                    as prescribed ia ASTM Specification E I  er
                                    IP  Thermometer 1SF (ISO conforming to
                                    specifications given la Appendix A3. shall be
                                           For tests ia whkh the indicated read-
                                    iaf falb wtthia the lUniu 230 to TOO F (110
                                    to 371 CX aa ASTM PtAiky-Martens Htjh
                                                »f ASTV
                                         33

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                                                                                         '*/
D 93 —
                                                     34
 Range Thermometer having a range Tram 200
 to 700 F (90 to 370 C) and conforming to the
 requirements  for Thermometers  10F  (IOC)
 as prescribed in Specification E I or IP Ther-
 mometer I6F (I6C) conforming to specifica-
 tions given in Appendix A3. shall be used.
  4.2.3 For  the  range 200 to  230  F (93 to
 110  C) either thermometer may be used.

 5. Preparation of Apparatus
  S.I Support the tester on  a level, steady
 table.  Unless tests are made  in a draft-free
 room  or compartment,  it is  good practice.
 but  not  required, to  surround the  tester on
 thres  sides with  a  shield, each  section  of
 which is about 18 in. (46 cm) wide and 24 in.
 (61 cm) high.

6. Preparation of Sample
  6.1 Samples  of very viscous  materials may
be warmed until they are reasonably fluid be-
fore  they are  tested. However, no  sample
should  be heated more than is absolutely nec-
essary.  It shall  never  be heated  above a tem-
perature of 30 F (16 C) below its expected flash
point.
  6.2 Samples containing  dissolved  or free
 water may be dehydrated with calcium chlo-
 ride  or by filtering through a qualitative filter
 paper or a loose plug of dry absorbent cotton.
 Warming the sample is permitted, but it shall
 not be heated for prolonged periods or above
 a temperature  of 30 F (16 C)  below  its ex-
 pected flash point.
  MOTE 4—if the sample is suspected of contain-
 ing volatile contaminant*, the treatment described
 in 6.1 and 6.2 should be omitted.

7. Procedure
  7.1 Thoroughly  clean and dry all parts of
the cup and its accessories before starting the
test,  being sure to remove  any solvent which
had  been used to clean the apparatus. Fill
the cup with the sample to be tested to the
level indicated  by the  filling mark.  Place  the
lid on the cup and set the latter in the stove.
Be sure  to have  the  locating  or locking de-
vice  properly engaged. Insert the thcrmoro*-
ter.  Ligh! the test flarr.c .snd adj'ist ii to  /  .-
in. (4 mm)  in  diameter. Supply Ihc  heat c:
such a  rate that the  temperature as indicated
       by the thermometer increases 9 to 1 1  F (5 to
       6 C)/min.  Turn the stirrer 90 to  120 rpm.
       stirring in a downward direction.
         7.2 If the sample is known to have a flash
       point of 220 (104 Q or  below,  apply the test
       flame when the temperature of  the  sample
       is not higher than 30 F (17 C) below the flash
       point, and  thereafter at a temperature read-
       ing that is a multiple of 2 F (I C\ Apply  the
       test flame by operating the mechanism  on  the
       cover which  controls the  shutter  and  test
       flame burner so thai the flame is lowered into
       the vapor space of the cup in 0.5  s. left in its
       lowered position for  I  s, and  quickly  raised
       to  its high  position.  Do not stir  the  sample
       while applying the test flame.
        7.3 If the sample is known to have a Rash
       point above 220  F (104 C) apply  the test
       flame in the manner just prescribed at each
       temperature that is a  multiple of S F  (3  C).
       beginning at a temperature not higher than
       30 F (17 C) below the flash point.
        7.4 Record as the flash point the tempera-
       ture read on the thermometer at the time  the
       test flame application  causes a  distinct flash
       in the interior  of the cup. Do not  confuse  the
       true  flash  point with the  bluish halo that
       sometimes surrounds the test flame at appli-
       cations preceding  the  one  that  causes  the
       actual flash.

          DETERMINATION or  FLASH POINT OF
                SUSPENSIONS  OF SOLIDS

       8. Procedure
        8.1  Bring the material to be tested and  the
       tester to a temperature of. 60 ± 10 F (IS i
       5 C)  or 20 F (1 1 C) lower than  the estimated
       flash  point, whichever is lower.  Completely
       fill  the air space between the cup  and the  in-
       terior of the air bath with water  at the tem-
       perature of the tester and sample. Turn  the
       stirrer 250 ± 10 rpm. stirring in a downward
       direction. Raise the temperature  throughout
       the duration of the test  at a rate of not less
       than  2 nor  more than 3 F (I to 1.5 C)/min.
       With the  exception of these  requirements  for
       rates of stirring and heating, proceed  as pre-
       scribed in Section 7.
         Ny:  •  Solid luibon dioxide ffO»| (dry ico
       shall ;ii .:o tasc U" uv.-J to ohlaih i!ie proper rut.-
       of  temperature  ri»c.  since CO: ha\  a  blanketing
       effect which leads to a false flash point.
                                           34
                                          Sh

-------
                                      n the
 cov;r  ar*. cc;--.p!i!cl>  clo-.;(J. and  -
-------
                                           D 93 —
       '34
mensional  requirements in Fig. A I. The  air bath
may be either a flame or electrically heated metal
casting  (Note  A I),  or an  electric-resistance  ele-
ment (Note A2). In  either case, the air bath must
be suitable for  use at the  temperatures to  which  it
wilt be subjected without deformation.

  NOTE A I—If the  heating element is a flame or
electrically heated metal  casting,  it  shall  be  so
designed and  used  that  the  temperatures of  the
bottom  and the walls are  approximately the same.
On  this account it should be not less  than  V, in.
in thickness. The casting shall be designed so that
products of combustion of the flame  cannot pass
 up and come into contact with the cup.
   NOTE A2—If the air bath is  of the electric-re-
 sistance  heated  type,  it shall be constructed  so
 that all  parts of (he  interior  surface  are  heated
 uniformly.  The wall and bottom of the air  bath
 shall be not less than V. in. in thickness.

   A 1.1.3.2 Top  Plait—The  lop  plate shall be of
 metal, and shall be  mounted with an air gap be-
 tween it and the  air bath. It may be attached to
 the air  bath  by  means of three  screws and spac-
 ing bushings. The bushings should be  of  proper
 thickness to define an air gap of .',t in., and they
 shall be noi more than V. in. in diameter.
         A2. MANUFACTURING STANDARDIZATION OF THERMOMETER AND FERRULE
  A2.I The low-range  thermometer, which  con-
forms also to  the specification Tor the cup ther-
mometer in the Tag closed  tester  (Method D 56)
and which  frequently is fitted with a metal ferrule
intended  to fit the collar on the cover of the Tag
flash tester, can  be supplemented by  an adapter
(Fig. A5) to be used in the  larger diameter collar
of the  Pensky-Martens apparatus. Differences in
dimensions of these collars,  which do  not affect
test results, are  a  source of  unnecessary  trouble
to manufacturers and suppliers of instruments, as
well as to users.                    •
  A2.2 Subcommittee  21  on  Metalware Labora-
tory  Apparatus,  of ASTM  Committee E-l  on
Methods of Testing, has studied this problem and
has  established  some  dimeaiional  requirements
which are shown in Fig. AS.  Conformity to these
requirements is not  mandatory, but is desirable to
users  as  well  as  suppliers  of  Pensky-Martens.
Testers.
                              A3.  THERMOMETER SPECIFICATIONS


                               TABLE Al  IP TlMrmoiMUr Specifications
  NOTI—The stem shall bt made with an enlargement having a diameter of ».3 to 20 mm greater thin the
stem and a length of 3 to 5 mm, the bottom of the enlargement being 64 to 66 am from the bottom of the bulb. These
dimensions shall be measured with the test gate shown in Frf. 1'of Sptcincation E I.*
Name
Range
Graduation
Immersion, mm
Over-all length ±10 mm
Stem diameter, mm
Bulb shape
Bulb length, mm
Bulb dianuter. mm


Length of graduated portion,
mm
Distance bottom of bulb to, mm

Longer lines ac each
Figured at each
Expansion chamber
Top finish
Scale error not to exceed ±

See iictes



1P13F
IP13C
IP16F
Pnuky-Martcos Low Peiuky-M
20 to 230 F
1 F
37
280
3.5 to 8.0
cylindrical
9 to 13
not less than 5.5
and not
greater than
stem
143 to 177
20 F
75 to 90
5F
10 F
Required
Ring
1 F

' anc st<: i*b;c
Tor emergent
stem temper-
atures
-7 to +110 C
0.5 C
57
280
5.5 to 8.0
cylindrical
9 to 13
not less than 5.5
and not
greater than
stem
143 to 177
-7C
75 to 90
1 C and 5 C
5C
Required
Ring
0.5 C

iiid tc • :.,
lot :nu:f,cni
stem temprr-
atures
200 to 700 F
5F
57
280
5.5 to 1.0
cylindrical
10 mix
not less than 3.5
and not
greater than
stem
143 to 177
200 F
75 to 90
23F
50F
Required
Ring
25 to 500C
3.5 F above
SOOT
. .tn'nicr£cni
stem temper-
atures
IP16C
artcns High
90 (o 370 C
2C
57
280
3.5 to 8.0
cylindrical
10 max
not less than 5.3
and not
greater than
stem
143 to 177
90 C
75 to 90
IO and 20 C
20 C
Required
Ring
I to 260 C
2 C above
260C
t »n<* trc fahle
for enicrceni
stem temper-
atures
                                               36

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                                                                     /     7  127 t
   0 93 —
                               34
      TABLE A3
Avenge
                                    Average
Column
                                     Column
   Thermometer 9F
     (30 to 230 F)
    32 F -   66 F
   100 F      86 F
   160 F      106 F
   220 F      123 F
              Thermometer 9C
              (-5 to + 100C)
               OC       19 C
              31 C       28 C
              70 C       40C
              10) C       SO C
   Thermometer 10F
     (200 to 700 F)
   212 F      141 F
   390 F      1»F
   570 F      180 F
   700 F      220F
             Thermometer IOC
               {90 to 370 C)
             100 C      61 C
             200 C      71 C
             300 C      S7C
             370 C      104 C
   IP 15F (20 to 230 F)
    32 F       66 F
    70F       TOP
    100 F       86 F
    130 F       104 F
    212 F       118 F
            IP I5C (-7 to HOC)
               OC      19 C
              20 C      20 C
              40 C      31 C
              70 C      40 C
              100 C      48 C
IP I6F (200 to 700 F)
200 F 140 F
300 F 149 F
400 F 160 F
300 F 173 F
603 F 193 F
700 F 220 F
IP 16C (90 to 370 C)
100 C 61 C
130 C 63 C
200 C 71 C
230 C 78 C
300 C 87 C
330 C 99 C
  Mart—The  emergent  column  temperatures are
those attained when uiing the thermometers in the
test equipment for which (he thermometers were
originally designed. In some eases these temperatures
are markedly  different from those realized during.
standardization.

             (TaM* AZ M MSI pat*)
                      37

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                                           D  93 — (&) 34
                             TABLE AZ  SpfciAadoM for ASTM Th«rm.iniUn
                                    All dimensions are in  millimeters.
                             See Table A3 for Standardization Temperatures.
                                                 Graduation!
   ASTM No.
   and Name
Range
For Test  Immer-
   at      (ion
Scale      _   .  ,
Error      Special
         Inscription
                                                                         FU pan-
                                                                           si on
                                                                        Chamber

9C-62
Pensky-
Martens,
Low Range
Tag Closed
Tester
9F-62
IOC- 62
Pensky-
Manens,
High Range
10F-62

-5 lo
+110 C
20 to
230 F
90 to
370C
200 to
700 F
Subdi-
vision*
0.3 C
57
1 F
2C
57
Sf
Long
Lines
at Each
1C
5F
10 c
23 F
Number
at Each
1C 0.5 C
10 F IF
20C •
30F »

A5TM
«Cor»F
57 MM I.MM
ASTM
IOC -•
  * Scale error: 2.5 F up to 500 F; 3.3 F over 300 F.
  • An expansion chamber is provided for relief of gas pressure to avoid distortion of the bulb at higher tem-
peratures. It is not for the purpose of joining mercury separations; and under no circumstances should the
thermometer be heated above the highest temperature reading.
                                              38
                                   (.0

-------
                                                                                     NOV
                                                                                          7 
stem

32 F
HOC
4.5
to
6.0
230 F
lance

F

85
to
98


86
to
99

to Line tance **n*' **u
at pj

C H
too c
221
to
237
212 F
360 C
227
to
245
680 F
'«• un« Wi-
th a". lo °° Len8»h
•", «««. I?,'
Lni MMI'M ill**
mm
I J K

7.5
lo
•.5
•

7.5
to
S.5


L

2.5
to
J.0<


2.5
lo
S.0<

Dis.
tance
to
Bot-
tom

M

64
lo
66


64
to
66

  4 The length of the enlargement, and the distance from the bottom of the enlargement to the bottom of the

bulb shall be measured with the test gage shown in Fig. A6.
                                           39

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                                                                            N'UV
                         
-------
                                                        KOV   71977
                    D 93 — (g) 34
HANDLE OPTIONAL
c
1_
_«^
1
F
i


1
FILLING
L t


—

MARK^


r .
r8
i t

G
1
J
H j
* J?
1 ^ T /
I W
1 U,^
f a
fi

                                         mm
                                                      in.
                                      mm
                                            max
                                                        mas
                  in.
  min
        max
              mm
                    max
A
B
C
D
E
F
C
H
I
J
79.0
1.0
2.8
21.72
45.47
50.72
55.75
3.8
53.90
2.29
79.8

3^6
21.34
45.72
50.85
56.00
4.0
54.02
2.54
3.11
0.04
0.11
0.855
1.790
1.997
2.195
0.15
2.122
0.090
3.14

OJ4
0.860
1.800
2.002
2.205
0.16
2.127
0.100
D
E
f
C
H
I
J
K
L
u.r
4.8
13.1
2J.8
1.2
7.9 .
12.27
16.38
18.65
13.5
5.6
14.3
24.6
2.0

12.32
16. M
19.45
0.50
0.19
O.JJ
0.94
0.05
0.31
0.483
0.645
0.734
0.53
0.22
0.56
0.97
0.08
. • .
0.485
0.655
0.766
                                    FIG. A3 Com Proper.
 FIC.A2 TtMCiy.
                         41

-------
                                      093 —
34
         FUMC EXPOSURE
        DEVICE
               THERMOUETER
       SHUTTER
        STIRRER
       TEST CUP
                                                               ma OF CUP MUST
                                                               BE IN CONTACT
                                                               WITH THE INNER
                                                               FACE OF COVER
                                                               THROUGHOUT ITS
                                                               CIRCUMFERENCE
                                       mm
                                                                     in.
                               nun
                                                             nun
                                                                            max
A
B
C
D
E
F
C
H
!•
J
K
L
M
N
18.3
2.38
7.6
2.0
0.69
2.0
6.4
9.6
43.0
».o
. . .
1.22
31.8
7.6
19.8
3. IS
1.4
2.8
0.79
2.8
10.4
11.2
46.0
51.6
0.36
2.06
44.4
8.4
0.72
0.094
0.30
0.08
0.027
0.08
0.25
0.38
1.69
1.97
• • •
0.048
1.23
0.30
0.78
0.125
0.33
0.11
0.031
0.11
0.41
0.44
1.81
2.03
0.014
0.08
1.75
0.33
' Includes tolerance for !cnglh of thermometer given :n \STV Spinfic.iiion FT I.' ASTM Thrrmnmrirrs

                           FIG. A4  7 «v ( .? irj COK. -.t*r»klt,
                                       42

-------
                                                              NOv    7 id/;
               D 93 —
                              34
  -CLAMP NUT
   -PACKING RING
   •FERRULE
-PACKING RING
   -ADAPTOR
                                B
                 -c-J
              — D—
           ADAPTOR- BRASS
                               CLAMP NUT-STAINLESS STEEL

                                    3&UNF THREAD
       BOXES TO SUIT THERMOMETER STEM
 SPLIT
        PACKING RINGS
       SOFT ALUMINIUM
                 SPLIT'
t
G
|
/
i
i
y
^.
I
i
t «
H-
                                         FERftULC
                                      STAINLESS STEEL
               into
                            max
                                          in.
                                                      nui
A 6.20
B 17.0
C 9.80
D 12.19
E 1.40
F 1.36
G 12.4
H t.tt
1 8.1
J 9.9
K 8.64
L 5.1
M 17.0
N 27.4
O 7.11
t 9.73
6.50
18.0
9.85
12.24
I.6S
8.61
13.0
8.61
8.6
10.7
8.69
5.6
17.5
28.2
7.16
9.78
0.244
0.67
0.386
0.480
0.055
0.337
0.49
0.337
0.32
0.39
0.340
0.20
0.67
1.C8
0.280
0.381
0.236
0.71
0.3SS
0.412
0.065
0.339
0.57
0.339
0.34
0.42
0.342
0.22
0.0
1.11
0.212
0.3S5
HC.AS
                       43

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                                                                                                     HUV
                                                 93 — Q0 34
                               FIC. Ai  Tot G»t« fo» Oickbf
                                            •• J BCfflMMMf Cn»


   »r fublitatio* o/ttiii ila*Jard no position it takm *itk mptei to ttit validity of any pmiiiu rigku /• coimtcito* Ikrrr.
wrr*. tntl iht American Sotitty for Tilling and Maitriali don HOI undtnakr to iiattrt tnyonr unliving iht
ofoioii liability for in/rintfi**n of any Lttun fattnl nor assume any such liability.
                                                 44
                                                         U

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       B-4 D3278-73





SETAflash Closed Cup Tester

-------
                                                                                HOV"  '<••-,;

            Designation: D 3278 - 73

                   AMERICAN SOCIETY FOR TESTING AND MATERIALS
                                  1914 Rac* Sr.. Philadelphia. Pa.. 19103
                        Reprinted from the Anniul Book of ASTM Standards, Copr"'c ASTM
            Standard Methods of Test for
            FLASH  POINT OF LIQUIDS  BY SETAFLASH CLOSED
            TESTER1
   This Standard is issued under the fixed designation D 3278; the number immediately following the designation indicates the
   year of original adoption or. in the case of revision, the year of last revision. A number in parentheses indicates the year of :asl
   reapprovul.
  1. Scope
     1.1  This method covers the determination of
  the flash point, by Setaftash® Closed Tester, of
  paints, enamels,  lacquers, varnishes,  and re-
  lated  products and  their components having
  flash points, between 32 and 230°F (0 to 110°C)
  having a  viscosity lower than  150 stokes at
  77°F  (25°C).»
    Norh I—Tests at higher or  lower temperatures
  are possible.
     1.2 The procedure may be used to determine
  whether a  material will  or will not flash at  a
  specified temperature or to determine the finite
  temperature at which a material will P.ash.
     1.3 The results from this method  are compa-
  rable  to those obtained  by the Tag  Closed
  Tester procedure  described  in  Method  D563
  and  the  Pensky-Martens Tester method  de-
  scribed in Method D 93.    .  .

  2. Applicable Documents
    2.1  ASTM Standards:
     D56 Test for  Flash Point by Tag  Closed
      Tester'
     D 93 Test for Flash  Point by Pensky-Mart-
      ens Closed Tester2
     DS50  Test  for Distillation  of Industrial
      Aromatic Hydrocarbons  and  Related
      Materials2
     D 1015 Test for Free/ing Points of  High-
      Purity Hydrocarbons'
     D 1078 Test for Distillation Range of Vola-
      tile Organic Liquids2

  3. Summary of Method
     3.1  By means of a syringe, 2 ml of sample is
  introduced through a leakproof entry port into
                      the tightly closed Setaflash Tester or directly
                      into the cut that has been brought to within 5°F
                      (3'C)  below the  expected  flash  point. As a
                      flash/no flash  test, the expected flash point
                      temperature  may be a specification or other
                      operating requirements. The temperature of the
                      apparatus  is  raised to the precise temperature
                      of the expected flash point by slight adjustment
                      of the temperature dial.  After 1 min, a  test
                      flame is applied inside the cup and note is taken
                      as to whether the  test sample Hashes or not. If a
                      repeat test  is necessary, a fresh sample should
                      be used.
                        3.2 For  a finite flash measurement, the tem-
                      perature  is sequentially increased through the
                      anticipated range, the test flame being applied
                      at 9°F (5°C) intervals until a flash is ovserved.
                      A repeat determination is then made using a
                      fresh sample, starting the test at the  tempera-
                      ture of the  last interval before the flash point of
                      the material and making tests at increasing  t°F
                      (0.5°C) intervals.

                      4. Apparatus
                        4.1  Setaflash Tester*, shown in  Fig. XI,  and
                      described in Appendix XI.
                        4.2 Thermometers* conforming to specifica-
                         'These methods are under the jurisdiction of ASTM
                      Committee D-l on Paint. Varnish. Lacquer, and Related
                      Products.
                         Current edition approved Oct. 29. 1973. Published DC-
                      .ember t°.'J.
                         '.'974 Annual Hook of ASTM Standards, Part 29.
                         *I971 Annual Boot, of ASTM Standard*, I'art 1$.
                         'Unit  shown in"Fig. XI is manufactured by Stanhope-
                      Seta  Ltd.. Park Close.  Eghum. Surrey. England.  It i>
                      available  in the USA from Erdco Kngiriccring Corp.  M6
                      Official Road. Addison. 111. 60101. or from Paul N. Gardner
                      Co.. Station 9. P O Rox«<»33. Fort Laudc.-dale. Ru. 33316.
                         ' Thermometers cnay be oi'Uuncil from the .suppliers of the
                      Setailash.
E 2 3.R. 550)
STATS REGISTER. MONDAY, SEPTEMBER t9, 1977
Page 553

-------
                                         0 3278
lions given in Table XI. Test to determine that
the scale error does not exceed 0.5'F (0 25'C).
The use  of  a  magnifying lens significantly
assists in making temperature observations.
   4.3 Glass Synnge, 2 * O.I-ml capacity  at
77 *F (25 "C),  to provide a means of taking a
uniform sample Check the capacity by dis-
charging  water  into a  weighing  bottle and
weighing.  Adjust plunger if  necessary.  A dis-
posable syringe of equal precision may be used.
   4.4  Cooling Blcxk. aluminum (described in
 Append)*  X2) which fits snugly within the test
 cup for rapid cooling of the sample cup.
   4.5 Barometer.

 5. Reagents and Materials
    5.1 p- X ylene'—Reference   standard   for
 checking  the Setaflash Tester.
    5.2  Cooling  Mixture of ice water or dry ice
 (solid CO J and acetone.
    5.3  Liquefied Petroleum Gas.
    5.4  Heat Transfer Paste1
  6.  Sampling
    6.1  The sample size for each lesl is 2 ml.
  Obtain ai least a 25-ml  sample from the bulk
  source and store in a nearly full tightly dosed
  clean glass  container  or in  other container
   suitable for the type of liquid being am pled.
    6.2 Erroneously  high  flash  points may be
   obtained if precautions are not taken to atotd
   toss of volatile material Do not open sample
   containers unnecessarily and do not transfer the
   sample to the cup unless its temperature is at
   teiu 20*F  (10*C) below  the expected  ftash
   point. Discard samples  in leaky containers.
   7.  Preparation of Apparatus
     7.1 Prior to initial use or after removal of the
   thcrmome'.er, insert  the thermometer  into its
   pocket. Fig.  X2,  with  a good heal transfer
   p*>le.
     7.2 To help in making the necessary settings
   during  a lest, determine  the relationship be-
   tween  the  temperature control dial  and ther-
   mometer readings at interval* not aver  lO'l-
   (5*C) throughout the  scale  range  of heater
    before the  initial use.
      7.3  Place  the tester in a subdued tight and in
    a position where it is not exposed to disturbing
    drafts. Provide  a black-coated shield, if neces-
    sary
                                                                                      W
                    7.4 Read the manufacturer's operating
                  maintenance instructions on the care and
                  vtcmg of the tester. Observe the specific
                  lions regarding the  operation  of its
                  controls.
                     7.5 Check  ihc  accuracy of  the  tester
                  determining the  flash point of the P-**'leT
                   reference standard in duplicate (Appendix X ,
                   The average of the results should be 81 = * •* _,
                   (27.2 x 0.8*C>. If not. remove the
                   and  observe  whether  sufficient  heat .-
                   paste surrounds  the  thermometer  to Pr°*
                   good heat transfer from the cup to the "*
                    mometer.

                          METHOD  *-FLASH/>O FLASH
                    8,  Procedure—Ambient to 230°F (110°O
                      8.1  Inspect the inside of the test cup. lid- *\
                    shutter mechanism for cleanliness and freed &
                    from contamination. Use an absorbent l'ssue,j
                    wipe  clean, if necessary.  Lock  the cover
                    tightly in place.
                       8.2 Switch  ihc  tester on. if not
                    stand-by. To rapidly approach the s
                    flash  temperature of the  charged sample
                    the heater dial fully clockwise (Note 2)
                    the heater signal (red) light to glow.
                    thermometer indicates a  temperature of ^"^
                     5"F  (3"C) below  the specification or  «;%
                     flash point temperature, reduce ihc heat iflr^
                     to the test cap by slowly turning the  hc*j
                     control  dial counter clockwise until the $'S
                     light goes out (Note 3).                    ,
                        Nort  2—When the correct temperature is.**f
                     on the temperature controller, the elapsed  tltny
                     reach it m*y be greater than when turned Fu" /V1"
                     leu  attenttoa »itt be required  in  the
                                                 ;rnju.                                    ^
                                                  NOT? J—The tesl cap temperature is stable *
                                               the signal light slowly cycles on and off.
                                                  8.3 Determine the barometric pressuf*
                                               determine the corrected specification temp*
                                               ture at that barometric pressure (sec 13.2)- y
                                                  8.4 After the lest cup temperature has s**^
                                                lized at the  specification or target flash P^
                                                charge the >ymipc with the sample to he K'L
                                                and  transfer the syringe  to the filling o^
                                                                     ~t U>»h Poini Check
                                                                       - Petroleum Co..

                                                                           from the ^"
                       Speviil Prodoct* l>«,
                       OWU
                         ' H«3I irvtdcr
                       Scufluh Toicr
                       as ihcu no >
                                                                       .>!•>•
                                                                                    »"T"
MO
STATE RCCiSTER, MONO AY. SEPTEMBER 19. 1977

-------
   (Fig. X2) taking care not to lose any sample.
   Discharge  the sample into the  test cup  by
   depressing the syringe plunger  to  its lowest
   position, then remove the syringe. If the sample
   has a viscosity greater than 45 SUS at 100°F
   (37.8°C)  or equivalent  of 9.5  cSt at  77°F
   (25.0°C). discharge the contents of the syringe
   directly into the cup.  Immediately close tightly
   the lid and shutter  assembly.
      8.5 Set the 1-min  timing device by rotating
   its knob clockwise to the required setting. In the
   meantime, open the gas control valve and  light
   the  pilot and the test flames. Adjust the test
   flame size  with the pinch valve so as to match
   the  size of the *$:  in. (4-mm) diameter flame
   gage.
      8.6 After  1  min has elapsed,  observe the
   temperature. If at the specification temperature
   (accounting for the  differences of the  barometer
   reading from 760 mm), apply the test flame by
   slowly and uniformly opening the slide fully and
   closing  completely  over a period of approxi-
   mately  2 '/a s. Watch  for a flash.
      NOTE 4—The sample is considered to have flashed
   only if a comparatively large blue flume appears and
   "lOpagaios  itself  over  the  surface of  the liquid.
   Occasionally, particularly near the actual flash  point
   temperature,- application of the test flame may give
   rise to a halo; this should be ignored.
      8.7 Turn off the test and the  pilot flame.
   Clean th« apparatus in preparation for the next
   test.

   9. Procedure—32°F (0°C) to Ambient
      9.1 If the specification or target flash point is
   at  or. below  ambient temperature,  cool  the
   sample  to  10 to 20CF (5  to 10aO below that
   point by some convenient means.
      9.2 Cool the  tester to approximately  the
   temperature  of the  sample by  inserting  the
   cooling block (Appendix  XI.2) filled with a
   cooling mixture (Notes 5 and 6) into the sample
   well. Dry the cup with a paper tissue  to remove
   any collected moisture  prior  to adding  the
   sample.
      Nors: 5: Caution—Be careful in handling the cool-
   ing  mixture and  cooling block, wear  gloves  and
   gosglci. Mixtures such js dr\ ice and acetone can
   produce severe frost bite.
      NOTK  6: Caution—Be careful  in  inserting the
   cooling block into the tester cup to prevent damage to
   the cup.
      9.3  Introduce the sample as in 8.4. Allow the
                      temperature to rise under ambient conditions or
                      increase the temperature of the cup by rotating
                      the heater controller clockwise slowly unltl the'
                      specification temperature adjusted for baro-_
                      metric pressure is reached. Determine whether
                      the sample flashes as in 8.5 and 8.6.
                        9.4 Turn off the test and pilot flames. Clean
                      up the apparatus.

                          METHOD B—FINITE FLASH  POINT

                      10.  Procedure—Ambient to 230°F (110°C)
                        10.1   Preliminary or  Trial  Test— Follow
                      steps 8.1 to 8.5 omitting the barometric reading
                      and using an estimated finite flush point instead
                      of a  specification flash point temperature.
                        10.2  After  1 min  has elapsed,  observe the
                      temperature, apply the test flame by slowly and
                      uniformly opening the slide fully  and closing
                      completely over a period of 2'/2 s. Watch for a
                      flash (Note 3).
                        10.3  Finite  Flash  Point—If a flash is  ob-
                      served proceed as below.
                        10.3.1 Using a temperature  of 9°F (5°C)
                      lower than the temperature observed  in 10.2.
                      repeat  10.1 and 10.2 (Note 6). If a Hash is still
                      observed, repeat  at 9-°F  (5°C) lower intervals
                      until no flash is observed.
                        NOTE  7—Never  make a  repeat test on the same
                      sample. Always take a fresh portion for each test.
                         10.3.2 Repeat  10.1  and  10.2 with a  new
                      sample, stabilizing the test cup temperature at
                      the temperature  at  which no  flash  occurred
                      previously. Observe  if a flash occurs at  this
                      temperature.  If no  flash occurs, increase the
                      temperature at 1°F (0.5'C) intervals by making
                      small incremental adjustment  to the tempera-
                      ture  controller and  allowing  1-min  intervals
                      between each increment and the flash point test.
                      Record  the temperature at which  the flash
                      acutally occurs. Record  the barometric pres-
                      sure. Turn off pilot and  test flumes and clean
                      up tester.
                        10.4  Finite Flash Point—If no flash point is
                      observed in 10.2,  proceed as follows:
                        10.4.1  Using a  lest tempsmiure of 9T(5°C)
                      higher  than the temperature observed  in 10.2,
                      repeat steps 10.1 and 10.2 (Note 7). If no flash
                      is observed, repeat at 9°F (5°C) higher intervals
                      until a flash is observed.
                        10.4.2 Repeat step 10.3.2 with a new sample.
iTr. 2 S.n  551)
STATS REGISTER. MONDAY, SEPTEMBER 19. t977
                                                                                              Page 56
                                             lo

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II.  Procedure—32" FiO'C) to Amb«««c Tem-
    perature
  11.1 frtliminary or  Trial  7>JI—Cool the
sample  to 5 to  10'F (3 to 5'C) below the
expected Hash point.
   11.2 Cool the tetter to approximately the
temperature  of the  sample  by inserting the
coohnf block filled with a cooling medium, into
the sample well (Notes 4 and 5).
   11.3  Insert (he sample  as in 8.4.  Set the
 I-mm timing device. After 1 mm, apply the lest
 flume by slowly and uniformly opening the slide
 fully and closing  completely over a period  of
 approximately 2h s. Observe for a flash (Note
 3). Record the temperature.
    11.4 Finnt  Flash  Poim—U  a  flash  is ob-
 served, proceed as follows:
    11.4.1  Cool  a  new sample and the sample
 cup to 9*F (S*C) below the previous tempera-
 ture (11.3). After I min. check for a flash as in
  M3  If the umple flashes, repeat test  it 9*F
 (5 *C) lower intervals until no flash is observed.
    11.4.2 Repeal with a new sample, cooling
  both sample and letter to the temperature ai
  which the  sample did not flash.  After t min.
  observe if a flash occurs at this temperature, if
  not. increase the temperature  at l*F (O.S'C)
  intervals by making small incremental adjust-
  ments to the temperature controller, allowing 1
  mm between each increment and me test for the
  f\a»h  point. Record the temperature at which
  ihe flash actually occurs. Record the barorr.ct-
  nc pressure.
     11.5  Finitt Flash Point—If no flash point is
  observed proceed as follows:
     ll.5.i Using a test temperature of 9*F(5'C)
  higher than the temperature observed in  11.3.
   repeat  step  11.3 (Note 6). If no flash is ob-
   served, repeal at  9»F (5BC) higher intervals
   until flash is observed.
     11.5.2  Using a  new sample,  repeat 11.4.2
   until a  flash occurs. Record the  temperature at
   which  the  flash  occurs  and  the  barometric
   pressure.

    12. Clean Up Of Apparatus and  Preparation for
       N«al Ten
      12.1 To prepare for the next  test, unlock the
    ltd assembly of the tester and raise to the hinge
    stop. Soak up liquid samples with an absorbent
    paper  tissue and wipe dry. Clean the underside
of the lid and filling orifice . A pipe dcancr
be of assistance in cleaning the orifice.
   12.2 If the sample is a viscous  liquid *
contains dispersed solids, after soaking up m^
of ihe sample, add a small amount of a suitabf
solvent for the sample to the cup and then so
up the  solvent  and  wipe clean  the inte
surfaces  of ihe  cup with an  absorbent ti
paper.
   NOTE 8— If necessary  10  remove residual
boiling solvent residues, moisten tissue with
and »ip« clean.
   NOTE  9 — If any further  cleaning is
 remo«e the l.d and shutter aiscmbly.  Disconnect
 siUcone rubber hose and slide the lid assembl) t"
 nghi to remove. If  *arm. handle carefull).
    12.3 After the cup  has  been cleaned.
 temperature may be rapidly increased to s
 stand-by  value  by  turning the  tempcraf
 control dial to an appropriate point.
    NoTf  10— It is convenient 10 hold the lest cop .
 some stand-by temperature  (depending on P'afl.y
 usage) to conserve time in bringing the cup wilhi" ^
 ust temperature range. The cup temperature "''{•jj
 quickly lowered  by inserting the aluminum c°° #
  block filled *nh an 3pn«onriaie cooling mixiurtr '
  the cup.

                                          tl
   12.4 The syringe is easily cleaned
several times with acetone or any comp»ll(\
solvent, discharging the solvent each time. *^
allowing the synngc to air dry with the pi""*
removed. Replace the  plunger, and pump *
eral times to replace any solvent vapor  with **

13. Correction for Barometric Pressure
   13.1  When the barometric pressure &™
from 760  mm Hg (101.3 kPa).  calculate'
flash point temperature by means of the
 ing equations:
    Calculated flash point  - F +• 0.06 (760 - £
                        - C + 0.03 (760 - r>
 where:
 F, C -  observed flash point. "F (or "O- *
 f    "  barometric pressure, mm  Hg.     ,
    132  Likewise determine  the corrected *r
 fication flash point by the following  equ3(l
             F - S  - 0.06 (760    f)
             C . S   0.0.\
    where:
    F. C  - flash point  to be observed to
            the  specification flash point *
            dard pressure (S).
    S     - specification flish point.
                             STATE REGISTER. MONDAY. SEPTEMBER 19, 1977

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   14. Report
      14.1  When using the flash/no flash method,
   report whether the sample flashed at the re-
   quired flash point and  that the flash/no flash
   method was used.
      14.2  If an actual flash point was determined,
   report the average of duplicate runs to nearest
   l°F(0.5°C) provided the difference between the
   two values does not exceed 2°F (I°C).

   15. Precision*

      15.1 The  following criteria  should be used
   for judging the acceptability  of results (95 %
   confidence):
      15.1.1 Liquids at or below 45 SUS at 100° F
   or equivalent viscosity measurements.
      15.1.1.1  Repeatability—The average  of  du-
   plicate results obtained by the same operator on
                        different days should be considered suspect if
                        they differ by more than 3°F (1.7°C).    •
                           15.1.1.2 Reproducibility—The   average  of
                        duplicate results,  obtained  by  each  of two-
                        laboratories  should not be considered suspect
                        unless they differ by more than 6°F (3.3°C),
                           15.1.2 Viscous liquids above  45  SUS  at
                        100° F or liquids with dispersed solids.
                           15.1.2.1 Repeatability—Duplicate results
                        obtained by the same operator on different days
                        should be considered suspect if they differ  by
                        more than 6°F (3.3°C).
                           15.1.2.2 Reproducibility—The   average  of
                        duplicate results obtained by each of two labo-
                        ratories should not be considered suspect unless
                        they differ by more than 9°F (5°C>.
                          ' Supporting data for this method has been filed at ASTM
                        Headquarters RR O-I-IOOO and reported in Journal of Paini
                        Technology. Vol 45. No. 581 Page 44.
                                           APPENDIXES

                                 XI.  APPARATUS SPECIFICATIONS
     Xl.l A typical apparatus is shown in Fig. XI and
   X2. Electrical heaters are fastened to the cup in such
   a way so  as to provide for efficient transfer of heat.
   The tester includes a variable heater control device
   with a scaled dial ar.d a visible signal :o indicate when
   energy is or is  not  being applied.~ E~«rgy-may be
   supplied from a 115 or 230-V a-c main service (for
   stationary use) or by a 12-V d-c battery sen-ice (tor
   field use). A reguhtable test flame and a pilot flame
                        to maintain the test flame, are provided. These names
                        may be fueled by piped gas service (fixed location) or
                        by  a  self-contained lank of liquefied petroleum gas
                        (5.3) (for portability). A test flume. Y>: in. (4 mm) in
                        diameter,  is provided against  which the size of the
                        flume may be judged. Never recharge  the gas tank
                        with the pilot or test flames lighted, nor in the vicinity
                        of other naked flames. A  l-min audible signal is a
                        desirable accessory.
                                        X2. COOLING BLOCK
     X2.1 The cooling block with dimensions as shown
   in Fig.  X3, is mads of aluminum and covered with
                        pipe insulation.
                   X3. SPECIFICATIONS FOR /»-XYLENE REFERENCE STANDARD
     X3.i  Specific   Gravity  (60/60"F)  (15.61
   IS.6*C)—0.860 min. O.S66 max.
     X3.2 Boiling Range—2°C max  from start to dry-
   point,  when  tested  by Method  D850 or  Method
                       D 1073. The range shall include the boiling point of
                       pure p-xylcnc. which i$ I3S.35°C (281.03»F).
                          X3.3 Freezing Point— I I.23°C min (95 So molal
                       purity) as determined by  Method D 1015.
KF.Y: H\i-ciiK rule-, jre printed in stuiuLrd t\pe t'aec. Proposed additions tu existing rule> arc printed in boldface, while prv>po>ctl
deletions t'ruiJi .*\i>ti:).: rulo arc printed within [single hrueket>|  Additions to prntn»wd rulo arc underlined ;nul liotdfaced.
deletions from proposed rules are printed within [(double t>r;:ekcts||.
  2 S.3. E'J3i
STATE REGISTER, MONDAY, SSPTEMBEn t9, I97T
                                           1

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                                     ame
           XXr XXC.
         SctnUvn Medium
 ImmcruoA
 Gn4u«no«v
   SvMmttont
   La«f unei •«' each
   Number at each'
 Scak error, mat
 Etpanuon cn»mb*r. for neat iV
  Sum. UO
  ftutb
    L««|tA
    00
  Sou location
                          CTC.
       J2io:»*F,0«o UO'C)

       *4 j s . mm

       I . F'l'O
       IO*F.IO'C
       IO*F.. :o*c>
       6 to " mm

       II.T 10 i3 T mm
       *.7 to }." .Tim

       49 to JI rern

        163 to :"6Tirn
    Botiom ^4
- IO*C - 160*
( - :3 10 --O'Cl
** 5 > I mm

I'Fd'O
IOTHO-C)
10'FilO-CJ
Oi'FtOIS'O
P6*F(80*O
204 z 3 mm
6 to 7 mm

 II. 7 10 13.7mm
 4.7 10 5.7 mm
 W mm to 61 mm

 1X3 to 185 mm
• Nomotr M thai u|urrt *n read from n\tu to left m » horuonul oUrx.
         bulb -a tM nuro|«n Tilled for aonjontal opcnjuon
RC, XI
                                                     Ttutr.
                            •TATE Recjsreii. MONDAY. SEPTEUSER 19 1977

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                                     — K
      BORE OF JET
       fryyxySt^
        	S/., ss. -.•-.•
     £

                                         "SOV  "7 i
                             A - HINGE
                             B-LID
                             C - PILOT JET
                             0-TEST JET
                             E - FILLER ORIFICE
                             f - GAS  CONTROL SCREW
                             G- SLIDE GUIDE
                             H- SLIDE KNOB
                             J- SLIDE
                             K- LOCK CLOSURE
                             L- SEALING 0-RtNG
                             M- THERMOMETER
                             N- SAMPLE  BLOCK
                             P- THERMOMETER POCKET
H                                          12.85' ± 3045
                                          I2.80P3O40
                                             inO
                                             
-------
              38.10

CM
                            o
                            CD
                        12.70
            •49.21-
              ARMSTRONG ARMAFLEX No. 22

             •PIPE INSULATION, S«ZE 615

              ( I 3/9" 1.0. , 1/2" THICKNESS)
   T


FIG. 3  Cooling Block
          STATE REGISTER, MONDAY, SEPTEMBER 19. 1977


                        7-T

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   B-5 Classification Test





Methods for Flammable Solids

-------
                                                          '  I 1 -   •
                                                          U w »   j'
Report of Investigations 7593
Classification Test  Methods
for Flammable  Solids
By J. M. Kuchta and A. F. Smith
Pittsburgh Mining and Safety Research Center, Pittsburgh, Pa.
  LJL
r '  /   . .   7- pof!;:-.it of Tf»p.2pcrtatio!i Project COT-OS-00007.
                              11

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                                   CONTENTS
                                                                           Page

Abs trac t	».     1
Introduction	     1
Proposed method for flammable solids	     2
proposed method for extremely flammable solids	     8
Classification of flammable solids by proposed test cethods	    10

                                 ILLUSTRATION

1.  Apparatus for determining ignitability of  flaircaable solids	     3

                                    TABLES

1.  Iguiuability of various flammable solids by rotating disk ignition
      method	     5
2.  Horizontal flame spread rates of various solids	     7
3.  Sunmsry of data from self-ignition experiments with various
      pyrophoric-type materials.	     9
4.  Comparison of hazard classification racings for various flammable
      solids and pyrophoric-type materials	    12

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            CLASSIFICATION TEST METHODS  FOR  FLAMMABLE  SOLIDS

                                       by

                            J. M. Kuchta1 and A. F. Smith2
                                   ABSTRACT

      Ignition and  flammability  test methods were developed by the Bureau of
 Mines  for use in the classification of flammable solids by the Department of
 Transportation.  A rotating disk ignition apparatus and a flame-spread-rate
 apparatus are proposed  for determining the ignitability and flammability,
 respectively, of most flammable solids.  Extremely flammable solids, such as
 Pyrophoric materials, are evaluated by determining their ease of spontaneous
 ignition in an environmental chamber at high-humidity conditions.  Data are
 nr«sented for various representative solids to show the reliability of the
_test methods •£or' classifying the materials.  A classification system is also
proposed for use in government  transportation regulations.

                                 INTRODUCTION

     The Bureau of Mines research programs are partly directed to developing
 safety guidelines  for the reduction of fires and explosions in industries that
produce, transport, or utilize sineral fuels and their products.  As a result
of a request by the Department of Transportation, the Bureau is evaluating
test methods for classifying hazardous materials and developing new methods,
where necessary, for use in government transportation regulations.3  A report
°n. methods for the classification of flammable liquids was recently prepared
under this work.*  The present report is on flammable solids for which no
classification test method is given in the transportation regulations.  Accord-
ing to these regulations, a flammable solid is defined as any solid material,
°ther than an explosive, which can be readily ignited or which can cause or
contribute significantly to fire under the conditions encountered during

 Supervisory research chemist.
 Research chemist.
3Agent T. C. George's Tariff No. 23,  Hazardous Materials Rngulations of the
   Department of Transportation, ICC No.  23,  Bureau of Explosives, 2 Penn
   Plaza, New York, 1969.
4Kuchta,  J.  M.,  and David Burgess.   Recommendation of Flash Point Method for
   Evaluation of Flammability Hazard in the Transportation of Flammable Liquids.
   April 29, 1970,  11 pp.  Available from National Technical Information
   Service (NTIS),  5285  Port Royal  Road,  Springfield,  Va. 22151.  PB-193077.

-------
transportation.   Thus,  to classify such materials,  it is  necessary to const*"'
both their ignicability and  flame spread behavior.   Since existing test
methods were noc  considered  adequate for this purpose,  nev nsthods were dev«l-
oped which are described in  this report.  The methods are designed to ev_
(1) flactnabie solids  that require high temperatures or an external energy
source for ignition,  and (2) extreseiy flassnable solids that can
at normal anbient temperatures.

                     PROPOSED  METHOD FOR FLAMMABLE SOLIDS

     Selection of a test method  for classifying flasaable solids  is compli-
cated by the fact that the  ignitability or flaraabtUcy hazard can vary
greatly with the ignition  stimulus, as well as with the physical  fora and «l
of  the cacerial.   Minimum  spark-ignition energies are frequently  used Co P'£
tially define the ignitability hazard  of finely divided oaterials such as
fla*=uable custs.   However,  such determinations are much less useful  for co»«
or  nasslva  solids since their  spark-ignition  energies tend to be  extremely
i'/to'at ?L»TJoA CM jfT f°C ^n^siua du,t clouds can increase
sn  r   "on   *     ' ?° ntlUJ°ul«s -Jh«  the particle sire is varied from
,>u  to  -.._-K.     «_     •
 in  *..,••.< .^.. i     n»-n»^a«3 ignnon  temperatures, such as those dete,—

 tjnuto» ^"":i^^:i"/::rt./:!!^l?er^
     «
    race
              d             • *" ?rinaril>  'PpUcnble  to  situations where
                               uc^^ly and under  quiescent  conditions to
                              C"rdin8ly'  *  °«hod  was  developed in which
                      compartd by measuring  their relative ease of
             fl«ce spread wh« txp^ed to fl^ in air.   ^^  simula,s

                I-.i011 th" :?Uld re8lilt fr°° Che i-dve^ent S" of
                    ",^0""-1' ^ * Car8° accidenc-  A nethod for
                    solids Is givtz in a subsequent section of this report-
,ctatin8di,kwifn
a pencil^'/
opening.  A butane
I/A inch ir dia*,ter  .nd
.ource.  A propan*  torch
were made with a
burnar head, ood.l
                                                                n
                                 .'       ppacacuJ coasls" essentially
                                            °UtCr circu=**rence through
                                 S'LiStS?1118' * the — 'u-  The S
                                 !7 !±*"bU "^ to var>' the Ien8th f
                                   1 I/?    ¥ •«"<«» J«, approximately
                                   '    "     lTO8' 1$ «Pl«V«* « thc
                                                th* '^ rcsults-  *««e
                                          "     "^ bUrne  with


-------
                                              Slot-ISO* arc,'4in wide
                                            '   Varicble-spsed
                                                                 Butane torch
                                                               used for test flan*
                                                    Specimen on SO-mesh screen
          FIGURE  1. • Apparels ?cr Csrsrnining Ignitability of Flommcble Solids.

8.5  rpu vere  used in  Che pr*s«r.:  work.   Duration of the flase In the sloe
opening is determined by means  cf a photoelectric cell and timer, as shown in
figure  I.  This apparatus is siailir in principle to one developed earlier by
t«»  Bureau for evaluating the igairabilicy of potentially unstable substances
like organic  peroxides.9  The Jacter method used a more severe heat source
< oxygen -hydrogen,  flame)  with ;h*  J*r?Ie confined to a small cup, as compared
to a totally  unccnfined  sarple  in the present net hod.  Cerraan investigators10
have proposed the use of a propane or manufactured coal gas flame from a
Bun sen  burner, as well as various other heat sources, for comparing the ignit-
Bbilicy of f leasable  solids.  However,  since ignition occurs more readily when
the  flacg ij  applied  to  the exposed surfaces of a sample bed,  chat is, from
above rather  than from below the  bed, the use of a Bur.sen fla=e is greatly
limited because of convection and buoyancy effects.

     In the proposed  method,  the  flaaa  from the butane torch is applied near
the  base of the sample bed,  which is ccae shaped -for povders or granular mate-
rials and which is supported by an 80-cesh stainless steel screen to permit
 ?Although the Bureau work is unpublishad,  the method is described in a report
     by  the National Board of Fire Undervriters, Research Report I.'o. 11, 1956
     ?. 22.
ln
  Noenen, H., K. H. Ide, and K. H.  Sucre.   (Safety Characteristics of Ecplo-
    sivc Substancts.)   Explosivestcffe,  v.  9,  1951.  pp.  4-13,  30-42.

-------
vertical circulation of air through the  bed.  A  cone-shaped bed,  at  least  ,.*
1 inch in height,  was required to obtain the  lowest and aost  reproducible iff.
tion tiaes; saaller size beds  yielded  inconsistent results for  the coarser ^
less i&nitable materials.  In  addition,  the distance between  the  satr.ple and
burner was fixed at approximately 1-1/4  inches,  beyond which  the  ignition
tines can be expected to increase.  With sheet saaterials,  small strips are
supported  in a vertical position to provide favorable conditions  for ignicict1'
the width  of the strips is varied, depending  upon the thickness o£ the sa«Pl<<
Generally, the shortest ignition tinea occur  when the £lane  impinges edge**5'
or. the strips.

     Since the ignitability of finely  divided solids can  vary with pareici*
 lize, the  test samples should be at least as  fine as the  materials nay be
 during their shipment.  Fine powders can be  evaluated primarily in their
  as-received" condition.  However, in the case of coarse  eaterials, sar=pl«s '
 fine as  about 50 to  150 m«sh  (Tyler screen series) should also be evaluated'
 .y pulverizing and/or  screening the "as-received" materials,  insofar as  i«
 p jjsiblc .                                                  *

      Table I  suramrizes  the ignition tises that were obtained with the  roC*''
 ing  d.s* apparatus  for various representative flasaable solids.   Mosr.  of  «**,
 bv rHer'--lr?8* V    "  °f " l"St two triali-   Reproducibility  is
 by the  ... c-wing average  ignition  tiaes and tfjviaLion*  for rcplicalc
                                                           distance was
                                      0.27.0.2 second (I* trl.la)
                           rcr^-.e....  6.5±0.3 seconds (4 trials)
              T.traphenyl  ci.i ........  9.4=0.6 seconds (3 trials)

                                                   I8nitton
                          r
 Ut, than 0.6 .ad  o    '. ftecoS""^;"?1" dl"anCe  ran«fl
            a, w.U ., wt«:«J  p"-ie"SS'nS"5*  ?    "  UkC Ci"a'
                          ^^
      c^B
 content wac apparently love-   rL T            °Id 5Cock  sanPlc whose   \
 varied in ch.2 t«., t S iinSJu^LS^1' "S" ^"^^ *"* ?*
 •ampler a, fine ., approxinafely 50 to lS "'^ 8eaerally d^ not increase *
 nature of such solid"-, canjh r.  scdiu^ l~ Uydri^ ^  K**""" °£
 •cid, ch.ir evaluation w£s neres^^ity ^     " e' "^ l he ««t«r-w«t Pf
 th.  rather co.r3e "..-r.c.w.d" oa

-------
      TABLE  L.  -  Ignitablllty  of  various  flarnaable  solids by rotating  disk.
                                      ignition pethod

Granular or powder materials:1









Ho 	






Do 	


Sheet materials:*

Photographic filn, safety, unprocessed...

fcod-shaped material:1 Matches, "strike
anywhere."
Description
50 to 150 mesh
100 to 200 'mesh
—10 to 30 mesh
	 do 	
70 to 150 mesh
MO to 30 mesh
-10 to 50 mesh
	 do 	
100 to 200 mesh
">80 aesh 	
	 do 	
70 to 150 aesh
30 to 100 nesh
40 to 70 mesh
50 to 150 aesh
50 to 200 mesh
20 to 70 nesh
50 to 150 mesh
40 to 50 mesh
	 do 	
1/4 in x i' in.
1/16 in x I in.
1/4 in x 1 in.
1/4 in x 1 in.
1/16 in X 1 in.
Hatchhead
fragments.
Ignition tine,
seconds
Burner -co -sample
distance
1.25 in
<0.02
<.02
.27
a.25
.3
.35
31.1
«3.i
1.9
2.2
«1.3
3.4
6.5
8
8.5
9.5
9
>10
56
6 1.4
2.5
2.3
2.3
6.5
9.5
.2
1.5 in
<0.6
«
.8
.4
31.3
4.5
16
13
15
16
 'Cone-shaped beds.
• I/16-in layer.
aOLd stock sample.
*New stock sample.
•Sustained glow.
'Vertically mounted strips.

     To classify flammable solids, a test method is also proposed for deter-
mining their horizontal flame spread rates.  Although the rates are generally
Higher with upward burning, depending upon the angle, they arc not normally
determined in this manner with finely divided solids because of the problem of
holding the samples in place.  As in the ignition experiments, the samples are

-------
supported by a  stainless steel screen (80 aesh) on a rectangular burning r**.
s^rius;  a re        : :'~- »™
                                                                 :



                                       by che

                                                         <    **,    *
 ub«anc.s.    ovr    .  -   *  3   *  Uaabllity  of  hazardou, household
?ll«»le solid, d^not re-,-!Vr°P    /? the K£"  «t»l»«.ion for rigid  «
condition for sustained ho— c^^'Y   J1^ Stri?S'  which is a "c
fhatogriphic safety  fu4-::      "^ °f S0!ae fla=°^l«  solids,  tnc
<*r povders  and grinul« ;o-?;*e' SM"-
4 in/au for MCerialsPsuch";;
wood char'.oal saaplaj agaLi dispUved
flaw »fcer  ignition.  L coaparing cable*                      °  pro
ignition data for sc»e material, do „« aecessarilv ^  l*  !VidCnC thaC Ch?
r.a:ard ranking that  is indicated V "°! J«c'»*»rlly P.ive the  same order of
sodi.L-a borohyJride is easier to  Unir* thln^ ^"^  4ata- For ^a,,ple,
Uccer solids have ouch higher £la-e «r^H >'"a:ixu:a  and "acnesiun but the
          Note also  that the ra  „ of 'eta' 1ST '^  Chat °f sodium
                                  of aecal povders such as magnesium
                                                              ,  and
                                                       '             ,
                                          14uml d««=ination of burning
                                    cor fast-buraiag substances.

                                        ^"S obcalned for various
                                            "CeS WCrc "Producible to
                                               de, and did not vary gread)'
                                               froa 1/4 to 1/2 Inch.  (
                                            are «nPioy«d.)  As noted, the
                                                naceri*l»  varied from
                                                *1 r*d PhosPho^ to Lass
                                          y    * Snd tetraPhanyl tin
                                                      «d  did
                                                      l*
                                     ?4

-------
greatly upon particle size.  However,  in the case of nomnetal powders, the
flame spread rates are not necessarily increased with a decrease in particle
size, particularly if the powders tend to agglomerate when forming the sample
bed.  Thus, although fine samples (—50 to 150 mesh) of the coarse materials
should be evaluated where possible,  their flame spread hazard with coarser or
"as-received" samples must be given equal consideration.   Generally, most of
the fla==.ible solids that displayed a  high ignicability hazard also had high
flame spread rates >10 in/rain.

          TABLE 2. - Horizontal flame  spread rates of various solids
                                Flaae spread race.1  in/oin
Bed size, in.
1/4 x 1/2 x 5 il/2  x 1/2  x 5
                                Description
Granular or powder materials:
  Phosphorus scsquisulf ide ...
  Phosphorus, red
  Titanitra .............. .
  Camphor
  Magnesium
       Do
       Do
  Sodiun ne thy late
  Picric acid, 10-20 pet HgC.
       Do
  2,4-Dinitroaniline
       Do
  Axaoniua dichrosate
  Sodiua borohydride
  Phthalic anhydride
       Do
  Tetraphenyl tin
  Charcoal, willovwood
  Charcoal, blend
Strio sizs. in
Sheet cacerials:
  Photographic fila, safer;-,
   processed.
  Photographic film, safety,
   unprocessed.
  Butyl rubber. 1/16 in thick.
Bed size, in.
Rod-shaped materials:
  Hatches, "strike anywhere'
       Do	<
       Do	
    115
     97
     60
     40
     30

      1.4
     21
     a5
      1.9

      3.5
      3.8
      «k
      2.8
      4.3
      *.2
88
75
35

13
 l.l
29
a7.5
 3.5
 6.5
 1.4
 4
 3.2
 3.4
 2.4
 1.0
 2.7
   1/2 x 5
                                                  1 x 5
     26

      9

      1.3
28

11

 2.2
           I x 5
            27
            21
            11
50 to 150 mesh.
100 to 200 mesh,
100 to 200 mesh.
—10 to 30 mesh.
>80 mesh.
70 to 150 mesh.
70 to 80 nesh.
70 to 150 mesh.
—10 to 50 nesh.
       Do.
40 to 70 nesh.
50 to 150 mesh.
30 to 100 mesh.
50 to 150 mesh.
—10 to 30 mesh.
20 to 70 mesh.
50 to 150 mesh.
50 to 200 nesh.
40 to 50 mesh.
       Do.
Inverted,
 V-shaped strips,
       Do.

       Do.
           4 uniform layers
           2 uniform layers
           4 crisscrossed
            lavers.
1 Total bed length is 7 in, rates measured over final 5 in of burning.
aOld stock sample.
3Sew stock sample.
*IncanJesjcnt-type burning.

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                PROPOSED METHOD FOR EXTREMELY FLAM1A3LE SOLIDS

     l!o standard method is available for evaluating extremely flaomable
such .» pyrophoric powders, which can Ignite spontaneously on exposure •
It ancient te^erature.  A test developed by the Bureau of ^'^V
Association of Railroads)  for pyrophoric liquids is considered  by  a  Un
i"£ni working group to be adaptable to some solids bur not  to powder like
'.ubstvices.-8  This method require rather  Urge quantifies  of  hazardous -J
rials  and  involves the  use of  a  sawdust reacting medium, although the part .
,i-t   noi»cure content,  and grade  of  sawdust arc not  specified.  Also,  the
rnaxlcun relative  hunidity that is  specified, 75 percent, nay not be. high
er.ough for evaluating the pyrophoricity of  s*ae rxatcrials.
                                                                           .
     A ewthcd is proposed here for  determining the ease of ignition of pyropo
t-p« subdtar.cas using small sanples at ambienr csrr.parntures of 90°  or  130
c-.d az vazi-us hunidlcy conditions.  The higher tespewrure is the  maximum
• •:c.:ific
-------
As noced by che 130* F data for Che cwo hydrides, che cicses required for igniclon gen-
erally decreased when che relacive humidity was varied front 54 co 88 percent with  *"
lithium hydride and from 68 co 87 percent with sodium hydride.  Since che measured Cta-
per a cure rises were dependent upon thermocouple location, che values shown in cable 3
do noc represenc maximum values.  Where ignitions are indicated, these were verified by
visual observation of flame.  Normal ignicions were noc observed co occur with che two
Grigaard reagencs at 90" or 130* F, although che cenperaeure rises produced wich che
methyl magnesium chloride reagenc (2.85 molar) were ac lease 1,000" F ac che higher-
hunldicy conditions.  The phenyl magnesium chloride reagent (2.54 molar) produced only
slighc charring ac 130" F and measured cemperacure rises were noc over 270* F.  Essen-
tially che seme results were found wich chis reagenc when che sample quantity was
increased from 30 co 60 ml or co 120 ml; also, che temperature rises were noc any
greater when che sample was mixed wich a dry red oak sawdust rather Chan glass wool.
Nevertheless,  although che cemperacure rises vere less for this material than for che
ochers examined here, chey are evidence of noticeable self-reaction which could con-
ceivably lead  to ignicion under more ideal reaction conditions, such as chose possible
wich large lots of the reactanc materials.  An increase in the concentration of the
Grignard reagent may also increase the possibilicy of ignicion.

        TABLE 3. - Summary of data from self-ignition experiments with various
                                    pyroohorlc-type materials


Solid materials:
White phosphorus, small -
size cuts.
Sodium, small -size cuts....


Lithium hydride, powder....










Crignard reagents:
Methyl magnesium chloride..






Phenyl magnesium chloride..



Sample
quan-
Cley

f-t
-S
<•*
*S
/ m
~b
5j
65
5s
i£
5g
5g
5g
5s
~9
3g
58
5g

30 ml
30 ml
30 al
30 ml
30 ml
30 ml
30 ml
60 al
30 al
30 ml
30 ml
Relacive
humidity,
pet

79
90
85
89
74
88
88
78
76
65
54
86
87
84
68
86

88
79
65
55
92
62
53
86
88
65
56
Initial
temp,
• r

130
90
130
90
90
130
130
130
130
130
130
90
130
130
130
90

130
130
)30
130
90
90
90
130
130
130
130
Road
Ceoo
AT,
• F

1,110
820
660
170
170
1,280
>1,500
1,200
>1,500
1,110
>l,500
270
>l,500
1,120
890
190

1,050
980
600
900
1,010
530
560
270
250
235
250
:ion
m
Tiwi>,
nin

0.5
2
8
24
24
.1
3
11
7
27
46
24
13
10
21
227

26
27
25
16
42
21
48
46
22
22
21
Visual
observation

Ignition.
Do.
Do.
No ignition.
Do.
Ignition.
Do.
Do.
Do.
Do.
Do.
No ignition.
Ignicion.
Do.
Do.
Ko ignition.

Charred residue.
Do.
Do.
b,>.
Do.
Do.
Do.
Slighc charring.
Do.
Do.
Do.

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10

          CLASSIFICATION OF FLAKXASLE SOLIDS BY PROPOSED TEST METHODS"""'

     The classification of most fUraable solids should be possible  by the
test nethods described in this report.  Since the ease of ignition of a soil'
nay give a different order of hazard ranking than indicated by  its flame-
spread behavior, both combustion properties auat be considered  to obtain a
reliable classification.  As outlined below, three classes of  flar.atabl.e- soli
                f°n?' "«»P°«»tion regulations.  Where cha  classification
                      is t
 .5  a
 10  in
tore   or br
1C  nluin   i
   »s -  e U-
    at..e c«s,t
                  of
                                         *"  "tad hi£hl>'  «™ble either
                          "  ?=  '«altl«  uh" «P«c«l  to flaoe such ns a b
                                 'T  '?  ?r°?aSaCa  "«*e at  races greater than
                                  n lcss than L  seco«d b>' the proposed
                               d in  this  class..
?c&~. slow ox ids tier..   The reac
h:ura 01 tore.  This  Srruc ir.=
Ci"-»rs.  A-.S particularly/ surl
table olU.  TO evaluate thei-
battc tester iinllar  to tha -.v
i* oeceifc-r:-; howav«rf the dt*
auapler U^.lgr.a such  as the -
uUtc adlcbitic coniitions ra"
eva4U5:lt,s »ylld§.  Although -
serious Iga'.tton hazard, thev"
"*Vl M1» & f .. . .  _.    .      '    -
                                                         at ambient;  te»
                                     :-a ror such solids is usually  several ^
                                     »ucr. jolids, as granulated charconl,  an*"'
                                      vhich have been contaminated with vcg**
                                 ^.irua spontaneous heating hazard,  an adJ»* f
                                  -a'.shaped by Lhe National Bureau of Stand*^
                               '-*^ -: ir.is type of tester is relatively coJP'j,
                               - -sve.opad by Factory Mutual Laboratories1* L
                               ;?: .rouS-a1' and a" not necessarily  intended ^
                               --las capable of spontaneous heating  can Pr5* f»
                                             	     -           *      ,teri*1


 ,5   v
     From  Kino:ic.ReactionbDat3

                  November  1953  p    l3
                                °n"j S*jf:ls"i;:lorl Te=?eratures of Material*
                                3   p  fl3     ; *acic:i*l Bureau of Standards,
                                                    T..ter.   KFpA Quarterly,

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                                                                              11


      On the basis of  the present experimental data, the flanmable substances
 that were investigated were classified according to the proposed scheme.
 Table 4 shews the classification ratings for the various materials by this
 method.  This table also compares the ratings or classes that are given by the
 Inter-Governmental Maritime Consultative Organization (IMCO)1S and the
 National Fire Protection Association (NFPA)17 ls for the sane materials and
 for a few others.  The IMCO classification designates flasrmable solids as
 class 4 with the following subclasses:

      Class A.I:  Flanrnable solids that  are easily ignited by external heat
 sources.
      Class 4.2:  Spontaneously combustible solids or liquids.

      Class 4.3:  Substances that eait flassabie gases when wet and which may
 ignite, spontaneously in sone cases.

      The NFPA classes of flammability are defined as follows:

      Class 1:   Materials that  oust be preheated to ignite.

      Class 2:   Materials that  sust be exposed to relatively high ambient ten-
 peratures  to ignite  and solids that  readily  give off flammable vapors.

      Class 3:   Materials that  can ignite  under  alnost all  ambient temperatures.
 Solids  that ..can-creata-flash, fires—and burn  rapid ly.-

      Class 4:   Materials which vaporize at normal ambient .temp era cure s-.or are
 easily  dispersed, and  which can readily fora explosive nixtures in air.

 In  the  NFPA  clarification, varsr-reactive materials are included under  a sepa-
 rate  reactivity hazard category.

      Since the classification  systems employ  different numerical ratings-or—-
 classes for hazard identification, it is difficult to nake a  direct comparison
 of  the  listings given  in  tibia  -.  Nevertheless,  some significant differences
 vhich are  evident are  worth zctir.j.  Under the Bureau classification, white
 phosphorus and the alkali ssctis end hydrides that were tested are assigned Co
 class 3, which is identified as  the most hazardous class on the basis of pyro-
 phoricity  in dry or moist air.   Except for white phosphorus,  such solids are
 also  included in the cost hazardous class by  the DiCO classification because
 of  their high reactivity with moisture or water.  In comparison, the IIFPA
 flaasubility classification gives a very low flanoability ha.rard rating
 (class 1) for sona of  these same materials (for exanple,  sodium), even though
 they may ignite spontaneously in moist air at near aobient temperatures.  On
 Che other hand, these materials are  also listed as highly water-reactive rub-
 stances by the NFPA.    In the case of  Grigr.ari reagents,  thcoe should r-.uid ;o
 fall in the pyrophoric class or a lower class, depending  upon  their composition

* International Maritime Dangerous Goods  Code, Class 4,  Inter-Governmental
    yjritice Consultative Organization,  101-104 Picadilly, London WIV, 1966
    pp. 4000-4410.
17National Fire Protection Association.   Hazardous Chesicals Data.  KFPA
    No.  49, 1959,  234-pp.
19 Work cit'.d in footnote 7,  pp. 5-155 to 5-207; p. 6-113.

-------
12
and concentration.  Substances which display an equally high flanraability
water-reactivity hazard should be assigned co both hazard categories in  the
Department of Transportation classification regulations; a classification test
method for evaluating water-reactive substances is currently being developed
by the Bureau.

      TABLE 4. - Comparison of hazard classification ratings for various
                     flammable solids and pyroph'"'ric-tyDe materials
Material



Lithium 	
Sodium-potassium alloys 	



Grignarc reagents:
Methyl magnesium chloric a, 2.85 no lac
Pheayl magnesium chloride, 2.54 molar










Picric acid, >10 pet H,0 	






Charcoal , wood . dry 	 	
Charcoal, animal or vezetable 	
Hazard classification
rating
Bureau
of Mines
3
3
.
3
3
3
_
2
2
2
2
2
_
2
2
2
2
2
1
1
I
1
1
1
L
IMCO1
4.2
4.3
4.3
4.3
4.3
4.3
4.3
4.3
4.2
4.1
4.1
4.1
4.3
4.3
4.2
4.1
4.3
4.3
4.1
4.1
4.1
C3)
C3)
<4>
4.1
4.2
NFPA'
3
1W
1W
1W
3W
4W
1W
1
I
1W
1
4
2
1
1
1
1
      MSiter-GoverTimental Maritime Consultative Organization (London)
      3National Fire Protection Association; numbers refer to flanrna-
         bility rating; W indicates water-reactive materials.
      3Classified as poisonous (toxic) substance.
      Classified as oxidizing substance.

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                                                                            13
     Wich flammable solids like phosphorus sesquisulfide and red phosphorus,
the hazard racing (class 2) assigned by the Bureau classification is more
severe than that given by the NFPA code (class 1).  The lowest IMCO class,
which includes most flammable solids, is assigned to the above powders and  to
materials such as titanium, camphor, motion picture film, and "strike anywhere"
matches.  All of these are in the intermediate hazard class by the Bureau
scheme.  Other finely divided solids in this grouping include magnesium,
sodium methylate, and sodium borohydride.  Although these are not extremely
flammable when dry, they are potentially water-reacr.ive, as indicated by the
IMCO classification.

     The least hazardous flammable solids that were evaluated in this work  are
included in the last group of substances listed in table 4.  This group
includes picric acid (>10 pet HgO), ammonium dichromate, tetraphenyl tin, and
other materials having a low ignitability and flarttmability hazard by the pro-
posed test methods.  Under the IMCO classification, some of the materials
having a low burning hazard are assigned to other hazard categories instead.
For example, ammonium dichromate is classified as an oxidizing substance and
dinitroaniline is classified as a poisonous (toxic) substance.  Although most
charcoals will tend to display a low burning hazard by the proposed flame
spread test, they should be assigned to clips: 2 instead of class 1 under the
Bureau classification system because of the spontaneous heating hazard that
reportedly can be encountered with such materials.  In all cases, the hazard
classification should reflect*the maximum hazard that the flammable solid may
present under transportation conditions likely to be encountered.
                                                        INT.-BU.OF MINES.raM..**. :r»j«

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          Appendix C





DOT Regulations Title 16, CPSC

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               Chapter (-^Materials.Transportation Bureau
                                                                      §173*15
 vlded the outside containers are marked
 as prescribed herein.
   (c) Toy paper caps of any kind must
 not be packed with fireworks.
   (d) Each outside container must be
 plainly marked  "TOY CAPS—HANDLE
 CAREFULLY".
 (29 FR 13683, Dec. 29. 1064. Redeslgnated at
 33 PR 580S. Apr.  5. 1967. and amended by
 Amclt. 173-94. 41  FR  16066.  Apr. 15. 19781
 § 173.110  Chnrswd oil well jet perform-
      ing puns, T,H.il explosive conlsnt  in
      guns  not exceeding 20 pound* per
      motor vehicle.
   (a) Charged  oil  well  1st perforating
 guns  transported by znotor vehicles op-
 erated by  private carriers engaged In oil
 well operations In which the total weight
 of  the explosive contents  of shaped
 charges assembled to guns being trans-
 ported does  not exceed 20 pounds per
 such  vehicle must ba  packed  aa pre-
 scribed In 5 173.80 (b). (c). (d) and (e).
    (b)  Charged  oil well jet perforating
 guns may be offered for transportation
 and transported only by private carrier
 by highway.
 (29 PP. 18683, D«c. 29, 1964. Redeslgnated at
 32 PR 5606, Apr. 5.  1967. and amended  by
 Amdt. 173-94. 41  PR 16033.. Apr.  15, 1978J
 § 173.111  Cigarette loads, explosive atUo
      olnrim,  toy propellant derice*,  toy
      •make  devices, trick  matches, and
      trick noi*e makers, explosive.
    (a) Cigarette loads,  explosive auto
 alarms, toy propellant devices, toy smoke
 devices, trick matches, and  trick noise
 matters,  explosive  must  be packed  In
, specification containers as follows:
    (1) Spec.  ISA.  15B,  ISA.  or  10A
 (§ 178.168. J 178.169. § 178.185. or } 178.-
 190 of this subchapter). Wooden boxes.
 Gross weight not to exceed ISO.pounds.
    (2) Spec.  12B (5 178.205 of this sub-
 chapter) . Fiberboard boxes. Gross weight
 not to exceed 65 pounds.
    (3) Each  outside container must  be
 plainly marked  with the proper de.yr1p»
 tire nam* and "HANDLE CAREFtTLpT
 (29 FR 18683. Dec. 29. 1964.
                                       190 of this subchapter). Wooden boxes.
                                       Gross weight not to exceed 150 pounds.
                                         (2) Spec. 123  l $ 178.205 of  this sub-
                                       chapter) . Piberboard boxes. Gross weight
                                       not to exceed 65 pounds.
                                         <3> Each outside container must  be
                                       plainly marked with the name "Oil Well
                                       Cartridge"  and  "HANDLE CARE-
                                       FULLY".
                                       (29 FR 18683. Dec. 29. 1964. Redeslgnated nt
                                       32 PR 5608. Apr. 5.  1967, and amended  by
                                       Amdt. 173-94/41 PR 1S063.  Apr.  15.  1976J

                                       § 173.113  Detonating fuzci, class C ex-
                                            plotives.      •
                                         (a) D»tonailna fuzes. clan  C explo-
                                       sives, must be packed la specification
                                       containers as follows:
                                         (1) Spec. 12H  <5 178.209 of  this sub-
                                       chapter) . Fiberboard boxes without liners
                                       with  well  secured Inside  pasteboard
                                       cartons.
                                         (2) In addition  to specification con-
                                       tainers prescribed In this section, deto-
                                       nating  fuzes, class C explosive, may be
                                       packed In well secured strong, tight out-
                                       side wooden or metal boxes.  The grow
                                       weight  of  the outside woe Jen or metal
                                       box must not exceed 190 pounds.
                                          tb) Each  outside  package  must  br
                                       plainly marked "DETONATDfC? FUZES.
                                       CLASS   C  EXPLOSIVES— HANDLS
                                       CAREFULLY".
                                        (29 FR 18683. Dec. 29. 1984. Redeslgnated a*.
                                       32 FR 5606. Apr. 5,  1967. and  amended by
                                       Amdt.  173-9-1. 41  FR 16066. Apr. 15, 107SJ
                                        § 173.114   Actniiting  cartridges;' •fecj»l«>-
                                            aive, fire extinguisher or valvew .
                                          (a)  Actuating  cartridges,  explosive.
                                        flre extinguisher or valve must be pacted
                                        in strong wooden or fiberboard boxes.
                                          (b)  Each outside container must be-
                                        plainly marked  "ACTUATING  CARTRIDGES.
                                        EXPLC,-^VB. TIRE EXTIWCtnSHEB — . HANDLE
                                        CARErr'-Lv" or "ACTOATIMC CARTRIDGES. EX--
                                        PLOSIVE, VALVE — HANDLE CARZFI7I.5.Y".
                                       x  (c)  When shipped as components with
                                        flre  extinguisher or with valve and with
                                        not  more-than»2 cartridges for each ex-
                                        tingulsher ' or  valve,  they are exenr^
                                             farfs 170-189 of , this  subchap-.r
 32 PR 5906. Apr. 6. ifl«7. and amended ~,  .   -.,.  .  A                         -
 Amdt. 173-9*.  41 PR 16068. Apr.  15. 1973).   Subpart r>T-Flammali!e. Combustib'* .-
 * 173.112  Oil w«ll cartridge*.    »*   '    ' PyrRphbdc Liquid* CWlniWcm* and...
§ 173.112  Oil well cartridge*.
  (a)  Oil  well  cartridges must be  so
packed that the explosive composition
does not exceed 20 grains per cubic Inch.
of space In  the  outside  shipping  con-*
                                                                        P. at»>
  (1)  Spec.   ISA.  15B.  leA.^or  IDA   '  (a)  Flammable  liquid.  '!•  F.--r  th-
({ 178.183, 9 178.169,  } 178.185. or 5 178.-   purposes oHhis subchapter i fb.::-.-•.;..

                         T           235
                                            aration
                                            Sotfwe- 20 PR 18700. Dec. 2ft l<)5i. utslesi ~
                                          otherwise noted. Redeslgnated at 32 FH 5503.
                                          Apr. 5. 1967. i.-    . • .    . *••  ••
                                                                                    ,


                                                                                    "

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§173.115
                           TiHe 49—Transportation
liquid  means any liquid having  a flash
point below 100' F. (37.8* C.), with the
following exceptions:
   (i)  Any liquid meeting one of the defi-
nitions specified in P> 173.300;
      200s 7: (93.3* C)  Is a limitation
of the application of the regulations in
this subchapter and should not be con-
strued as indicating that liquids  with
higher flash points will pot burn. Mark- •
ings such  as  "NONFLAMMABLE"  or
"NONCOaiBUSTIBLS" shoul-i  not  be
used on a vehicle containing a-material \
that has a flash point of 200' F. (93.3'
C.) or higher.
   (c) Pyrophoric  liquids.  (1> For  the
purposes of this subchapter. a pyrophoric*'
liquid  is any liquid that ignites sponta- ^
neously in dry or  moist air at or below
130° F. (54.5* C.).
  NOTE  1: Tha Bureau of Explosives la
equipped to test samples of flammable liq-
uids to determine whether or not they are
pyrophorlc.
                                           (d)  Flash point.  (1)  "Flash point"
                                         means  the minimum  temperature at
                                         which a liquid sives off vapor  within a
                                         test vessel in sufficient concentration to
                                         form an IgnitabJe mixture with air near
                                         the  surface of the liquid and  shall b»
                                         determined as follows:
                                           (i) For a homogeneous, single-phase.
                                         liquid  having a  viscosity less  than 45
                                         S.U.S. at 100* P. (37.8* C.) that does not
                                         form a surface film while under test, one
                                         of  the following test procedures  jliall
                                         be used:
                                           (A)  Standard  Method  of  Test  far
                                         Flash  Point  hy  Ta*  Closed  Tester
                                         (ASTM D5p-70>;       -
                                           (B)  Standard  Method  of  Twt  for
                                         Plash Point of Aviation Turbine Fuels by
                                         Setaflash Closed Tester. (ASTM D3243-,
                                         73) or
                                           (C)  Standard  Methods ' of  Test  for
                                         Flash  Point of  Liquids  by  SetaQash
                                         Closed Tester, (ASTM D3278-73).
                                            For a liquid that Is a jnlxture of
                                         compounds that have different volatility
                                         and flash points, its flash point shall be '
                                         determined as specified in paragraph (d;
                                         (1) of this stolon, on the  material In
                                         the form in whwh it Is to be shipped. IT
                                         it  is determine  by this test that th»
                                         flash point is h.^ner than 20* P. (-6.8T
                                        X7.)  a  second  test shall be  made on a
                                         sampte of the liquid evaporated from
                                         an open, beaker-(or similar  container)
                                         under ambient pressure and temperature
                                         (20 to 25' C.) conditions, to 90 percent
                                         of its original -volume or- for a period of
                                         4.hours, Whichever comes Qrst.,The lower
                                        "flash point of  the two tests shall be th'e
                                         flash point o*f the material.
                                           (3) For flash point determinations by*
                                         Setaflash closed tester, the glass &yring«>»
                                         specified need no.t be used as the method
                                         of measurement' of the test  sample if. a
                                         minimum quantity of 2 mlUiliters is as-
                                         sured In the test-cup.
                                     236

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                 Chapter !—Materials Transportation Bureau
                             §173.116
   (e) "S.U.S." means Sayholt Universal
 Seconds as determined by the Standard
 Method of  Test for Saybolt Viscosity
 (ASTM D38-56) (reapproved 1963) and
 may be determined by use of the S.U.3.
 conversion  tables  specified  in  ASTM
 Method D2161-66  following determina-
 tion of viscosity in accordance with the
 procedures  specified  in the  Standard
 Method of Test for Viscosity ot Trans-
 parent  and Opaque  Liquids  (ASTM
 D445-65).
   (f) (Reserved)
   (g) If experience or other data Indl-
' cats that the hazard  of  a  material is
 greater or less Chan indicated by  the cri-
 teria specified  in  paragraphs (a), (b).
 and (c) of this section, the Department
 may revise Its classification or make the
 material subject to the requirements of
 Parts 170-18D of this subchapter.
 [ABldt. 173-VaA. 40 FR 22264. May 22. 1975.
 as amended by Amdt. 173-94. 41 FR 16068.
 Apr. 15. 1978]

 § 173.116  Outage.
   (a) Outage for packings of flammable
 liquids offered for transportation, except
 as otherwise provided in this part, must
 be as prescribed In par i^raphs (b) to (h)
 of this section.
   (b) Packaging must not be completely
 filled. For packaging of  a  capacity of
 110 gallons cr less, sufficient outage must
 be provided so that the packaging will
 not be liquid full at 130a F. (55° C).
   (c) [Reserved!
     Flammable liquids must not  be
 loaded into donses of tank cars.  If the
 dome of  the tank car does not  provide
 sufficient outage, then vacant space must
 be \stt in the shell to make up  the re-
 quired outage-.
   (e) Flammable  liquids. having vapor
 pressure of 16 pounds per square inch
 absolute  at 100* F. or  less  must be £••• •
 loaded in task cars that the outage sha.i
 be not less than 2  percent.    t
   -	i-i	-	* .00055
"SS.l-60* A. P.I.1		0006ft.-
  00.1-65' A.P.I.1	  .00565
  6S.I-70* A. P. I.1	  .00070
'. 70.1-75' A.P.I,1-	,-  ,00375 •
' 7S.I-80' A.Pfl.1	-  .00050
  80.1^85' 'A. P.I.»	£.—•	  .00085
  85.1-90' A.P.I.1	  .00090
  1 *A. P. I. (American. Petroleum Institute).
according to ttw following-formula:  •
                                      237

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                 Chapter  I—Materials Transportation  Bureau
                             §173.151a
 Ing is required for transportation by air).
 In addition, shipments are not subject
 to Subpart P  of Part 172 of this sub-
 chapter, to Part 174 of this  .'ubchapter
 except  § 174.24 and to Part  177 of this
 subchapter except 5 177.817.
 (29 PR  187UO. D*c. 29. 1934. Redealgaated at
 32 FR 5303, Apr. 5. 1967. -ami amended  t>y
 Amclt. 173-94. 41 FR 16069.  Apr. 15.  1078;
 Amdt. 173-94A,  41 FR 40631. Sept. 20. 1973)
 § 173.148   Monoctliylumirte.
    Tank   cars   prescribed   In
 S 173.119(f)(3).
   (4) Specification 10SA500X or 110A-
 500W (§§179.300.  179.301) tanks.  Au-
 thorized only for transportation by rail
 freight  and by highway. (See §§ 174.560
 and 177.834(m) -of this subchapter for
 special requirements.)
   (5) Specification MC  3C4 or MC 307
 (§§178.340. 178.342).  Tank motor ve-
 hicles. Tank  bottom  outlets  must be
 equipped with valves  conforming  with
 § 178.342-5§ 173-lSla
 graphs (a) and (b).         i"   »
   (2)  Spec. 12B (! 178.205  ofxthi3^lib-
 chapter). Fiberboard boxes with inside
glass  bottles not over 1 quart capacity
 each.  Inside containers  must be't sur-
rounded on all sides with dry absorbent
noncombustible material In quantity suf-
ficient to absorb entire cforitents. Author-
ized gross weight not over 65 pounds.
   (3)  Spec. 17C (§ 178.115  of this  sub-
chapter) . Metal drums (single-trip)  with
 openings  not exceeding 2.3 Inches  in
 diameter.
 (Order 66. 30 FR 5744. Apr. 23. 1053. Rtd^at*-
 nattcl at 32 FR S605. Apr. 5. 1067. MU! amend-
 ed by Amdt. 173-94.  41 FR 16059. Apr.  15
 1076|
§ 173.149a  i

  Nitromethane  must be  packaged  as-
specified  in  § 173.119(b)  except  that
shipment In cargo tanks, tank cars port-
able tanks, and any container having a
capacity greater than 110 gallons Is for-
bidden.        *
fAmri'. 173-94.  11  F!> 1505}.  Apr.  !5. !97fl|

Subpart E—Flammabl* Solids. Cxiduers;
  and  Organic Peroxides; Definition* and
  Preparation
  Sour.cc: 29 FR 18709. Dee. 29.  1964.
otherwise noted.  Redaslgn&ten  at *3°
5808. Apr. 8. 1867.
                                    PR
 § 173.150  Flammable solid ; definition.
   For the purpose  of this subchapter
 "Flammable solid" is any solid material^
 other than one classed as an explosive
 which,  under conditions  normally  inci-
 dent to tranipprtation is  liable to cause
 fires through f ristton. retained heat f rorn-
 manufacturing or processing. or which
 can be  ignited readily and when ignited
 burns so  vigorously  and  persistently as
 to create a serious transportation hazard.
 Included in this class are spontaneously
 combustible' and  water-reactive- mate-
 rials.             ;
 (Amdt.  173-94. 41  FR 16089. Apr. 13  1978
 ns amended by Arntft.  173-04A.*4t-FR 4osat"
 Sept. 20, 1976]                         *

 § 173.151  Oxidizer; definition.
  Anoxidlzer for the purpose of this sub- "
 chapter is a substance such as a chlorate
 permanganate. Inorganic peroxide. nlrro
 carbo nitrate, or a  nitrate, that ylelcL-$
 oxygen  readily td stimulate the combus-
 tion of organic matter.
     t. 173-04, 41 Fa'lflO89. Apr. 13. 1079J

            Organic
     UpiK  .   .   t

 «  (a)'" An organic compound containing
 the  bivalent  —0—0— structure  and
 which may be considered a derivative- or
 hydrogen peroxide where one.uir more ot
 the hydrogen atoms  have  been replaced
 by organic radicals must be clashed as art
 organic peroxide unless:
   d") The material meets the definition
of an .explosive 'A or explosive B. as pre-
scribed  in Subpart  C of  this  part,  in
                    peroxide; - defini.
                                      257

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                 Chapter I—Materials Transportation  Bureau
                              § 173.300s
 § 173.300  Definitions.
   For the purpose of Parts 170-139 of this
 subchapter, the following terminology is
 defined:
   (a)  Compressed eas. Thtr term "com-
 pressed gas" shall designate aay mate-
 rial or mixture having In the container
 an absolute pressure exceeding 40  P.S.L
 at 70' F. or, regardless of the pressure at
 70° F.. having an absolute pressure ex-
 ceeding 104 p-si. at 130* P.; or any liquid
 flammable material having a vapor pres-
 sure exceeding 40 p.s.1. absolute at 100*
 P. as determined by ASTM Test D-323.
   (t»  Flammable vomprsfsed  ysj. Any
 compressed gas as defined In, paragraph
   of this section shall be classed  as
 "fb.nimable gas" if any one of the follow-
 In? occurs:
   (1)  Either a mixture of 13 percent or
 less (by volume) with air forms a flam-
 mable mixture or the flammable range
 with air is wider than 12 percent regard-
 less of the lower  limit. These limits
 shall  be   determined  p.t atmospheric
 temperature and pressure.  The method
 of sampling and test procedure shall be
 acceptable to  the Bureau of Explosives.
   (2)  Using the Bureau  of Explosives'
 Flame Projection Apparatus (see Note,
 l). the flame projects  more  than 18
 laches beyond the- ignition source with
 valve opened fully, or; the flame flashes
 back  and sums  at the valve with any
 degree of valv« opening.
   (3) Using the Bureau  of Explosives'
 Open  Drum  Apparatus (see  Note  1).
 there is any significant propagation of
 flame away from the ignition source.
   (4) Using the Bureau of Explosives'
 Closed Drum  Apparatus  (see Note 1).
 there is any explosion of the vapor-air
 mixture in the drum.
       1:  A description or th» Bureau .oft
Explosives'  Flam*  Projection  Apparatus,
Open Drum Apparatus. Closed Drum Appa-
ratus, aad eifrthod of tasta may be procured
froa tbft Bureau otZzploalves.         ,.

  (c> Non-liquefied compressed pas. A
"non-liquefied compressed; gras" is a gas.
other than gas in solution, which under'
the charged pressure is entirely gasebus
at a temperature of 70* F.            x.
  (d) Liquefied  compressed   yea.
A "liquefied compreased  gas" Is  a gas
which, under  the  charged pressure, Is
partially liquid  at  a  temperature or
70*  F.       '                , 4
  (e)  Compressed  gas In solution.  A
"compressed gas In solutlon'Vls a non-
  Uquefled compressed gas which Is dis-
  solved In a solvent.
    (f)  FI am mable range.  The term.
  "flammable  range" shall designate ths
  difference between tha mlnlntum.  and,
  maximum volume  percentages  of the
  material In air that farms  a flammable-
  compressed gas.
  •  (g)  Filling density.  The term "filling
  density" shall  designate  the  percent
  ratio of the weight of gas In a container
  to the weight of water that the container
  will hold at 60* P.  (One pound of water
  equals  27.737 cubic Inches at  60* P.)
  Tor example, for a llqul^ed petrolttus
  gas of 0.504/0.510 specific gravity, a 100-
  pound  cylinder holds 238.1 pounds of
  water and the filling density Is 42 per-
  cent; therefore the amount of gas per-
  mitted is 0.42X238.1 or 100 pounds.
   (h)  Service pressure. The term "serv-
  ice pressure" shall designate the author-
  ized pressure marking on the container.
 . For example, for cylinders marked "DOT
  3A1800". the service pressure is 1300 pslg
  (pounds per square Inch gauge).
  (29 FR 18743. Dec. 29. 1964. Redestgoated at
  33 FR  5608. Apr. 5,  1967, and amended by
  Amdt.  173-16,  34 FR 18243, Nov. 14. 1069;
  Amdt.  173-54-, 38 FR If) 163, Sept. 15. 1971:
  Amdt.  173-94.  41 FA 16079, Apr. 15, 1976;
  Amdt. 173-94B. 41 FR 57069, Dec. 30, J978J

  § 173.300a  Approval of independent In-
      spection agency.
   (a)  Any person  who  (1)  does  not
  manufacture  cylinders  for  use--in- -the
  transportation of  hazardous materials
  and (2) is not directly or indirectly, con-
  trolled  by . any  person or  firm  which
  manufactures cylinders for use  in  the
  transportation of hazardous materials,
  may apply to the Department of Trans-
 portation for  approval as an independ-
 ent inspection agency for the purpose of.
 performing cylinder Inspections and veri-
 fications required by Part 178 of this sub-
 chapter,   .••.'<•-
   (b> Eaelv.appHcatton'filed under this
 section  for approval as an independent
 inspection agency must:   '
  '(IkBe submitted in writing to: Office
•• of Hazardoui'Materlal^ Operations, U.S.
..Department'-bf  Transportation*. Wash-
 ington. D.C. 20590;       *  •      .   "
   (2) State the. name, address, principal
• business activity, and telephone number,
'of the  applicant and the name and ad-
 dress of'each .facility- where tests  and .
 inspections are to be performed:
   (3) State'ths name, address and prin-
 cipal business activity of each person
                                     335

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 § 1500.3
TJh'e 16——Commercial Practices
 action, but shall not refer to action on
 inarJmate surfaces.
    (8) "Irritant"  means any substance
 not corrosive within the meaning or sec-,
 tion 2(1)  of  the act (restated in para-
 graph. ue tiirouKti  aa -iUssr^'-c  or paotody-
 naialc process A hypirsecsltlTlty  which
 becomes evident on reduplication of the
 su:na substance and which is designated
 as such by the Commission. Before deslgr-
 nating any substance us a strong sensi-
 tizer.  the  Commission, upon considera-
 tion of the frequency of occurrence and
 severity of ths  reaction, shall find that
 the substance has a significant potential
 for causing hypersensltivity.
   (10) "Extremely fiammabla" shall ap-
 ply to any substance which has a flash-
 point  at or below 20' P. as determined
 by  the  Tagllabue Open  Cup  Tester;
 "flammable" shall apply 10 any substance
 which has a  flashpoint of above 20 • F;,
 to and including SO*  P.,  as  deter-
 as determined  by  ths Taguabue Open
 Cup Taster; aad "combustible" shall ap-
 ply to any substance which has a flash-
 point  above  80*  P.  to and Including-
 150' P., as determined by the Tagllabua
 Open Cup Taster; except that tha flam-
 inability or combustibility of solids and
 of the contents of self-pressurized con-
 tainers shall be determined by methods
 found by the Commission to be generally
 applicable to  such materials or contain-
 ers, respectively, and established by reg-
 ulations issued by the Commission, which
 regulations shall also define tha terms
 "flammable," "combustible,"  and  "ex-
 trem apeara (I)  or,
                 tho outside container cr wra.oper. if an'y
                 there be, unless it is easily legible throu?b
                 the outside container  or  wrapper and
                  (II)  on all accompanying  literature-
                 where there are directions for use. writ.
                .. ten or otherwise.
                   (13) "Immediate container" does not-
                 Include package liners.
                   (14) "Misbranded   ha:r.rdouj   sub-
                 stance"   rneana   a   hazardous  j-ib—
                 stance (including » toy. or other articla-
                 Intended for use by children, which is *
                 hazardous substances, or which benrs or
                 contains a hazardous substance in such •
                 manner as to be susceptible of accesj 17
                 a child to whom such toy or other article
                 is entrusted) intended, or packaged in a
                 form suitable, for use  In the household.:
                 or by children, if the packaging-or label-.
                 ing of such substance Is in violation  of au
                 applicable regulation isjiued puisuant to.
                 section 3 or 4 of the Poison Prevention
                 Packaging  Act of  1970 or  If such sub—
                 stance, except as otherwise provided  by-,
                 or pursuant to section 3 of the act (Fed-  '
                 eral Hazardous Substances  Act), fails to
                 bear a label:
                  (i) Which states conspicuously:
                  (A) The name .".rid place.of business
                 of the manufacturer, packer, distributor;.
                 or seller;
                  (B) Tha  common or usual nanjs  or
                 the chemical name (if there be no  com-
                 mon or usual name) of the nazardoai
                 substance or of each component which
                 contributes  substantially to Us hazard,
                 unless the Commission by regulation per-
                 mits or requires the use of  a recognized
                 generic natr.e;
                  (C) The signal  word "DANGER" on ^
                 substances which  aro  extremely flam-
                 mable, corrosive, or highly toxls:
                  (D) The signal word "WAPJTOTG" oc .
                 "CAUTION" on till other hazardous sub---,
                stances;
                  (E) An affirmative statement of th«
                principal hazard  or hazards, such  as
                "Flammable."  "Combustible."  "Vapor
                Harmful."  "Causes Burns." "Absorbed
                Through  Skin," or similar  wording de-
                scriptive of the hazard;
                  (F) Precautionary measures  de»crib-
                in^ the action to be followed or avoided.
                except when modified by regulation  of
                the Commission pursuant to section 3  of
                the act;
                  (G) Instruction, when necessary  or
                appropriate, for first-aid treatises^;
                  (H) The word "Poison" for any  liaz-
                ardous substance  which is dsdned &>
                                     5GG

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§1500X3
Title  7<5—Commercial  Practices
loupe, hand silt-lamp, or other expert
means. Alter the  recording, of observa-
tions at 24 hours, any or all eyes may be
farther examined after applying fluores-
celn. For this optional test, one drop o*
fiuoresceia sodium ophthalmic  solution
U.S.P. or equivalent  is dropped directly
on  the  cornea. After  Gushing  out the
excess liouTfesceia with sotfluai  chloride
solution  U.S.P. or  equivalent,.  Injured
areas of the ccraea appear yellow; this is
beat visualized in z. darkened room under
ultraviolet niuolnaticru Any or all eyes
»£.:••  by wsiftiwsii vri'-U  s-iCuBi chloride so-
lution U.3-?. or equivalent alter tae 24-
hour reading.
  (b) (1) An animal  shall toe considered
ta  exhibiting a positive reacvlou. if the
test substance  produces  at  ?.xy of the
readings ulceration of tbe coraua (other
than a fine sttjppiing).  or opacity oi the
cornec. (other  than  s.  slight dulling of
the norwal luster),  or Inflammation of
the iris  (other than  a slight deepening
cJ  the folds (cr mcae) or a slight clr-
cuExooracal Injection of the  blood ves-
sels?, or if such substance produces In
the conjnnctivee (excluding the cornea
and iris) an obvious  swelling with  par-
tial eversion of la.- lids or  a  duTuse
crimson-red -with  individual vessels riot
easily discernible.
  <2) The test shall.be considered posi-
tive if four or aore of the anttsuls in the
test group exhibit a  positive reaction. If
only  one anircal exiv.blts  P,  positive re-
action,  the  test sl»?. 11 be  regarded as
negative. If two or  three ftrvisuls ex-
hibit a positive reaction, the test Is re-
peated using1  a diStirer.t giuup of six
erir...Ij. The second test shall  be  con-
sider^ positive if three or more of tbe
a:iln;iis exhibit a positive  reaction. If
onl."  one or two animals In the second
test exhibit & positive reaction,  the test
stall be repeated vritli a dlffirert group
of  sir. animals. Snciild a third test be
ne&dfed,  the substance will be regarded
as  c.a irritact  If any anunal axliibits a
posJtlTe response.
  (c) To assist testing laboratories and
other Interested persons In
the result? obtained when u
Is tested in accordance vriih tlte method
•iescrlr>ed  In paragrarti fc)  ol this sec-
tion, an "riustratec!  O-oicSe for Grading
Eye Irritation by Hrjiavdous SubstaEces"
vrtll b?  soW  by the  ;3;iperintOTd;jnt of
UocuTntn^jj, TJ.S.  Gov«iTimanfc
Office, V7ashiagtoa, D.C. 50405. 'llio
vi-iU contftiu  color pifties  dspl<:tins re-
sponses  o' vaiylng int'.insriti  to specific
                   test solutions. The grade of response ana
                   tbe substance used to  produce the  re-
                   sponse vrtll be indicated.
                   [33 ra 27013,  Sept. 27, 1S7S; 38 F3 30103.
                   NOV. 1. 1973)
                   § 1503.43   Method of test fur fl
                       of  volatile floinmnWo malertala by
                       Tagiiubue open-cup a;>v*ratua.
                   Boors

                    1. (e.)  This method  describes a test pro-
                   cedura for tt» dttennlaatJon of open-cup
                   Cashpoints of  voi&tUe 2&suaa^)!e
                   having Sjtiii paint* twlow 175° y.
                    (b) '7*i U radtiiuil. wh»n appilBd
                   and reiUi solutions \?Mc2i toad to
                   or which ar» very viscous, gives Jess To-pro-
                   ducible results than wbea applleti to solvents.
                           OT liiTTHOD
                    2. The gftTnplft 13 placwl In t^se cup of G
                   Tag O;JCB Tesier, evrxl !)e-»t^tl at a. slov? bvs
                   constant rtto. A EiiiiU test Hiime is passed
                   at a uniform rate across tlie cup At Fpcct£e4
                   tatcrrals.  Tbe  Suapelnfe t3 taken us  the-
                   lowest tesip«-r&turer at wtlcb nppllcatloa o:
                   liie t«st 2»3ie c&uses tae v::pcr .'it tt^i ev^r-
                   tace of the Liquid to flash, that Is, Ignite tut1
                   not coatinue to burn.
                    3. Tba Teg open-c-up tester is Ulustrated ts
                   Pig. 1. It  consist* or ttft folla^rtag psr'-s.
                   which must cj^onn to  th« tlrQcnrlo^i
                   shown, aad bnv» ti* additional characteris-
                   tics as noted:
                    (ft) Ccpper tflt/t. prcreraWy equipped W.'TI-
                   a constan'j level overflow  so  placed u  to
                   matTitgjiT i:-e b^tlx liquid lertl ?4 Incii belov
                   th* r'.ru of the 3' ws cup.
                    (b)  rJurrmo.-.-'.'ffCT' holder. Support find;
                   with, ringstand «.ad clorap. '
                    (e)  rj;erm'.v;(jfer. For flashpoints alx>7«
                   40- P., us*  t;:s» ASTM  Teg aoseti  Tester
                   Thens.om.eter. range of -j-20 to +S3Q* P.. in .
                   1*  P. divisions, and coeforralns to tberrr-cm-
                   et«r BF. ot ASTM Standnrd 32 1.  For £ir.b-
                   potata rrom 20» F. to 40" r.T use ASTil 7*5
                   Closed Testsr, I*ovr Rang*, Tt«nnosjet*r 577.
                   ftor flashpoints below 20* P, use AST1I Tbsr-
                   moaseter 33P. The original Tag  Open-Cup
                   (Pep*r Sctlo) Taenaometw trtll o» a permis-
                   sible  altemot*  until January  1. 1963. It !*
                   calibrates to —SO" P.
                    (d)  Gfciw Jest cup. Glsss test  cup (?i
                   2) . of molded deer glass. ftuaeAlal. h
                   slitint, and f reei frcru surface defects.
                    (e)  Leveling  device.  Leveling  device  or
                   gultfc, for  proper adjustment ol tn* liquid
                   lerel In the cup (F12. 3). This shsOl ba rravdo
                   of  Ko. 18-E8B* polished  aluminum, Trfta n
                   projwtloa for adjusting; tl>6 liquid level wbea
                   tac soaip!o is added to eiactly *i-Sac'a !>u-
                   low tlie level or toe *dg« or rtm ol the cup.
                    (f ) -'MIoto," or sra&U c«w burner of BalUt-
                   blo dUneustons  for ae^tlag  the br.th.  A
                   rcrew clasip =w>y b» used to help reculat* tit»
                   pas. A gptr-ij »i«ctrlc heater may b» used.
                                        580

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       Chepler  U~— Consumer Product Safety  Commission
                                 § 1500.43
          fl
PISCES 1—Tag oper»-e"jp f,aat», tester.
c
1

|ta
cT
f
                                                   3 — IcrcJinp dcrir* /or ctfjiuH
                                                         level in ir.:t cup.
     Ptcrss 3—CfJoss >a  Cup  (AS'flJ  di-sl^ai,.:?:::  r,  22-.  '^
satisfactory.
   (h)  Alternative methods foe malnUUilsg
tha Ignition taper la a fixed horizontal pltaa
above the liquid mny b» used, ts follows:
   (1) Guide wire. '-'u-inch  In diameter and
3% Inches In length, with a rlsbt-cngio b*nl
%-lncb from each  end.  This  vnre la plscrd
•snugiy In ho>3 drl!l»-(i  In the r!n.  of ti;c
bbth. so  ihat the guide wire li *i-la*ii i:om
the  center  of tho  cup azd restluj oa tho
rim o; the cup.
   (2) Swlvel-typ1* taper holder, *uch aa t»
US4d In  AET1I J.li.'1'iiOD D 02. Tb« hclrjj-.i
and position ol the tep«r HTtr fixec'. t>v »3i«t*r.
   (d) Pill the (ilttss  cup with the sample
liquid to a depth  just  Vi-^ch below th»
edge, as  determined by th* leveUng U«7lc«.
   (e) Place  the guld* wtr*  or swivel 'iertc*
la position,  nnd Mt the draft Ehlrid broucd
the tester so that th« nldM form right aag:«g
with earn oth«r c.ad the t»»t-r la w*u to-
warrl the bade of ib» shield.
                                     631
                                        100

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§ 15C0.43
Titla 16—-Commercial  Practices
   (l) If s.  guide wire Ls usad, tU»  taper.
 when pasiied. should re-rt Ugfcily oa the v/lr»,
 with taa end ot tie tat bunwr Just clear oT
 th» edge  of t'a* eulde wire. IT the swlvel-
 typa bol^.'f Is used, tfaa horizon i-.ai and verti-
 cal ;vj5t:ioas or tha Jst are so adjusted tb.it
 tha j»t p-=^*ea oa the cirourp^-r->ac9 of a cir-
 cle, h;iylag a  radius  of  as  least 6 Inches,
 across tha center of the cup at right angles
 to  tha  diameter passing  through. the ther-
 mometer. and la a ploae %-luch above the
 'upper erf^e  of The CTJO. The taper should b»
 iepc 'a :>i<* "or?" posktioa, .'.S oa» acd or ta*
 oifi^r o' tUfr »\viag, assups whsa t-a  £asi<»
 is applied.
  (g) Light the Ignition flame and adjust
 1C to form a flame o£ spherical 'orm matoa-
 mg  la size tha  ijj-lnch  sphere  on  th»
 apparatus.
  (h)  Adjust heater source  under bath so
 that thB temperature of the sample lacrea&es
 at  a rate of 2  ±0.5'  P.  per minute. With
 viscous materials **'« rate of heating can-
 not always b» obtained,
 INITIAL Tsar
  5. Determine an approxlzaata fi&shpolnt 07
 passing the taper flarae across the sample at
 intervals of 2* P. Each  pass must be la
 ono direction only. The  tlsie  required to
 pasa th». Igdtton 3ms across the surface of
 the  SMnpIa should be 1 second. Remove
 bubbles from the surface of the staple liquid
befort startle; a determination. Meticulous
 attention to all details relating to the taper.
 sl«a of taper £s.oi4, aud rate of poising tha
 taper Is necessary for good  results. V.Tir'n
 determining the flashpoint of viscous liquids
 aud those liquids tiiit  tend to form a film of
 polymer, etc.. on the  surface,  tha surface
 film should be disturbed  mechanically each
 tiTns before the taper flame Is passed.
 Keconaca TESTS
  0. Repsrxt the procedure b^ cooling a fresh
 portion o* the saotp!*, the gli33 cup, the bath
 •olut'.on. and the thermometer at least 20' '?.
 helo-.v  tha sppro.Tlaaata fiashpotat.  Resume
 heating, and  pass the taper flame across
 the sample at tTO interrals of S* F. and thea
 •at  Intervals of 2* F.  until   the flashpoint
 occurs.
  7. Tha average or not less than three re-
corded -asts. other than the initial test, shall
be  used In determlnlnz the flashpoint and
flamoiablUty of the substance.
  3. (a) Maks determinations In triplicate
on  the ."..uhpolnt af standard parsjcylenc and
of standard 'jopropyl alcohol which meet th*
following r.p*rtflcatlons:
  (I) Specifications for -p-sylsng, flashpoint
"tiesfe yradi. y-'.Cy'>:-ze shaU conform to the
following re
                         i,' rar.se: y c. maximum from start to
                     dry point when tested in tcccrd-iac'ii vith
                     the method of test for dUUllatioa of ia-
                     duscrial  aromatic  hydrocarbons  (ASTM
                     designation: D 050}, or the mecbod o; test
                     for distillation range of lacqusr sol?«nt»
                     and diluents (AST.M ciesignr.Uon: D I073J.
                     The  range shall include  the tolling point
                     of pure jj-xylene,  which.  Is _ 138.35*  C.
                     (231.03* P.).
                   Purity: 95 percent minimum, calculated  ia
                     accordance -vtth th* nwtaott of t>jr.  r'ri.-

                     poir.cs of hlih-purlty compocatis'iAi'Ej
                     tleslgsatloa: D 101S). frost the exparins»n-'
                     tally determined freezing point, measured
                     by the raetaod of test for meitsureraeau of
                     freezing polcta.of high-purity compounds
                     for evaluation of purity (ASTM desitna-
                     tlon:  D 1015).

                     (11) Specificctlony  for  iiopropcnol, flash-
                   point check grade. Isoprop&aol shall con-
                   form to the following requirements:
                   Speclflc era-rlty:  0.8175 to 0.3185  at 20' C./
                     20* C. as determined by  means  of a cali-
                     brated pycaometer.
                   DlstUlatlo.i  range:  ShaU  entirely  distill
                     within a 1.0* C. range which shall include
                     the temperature 80.4* C. as determined by
                     ASTM method D 1073.
                   Average these values  for  eaca  compound.
                   If  the  dlfferanca between  tha values foe
                   thesa  two  compounds is lass than 15*  ».
                   (8.5' C.) or more than 27* P. (]6* C.). repeat
                   the determinations or obtain fra*h stsadards,
                     (b)  Calculate  a   correction   factor  113
                   follows:


                     y=71-F
                     Correct!on=
Specific  gravity:  1S.5C* Cyi3.56«  C^ 0.860
  minimum, 0,869 maximum.
                   Where :
                     A = Observed fiasb, of p-sylene. and
                     B = Observed Cash of isopropyl alcoUoL

                   Apply this correction of all determinations.
                   Half  units in  correction shall b» discarded.
                   PSECISJON

                     J>.  (a)  Far  hydrocarboa. solvents having
                   flashpoints between 60* F. and  110* P., re-
                   peatabUlt/ is ±2* p. and tha reproduclMUtT
                   Is 2:3* F.
                     (b) If results  from ftro tests dlifer br
                   more  than 10* P, they shaU be considered
                   uncertain, and should be chwkad. The cali-
                   bration  procedure provided In  ihi* mec^od
                   drill cancel out the eisct of, barometric pres-
                   sure  If calibration and test* ore run at tha
                   some  pressure. Data  supporting the preci-
                   sion  ar» slven iu Appendix HI  of the;  1058
                   Ropcirt of Committee D-l on Paint. Varalsa.
                   Lacquers aid Related Prociucts. ProoeetlLags.
                   Am, SOC. Testing Mats.. Vol. SB (193»).
                                          582
                                       10

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          ChupJar  11—Consumer  Product Safety  Commission
                              fj 1500.-17
£ 1500.44  Method for tlel*rmioln£ ex.
             flammable  and ilanunable
  (a) Preparation   of   scruples — (1)
Granules, powders, and pastes. Pack the
sample  Into  a flat, rectangular , mstal
boat vrith laser dimensions ;h. self-sustained flams. Do not
exceed  60 seconds.  Extinguish   flame
with  a COi  or similar  nondestructive
type extinguisher. Measure .the dimen-
sions of the burnt area and calculate the
rate o! burning along the major  a:cis of
the  sample.
§ 1500.45  Method  for determining ex-
     tremely  flammable anil  tlammuhla
     contwit* of sett"'pr
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BD-2
                             DRAFT


                     BACKGROUND DOCUMENT
           RESOURCE CONSERVATION AND  RECOVERY ACT
           SUBTITLE C - HAZARDOUS WASTE MANAGEMENT
        SECTION  3001 - IDENTIFICATION AND LISTING OF
                       HAZARDOUS WASTE
      SECTION 250.13 - HAZARDOUS WASTE CHARACTERISTICS
                        CORROSIVENESS
                                          DECEMBER 15, 1978
            U.S. ENVIRONMENTAL PROTECTION AGENCY
                   OFFICE OF SOLID WASTE

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     This document provides background  information and
support for regulations which have been designed  to  identify
and list hazardous waste pursuant to Section  3001 of the
Resource Conservation and Recovery Act  of 1976.   It  is being
made available as a draft to support the proposed regulations.
As new information is obtained, changes may be made  in the
background information and used as support for the regulations
when promulgated.
     This document was first drafted many months  ago and has
been revised to reflect information received and  Agency
decisions made since then.  EPA made some changes in the
proposed regulations shortly before their publication in the
Federal Register.  We have tried to ensure that all  of those
decisions are reflected in this document.  If there  are any
inconsistencies between the proposal (the preamble and the
regulation)  and this background document, however, the
proposal is controlling.
     Comments in writing may be made to:
          Alan S. Corson
          Hazardous Waste Management Division (WH-565)
          Office of Solid Waste
          U.  S. Environmental Protection Agency
          Washington,  D.C.  20460

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                     Corrosive Waste

 INTRODUCTION:   Subtitle C of the Solid Waste Disposal Act
 as amended by  the Resource Conservation and Recovery Act  of
 1976 (referred to herein as Pub.  L.  94-580 or "the Act1*)
 creates  a regulatory framework to control hazardous waste.
 Congress has found that such waste presents "special dajiqetf
 to health and  requires  a greater  degree of regulation than
 does non-hazardous solid waste"  (Section 1002(b)(5)  of ^^e
 Act).
      This rule is one of a series of  seven being developed
 and proposed under Subtitle C to  implement the hazardous
 waste management  program.   It is  important to note  that thi
 definition of  solid waste (Section 1004(27)  of the Act)
 encompasses garbage,  refuse,  sludges, and  other discarded
 materials  including liquids,  semi-solids,  and contained
 gases (with a  few exceptions)  from both municipal and
 industrial sources.   Hazardous wastes, which  are a suh«.«,
                                                    ^** set
 of all solid wastes  and which will be defined by
 under Section  3001,  are those which have particularly
 cant  impacts on public health and the environment.
     Subtitle C creates a management control system wh±
 for those wastes defined as hazardous, requires "cra
-------
management control system constructed under Sections 3002-
3006 and 3010.  Those that are excluded will be subject to
the requirements for non-hazardous solid waste being carried
out by States under Subtitle D under which open dumping is
prohibited and environmentally acceptable practices are
required.
     Section 1004(5) defines a hazardous waste as that which
may -
     •(A) cause, or significantly contribute to an increase
     in mortality or an increase in serious irreversible, or
     incapacitating reversible, illness; or
      (B) pose a substantial present or potential hazard to
     human health or the  environment when  improperly  treated,
     stored, transported, or disposed of,  or otherwise
     managed."
     Section  3001(b) requires  EPA to promulgate  regulations
 identifying those characteristics of a waste which cause  a
 waste  to be a hazardous waste.
     Three criteria were  used  in developing the  candidate
 set of characteristics:   that  a characteristic was specifi-
 cally  stated  in Section  3001 by the definition of  hazardous
 waste  in Section  1004(5)  of the Act; and/or that damage
 cases  collected by  EPA over the past  several years demonstrated
 incidents of  harm to human health or  the environment attrib-
 utable to a characteristic or  property of waste;  and/or that
 other government  agencies or private  organizations which

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regulate or recommend management methods for hazardous
substances have identified a characteristic to be of concal
     This candidate set of characteristics was then re£in«d
on the basis of the following:  that the characteristic coc
provide a general description of the property or attribute
rather than appearing merely as a list of sources; that tb
likelihood of a hazard developing if the waste were
managed is sufficiently great; and that a reliable
cation or test method for the presence of the charactejriatJ
in waste is available.  Use of this last criterion has  led
EPA to describe each characteristic by developing or a^Opt
ing specific testing protocols.
     This Background Document describes the rationale ben!
the test procedures developed to describe the cor
characteristic stated in the proposed regulations
on December 18, 1978 as 40 CFR 250.10 - 250.15.
     For regulatory purposes corrosives have been
in the following ways:
     (1)   substances that cause visible destruction
     irreversible alteration in human skin tissue at
     site of contact.
     (2)   substances that cause metal to corrode  at a s «<
     rate.                                                ;
     (3)   substances that are highly acidic or  highly-
     alkaline.

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      The State of New York and several Federal agencies  (FDA,
 CPSC,  OSHA)  use tissue damage alone as a criterion for
 corrosiveness and make no reference to effect on inanimate
 surfaces.   DOT employs a definition that includes damage
 to  tissue and metal surfaces,  and proposed Minnesota regula-
 tions  for hazardous waste disposal encompass tissue damage,
 a severe corrosion rate on steel and pH levels below 3 and
 above  12.   Hazardous waste regulations suggested for the
 State  of Washington specify corrosives as substances which
 yield  a  pH less than 3 or greater than 11 when mixed with an
 equal  weight of water,  and Illinois  EPA land disposal criteria
 state  that wastes  with a pH less than 3 or greater  frhf-m  10
 must be  analyzed for percentage  of acidity or alkalinity.
 Proposed California regulations  for  the identification of
 hazardous  wastes characterize  a  material as corrosive if it
 has a  pH less  than or equal to 2 or.  greater than  or equal to
 12 or  causes destruction of skin tissue.   Comments  received
 on the ANPR of  May 2,  1977  for hazardous waste guidelines
 and regulations  generally advocate approaches  similar to those
mentioned  above.   Approximately  35% of  the responses  favored
 standards  which address  corrosive wastes in need  of proper
containerization.  Another  35% suggested adoption of  DOT
standards  on tissue damage and metal corrosion, and 21%
preferred  a criterion based on pH.  9%  of  the  responses
proposed standards based on other combinations  of the tissue
damage, metal corrosion rate and pH criteria.

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      For  the  purpose  of  establishing guidelines and regula
 tions for the management of hazardous waste, the definition
 of  a  corrosive  substance should reflect circumstances
 surrounding transportation, storage and treatment of the
 wastes.   The  primary  reason for applying a tissue damage
 criterion to  such situations is to protect waste handlers.
 A standard technique  referenced by Federal agencies and
 States using  this criterion employs the application of the
 suspected corrosive to the bare, intact skin of albino
 rabbits followed by an assessment of tissue damage after  a
 4 hour period.  Because  the conduction of the test requires
 special facilities and skilled personnel, it would be diffi
 cult  and  expensive to perform the required procedures fOr
 each  batch of waste.
      For  purposes of RCRA,  relating tissue damage to an
 easily measurable characteristic such as pH may be a more
 practical approach.  In  injuries attributable to acids and
 alkalis,  the hydrogen ion or hydroxyl ion concentration is •
 factor related to trauma.  Generally,  acids coagulate sfcin
 proteins and form acid albuminates,  and strong alkalis
 chemical action by dissolving skin proteins,  combining
 cutaneous fats and severely damaging keratin.   Alkali burns
 tend to be progressive due  to the formation of soluble
 alkaline proteinates and are therefore more dangerous than
acid burns which are limited by the  insolubility of the aQ
albuminates.   Oils and solvents are  capable of damaging

-------
 tissue  by  removal  of surface lipids,  but the effects are
 usually not  as  severe as  those caused by acids and alkalis.
 It has  been  suggested that pH extremes below 2.5 and above
 11.5  are not tolerated by the body, and contact will often
 result  in  tissue damage.   The studies establishing these
 levels  were  conducted on  corneal  tissue which is more sensi-
 tive  to injury  than  skin.   By designating an upper pH limit
 of 12,  sufficient  protection should be provided to those
 exposed to caustic wastes.   However/  a lower limit at pE 3
 has been set to provide additional protection to the environ-
 ment.   Heavy metal salts may become solubilized in acidic
 media,  thereby  releasing  toxic heavy  metals  capable of
 migrating to groundwater and surface  waters.
      pH determinations can  be  made simply and inexpensively
 so the  choice of a pH characteristic  would not be  economically
 burdensome.   pH can be measured by colorimetric or electro-
 metric means.   Colorimetric  techniques  are inexpensive but
 have  limitations that make  them inappropriate for  use in
 waste disposal  situations.   Colorimetric  indicators  are  unreli-
 able  at  pH levels  below 3 and  above 10  and may experience
 interference  due to salinity,  turbidity,  color,  protein  and
 colloidal matter present in  the test  situation.  Also, the
 pH range within which a single indicator  functions  is  rela-
 tively narrow.
     Electrometric methods are better suited  to  the  pH measure-*
ment of waste streams.  The hydrogen  electrode is  the  tradition
 standard for determination of pH values,  but  it  has  several

-------
 disadvantages.   It is  awkward  to  use,  attains  equilibrium
 slowly and  cannot be employed  in  the presence  of materials
 which inhibit the reversibility of  the electrode process.
 more  practical method  utilizes a  glass electrode and  a  refd
 ence  electrode of calomel or silver -  silver chloride or a
 combination electrode  (glass and  reference) connected -bo as
 electronic  pH meter.   The glass electrode is relatively fre<
 from  most types  of interference,  but does display impaired
 responses at  low and high pH readings.  In highly alkaline
 solutions the actual pH is somewhat greater than the  measttf
 pH, and in  very  acidic solutions  the actual pH is lower tin
 the measured  pH.   The  alkaline error may be reduced by  usia
 "low  sodium error"  electrodes.  Other  difficulties encour
 when  using  glass  electrodes include the effect of corrosiv*
 solutions which  attack glass and reduce electrode life,  ao*
 the action  of alkali liberated by the  electrode itself,
 thereby influencing the reading of a weakly buffered  solut
      Problems can also be created by the form of the  -test
 stance.  When measuring the pE of suspensions,  sols or  gel
 care must be taken to prevent blockage of the liquid
 between the salt bridge and the test solution.
 of highly charged sediments such as soils or ion exchange
 resins may give a pH reading lower than true pH;  the
 should be allowed to settle and the pH of the
measured.   Oils and viscous materials create sluggish
 pH response.  Glass electrodes requiring less hydra-tiOn 
-------
     The Manual of Methods  for Chemical Analysis  of Water
 and Wastes  (EPA-625- /6-74-003) describes  an  acceptable
 procedure for the measurement of pfl.
     The greatest difficulty associated with  a definition  of
 corrosiveness in terms of pH is the possibility that  some
 corrosive substances will not fit the characteristic.  The
 corrosiveness of aprotic materials, such as the halogens,  is
 not pH-related, and substances of the same pH do  not
 necessarily behave in the same manner.  However,  the validity
 of the approach should not be significantly affected.  Sub-
 stances most frequently implicated in occupational skin
 injuries and environmental damage are sulfuric, hydrochloric,
 hydrofluoric, nitric, acetic, carbolic, formic, and oxalic
 acids and inorganic alkalis such as ammonia,  caustic soda,
 and caustic potash.•
     Application of a characteristic based on pH will encompass
 other hazardous properties.  Damage incidents cited in this
 chapter describe the consequences of improper disposal of
 highly acidic and caustic substances which caused contamina-
 tion of groundwater and surface waters.  The disposal of
 acids and bases together in landfills can create heat generat-
 ing chemical reactions due to the incompatibility of the wastes
 Solubilization of toxic metal salts at pH extremes is another
matter of concern.   Data on the solubilities of heavy metal
 salts as a function of pH are available for pure compounds
 in simple systems.   These findings cannot be extrapolated

-------
 directly to complex systems,  but they indicate trends In t
 relationship between solubility and pH.   Although solubiijji
 tion of waste stream components is also  dependent upon ionic
 strength,  oxidation potential,  available anions and compier
 ing and chelating agents,  the pH factor  is  of  major imports
 especially in the high and low  ranges that  have been men-bid
 previously in this document as  hazardous.   It  is known -that
 compounds  of some elements such as arsenic  or  selenium beeo
 more  soluble under alkaline conditions while nickel salts
 solubilize more readily in an acidic  environment,  and salts
 of  amphoteric toxic metals such as zinc, copper,  chromd>un
 and lead display  increased solubility at either end of -the
 pH  scale.   Contact between these types of compounds and
 strongly acidic or highly  alkaline substances  can  result it
 increased  environmental mobility of the toxic  constituents
     The rate at which a substance corrodes metal  is  also
 significant factor when hazardous wastes in metal  con-tain*
 are stored  or  buried.  A hazardous waste with  corrosive
 properties  could damage a metal  receptacle in which
 contained and  be released  into the environment, or
 containers  holding non-corrosive hazardous wastes coul
-------
year on steel  (SAE 1020) at a test temperature of  130.F.   An
acceptable test is described in NACE Standard TM-01-69.   The
test requires inexpensive materials and little technical
expertise to conduct.  A metal sample of known surface area
is placed in the suspected corrosive for a specified length
of time, and weight loss due to corrosion is measured.  A
simple mathematical calculation yields a measurement of the
depth of corrosion per year.  The procedure was devised pri-
marily to determine the extent to which a particular metal
will corrode when in contact with a corrosive liquid.  For
waste disposal purposes it is important to determine the
corrosiveness of the test "solution" itself.  The NACE
standard is flexible enough to accommodate the minor procedv  %
changes required.  Corrosive constituents would not have  to
be replenished after being exhausted because metal waste  con-
tainers will be in contact only with a limited amount of
solution.   If the ratio of the surface area of the metal  sampl
used in the test to the amount of test solution is smaller tha
the ratio of the inner surface of the container to the amount
of corrosive inside/  general corrosion will proceed at the
rate indicated by the test.   There are disadvantages to utiliz
ing this protocol.   Localized,  galvanic or intergranular
corrosion will not be indicated;  leakage of hazardous material
could occur by these means.   Furthermore,  some materials
exhibiting a severe corrosion rate on steel might not be
considered a hazard to public health or to the environment.

                            12

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 In general, though, the NACE procedure is a reasonable
 method of gauging the ability of a substance to damage
 metal.
      Several other methods of corrosion testing have b
 considered.  NACE Standard TM-01-69 is recommended
 necessary equipment is relatively inexpensive,  the
 be conducted by someone without a great deal of
 expertise,  and the procedure is referenced by the
 of Transportation in 49 CFR 173.240 and is therefore
 to many potential hazardous waste generators.
      ASTM Standard D 2776-72 describes two electrical
 of testing corrosion.   The electrical  resistance raetho«j  M
 the linear polarization method  are suitable for
 the corrosiveness of aqueous solutions.   Equipment for
 tests is  expensive,  ranging in  price from $395  to $15QO  ^
 requires  technical proficiency  to  manage.   DeterminatiOn «
 the corrosion rate by  the  electrical resistance metho^ d *
 on several  successive  readings  taken over a period of 
-------
 ability to damage metal.  It is believed that control of dis-
 posal of wastes with, a pH equal to or less than 3 or equal to
 or greater than 12 will provide a certain amount of protection
 to those likely to come into direct contact with the waste.
 Protection of the environment will be afforded by preventing
 the solubilization and subsequent migration of heavy metals
 and by decreasing the likelihood that dangerous heat generat-
 ing chemical reactions will occur as a result of co-disposal
 of incompatible wastes.  Ose of a metal corrosion characteristic
 will assist the development of proper containerization practices
 thereby furnishing additional safeguards to public health and
 the environment.
      The following is  a brief list of cases documented by EPA
 illustrating the  mismanagement of corrosive wastes.
                       Damage Incidents
 Pennsylvania
                North Cordorus Township,  1975
      The Sunny  Farm Landfill was  not  authorized  to receive
 industrial waste,  but upon inspection such  wastes were  found.
An  inspector  attempting to halt disposal of a drum of  indus-
trial waste was splashed by  the contents of the  drum as it
was being compacted.  He sustained burns on the  face and
neck.
                   Pleasant  Township,  1972
     An earthen dike at a refinery waste lagoon  ruptured, re-
leasing sludge with a pH of  1.7 into  the Allegheny River.  Abcut
450,000 fish were killed along a 60 mile stretch of river.

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                  New Beaver Borough,  1971
     A sludge composed of spent pickle liquors and org
wastes and having a pH of 1.6 was stored in a mine pifc
a shale dam.  Local residents complained of well water
tion, and a nearby pond turned highly acidic and becaffl
lifeless.
                     Elkland Borough,  1973
      A  former tannery site  with 2-4 million gallons <^
 sulfuric acid, tannic acid, liae and sodium hydroxide
 stored in lagoons and tanks was destroyed by fire.
 leveling operations 20,000 gallons of waste liquid
 and drained  into the Cowanesque River, killing
 for 7 miles.
 New Jersey
                      Kin-Buc Landill,  1974                .
                                                       i X
       During the first 10 months of 1974,  five chemicaJ-
  disposal injuries were noted in the Kin-Buc logs.  &$
included eye irritation and chemical burns from
corrosive wastes.
Virginia
                         Carbo, 1967
     A dike containing an  alkaline waste  lagoon for a
 generating  plant collapsed and released 400  acre feet
 fly ash into  the Clinch River.  It  traveled at 1 mil6 £
 hour down river for several days, killing 216,000
                                                         °
                                  15

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Illinois
                    Granite City, 1975
     A leaking storage tank discharged caustic  soda  into  a
creek.  Five children who came into contact with the creek
suffered severe chemical burns.
Texas, 1971
     Barrels containing chemical wastes were caught  in
shrimpers' nets in the Gulf of Mexico.  Physical damage to
nets *T"* equipment occurred, and exposed shrimper crewmen
experienced skin burns and eye irritation.
Minnesota
                       Fine Bend, 1972
     Seepage with a pH less than 2 from a waste basin at  a
chemical plant was believed responsible for well water
degradation by reaction of the acid on subsurface formations.
                               16

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                       REFERENCES

                                                       29*
Bates, R.G. Determination of pH, theory and practice.
  New York, John Wiley & Sons, Inc., 1973

Birmingham, D.J. Acids, alkalis, oils and solvents.  -gtft
  Cantor, ed.  Traumatic medicine and surgery for tne
  Washington, Butterworth, Inc., 1962. pp. 364-370.

Corrosives.  In Encyclopedia of  occupational health a°
  v.l.  Geneva, International Labour Office, 1971-72.
  220-221.
 Epstein,  E.  and R.L. Chaney.   Land disposal of toxic^
   and  water  related problems.   Washington,  U.S. " ~"
   of Agriculture.
                                                         ™
 Fitzpatrick, T.B.,  ed.   Dermatology in general medic*11
   York,  McGraw-Hill,  1971.
                                                     i a I £8$
 Kohan, A.M.   A summary of hazardous substance  cla
   systems.  Environmental Protection Publication
   Washington, U.S. Government Printing Office,  1975
                                                      	^v>
 Lewis, G.K. Chemical burns.  American Journal  of.
   98:928-937, 1959.
  Luckey, T.D,r B. Venugopal and  D.  Hutcheson.   Heavy
    toxicity,  safety and hormology.   Supplement v.l. Ne
    San Francisco, London, Academic  Press,  1975.          *
                                                       $i>
  Mattack,  A.  pH  measurement and  titration.  New York/ ^
    1961.

  McCreanney,  W.C.   Skin care.  In W. Handley,  ed.
    safety handbook.   Maidenhead, Berkshire, EngTand,
    Hill,  1969

  Meidl, J.H.  Explosive and toxic hazardous material*
    Hills, Glencoe Press, 1970.                            ,
                                                          y
   Montagna, W. and W. C. Lobita, Jr.   The epidermis.
    Academic Press, 1964.
                                                          tr
   Peterson, J. E.  Industrial  health.   Englewood Cli£fs'
     Jersey, Prentice-Hall,  inc.,  1977.                    ,
                                                         V**
   pH value,   in  Standard methods for the examination
     wastewater.   14th ed.   Washington, American Health
     Association, 1975.
                               17

-------
Pourbaix, M. Atlas d'equilibres electrochimique a 25°C.,
  Paris, Gauthier-Villars s Cie., 1963.

Solubility chart.  In  Handbook of chemistry and physics.  56th
  ed. Cleveland, CRC Press, 1975-76.  D131-132.
                               18

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BD-3
                             DRAFT


                      BACKGROUND DOCUMENT
            RESOURCE CONSERVATION AND RECOVERY ACT
            SUBTITLE C - HAZARDOUS WASTE MANAGEMENT
         SECTION 3001 - IDENTIFICATION AND LISTING OF
                        HAZARDOUS WASTE
       SECTION 250.13 - HAZARDOUS WASTE CHARACTERISTICS
                          REACTIVITY
                                           DECEMBER 15, 1978
             U.S.  ENVIRONMENTAL PROTECTION AGENCY
                    OFFICE OF SOLID WASTE

-------
     This document provides background information and

support for regulations which have teen designed to identify

and list hazardous waste pursuant to Section 3001 of the

Resource Conservation and Recovery Act of 1976.  It is being

made available as a draft to support the proposed regulations.

As new information is obtained/ changes may be made in the

background information and used as support for the regulations

when promulgated.

     This document was first drafted many months ago and has

been revised to reflect information received and Agency

decisions made since then.  EPA made some changes in the

proposed regulations shortly before their publication in the

Federal Register.  We have tried to ensure that all of those

decisions are reflected in this document.  If there are any

inconsistencies between the proposal (the preamble and the

regulation) and this background document, however, the

proposal is controlling.

     Comments in writing may be made to:

          Alan S. Corson
          Hazardous Waste Management Division  (WH-565)
          Office of Solid Waste
          U. S. Environmental Protection Agency
          Washington, D.C.  20460

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                CHAPTER 4 - REACTIVITY


     Highly reactive waste present a danger either from high

pressure and heat generation and/or toxic fume generation

during reaction.  Reactive wastes have been implicated in

landfill incidents causing damage to persons and property

(Table I lists and discusses some of these damage incidents.)

Also reactive substances have caused damage during transportation

storage and handling, and various Federal Agencies have

promulgated regulations prescribing how these reactive

substances should be managed.   (Table 2 lists and discusses
                        o.\ Will 14
Federal regulations for. the National Fire Protection Association

guidelines . )

     For these reasons wastes which are highly reactive

should be identified and placed in a management system to

ensure proper and precautious handling.

     Reactivity is a relative term and has meaning only in a

relative sense.  Reactive substances have been described as

those which:

     1)  autopolymerize

     2)  are unstable with respect to heat or shock

     3)  are explosive

     4}  are strong oxidizers

     5)  react vigorously with air or water

     6)  react with water to generate toxic fumes

     These descriptions (or categories) of reactive substances

are also relative and not absolute measures.

-------
Rather, these categories  are descriptions of either the
physical consequences of>or descriptions of,the type of
reaction undergone.  Also they are not discrete phenomena
and a particular waste  (or substance) undergoing a reaction
might exhibit several of the characteristics of these categories
(for example, certain organic peroxides would fall into four
of the six categories).  These categories not only overlap
with each other but also with other characteristics, such as.'
flammability (the difference between a conflagration and a
deflagration is only one of degree^and corrosiveness (the
chernQijal parameters that make something a strong oxidizer
can also make it a corrosive).
     As discussed in the introduction to the 3001 background
documents,  a primary goal of OSW has been to identify simple
standardized testing methods which a generator could use to
unambiguously determine if his waste would fit each 3001
hazard criterion.  As was the case for flammable solids the
testing methods identified for reactive wastes are less than
ideal.  The available testing methods suffer from the follow-
ing deficiencies:
     1.  The Tests are too Specific
     These tests are used to dfetermine how a specific
     aspect or manifestation of waste reactivity behaves
     under a special and specific type of stress.   For
     example, DTA  (Differential Thermal Analysis)  measures
     how temperature gradients produced by the waste,

-------
(one specific aspect of waste reactivity) behave  under

a slow input of thermal energy  (one special and specific

type of stress).   This would not indicate how  the waste

reacts to mechanical shock  (a drop test would  be

necessary to determine that), electrical shock, whether

or not the waste is a strong oxidizer, or even what  is

producing the temperature gradient (pressure buildup,

toxic fumes, heat of mixing, etc.).  The information

derived then is specialized and these tests do not lend

themselves for use in a rigid regulatory program.

2.  Reactivity of a Sample may not Reflect Reactivity

    of the Whole Waste;

    In the case of wastes which are thermally  unstable

the reactivity of the sample may not adequately reflect

the reactivity of the whole waste.  The kinetics  of

reaction are not only a function of the available

initiating sources and ambient temperature, but are

also a function of the mass, configuration, geometry,

etc. of the sample.  For a "runaway" reaction  to  occur,

the system must surpass that steady state where the
(V*aV) -pfo4«t»L*.6H
energy^radiated or transferred to the surroundings

from the reacting mass.  When this critical tempera-

ture is reached, the mass experiences catastropic self-

heating.  As is obvious from the foregoing, this  heat

transfer phenomenum is a function of sample size, density,

and geometry.  The relationships are demonstrated in

equation 1, for the rate of temperature rise:

-------
     CdT/dt =  QVp  exp  (-E/RT)  + hs  (T  -  To)



     C = me



     m = mass



     c = specific  heat



     T = Temperature of the material



     Q = Heat  of decomposition



     V = Volume



     p = Density



     E = Activation energy



     R = Gas constant



     h = Heat  transfer coefficient



     S = Surface area of the material



     As is evident from the above, the physical para-



meters (extensive  and intensive) of the  sample will all



play an important  part in the  rate of temperature rise.



3.  The Test Results are in Most Cases Subjective



    or not Directly Applicable



    The ideal  test to use in a regulatory program is



usually one which  requires minimal interpretation:



The majority of available reactivity testing methods



are not of the "pass-fail" type.  Rather the test



results usually consist of a first order differential



plotted against time  or against  a standard, from which



relative reactivity can be accessed.  The decision as to



whether a waste meets the criterion now requires inter-



pretation of these results.   That the available testing



methods are of this type is not surprising, usually when

-------
     a test of this sort is run, it is not run to determine


     reactivity "per se" but rather to elicit information


     concerning how "fast" a material reacts (or exhibits

                                  i         &
     some measureable physical manifestation reaction )
                                            r+

     to a particular stress (i.e. kinetic information)


     or how vigorously it reacts (thermodynamic information) .


           This information may not be directly related


     to the reactivity 4 for example, the resultant informa-


     tion extracted from the test might be activiation


     energy, an interesting bit of information, but potentially


     misleading.


     Again this harkens back to the indefinite meaning of


the term "reactivity" , a term which draws its meaning from
the context of its use. A chemist^think of a "reactive"


substance as one with a small activation energy (the energy


difference between the initial and transition states) i.e.


one which reacts easily.   Even this simple concept is a


relative one,  since the magnitude of "low" depends upon the


energy profile of the system.  We^unlike the hypothetical


chemist, are not only interested in things that react "easily"


but also those which react vigorously.  This depends not


only on the activation energy,  but also the heat of reaction,


the molecular ity of the reaction and other factors, .  .


We're not really interested in performing a thermodynamic


measurement, but rather are interested in observing if the


waste in question behaves in such a way to pose a danger


under normal handling conditions

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 4.   The  Standardized  Methods  That  Do  Exist Were Not



 Developed  For Waste Testing.


                            «r

 The  consequence of this  fact, is  that  standardized



 methods  are  applied to non-standardized  samples,



 standardized methods  applied  to  samples  with physical



 consistencies the method was  not designed for, and



 more importantly standardized method  used to evaluate



 (waste) materials even though no data base exists



 for use of these methods with waste materials.


                       -r                &•
                      ' if such methods ***re used,



 the results  would be  difficult to  interpret with



 certainty.



 5.  The Available Methods Do  Not Reflect Waste



 Management Conditions.



 Using a laboratory testing method  to  predict field



 behavior is  difficult enough  for well understood



 systems.  There are always complexities one is not



 aware of, e.g., trace contaminants, local concentration



 fluctuations, etc.  It is important to attempt to



 simulate the field conditions as closely as possible.



This presents a problem in the case of waste



reactivity, not only are we unsure of the ambient



conditions the waste will be  subject  to  (there are



wide fluctuations), but we cannot  even predict the



magnitude  (and in some case the kind)  of stresses,



 (i.e., initiating forces) which might be present.



 Ideally, the initiating force used in the testing



procedure should be id^ejtical (or  as  similar

-------
          as practical) to the field initiating  force.  Obviously

          if we cannot predict the initiating force, we can't

          duplicate it.

     The available reactivity testing methods are  described

and evaluated in Appendix A*.  As is evident from  those

specific evaluations and from the preceding discussion  of tV>£

five generic shortcomings of the available testing methods,

                  none of these "type" methods are suitable

for use to unequivocally determine if a was.te is a reactive

hazardous waste.  This is not as big a problem as  might be

thought on initial reflection. Most generators who generate

waste which are dangerous due to their reactivity  are well

aware of this property of their waste.  Reactive wastes are

rarely generated from unreactive feed stocks, or in processes

producing unreactive products.

     Also, as is evident from the damage  incidents synopsized  in

Table 1, there does not seem to be any widespread  consistent

pattern of mismanaged reactive wastes.  There are  only a  few

damage incidents, and these are either the result  of the

formation of H2S (from either soluble sulfides or  biological

degradation of sulfur containing wastes)  or explosions of some

"unidentified" waste material. Since there are no  systematic

_	                , j- <,

*  These evaluations are taken from "A second appraisal of
   T^thnds for Kst-JTiiaH ng^Self Reaction Hazards" ,  B. S.
   Domalski, Report No. DOT/MTB/OHMD-76-6, ".Classif ication,
   of Test Methods for Oxidizing Materials" V.M. Kuchta,
   A.C. Furno, and A.C. Imof, Bureau of Mines, Report of
   Investigations 7594 and "Classification of Hazards of
   ^aterials-Water Reactive Materials, and Organic Peroxides".
   C. Mason and V.C. Cooper, NTIS No. IB  209422, slightly
   modified so as to determine applicablity to waste
   materials.

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examples  of  environmental  damage  from reactive  wastes,
rather only  the  anomalous  incident,  either  the  quanity of
reactive waste is  small,or it  is  being  properly managed.
Those few wastes that  have been identified  as reactive,
have been  placed  on the hazardous waste  listings.
     Therefore it  will only be in rare  instances      a
generator will be  unsure of the reactivity  class of his
waste, or will be  unable to judge whether        it fits a
prose definition,  and  would therefore require the applic-
ation of testing protocols to  determine the  reactivity of
his waste.   Even in these  cases the  generator should know
what types of stress his waste is unstable  towards, and
could choose from  a battery of tests, chosen and listed on
the basis of stress type.   The tests chosen  (by  stress type)
for inclusion in the regulations  are as follows:
     1.   Explosion temperature test  for thermally unstable
     waste.
     2.   The Bureau of Explosives impact apparatus and the
     test cited  in 49 CFR  173.53(b),(c),(d), or  (f)  as
     appropriate for waste  unstable to shock.
     These test are "pass-fail" test which require no
subjective interpretation.    They  may not however, be applicable
for all waste types or for  all waste management  conditions,
However,  the prose definition -should characterize as hazardous
those wastes which cannot be tested by the approved methods
                                 f

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Since the testing methods available are not ideal for



identifying those wastes categorized as hazardous due to



reactivity, the alternative chosen is to make use of a



prose definition coupled with a comprehensive listing and



suggested testing methods for those instances where the



generator is uncertain if his waste fits the prose defini-



tion.  The regulation presently being proposed is the



following:



     Reactive Waste



           (1)  Definition - A solid waste is a reactive waste



          if it:



                (A)  Is normally unstable and readily



               undergoes violent chemical change without



               detonating; reacts violently with water,



               forms potentially explosive mixtures with



               water, or generates toxic fumes when mixed



               with water; or is a cyanide or sulfide



               bearing waste which can generate toxic



               fumes when exposed to mild acidic or



               basic conditions.



                (B)  is capable of detonation or explosive



               reaction but requires a strong initiating



               source or which must be heated under



               confinement before initiation can take



               place, or which reacts explosively with



               water.

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 (C)  is readily  capable of detonation or

of explosive decomposition or reaction at

normal temperatures and pressures.

 (D)  is a forbiden explosive as defines in

49 CFR 173.51, Class A explosive as defined

in 49 CFR 173.53, or Class B explosive as

defined in 49 CFR 173.58.
NOTE; Such wastes include pyrophoric sub-
stances, explosives, autopolymerizable
material and oxidizing agents.  If it not
apparent whether a waste is a reactive waste
using this description, then the methods cited
below or equivalent methods can be used to
determine if the waste is reactive waste.

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     (2)   Identification Method



          (A)   Thermally unstable wastes can be identified



          using the Explosion Temperature Test (see Appendix B)



          of this document.  Those wastes for which explosion,



          ignition, or decomposition occurs at 125 C after



          5 minutes are classed as reactive wastes.



          (B)   Wastes unstable to mechanical shock can be



          identified using the test cited in 49



          CFR 173.53(b),(c),(d),  or (f) as appropriate.



     This covers all the types of reactivity of concern;



oxidizing agents, and autopolymerizers fit into part A,



i.e. "undergo violent chemical change", and likewise the



rest of the categories listed at the beginning of this



chapter are paraphrased in this definition.  Also, this is



as inclusive as any State regulation, and is a paraphrase



of the NFPA catetory 2, 3, 4 reactive material definitions



(which have been advocated for use as a reactivity definition



by several commentors to the Advanced Notice of Proposed



Rulemaking.



     Oxidizing agents are covered under this section of the



Section 3001 regulations and are also covered under the



ignitable waste definitions.  Oxidizing agents fit parts of



the prose definition for hazardous waste, however the main



danger from these waste are the fires they initiate.  Since



there are no  tests available

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 satisfactorily  determining  whether a waste  is  hazardous



 due  to  oxidizing  capacity  (see  Appendix  A),  these  types



 of wastes  are also  listed with  flammable solids, to  be



 consistent with the DOT  approach.




      The  test chosen as  an  indicator of  thermal  instability



 is a modification of the explosion temperature test  (Test



 VII  in  Appendix A).   The Wood's metal bath  has been  replaced



 by a standard temperature bath  because of the  cadmium fumes



 given off  by the  Woods metal bath,  and because the Woods



 metal bath is not commonly  available for use.  This  test was



 chosen  as  it met  the  criteria of being easy  to perform



 (minimal technical  skills and standard apparatus are used)



 unambiguous to  interpret (either some decomposition, ignition



 or explosion occurs  or it doesn't). (See  test evaluation Appendix



 A).   The mechanical  instability tests chosen are those cited



 by DOT  for transportation (the  DOT  thermal  instability test



 is included by  references in the prose definition).  These



 tests are  familiar to industry  and  DOT has  found them to be



 adequate for transportation purposes.  Since the shocks



 experienced by wastes during management  will certainly be of



 no greater magnitude then the potential  shocks a commodity



may experience during transport, these tests are satisfactory



 for our purpose.

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                           TABLE I



 DAMAGE INCIDENTS INVOLVING LAND DISOPSAL OF REACTIVE WASTE








     1.  Baltimore County, Maryland  - 6 men hospitalized



due to inhalation of hydrogen sulfide gas liberated from



salts being landfilled.



     2.  Edison Township, New Jersey, - bulldozer operator



killed at landfill when barrel of unknown waste exploded.



     3.  Crosby, Texas - residents subjected to sore throats,



nausea, and headaches from reaction between oily wastes and



acids, dumped in an abandoned sand pit (twenty-six wells



were closed by this incident).



     4.  Edison Township, New Jersey, - cases of conjunctiv-



itis, eye irritation, burn on cornea, and chemical burns due



to reactive wastes being landfilled.



     5.  Juean County, Wisconsin - Police officer injured



and squad car damaged by explosion of battery wastes.



     6.  Santa cAr/2, California - Bulldozer operator overcome



by hydrogen sulfide fumes generated while mixing tanning



waste with other wastes.  (Four deaths have occured in



California between 1963 - 1976 from inhalation of H2S from



waste tanning sludge).



     7.  Northern California - drum of toluene diisocyanate



(TDI)  exploded spreading extremely toxic toluene diisocyanate



throughout the area.

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                         TABLE  2

     STATE, FEDERAL AND NFPA REGULATIONS AND  GUIDELINES



1.  Texas

(Texas Water Quality Board)  Texas uses the following  defini-

tion "Industrial Hazardous Waste" means any waste  or mixture

of waste which  . . . generates  sudden  pressure  by  decomposition,

heat or other means and would therefore be  likely  to cause
                                 ii
substantial personnel injury.  .  .-in combination with  a

listing of 40 reactive compounds.

2.  State of Washington

Defines explosive using a  5" drop test, or  class A explosive

(see DOT) 
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          1)   Is a Forbidden or class A, B, or C explosive



          as defined in Title 49 CFR, Sections 173.51,



          173.88, and 173.100 respectively* (see DOT)



         n2)   Is a water reactive material



          3)   Is in NFPA category 2, 3, or  4  (see NFPA)1



5.  Illinois



Uses the following definitions:



     "Explosives - Any waste having concentration of 1% or



morj5 of a substance described as an explosive  (high, low, or



permissible) by Sax  (Dangerous properties  of Hazardous .Materials



by N. Irving Sax, Van Nostrand Reinhold) shall be considered



as explosive "per se".



     "Reactives - Any waste having a composition of 5% or



more of a substance that (as described by  Sax) readily



reacts with air, water, or other substances to produce heat



and/or toxic fumes shall be considered a reactive waste..



The definition includes oxidizing agents.



6.  NFPA



          Category 0 - Materials which in  themselves are



                       normally stable, even under  fire ex-



                       posure conditions,  and which are not



                       reactive with water.



          Category 1 - Materials which themselves are norm-



                       ally stable, but which can become un-



                       stable at elevated  temperatures and



                       pressures or which may react with



                       water with some release of energy but




                       not violently.



                             /->*"

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 Category  2  -  Materials which  in  themselves  are



              normally unstable and  readily  under-



              go violent  chemical  change but do not



              detonate. Also materials which may



              react violently  with water or  which



              may form potentially explosive mix-



              tures with  water.







Category  3 -  Materials which  in themselves  are cap-



              able of detonation or  explosive reaction



              but require a strong initiating source



              or which must be heated under  confin-



             ment before initiation or which react



              explosively with water.
Category 4 - Materials which in themselves are



             readily capable of detonation or of



             explosive decomposition or reaction at



             temperatures and pressures.

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7.  DOT   The Department of Transportation lists explosive



wastes (these are typically propellants, explosives, initiating



compounds etc.)  and also specifies testing methods for liquids



and solids unstable to thermal and mechanical stresses.



(See 49CFR 173.53).  We have included all the definitions,



listings, and protocols used by DOT in the regulations by



reference.

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                         Appendix A










     The testing methods examined in this section-'- are separated



into tests for thermal instability,  (Tests I thru X) tests for



impact mechanical shock instability  (Tests XI a and b) test



identifying oxidizing agents, Tests XII, XIII, and XIV) and



a test identifying water reactive materials, Test XV.







      Most of the information contained in this Appendix was



taken from "A second appraisal of methods for Estimating Self



Reaction Hazards" E.S. Domalski Report No. DOT/iMTB/OH.MO-76/6.

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   A. Tests Indentifying Wastes Unstable"co "Thermal Stress

I.   JANAF (Joint Army Navy Air Force)  Thermal Stability Test

Number Six for Liquid Propellants.


1.   Purpose of Test;

     To determine the maximum temperatures to which thermally

unstable liquids can be subjected for short periods of tine

without danger of explosive decomposition.

                 t
2.   Operating Principle;

     Under confinement in a microbomb a liquid sample is either

heated rapidly and held at a pre-determined temperature for

an arbitrary time interval, or heated at a constant rate until

evidence of rapid decomposition appears.  Spot immersion is

also possible, where the microbomb containing the  sample is

immersed into the bath at some elevated temperature.


3.   Test Description;

     A microbcmb which is drilled and tapped for a thermocouple

and  burst disc fitting, has an internal volume of  1.3 cm3.  A

liquid sample of 0.5 ml volume is used and burst diaphrams

ranging  from 300 to  8400 psi failure pressure can  be used.  The

microbomb is immersed in a bath containing a bismuth-lead alloy,

which melts in the range 150 to 250 F.  Maintenance of the bath

around 200 F and of  the heating rate at 20 F per minute, allows

detection of rated of decomposition of 2 - 5 F per minute.  An

air-vibrator is used to agitate the bath and the sample in order

-------
                                                         -7
                          A2       "     •   .. r  .•
to establish  the desired heat  transfer between bath and

sample.  The  sample  temperature and  the temperature difference

between the bath and sample are recorded as a functions of

time.  The temperature at which self-decomposition begins and. the

rate of decomposition can be derived.


4 .    Test Evaluation;

     This test utilizes small  samples of material in good thermal

contact with  thermos tated suroundings.  The temperature of the

sample can be increased with time at such a slow rate that

quasisteady states are maintained.

     Rates of decomposition can be estimated from plots of th.e

sample temperature vs. time, and from plots of the temperature

difference between the sample  and bath vs. time.  The slope of

the temperature differential curve represents the rate of heat

transfer between the sample and the bath.  Factors which nee«3.

to  be taken into account are the rate at which the bath is fc>ei

heated, heating from the self-reaction of the sample, and

temperature gradients in the microbomb.  From a plot of the

self -heating rate of the sample vs.  the reciprocal of the

temperature,  a linear slope proportional to the activation

energy should result.  The precision of activation energies

derived in this manner is about _+ 15 percent.


5.   Applicability of Test as an Index of Waste Reactivity;

     The activation energy of  the reaction in question,  whii

certainly an important parameter in assessing waste reacti

-------
                                                 53  fij  !
                                      	     _  ___   is-  i
                             A3
(as discussed previously)  is not the only parameter.

 Also important are heat of reaction, waste geometry,

density, the heat transfer etc.  To indicate a particular

activation energy as a cut-off for waste reactivity would

result in many false positives, and negatives.


II.  ASTM (American Society for Testing Materials) Standard
     Method of Test S-476-73, Thermal Instability of Con-
     fined Condensed Phase Systems  (Confinement Test)


1.  Purpose of Test;

     To determine the temperature at which a chemical mixture will

commence reaction, liberating appreciable heat or pressure/

when subject to a programmed temperature rise.  This method

applies to solids or liquids in a closed system in air or some

other atmosphere present initially under normal laboratory

conditions.


2.  Operating Principle:

     The sample to be tested is confined in closed vessel equipped

with a burst diaphram, pressure transducer, and thermocouple.

The apparatus is equilibrated in a bath at room temperature and

subsequently heated at a constant rate.  The temperature

difference between the bath  and sample, the pressure in the

closed vessel, and the bath  temperature are recorded continuously

during  the course of the test.

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                                                                3
 3.   Test  Descrintion:
     This  apparatus  is  a modification of  that described under



 the JANAF  Thermal  Stability  Test.  The  sample  (300 mg.) is



 placed  in  the test cell or vessel  (volume 1 cm3) and is in



 intimate contact with a thermocouple.   The apparatus also has



 a burst diaphram-vent tube system  to release gases formed during



 decomposition if the pressure reaches too high  a value, and a



 pressure transducer  to provide measurement of the total pressure



 inside  the vessel as heat is supplied from a bath at a



 constant rate.  The  nominal  heating rate  of the bath is 8 to lo



 C per minute.  Silicone oil  is used in  the range 0 to 370 C.



 and a low-melting alloy  (i.e., Wood's metal) in the range 100



 to 500 C.  Recorders are used to monitor, first, the difference



 between the sample temperature, T, and  bath temperature, TQ, as a



 function of bath temperature, and, second,, pressure, P, as a



 function of bath temperature.  No  agitation to minimize thermal



 lag is used.



 4.   Test  Evaluation:



     The threshold temperature is  the lowest temperature at th



 left hand  base of the positive peak which appears in the plot



 of T-T0 vs T0.  The  threshold temperature is an indication of



 the onset  of thermal instability in the sample.  A potential



 hazard exists, therefore, when the temperature of the sample



 exceeds this value.  The instantaneous  rate of pressure vs.



bath temperature.  The maximum pressure generated and the rat



of pressure rise are useful hazard parameters related to roucrK



approximations of reaction time, and damage potential.

-------
     Examination of the rate of temperature rise of the
sample, cT/dt,  and rate of temperature rise of the bath, dTQ/dt,
not only allows an evaluation of the Arrhenius constants, but
also provides for arbitrary scaling of the process.  A simpler,
and probably preferable procedure, may be to record only To
corresponding to a runaway condition  (e.g., a specified value
dT/dt dT0/dt, or rupture of a pressure disk; there is some
arbitrariness in the definition of the runaway criterion, but
this feature may not be serious), and then repeat  the experiment
with a different sample diameter, d.  The Frank-Kanenetskii
condition then gives the value of S from
           (dL/d2)2 =  (Tol/To2)2 exp   (E/R) (l/Tol-l/To2)l.
This procedure obviates the necessity of evaluating A and   , and
allows immediate scaling to any size.
5,   Applicability of  Test  as  an  Index of Waste  Reactivity;
     This test suffers from the same  drawbacks as  the JANAF
test  (pA-2), i.e.  the  activation  energy gotten from the  test
is  not a definitive  indicator  of  waste reactivity.
III. SELF HEATING  ADIABATIC TEST
     This  test  is  run  under adiabatic conditions,  conditions of
this sort  do not correspond to normal waste management  conditions,
and the test results by the test  is comparable to  the  test  results
of  I and II.   Since  different  information  cannot be gotten  from
this test,  than  is already  available  from  tests  I  and  II, and
the test conditions  correspond less to waste  management conditions
than do tests  I  and  II, no  further  evaluation of this  test  is
presented  here.                   ^3

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 IV.   THERMAL SURGE TEST



 1.    Purpose of Test;




      To  determine explosion temperature (temperatures for



 which there  is  a delay time of 250  sec before explosion).



 2.    Operating  Principle:



      The discharge of  a capacitor across  a thin-walled tube



 provides the termal stimulus  to  initiate  explosive decomposition.



 The  time-temperature profile  of  the  decomposition is  obtained



 from oscillographic records.   Although the tubes  are  thin-walled



 (0.089 nun),  they  have  considerable strength and provide  a state



 or heavy confinement for the  explosive or  unstable material.






 3.    Test Description;



      A test  sample is  loaded  into hypodermic needle tubing which is



 heated,  essentially instantaneously, by a  capacitor discharge.



 The  temperature and time of the  explosive  event are recorded



 from a continuous  measurement of  the electrical resistance of



 the  tubing by means  of  an oscilloscope.  The test is  particularly



 suited to liquid  material but solids can also be  accomodated



by melting prior,to  their insertion into hypodermic needle



tubing.  Materials  are  subject to temperatures  in the  range of



260  to 1100 C and delay times  of  50 m  sec.  to 50   sec.  The



delay time, T is  given by A exp  (B/RT)  where A  and B  constants



 (somewhat related to the Arrhenius pre-exponential factor  and




activation energy),  R  is the  gas  constant,  and  T  is the absolute



temperature.

-------
     Test Svaulation;



     The thermal surge test supplies data on explosion



temperatures which represent conditions of minimal heat transfer.



This test measures the true induction time of an explosive rather



than the time required to heat up the sample.  Wenograd  15



was able to show a correspondence between the temperature of the



system 250  sec prior to explosion and impact test data.  The



activation energy parameter obtained in thermal surge test



measurements under dynamic conditions are considerably lower



than those determined in other measurements under isothermal



conditions.  This test is probably one of the best available



approximations to a point source heat initiation of an unstable



material in a multicomponent system.





5.   Applicability of Test as an Index of Waste Reactivity



     The high temperatures the test materials are subject to in



this test, do not correspond to those temperatures wastes might



be subject to during management (unless the waste is subject



to a strong electric discharge).  For this reason, this test is



unacceptable.





V.   ADIABATIC STORAGE TEST



     Like test III, this test is run also under adiabatic



conditions, and therefore no further evaluation is presented.

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 VI.   ISOTHERMAL  STRONG TEST
      This  test  determine  the  heat generation rate as a function




 of  time  and  estimates  the  induction period at a given temperature




 for a material.   This  test is run under isothermal conditions



 and takes  anywhere  from weeks to  months to complete, for these



 reasons  no further  evaluation is  presented.






 VII.  EXPLOSION  TEMPERATURE TEST
 1.    Purpose  of  Test:



      To  determine  the  temperature  at which a material explodes,



 ignites,  or decomposes after  a five  second immersion in a Wood's



 metal bath.





 2.   Operating Principle:



      This test gives  an estimate of  how close the  explosion



 temperature is to  ambient condition  for a  material,  and,  hence,



 provides  a measurable  indication of  thermal instability.






 3.    Test Description;



      The  material  to be tested (   25  mg.)  is  placed  in a  copper




 test  tube  (high  thermal conductivity) and  immersed in a Wood's



metal bath.   This  test  is made at  a series  of bath temperatures,



and the time  lag prior  to explosion at each temperature is  recorded,



The bath temperature is lowered until a temperature is reached



at which explosion ignition, or apparent decomposition does not



occur.  The bath  temperature working range from about 125 to 400 C.



The sample is  removed from the bath after 5 minutes if no



explosion had  occurred at 360  C.

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                             A9
     -T-.C, - ^valuation:
~~l •    ""  ""* *""   ..... . — _,.-  —

     ThTexolosion time is very nearby independent of sample


SJ2e crovided the sample size is in  the  range  10  to  40 ,g .

Pa-t;=l, size is also important in providing consistent  re-

au-, -or a group of material.  Rapid equilibration of  tte

 s^:l.  u=on contact  with  the  high  te,perature  bath  will  depend

 ..,-m -;.,., heat capacity  and thermal  conductivity of  the  material,


 L 'could '-  - **1™ •»«=« tainty  la th*  '""•   EX?1°Slm
 t.,,erature data is  a  function of  ti.e serve as useful  indi-


 cators  to  assist in  .maintaining safe thermal condition


 durir.3  handling  and transport.
 5
           test is the most suitable  for our purposes.   The  test

         ar, pass-fail, either  an  explosion, ignition,  deco.po-

 .ition etc. taxes place or not.   The results  are not subjective

 i-. th,, sonse, as are most of  the other  available tests.

       Proble,s  do arise out of  distortion of  th«nal transport

 ,ron  samPle  si.e, however,  this is a problem with all tests.

 vso  the  Woods Metal Bath results in Cadn>ium furaes being generated

 lid  should only be  operated in a hood.  A sand bath or nonfl-n^bl.

 oil  bath might be more suitable  for our purposes.
             _

          determine  the  self-heating  of  a sample at small  to

         v ,eat  generation rates as a function of temperature
       rtt.1-- -•
  or

-------
                                         :;
2.   Operating Principle;                '•   ~  . ..:.."—-'-~^_	-	-'

     A cylindrical aluminum block contains a cavity which has

a Peltier element attached at the bottom and a sample is placed

on the Peltier element.  Heat flow from the block to sample

is measured by means of the Peltier element which provides

an electrical signal to a recording device.


3.   Test Description;

     A sample vessel constructed of stainless steel  (volume,

2 crn3) is positioned over a Peltier element, and both are

housed inside the cavity of a cylindrical aluminum block.   This

central block is surrounded by mantles containing electrical

heating elements in addition to an insulating layer.  The

electrical input to the block and mantles is maintained in

such a manner as to keep the temperature difference between

the block and mantles  as small as possible while the block

is heated linearly at  about 10 C per hour.  The heat flow from

the aluminum block to  the sample is measured by the Peltier

element.  As soon as the sample begins self-reaction the heat

flux to the sample starts to decrease.  From a plot of  the

heat generation of the sample vs. the reciprocal of the absolute

temperature, the activation energy can be calculated.

-------

                                                     $,   ft
                                        -.f.iyf^r^-   "


4.   Test Evaluation:
     Changes in the heat capacity of the aluminum block over



the temperature range 20 to 200 C will cause the temperature



increase over this range to be slightly non-linear.   The



Peltier element is temperature dependent, and calibration



using a pure copper sample having known thermal properties is



recommended.


                                                       4


5.    Applicability of Test as an Index of Waste Reactivity



     This test yield activation energy as a result,  subject



therefore to the same drav/backs as tests I and II.





IX   Homogeneous Explosion Test



1.    Purpose of Test^:



     To determine the pressure-time profile of the thermal



explosion of solid or liquid materials.





2.    Operating Principle;



     A sample is heated under adiabatic conditions in a closed



vessel until explosion occurs.  The maximum rate of  pressure rise



and the maximum overpressure are measured as a function of



time at different heat input rates.





3.    Test Description:



     About 100 ml of a sample is introduced into the lower part of



a stainless steel vessel.  The lower section is sealed off from



a larger upper section above by a membrane (breaking pressure



1 bar).   The larger upper section serves as a free space for
                                      j

-------
                                  A12
the expansion of reactant or product vapors.  During the



main part of the induction period, pressure equalization is



accomplished by a capillary tube connecting the upper and



lower sections of the vessel.   The two-compartment vessel is



placed inside a larger vessel of 20 liter capacity which seals



the former from the external surroundings.  A heating.mantle



around latter vessel allow heating of the inner vessel to take



place as near to adiabatic conditions as possible.  Around



the sample vessel there is also an auxiliary heater which



heats the sample at a constant  (but adiabatic) rate until



explosion occurs.  When explosion takes place, the membrane



is ruptured and expansion into  the larger volume takes place.



A piezo-electric pressure transducer records the pressure



prior to, during, and after explosion.





4.  Test Evaluation;



     Differentiation of materials which give large rates of



pressure rise and overpressures can be singled out from those



which give low values.  Subsequent precautions for management



can be taken.





5.   Applicability of Test as an  Index of Waste Reactivity;



     This test identifies those wastes which react under



thermal stress to produce large pressure  gradients.  This



information could be of use to .identify potentially reactive



wastes, hazardous due to pressure generation.  This type of

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                                                       '  1
 reactive vasts would also be identified by the explosion



 temperature tast.  Since some part of degradation or change in



 the sample would be apparent for these samples failing this test





 X.    Differential Thermal Analysis (DTA)  Test



 1.    Purpose of Test;



      To determine exothermic and endothermic reactions in a



 material as Reat is applied at a particular input rate.





 2.    Operating Principle;



      The material under test and a stable reference material



 are heated simultaneously  at the same rate.   Exothermic  and



 endothermic traces  are  measured using a recorder providing a



 temperature-time plot of the reaction process.






 3.    Test Description;



      The material to be tested ( 5  to 25  rag)  and a  reference



 material (such as alumina  or glass  beads)  are placed into



 identical compartments  in  an aluminum block.   Heat  is  supplied



 to  both  compartments at the same constant rate  of input.



 Temperatures are measured  using thermo-couples  in conjunction



 with  automatic recording devices so that  a plot of  temperature



 vs.  time is  obtained.   A shift  in the base line results  from a



 change in the  heat  capacity or  mass of the material  under  test.



 Particular care must be given  to the  type  of  temperature sensor



 used  and to  the choice  of  its  location in  the compartment  inside



 the  aluminum block.  The geometry of  the  sample and  thermal



 characteristics (such as thermal conductivity)  of the sample



will  affect  the shape of the DTA curve.

-------
                                          "N'ar-^v- f^rS^
4.    Test Evaluation:


     From the exotherms and endotherms of"the DTA curve


decomposition temperatures corresponding to various rates of


temperature rise can be obtained.  Kinetic parameters can be


calculated as a result of properly varying the heating rates


and assuming a constant degree of conversion of reactant when


a specific thermal event  (such as the peak temperature of a


given exotherm) takes place.  When the temperature sensors are


placed in the path of the heat flow the DTA apparatus can


measure the enthalpies of processes such as heats of decomposition


or transition.



5.    Applicability of Test as an Index of Waste Reactivity:


     This test will  give  information as to how a waste reacts,


thermally, to thermal stress.  There are several problems beyond


those normally associated with test's of this kind:


     ' 1)  The stress is specialized, as is the reactivity


     information.


      (2)  The test must be interpreted, and is sometimes


     ambiguous  (as in the case where several reactions are


     taking place, one of which  is endothermic e.g. decomposition


     of NH4N03).


      (3)  Usually very small  samples are used, which makes


     getting a  representative sample even more difficult.


On the other hand this is a standsrdized, procedure which is


familiar to-industry, widely  known and often used.

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                                          , Ilil4lr  s
3 .   T e s t s ~ o r ?. e act; ive Wastes Sensitive to Mechanical Stress
     A great many sensitivity tests using mechanical stimuli
have Loc.n devised, mostly by the military, hencs generally
ir.tonJcc: for the rating of sensitive energetic materials
(explosives and propellants ) .   Since we are interested mostly
in waste commercial materials or byproducts of lower sensitivity
(although handled in larger amounts), the main problem is to
select a few suitable tests from the large number of existing

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XI.  Impact Test




1.   Purpose of Test:




     To determine the minimum drop height of a falling weight




which strikes an explosive material and produces either a mild




or violent decomposition reaction.  Both falling weight and




explosive material have a fixed and constant mass.






2.   Operating Principle:




     Impact energy is supplied to an explosive by a weight of



constant mass which is dropped from varying heights to establish




the minimum height to provide detonation, decomposition, or




charring.  The impact provides rapid compression and crushing




of the sample (which may involve a frictional component of



crystals rubbing against crystals) and detonation ensues.






3.   Test Description:




     The two most prevalent impact tests are those by Picatinny




Arsenal  (PA) (Test XI a) and the Bureau of Mines (B*l) (Test XI b) .



     In the PA apparatus a sample is placed in the recess of a




small steel die cup, and capped with a thin brass cover.  A




cylindrical steel plug is placed in the center of the cover,




which contains a slotted-vent and the impact of the 2 kilogram



weight is transferred to the steel plug.




     In the BM apparatus a 20 mg, weight is always employed while




the PA sample size may be varied for each experiment.   The explosive




sample is held between two flat parallel plates made of hardened




steel and impact is transmitted to the sample by means of the



uoper plate.  Sample decomposition is detectable by audible,




visual or other sensory means.

-------
                                     "i ^ «^ ' ik"~ *-"• J  *\ -'  ' *•   «•- •
                                     "i
                                    4


      In an apparatus used by the Bureau of Explosives  (part
of the Association of American Railroads) and cited in Title
49 CFK (DOT Hazardous Materials Regulations) a falling weight
is guided by a pair of rigid uprights into a hammer-anvil
assembly containing a 10 rag. sample of explosive.  Reproduci-
bility can beccme a problem here because of a non-ideal
collisions between the "drop weight and the impact hammer since
only a fraction of the drop-weight energy is transmitted to
the sample.

4 .    Test Evaluation :
     Greater confinement of the sample will limit the translationa1
component of the impulse to a smaller area as is the case with
the PA apparatus.   Factors which play an influential role in
the test are:  materials of construction, sample thickness , sample
density,  hammer geometry, mass of drop weight, impact area,
surface finish, the surrounding atmosphere, temperature, and
pressure.  Modifications can also be made to accomodate cast
and liquid samples.

5.    Applicability of These Tests as Indicies of Waste Reacti v^ |.v.
     Impact tests suffer from the drawback that the fundamental
processes leading to energy release are complicated and poorlv
understood.   Failure of good agreement between various imoact
tests shows that these tests contain uncontrolled parameters

-------

On the other hand, (I) partial correlations do exist,  (2)



the history of the test indicates rough agreement with



field experience, (3) the stimulus is of reasonable severity,



(4) the test are widely known and relatively wasy to use.



These facts make them useful for a partial definition of



hazards.

-------
                         A19
C.  Tests Identifying Oxidizing Wastes



XII.  Burning Rate Test for Solid Oxidizers



1.  Purpose of Test:



     To determine the relative fire hazard present when in-




organic oxidizers are heated in the presence of wood or cellulosic



substances.





2.   Operating Principle;



     A set sample size and ratio of dried sawdust (12-50 mesh)



and oxidizer is ignited and the burning rate is determined by



measuring the time for the burning to propogate at least 5 inches





2Most of the information contained in this section was taken



from "Classification Test Methods for Oxidizing Materials" by



J.M. Kuchta, A.L. Furno, and A.C. Imhof,  Bureau of Mines,



of Investigations 7594.

-------
                        A20
                                   ';  -j"'^^"-^ :M. fr*"*""?!--''
                                    ;                I
3.   Test Description


     For the test, sawdust is initially screened to provide


particles ranging in size from 12 to 50 mesh  (Tyler screen


series).  The sawdust is dried in an overn at 215 + 5 F for


about six hours, and then test mixtures having various


concentrations of the oxidizers are prepared.  To obtain a


uniform mixture, the materials were agitated for 10 minutes or


more in a closed container. Generally, fine oxidizers are used


"as received" but coarse oxidizers can be pulverized and


screened to obtain samples at least as fine as the wood sawdust.


For most of the oxidizers, a particle size range of about 20 to


100 mesh appears to be adequate for determining their hazard


classification by this proposed test.  However, where the


hazard level of such materials is uncertain because of particle


size considerations, the burning rates of the mixtures should


also be determined using oxidizer samples that have fractions


finer than 100 mesh.


     Burning rates are measured using a rectangular rack that


was mounted horizontally and equipped with a 60-mesh steel screen


to support the sample.  The sample bed is separated from the side


rack mounts to insure unrestricted burning along the sides of the


sample.  To form the sample bed, the sawdust-oxidizer mixture


is placed on a rack between a pair of spacer bars which fixed the


bed size and which are removed before ignition.  The bed can also


be formed in a U-shaped wire screen channel which is transferred


onto the burning rack; the wire screen channel is then removed

before ignition.  The sample is ignited by a propane torch or

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 or  similar flame source and the burning rats determined by


 measurements are made with two fuse wire (0.5 amp)  stations


 and an electric timer,  although slow-burning mixtures  can be


 followed visually and timed with a stopwatch.   The  sample bed


 was normally 7  inches long and the rates are measured  ever a


 distance of  5 inches  and at least 1 inch from the point of


 ignition.


 4.   Test  Evaluation:
    • This proposed  test method  permits  classification of


oxidizers into two  or more  groups  based on  their  relative


burning rates with  a cellulose-type  combustible such as wood


sawdust.  The least hazardous class  includes  those oxidizers


burn at low rates  ( 10 in/min) when mixed  with the select-q>- ^


red oak sawdust.  A second  class consists of  oxidizers, such


the alkali nitrates and chlorates, which burn at  relatively  >>•


rates  (  10 ir./min) when mixed  with  this sawdust.  A thirr)
                                                       1XiU/  rtiore

hazardous class should include  those oxidizers, which when \i


mixed or mixed with a combustible, might ignite spontaneous!


and burn vigorously if moisture is present  or if  they are he


slightly.   This class would include  sodium  peroxide and calc *


hypochlorite (69.5  ptc  C1.2) which gives very hioh burnin


with the sawdust.   A fourth class is also required for thos


oxidizers, such as  ammonium perchlorate, which may detonate


when heated under confinement or when exposed to shock.

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5.   Applicability of Test as an Index of Waste Oxidizing Strength



     This method is designed to provide a relative measure of



the increased ignition or burning hazard that may exist when



inorganic oxidizers are mixed with an organic substance such



as sawdust.  They are not applicable to organic peroxides or



to inorganic oxidizers that may detonate when heated with or



without a combustible.



     In the application of this test method, it must be recognized



that a reliable hazard rating may not be possible for all



oxidizers using a single reference combustible.  If the adjacent



material is not cellulosic in nature, (and in a landfill



this may or maynot be the case) it is conceivable that



an oxidizer may display a greater level of hazard than observed



with the select-grade, red oak sawdust used in the present



study.






XIII. Ignition Hazard Test for Liquid Oxidizers;



1.   Purpose of Test:



     To determine the relative fire hazard by exothermic reaction



of liquid inorganic oxidizers with other substances or by



decomposition to products which ignite or sustain a fire.



Generally, these liquids react with many organic substances and



some are capable of producing spontaneous ignition when mixed



with the combustible at normal or slightly elevated temperatures;



some may also ignite spontaneously when heated in the absence



of a combustible material.

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2.    Operating Principle:


     In this proposed test, the ignitability or reactivity of


the oxidizer sawdust mixtures is determined in an open reaction


vessel using small quantities of the reactants.  Temperatures


up to at least 190 F are used to compare the oxidizers, depend-


ing upon their reactivity.  Such temperatures are not


necessarily unrealistic, considering particularly the possibilitv


of over-heating from the reaction of liquid oxidizers with


contaminants.  The reaction vessel in these experiments is a


200-cm3 Pyrex beaker that is equipped with insulated heating


tapes and which rested on a flat ceramic heater; however, a


stainless steel beaker can be used.  Because of possible violent-


reactions, the reaction vessel is placed in a larger vessel of


heavy-duty steel and the experiments are to be performed in a


protected area.




3.    Te s t D i s cription:


     In a trial, a predetermined quantity of the sawdust Ho  ^_
                                                         x *  to

50 mesh) is added to the reaction vessel and brought to the


desired temperature.  The liquid oxidizer is then cautiouslv


injected with a long hypodermic syringe ( 12 inches)  from belt • A


a protective shield, and the extent of reaction is determ


from continuous temperature measurements arid visual observ
                                                          5

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The mixture temperature is measured with a 30-gage iron-




constantan thermocouple protected against corrosion by a thin-




walled glass sheath and located near the center of the reacting



mass.  Ignitions are confirmed visually since the flame reactions




does not necessarily occur in the immediate area cf the



thermocouple; in many ignitions, the sawdust-oxidizer mixture




is scattered or the flames occurred primarily near the top or



outside of the test vessel.  Generally, evidence of ignition



is observed for periods of at least 15 minutes.  If no significant




temperature increase occurred, experiments are made at higher




temperatures and with various sawdust-oxidizer quantities.



Preliminary trials are always made with a small quantity of



oxidizer  (  1 ml), particularly in the case of an oxidizer of




unknown reactivity.






4.   Test  Evaluation:



     This  method is not applicable to  detonable  liquid oxidizers,




such as concentrated hydrogen peroxide  (  90 pet) or perchloric




acid (  72 pet).   A shock  sensitivity  or  thermal  stability test




 (s.a. test XIV) is required  for evaluating these  types.






5.   Applicability of  Test as an Index of Waste  Oxidizing Strength




      (se  Test XII, No. 5).

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                            hWftftl3^
XIV. Self-HeaJ:irT.g__?est for Organi'C'Tefoxides-*-
1•    Purpose of Test:
     To determine the  minimum ambient temperatures  for  the  self-
heating to explosion of thermally unstable compounds  in charges
of specified shape but varying size.

2.    Operating Principle:
     The thermal decomposition of organic peroxides is  observed
from studying temperature-time plots  to obtain the  critical
temperatures for explosion,  heat transfer coefficient data, and
apparent activation energies.
     A circulating fan located within the working space of  the
furnace provides temperature control  to within 0.5  C.

3.    Test Description:
     A cylindrical tube furnace constructed of steel  housed
an  aluminum open-topped cylindrical container  which could hold
40  to 60 grams of organic peroxide.  The furnace was  heated
electrically over the  range  50 to 350 C and could be  maintained
at  a fixed temperature to within 0.3  C.  The progress of self_
heating in the peroxide sample relative to the furnace  was
observed by using a differential thermocouple  at the  center   f
the sample.  A second  thermocouple attached to the  side of  -nh
container monitored the surface temperature.   Temper ature-t-;
plots were recorded for different cylindrical  diameters
the samples and critical temperatures were calculated.

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                             A26
     Explosion studies were carried out with sample amounts




as large as 800 grams using a somewhat modified apparatus,




and similar parameters examined.






4.   Test Evaluation:



     The chief disadvantage of the method is the long period



over which readings must be recorded and the long time required




for the furnace to stabilize following a large change in




operating temperature.






5.   Applicability of Test as an Index of Waste Oxidizing Strength




     This test can be used to identify detonable oxidizers.  This




ioes not give any additional needed information than provided by




the explosion temperature test.
                                    c/t

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                                               "
                                              f~.
                        A27
XV.  Test Method for Water Reactivity



1.  Purpose of Test:



     To identify materials which  react so violently with



water and provide a danger from ignition of nearby cornbustables,



generation of flammable gases or  generation of  toxic  fumes.






2.  Operating Principle:



     Water reactivity of a substance is determined either



by adding a given weight of water to a given weight of material



or vice versa.  In either case, the rate of temperature rise



and the gross temperature rise are recorded, and  the  gases



evolved are sampled for analysis.






3.  Test Disc rip tiojn;



Tests XV, XVI, and XVII are taken from "CLASSIFICATION OF



HAZARDS OF MATERIALS—WATER-REACTIVE MATERIALS  AND ORGANIC



PEROXIDES" - C. Mason and J. C. Cooper, NTIS No.  PB 209422.

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                                               •li-^S  1
                              A28          . ...;._: "•-— ""





      The sample container is a Pyrex tube, 1-3/8 inches in



 diameter by 10 inches long,  imbedded to a depth of 3-1/2



 inches in block of insulating foam (polyurethane or poly-



 styrene) 3 inches square by  5 inches high. A thin piece of



 copper 3/8 inch square and weighing 0.5 gram (about 0.025



 inch thick)  is silver-soldered to the tip of a chromel-



 alumel thermocouple which measures the temperature rise.  This



 thermocouple is placed in the Pyrex tube in such a way that the



 copper square is near enough to the bottom to be covered by



 the sample.   The output of the thermocouple is fed to a



 suitable recorder.



      An initial estimate of  the severity of the reaction is



..made by adding 5 grams of water slowly to 0.5 gram of material



 with the apparatus behind a  protective shield.   Since either



 toxic or flammable gases may be evolved, the test must be



 carried out in a suitable fume hood.   The temperature rise



 is measured by adding 10 grams of water slowly (10-20 sec)  from



 behind a protective shield to 1, 2, 5, 10, and 20 grams,



 successively, of the sample.  Measurements are continued



 until the temperature reaches a peak and then begins to drop.



 If 1, 2, and 5 grams of the  material give virtually no temper-



 ature increase in 4 minutes, 10 grams of water are added to



 10 grams of sample and the temperature is monitored for 1



 hour to determine whether a  slow reaction occurs ('as in the



 case of A 4C3).  If the reaction is not too violent, 10 grams

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                                  A29
of water  are  added  to  20  grams  of  the  material  to  see whether
a greater rise  in temperature results.   The  procedure may be
reversed  by adding  the material to  the water in the  container.
     The  best method to determine whether  a  flammable or toxic
gas is evolved  is by chemical analysis of  the gas.   If  a gas
is*evolved, a sample from the reacting material is collected
through a flexible  needle inserted  into  the  reaction con-
tainer to within about an inch  of  the  reacting  mixture.  The
sample is then  analyzed on a chromatograph for  flammable and/or
toxic gas.

4.  Test  Evaluation;
     The  test is reproducible to withing 10  percent.  The test
results for known reactives like the hydules of the  alkali
metals are positive.  There seems  to be  little  difference in
the results caused  the order of mixing.

5.  Applicability of Test as an Index of Waste  Reactivity;
     A test such as this  could  be  used to  identify pyrophoric
wastes, wastes which generate toxic gases  when  contacted with water
etc.
     The  test method appears to define the activity  of  the
various materials tested.  Classification  of the water  reactivity
hazard could  be based on  the temperature rise which  is  a
measure of the  heat released by reaction with water.  The
release of flammable and/or toxic  gases  would create an
additional hazard which could be covered by  a classification
such as the following:

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                                                               "D'J
                                                                 ex
                              A30
                       Reactive Wastes:
          Wastes which react with water to give



          temperature rises of 140° F and evolve



          toxic or flammable gases.
          Wastes which react with water to give



          temperature rises greater than 140° F or



          evolve toxic or flammable gases.








     Simplified methods of analysis for toxic gas,  (partic-



ularly HCN and H-S) must be developed before this test could



be considered.

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                          Appendix B



                  Explosion  Temperature  Test





 1.  Purpose  of  Test:



     To determine whether a material  explodes,  ignites,  or



 decomposes after  a  five  second  immersion  in a  sand bath



 or low flammability liquid  (such  as high  molecular weight



 silicone oil) at  temperatures up  to 125°C and  if  so,  at  what



 temperature.






 2.  Operating Principle:




     This test  gives  an  estimate  of how close  the  explosion



 temperature  is  to ambient condition for a material, and, hence,



 provides a measurable indication  of thermal  instability.





 3,  Test Description:




     The material to be  tested  (25 mg.) is placed  in  a



 copper test  tube  (high thermal  conductivity) and immersed



 in the controlled temperature bath.   This  test  is  made at a



 series of bath  temperatures, and  the  time  lag prior to



 explosion at each temperature is  recorded  (up to 10 min.).



 The bath temperature is raised  until  a  temperature of 125°C



 is reached if no explosion,  ignition,  or  apparent  decompostion



 occurs.
Note:  This is a modification of the test taken from K. Henkin,



and R.G.  McGill, Industrial & Engr.  Chera. V44 p!35

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ED-4

                          DRAFT
                   BACKGROUND DOCUMENT
         RESOURCE CONSERVATION AND RECOVERY ACT
         SUBTITLE C - HAZARDOUS WASTE MANAGEMENT
      SECTION 3001 - IDENTIFICATION AND LISTING OP
                     HAZARDOUS WASTE
    SECTION 250.13 - HAZARDOUS WASTE CHARACTERISTICS
                        TOXICITY
                                             December 15,  1978
          U.S.  ENVIRONMENTAL  PROTECTION AGENCY
                 OFFICE  OF  SOLID WASTE

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     This document provides background information and
support for regulations which have been designed to identify
and list hazardous waste pursuant to Section 3001 of the
Resource Conservation and Recovery Act of 1976.  It is being
made available as a draft to support the proposed regulations.
As new information is obtained, changes may be made in the
background information and used as support for the regulations
when promulgated.
     This document was first drafted many months ago and has
been revised to reflect information received and Agency
decisions made since then.  EPA made some changes in the
proposed regulations shortly before their publication in the
Federal Register.  We have tried to ensure that all of those
decisions are reflected in this document.   If there are any
inconsistencies between the proposal (the preamble and the
regulation)  and this background document,  however,  the
proposal is controlling.
     Comments in writing may be made to:
          Alan S. Corson
          Hazardous Waste Management Division (WH-565)
          Office of Solid Waste
          U.  S.  Environmental Protection  Agency
          Washington,  D.C.   20460

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                     Table of Contents


Introduction

Toxic properties Considered and Those Selected

Extraction Procedure

     Sample Preparation
     Leaching Media Composition
     Extractant to Sample Ratio
     Agitation Methods
     Extraction Contact Time
     Post Extraction Sample Handling

Groundwater Dilution

Toxicity

     Genetic Activity
     Bioaccumulation and Persistence
     Human Toxicity
     Aquatic Toxicity
     Phytotoxicity

Regulatory Approach Selected

Bibliography

Appendices

     I  Proposed Toxicity Definition
    II  Mutagenicity Test Protocol
   III  Controlled Substances List
    IV  Bioaccumulation Potential Test
     V  Biodegradation Assay
    VI  Daphnia Magna Reproduction Assay
   VII  Terrestrial Plant Assays
  VIII  Demonstration of Non-Inclusion in the
          Hazardous Waste System Procedures

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                        Introduction

Subtitle C of the Solid Waste Disposal Act, as amended by
the Resource Conservation and Recovery Act of 1976 (referred
to herein as Pub. L. 94-580 or "the Act"), creates a regula-
tory framework to control hazardous waste.  Congress has
found that such waste presents "special dangers to health
and requires a greater degree of regulation than does non-
hazardous solid waste" (Section 1002(b)(5) of the Act).
     This rule is one of a series of seven being developed
and proposed under Subtitle C to implement the hazardous
waste management program.  It is important to note that the
definition of solid waste (Section 1004(27) of the Act)
encompasses garbage, refuse, sludges, and other discarded
materials including _liquids^u-_aemiTSolids,. .and,. contained
gases (with a few exceptions) from both municipal and
industrial sources.   Hazardous wastes, which are a sub-set
of all solid wastes and which will be defined by regulations
under Section 3001,  are those which have particularly signif i.
cant impacts on public health and the environment.
     Subtitle C creates a management control system which,
for those wastes defined as hazardous, requires "cradle-to-
grave" cognizance including appropriate monitoring, record-
keeping, and reporting throughout the system.  Section 3001
requires EPA to define criteria and methods for identifying
and listing hazardous wastes.  Those wastes which are
fied as hazardous by these means are then included in the

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management control system constructed under Sections
3002-3006 and 3010.  Those that are excluded will be subject
to the requirements for non-hazardous solid waste being
carried out by States under Subtitle D under which open
dumping is prohibited and environmentally acceptable prac-
tices are required.
     Section 1004(5) defines a hazardous waste as that which
may -
     "(A) cause, or significantly contribute to an increase
     in mortality or an increase in serious irreversible/ or
     incapacitating reversible, illness; or
     (B) pose a substantial present or potential hazard to
     human health or the environment when improperly treated,
     stored, .transpor.ted,- ~or™dispased-.of.*. ,or.-otherwise		
     managed."
     Section 3001(b) requires EPA to promulgate regulations
identifying those characteristics of a waste which cause a
waste to be a hazardous waste.  In order to carry out not
only the mandate laid out in Sections 1004(5)(A) and 3001(b)
but also 1004(5)(B), the development of the toxicity hazard-
ous waste characteristics was keyed to the concept of improper
management.
     Three criteria were then used in developing the candi-
date set of characteristics:  that a characteristic was
specifically stated in Section 3001 by the definition of
hazardous waste in Section 1004 (.5) of the Act? and/or that

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damage cases collected by EPA over the past several years
demonstrated incidents of harm to human health or the environ-
ment attributable to a characteristic or property of waste;
and/or that other government agencies or private organizations
which regulate or recommend management methods for hazardous
substances have identified a characteristic to be of concern.
     This candidate set of characteristics was then refined
on the basis of the following:  that the characteristic
could provide a general description of the property or
attribute rather than appearing merely as a list of sources;
that the likelihood of a hazard developing if the waste were
mismanaged is sufficiently great; and that a reliable identi-
fication or test method for the presence of the characteris-
tic in waste is available.  Use of this last criterion-has.
led EPA to describe each characteristic by developing or
adopting specific testing protocols.
     This Background Document describes the rationale behind
the test procedures developed to describe the toxicity
characteristic stated in the proposed regulations published
on December 18, 1978 as 40 CFR 250.10 - 250.15 (Appendix I).
                         The Problem
     In order to select those properties of a waste which
could result in their becoming a human or environment health
hazard, an examination was made of damage which has resulted
from past improper disposal.
     In 1977, a study  (1) of 50 land disposal sites that had
received industrial wastes was conducted to determine the
                               6

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prevalence of subsurface migration of hazardous chemical
constituents.  At 13 sites, the study was able to obtain
confirmatory evidence for the migration of organic chemicals
from the disposal location.  At these sites organic contami-
nation of the groundwater had occurred.  In those cases
where it could not be clearly shown that the landfill or
lagoon under study was the source of the specific contaminant,
the site was ruled out as one at which migration had occurred.
Similarly, while heavy metals (excluding iron and manganese)
were found at 49 sites, migration could only be confirmed at
30 sites.  Selenium, arsenic, and/or cyanide were found in
37 sites with migration confirmed at 30 sites.  At 26 of the
sites, hazardous inorganic constituents in the water at one
or more monitor ing-wells was-found to-exceed—fche"-EPA"tfrinkfc	
ing water limits.  Of the hazardous substances, selenium
most frequently exceeded drinking water limits, followed by
arsenic, chromium, and lead.
     Ground water contamination was measured by drilling
sampling wells at various distances from the landfill and at
various depths.  Distances of wells from the disposal site
ranged from 3 to 300 meters (10 - 1000 ft.), while depths
ranged from 2 to 49 meters  (6 - 160 ft.).
     A few specific examples of damage which has occurred as
a consequence of improper storage or disposal of wastes
further illustrate the problem.

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 New Jersey
 Middlesex County,  1967
     A plant recovering metals  such as lead and
 zinc from waste,  stockpiled their raw materials
 in  the open.   Metals  subsequently leached into
 the ground water  resulting in contamination and
 closure of public  water supply  wells in 1971
 and 1972.
 Salem  County
     Groundwater beneath a 40-acre chemical
manufacturing  site has been contaminated by
waste  chemicals disposed of over a 50-year
period.
Atlantic County 1973,	
     A landfill which has been  the depository
of large quantities of industrial wastes is
causing a  groundwater pollution problem.
Camden County  1973
     The wall  of an industrial  lagoon ruptured
resulting  in 75,000 gallons of  latex paint sludge,
containing high concentrations  of lead and
mercury, entering  Billiard Creek.
Gloucester County  1970
     During the 1960's a landfill in Mantua
accepted miscellaneous industrial wastes which
eventually leached out and entered the Chestnut
Branch of  Mantua Creek.  This subsequently
                    8

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           resulted in contamination of the groundwater
           system.
           Maryland
           Somerset County,  1975
                At  Crisfield there is a holding pond that
           daily received 15,000 gallons of waste water
           containing toxic  chemicals such as arsenic,
           lead, nickel,  chromium and cyanides.  The pond
           is unlined and contamination of the underground
           waters has been found to extend to a depth of
           50 feet  and a  radius of 1,000 feet.
           Illinois
           Jo Dayiess County
                Between 1966 and 1968 a mining company
           discharged waste  water into an abandoned shaft
           of a  lead-zinc mine.   As a result,  the Galena-
           Platteville aquifer  has become contaminated.
           Washington
           Spokane  County
                Aluminum  processing wastes were dumped  into
           an old basalt  quarry  during the period 1967-1974.
           Heavy rains  in 1973 caused  two  sources  of domestic
           water to become contaminated with chloride rang-
           ing from 600 to over  1100 ppm.
     These examples illustrate that damage to ground and
surface water frequently result from migration of toxic

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chemicals from the initial disposal site.  Groundwater
contamination is a major concern because it is a source of
drinking water for approximately one-half the population of
the United State.  Furthermore because it is widely available
                />                                              *
and less subject to the fluctuations that affect surface
water supplies, its use is increasing each decade by 25%.
Within a specific locality, the quality of groundwater is
fairly uniform, and little or no treatment may be required
prior to utilization.  However, once contaminated, an aquifer
cannot be easily restored to its original state and its use-
fulness as a source of drinking water may be impaired for
years.
     There is now ample evidence of damage to these important
resources as~a~result -of "improper-disposal- of..wastes*~^Table
1 summarizes the results of a 1974 study (2)  of ground and
surface water contamination in the Northeastern United
States.  Of the 60 municipal and industrial landfill contami^
nation cases studied, 25 resulted in water supply wells
being affected.  At least 9 of these wells had to be abandoned,
       Toxic Properties Considered and Those Selected
     In order to devise a contamination model suitable for
use in estimating the consequences of improper disposal,  a
groundwater scenario was selected.  By selecting a ground-
water contamination scenario we do not mean to imply that
other vectors are not important.  However, we do feel though
                          10

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TABLE 1.  SUMMARY OF DATA ON 42 MUNICIPAL AND 18 INDUSTRIAL
          LANDFILL CONTAMINATION CASES.
Findings                                     	

Assessment of principal damage

  Contamination of aquifer only                  9
  Water supply well(s) affected                 16
  Contamination of surface water                17
                          i
Principal aquifer affected

  Unconsolidated deposits                       33
  Sedimentary rocks                              7
  Crystalline rocks                              2

Type of pollutant observed

  General contamination                         37
  Toxic substances                               5

Observed distance traveled by pollutant

  Less than 100 feet                             6
  100 to 1,000                                   8
  More than 1,000 feet                          11
  Unknown or unreported                         17

Maximum observed  depth penetrated by pollutant

  Less than 30 feet                             11
  30 to 100 feet                                11
  More than 100 feet                             5
  Unknown or unreported                          15
     A
Action taken regarding groundwater resource

  Water supply well(s) abandoned                 4
  Groundwater monitoring program established    12
  No known action                               26
     Type of Landfill
MunicipalIndustrial
                    8
                    9
                    1
                   11
                    3
                    4
                    4
                   14
                    0
                    4
                    2
                   12
                    3
                    3
                    2
                   10
                    5
                    2
                   11
                                11

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that except in rare cases, control levels set using this
model will be sufficient to protect against other routes of
contamination.
     The contamination model selected is based on chemical
wastes creating a problem by leaching or leakage of toxicants
from the disposal site to a drinking water aquifer.  The
control thresholds used in defining the toxicity characteris-
tic have been designed to insure the safe disposal of wastes
which could, if improperly disposed of, contaminate ground-
water to such an extent that use of the water would consti-
tute a human or environmental health hazard.  It must be
emphasized that the contamination model has been developed
for definitional purposes only.  It does not address actual
disposal methods which might be used in any specific circum-
stance.  Site or waste specific models could be used in the
permit process for determining the suitability of a particu-
lar disposal method.
     In addition to being chronically toxic upon ingestion,
materials present in wastes can cause other environmental
and health problems.  Toxicity is thus used in its broader
sense to encompass the specific properties of acute and
chronic toxicity, aquatic toxicity, phytotoxicity, carcino-
genicity, mutagenicity, and teratogenicity.  Another group
of potential hazards consists of those materials which can
persist in the environment and bioaccumulate in animal
                           12

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tissue.  Other manifestations of toxicity, while of  impor-
tance in specific instances, are not thought  to be critical
to the definition of a hazardous waste.
     Inhalation toxicity, for example, has not been  specifi-
cally addressed in this definition for two reasons:
     1)   The number of volatile chemicals ..which are toxic
          by inhalation without also being either flammable,
                                         i
          genetically active, bioaccumulative, or toxic by
          oral ingestion is thought to be very small.
     2)   Wastes containing potentially  hazardous volatile
          chemicals have often resulted  in environmental
          contamination and human exposure through improper
          handling of wastes at hazardous waste disposal
          facilities.  -This is-in contrast to^problems^-
          resulting from improper disposal of potentially
          hazardous wastes because they  were  not identified
          as hazardous.  Prevention of improper disposal
          practices is the objective of  the section  3004
          regulations not 3001.
Some examples of actual damage incidents, supplied by the
California Department of Health, serve to illustrate this
second point.
     1)    During late 1975,  a liquid waste hauler deposited
          5,000 gallons of a liquid waste containing volatile,
          chlorinated organic compounds into an evaporation
          pond at a Class I disposal site in the San Francisco

                             13

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     Bay Area.  A Class I site is a permitted hazardous
     waste facility.  The material appeared to react
     with the contents of the pond, releasing a large
     cloud of extremely odoriferous material.  Hundreds
     of complaints were filed by residents in the City
     of Richmond, with several persons claiming illness
     from the odors.  A visible plume produced by the
     incident was reported still visible over ten miles
     down wind over San Francisco Bay.  The hauler had
     driven from Los Angeles with the waste because
     Class I disposal site operators in Southern
     California rejected it due to its odor.
2)   A load of concentrated nitric acid was discharged
     into a disposal well at an unauthorized chemical
     dump in Los Angeles.   The well subsequently emitted
     a brown cloud of nitrogen dioxide.  A workman at
     the site was observed standing over the well
     shoveling dirt into it in an attempt to stop the
     discharge of the gas.  He wore no respirator.
3)   The cyanide wells receiving alkaline cyanide
     wastes at a Class I landfill in Los Angeles were
     closed down in January 1977, because routine air
     sampling detected hydrogen cyanide gas being
     emitted from the landfill in the vicinity of the
     wells.  It is speculated that the acid conditions
     produced by the decomposing rubbish in the landfiii
     lowered the pH sufficiently to release HCN.

                      14

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4)    In Southern California, a mixture of liquid waste,
     including sludge from the production of perchloroethy-
     lene and trichloroethylene,  was dumped into a cavity
     dug in the working face of a Class I landfill.
     Subsequently dense fumes were seen coming out of
     the cavity, so two bulldozers were summoned to cover
     the waste.  Both bulldozer operators, as well as
                                                     i
     a truck driver, were overcome by the fumes.
5}    At a Class I landfill near San Diego, a waste hauler
     emptied several gallons of methyltrichlorosilane
     into the rubbish.  The material reacted with moisture
     in the landfill, releasing hydrogen chloride gas.
     During covering operations,  a bulldozer operator was
     overcome by the gas and was sent to a hospital .for - -
     recovery.
6}    At a Class II-1 landfill in Martinez, California, a
     Health Department inspector observed several large
     piles of uncovered, powdered waste from refineries
     discharging large quantities of dust into the air
     because of the high winds.  Samples of the powders
     were taken, and analysis showed the presence of Cu,
     V, Ni, Cd, Zn, Pb, Cr, Co, and Hg in varying concen-
     trations from 10 ppm to 2%.   Accordingly, to prevent
     environmental contamination, the site operator was
     required to cover the material daily.

                        15

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Prevention of environmental exposure due to improper disposal
site practices will be covered under Section 3004  regulations.
Protection of disposal site personnel from exposure to
hazardous wastes during transportation and at the  disposal
site will be derived from operational procedures of Section
3004 as well as by regulations of the Occupational Safety &
Health Administration. The purpose of the Section  3001
regulations is to identify wastes that are potentially
hazardous so that proper management practices can  be brought
to bear on their disposal.  Other sections specify how
wastes should be controlled during transportation, disposal,
or resource recovery.
     Additional properties of toxicants that have  not been
addressed are those related to allergens and sensitizers^
Though exposure to these agents can lead to debilitation,
the effects are usually reversible once exposure has ceased.
There are two reasons why controlling human exposure to such
substances is a problem.
     a.   The response of the population to sensitizers and
     allergens is very diverse; it is doubtful that there
     is any chemical to which at least some group is not
     sensitive.  Under these circumstances,  it  is difficult
     to determine  the  existance of  a significant health
     hazard.
     b.   Procedures for identifying substances  with allergic
      properties are very expensive, time consuming, and
      imprecise.
                            16

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Therefore, sensitizers and allergens have not been addressed
in these regulations.
     Once those properties of toxicity having a significant
effect on public health and the environment were selected,
other objectives of the hazardous waste definition became
important.  These include:
          1)  formulation of a dynamic definition which
          would not only identify those wastes which contain
          known toxicants but also those wastes which con-
          tain materials or combinations of materials whose
          toxic properties have not been recognized, and
          2)  specification of toxicant control levels con-
          sistent with environmental goals formulated under
          other regulatory authorities.
          3)  maintenance of low testing costs so that
          non-hazardous wastes will not be forced into the
          hazardous waste net as a result of prohibitively
          expensive test procedures.
The test scheme devised to meet the aforementioned goals
employs a combination of analytical procedures and bioassays,
and is outlined in Figure 1.
     While use of this type of definition has been under
active study since June 1977, the data obtained to date is
insufficient to permit this total test scheme to be proposed
at the present time.
                          17

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                            FIGURE 1
       PROTOCOL FOR  CLASSIFICATION OF
                  HAZARDOUS WASTES
                                Waste
                              Liquid-Solid
                              Separation
          KEY
Exceeds
Threshold
        Lass than
        Threshold
         (Passes
          Test)
^.Exceeds
  Threshold
   (Fails
   Test)
                                     Solid
   Extraction
   Procedure
40 CFR 250.13dX2i)
        Analytical
       Analysis for
       DWS Species
     40 CFR 250.12 
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     The complete definition would employ biological tests
for mutagenic activity and environmental persistence coupled
with an instrumental method for bioaccumulation potential.
          *•/
It also includes a choice between using either bioassay or
analytical tests for measuring chronic toxicity, aquatic
toxicity/ and terrestrial plant toxicity.  For those toxicants
known to be either mutagenic, carcinogenic, or teratogenic
but which are not biologically active in the in vitro muta-
genicity assays prescribed, control will be via listing on
the "Controlled Substances List".
     A major goal of the characteristics development program
has been to keep testing costs to a minimum consistent with
the need for adequate information.  Toward this end standard
procedures and short-term in vitro bioassays have been
selected whenever possible.
     In order to take into account the difficulty of formulat-
ing a testing scheme applicable to wastes of widely varying
complexity, a parallel approach was selected.  These two
parallel criteria sets are being designed so that either one
may be used to evaluate whether a waste is hazardous.  The
analytical approach relies on a quantitative analysis of the
mobile portion of the waste  (the extract), combined with
hazard thresholds calculated based on mammalian, aquatic,
and terrestrial plant toxicity data.  If the concentration
of any species in the extract exceeds the calculated threshold
value the waste is deemed to be a hazardous waste.  A

                             19

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bioassay approach would be available to use when complicated,
or hard to analyze, extracts are to be evaluated.  In this
approach sensitive aquatic and plant species are exposed
to the extract and examined for signs of toxicity.  if mani-
festations of toxicity are noted then the waste is a hazard-
ous waste.  We feel that using this type of definition is
desirable for several reasons.
     1)  The definition is dynamic because it is keyed
     to waste properties rather than a static list of
     known hazardous materials or wastes.  As new toxic
     agents enter the waste disposal network they are
     immediately covered.
     2)  the use of biological indicators offers a mechanism
     for assessing toxicant synergism and antagonism in
     complex mixtures characteristic of wastes.
     3)  A choice of cost effective testing schemes is
     offered to the generators.
     At this point it would be useful to examine in some
detail the specific aspects of toxicity which are of concern
and our present thinking on appropriate test procedures to
use in defining what should constitute a hazardous waste.
However it must be pointed out that many of these tests and
threshold setting approaches have not undergone sufficient
testing to permit their incorporation in this initial
proposal.  The toxicity definition proposed in the Federal
Register on December 18, 1978 incorporates a measure of
                             20

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migration potential coupled with hazard thresholds derived
from the National Primary Drinking Water Standards.
     The first aspect of toxicity to be discussed relates to
the tendency of the constituents of a waste to migrate out
and become available to contaminate the environment under
poor management conditions.  The approach developed to measure
this aspect has been termed the Extraction Procedure.
                    Extraction Procedure
     Two general approaches can be used to evaluate the
teachability of waste material:
     (1)  A very intensive study of the leaching
     characteristics of a specific waste using conditions
     representative of both the waste and its disposal or
     (2)  A quick test subjecting the waste to standard-
     ized procedures.
     The intensive study gives more meaningful information
about the leaching characteristics of the waste since test
conditions can be varied as needed, and the effects of differ-
ent environmental stresses on leaching can be measured.  Such
a test takes considerable time/ money, and personnel.  The
standardized test uses only predetermined testing conditions,
and therefore it cannot show the effects of the different
variables on the itaste leaching pattern.  It can, however,
be used for screening purposes and in this mode can give
useful information on the leaching characteristics of a
waste in a short period of time and with limited resources.
                           21

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As with any  screening  procedure  it  is  important to clearly
define how the results are  to be interpreted.
      In devising  a  test to  use in defining a hazardous waste
it is important to  insure that problems which may manifest
themselves only after  many  years are identified (i.e., the
method roust  be agressive enough  to  accommodate long term
exposure conditions).
      The RCRA set up a control system  for waste disposal in
order to insure the  safe disposal of those wastes which if
improperly disposed  of could result in harm to either humans
or the environment.  It was thus incumbent upon the Agency
to develop a definition of  a hazardous waste which will
identify those wastes  which when improperly disposed of could
result in the types- of damage 
-------
     In order to devise such a standard test a grant was
given to the University of Wisconsin, Madison, in July, 1976
to develop a leaching test which could be used widely to
assess the leaching characteristics of industrial waste.
While this work was in progress, a contract was awarded to
the Mitre Corporation to study those leaching tests currently
in use by industry and government organizations and to
compile and evaluate these procedures.  The object was to
select the most promising of the available procedures for
later evaluation at Madison along with the procedure under
development.
     During mid-1977 the D19.12 subcommittee of the American
Society for Testing Materials (ASTM) began to address the
problem of developing a standard extraction procedure.  in
early 1978 they selected for further evaluation a modified
test developed by a supplier of fixation technology, then in
use for evaluating the leaching potential of stabilized
wastes.  Since information on the reproducibility of this
procedure was not available, ASTM began an inter-laboratory
reproducibility study in the later part of 1978.  This study
is still in progress.  However information developed by
members of the ASTM D19.12 subcommittee and made available
to us was used in developing the extraction procedure (EP) .
     Before the work at Wisconsin had been completed, how-
ever, it became apparent that the extraction fluid developed
                           23

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would be too toxic to permit its use later in bioassay tests
for toxicants which might have been extracted.  Thus in the
fall of 1977, research began at the Oak Ridge National
Laboratory on an extraction procedure suitable for use in
the scheme shown in Figure 1.  The development of the extrac-
tion procedure which resulted from the work at Wisconsin and
Oak Ridge is described on the following pages.  (It has been
included in the proposed toxicity characteristic, as described
in Appendix I.)
     Two types of tests are commonly employed for determining
the leaching potential of a landfilled waste—batch and
column tests.  In a batch test, a properly prepared sample
of the waste to be tested is placed in a container along
with the leaching medium..  After a suitable-period-of-time,
and under conditions specified as being appropriate to the
test, the extract or leachate is separated from the waste
and analyzed to determine the material leached from the
waste.  Column tests, in which the waste is packed in a
column and the leaching solution passed through, give a
closer approximation of landfill conditions than a batch
test, at least at first glance.  The column test simulates
both the waste-leachate contact (except around the column
edge) and the rate of leachate migration found in landfills.
The column test also is good for predicting the release
pattern with time, since it models the continuous leaching
found in landfills and can be run for long periods of time.
                            24

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However, column tests have the following disadvantages:
          1.  problems arising from channeling and non-
              uniform packing.
          2.  potential unnatural clogging,
          3.  possible unnatural biological effects,
          4.  edge effects,
          5.  long time requirements, and
          6.  difficulty in obtaining reproducible results
              even if done by experienced lab personnel.
     All of these difficulties, but particularly the time
requirement for an adequate column test  (months to years),
suggest that a batch test be chosen as the standard testing
procedure.  Both batch and column test might be used though
in an intensive study.
     There are several parameters affecting toxicant con-
centration in the extract from a batch test that need to be
considered in designing any leaching test.  Some of these
parameters are:
          1.  Sample preparation
          2.  Leaching medium composition
          3.  Solid to liquid ratio
          4.  Agitation technique
          5.  Extraction contact conditions
          6.  Sample preparation after extraction
     Several batch leaching tests have been developed.  A
survey of some of the existing tests has been done by the
Mitre Corporation (3).  A summary of the surveyed tests is

                             25

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given in Table 2.  The table provides both the range and the
frequency at which values occur within the range for each of
the various test variables discussed in this section.  For
those factors for which the selection of a value is somewhat
arbitrary, as in the solid to liquid ratio or the elution
time, the range of values reported has been given consider-
ation in the specification of values to be used in a test.
and an average value used.  For other factors (especially
the number of elutions, for example), average values have
little meaning.  The wide variety in all the specified
factors indicates the need for a standardized test so that
results on different wastes and by different laboratories
will be comparable.
     In developing the Extraction Procedure each of the
previously described parameters was taken into account.
Consideration was given to values already in use in leaching
tests developed by other regulatory and testing groups as
well as to results of research carried out in support of
this effort.  A discussion of each of these parameters
follows.
Sample Preparation
     The initial step in the leaching test is the separation
of the solid and liquid components of the waste.  "Solid"
and "liquid" in this context are defined by the separation.
The rationale for the separation process is that the solid
and liquid components of the waste will probably separate in
                           26

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                    .   TABLE 2 !  SUMMARY OF EXISTING   JCHING TEST VARIABLES

                   (NUMBER OF-TESTS SPECIFYING EACH OPERATING VARIABLE INDICATED)
     Leachates
to
-4
H20.(dist, deioh/ dist-deion Or unspecified)
II20 with pH 'adjustment or simple acid base
Site specific
Acetate buffer '
Synthetic municipal landfill leachate
Synthetic natural rainwater
Bacterial nutrient media
Tests with more than one leachate
Solid-liquid ratio .

Time per elution

•
No, of elutions


Agitation
rt A
• iirfaco area
— -'
range 1:1-1:500

range 30 min-
10 days
r
• ,
range 1-10
• .
: • • ' .:-.-. • .


TilO
2

72
hrs

2

10 '
.
/>
'
No.
17
5
1
l
l
1
1
5

varied
2

>72
hrs
•
3

"





calculated
l

to
"equiV."
• •
2
c

• •
: •

use short agitation times
aati-V-UJF1-'i''"-"-1 'I'lAnK PfJH,,l,l ,' ii. j: n.f"<' ; ' . r;]-. ^>.-r ••.;..., .->....-.--.-

-------
a landfill.  As Figure 2 illustrates, three separation
processes might occur.  After the waste is deposited in the
landfill, the liquid components could flow downward due to
gravity, be absorbed by surrounding materials, or move away
from the waste by capillary action.  In municipal refuse,
the predominant material is often paper so that absorption
is probably important.  The solid material remaining after
                                  i
the liquid components have moved will be subjected to leach-
ing by whatever leaching media is available in the landfill.
Thus, it is more realistic to use only the solid portion of
the waste in the leaching test, and to analyze the liquid
portion separately, than to use the whole waste in the
leaching test.  The movement of the liquid portions of a
waste from a landfJ.ll..-ls-.no.t..Jiecessarily.-depjendent.Qa.tlifi
leaching process.
     Separations occurring in landfills will depend both on
the environment immediately adjacent to the waste and on the
landfill conditions and design.  Modeling such potentially
varied conditions in the laboratory is very difficult.
Therefore, it was considered more useful to develop a widely
applicable and relatively easy to use solid-liquid separa-
tion scheme.  Although the separation scheme is not unrealis.
tic with regard to the separation that might occur in a
landfill it should not be considered an attempt to model
that separation.
                           28

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municipal
   refuse
                                                   action and
                                                                     absorri.
                                                   municipal -refuse
                                                    absorption, and capiTIar
                                                    flow
                       gravity flow to
                       underlying soil
      Figure 2:  Movement of moisture frcm waste in: a landfill.
                                  29

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     Several particle separation techniques are given in
Table 3.  Of these, screening, filtration and centrifugation
where chosen as being the most appropriate for the test
scheme.  Filtration was chosen as a final step in the
scheme, since it is easily appled, readily available and
standardized, inexpensive, and roughly approximates the
separation processes in the landfill.  Filtration operation-
ally defines solids and liquids—anything that will pass
through the filter is liquid, and all that does not is
solid.  It is important that the nature of waste components
not be changed, but rather that they simply be separated.
This precludes addition of coagulating or deemulsifying
agents, for example.

                         Table 3

   A List of Several Particle Separation Techniques

          Filtration          Particle Electrophoresis
          Sedimentation       Electrostatic Precipitation
          Elutriation         Flotation
          Centrifugation      Screening
                           30

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      The selection of filter pore size is an important
 consideration.   A small pore size will retain particles in
 the solid portion which might be considered liquid if a
 larger pore size were used.   For example, hydrous ferric
 oxide Cferric hydroxide precipitate in water)  precipitates
 in colloidal size particles.   A 0.45 micron pore sized
 filter will trap many of the colloidal sized particles in
 the solid portion, whereas a larger pore sized filter, e.g.,
 8.0 micron, will allow most of the colloidal sized particles
 to pass through the filter.   Analysis for iron in the
 filtrates from  the two pore sizes would give different
 values for the  iron concentration in the "liquid" portion.
 Many materials  may occur in or be associated with colloidal
 sized particles, .so .it is .important to standardize the pore
 size used and to keep in mind the importance of the pore
 size on the designated liquid and solid fractions.
      Centrifugation is employed in those cases where the
 nature of the mixture is such that use of filtration would
 require too much time.   Centrifugation conditions have been
 selected so that separation of particulate material is
 insured.
      A filter pore size of  0.45 micron was selected on the
basis of its wide  use in water and wastewater  analysis,  its
availability/ and  the resonableness of the pore  size for
modeling landfill  situations.   Particles  larger  than 0.45
                           31

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micron occur in leachate, as shown by suspended solids
measurements and the presence of bacteria, but such mater-
ials are usually removed by passage through soils,, as evi-
denced by the low suspended solids content of most groundwaters.
     In order to insure reproducibility of test results a
homogenenous sample is required.  This can best be accomplished
by reducing the particle size of the waste sufficiently to
insure that a given aliquot of the original sample is
representatative of the whole.  Since data relating homogene-
ity to particle size are not available, a compromise was
selected between very fine grinding, as specified in the
procedures used by Illinois and California, and the use of
a monolithic mass as in the ASTM and IU Conversion Systems
procedures.  The resul-t is- the -requirement--that" the'-sol-id
portion of the waste sample must be ground to pass a 3/8"
standard sieve.
     However, the concern for reproducibility is balanced by
the need to consider real world conditions.  A variety of
processes have been developed for "fixing" wastes in order
to reduce the mobility of the toxic species in the waste.
These processes function by either incorporating the waste
into a solid matrix, encapsulating the waste with an imper-
vious coating, or causing a reaction within the waste through
the addition of binders.  These wastes need special consider-
ation with regard to sample preparation. If it can be shown
                            32

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that these wastes do not physically break down during dis-
posal, then it would be inappropriate to divide the waste
into smaller particles than is necessary for testing.  The
leaching characteristics for a divided waste may be quite
different from that of the waste in it orginal monolithic
form.
     In order to accommodate this problem a Structural
Integrity Procedure (SIP) has been adopted.  The SIP is
designed to be a moderately severe approximation of the
disintegration which might be expected to occur if a fixated
waste was used as fill or construction material.  Under
these conditions crushing might occur from the passage of
heavy equipment over the waste.
     Mahlock and coworkers (4) determined that a compaction
test identical to the procedure of ASTM D698-70 but using
only 15 hammer blows simulates the compactive effort that
might be expected from passing equipment over a placed
landfill.  Their 15-blow test uses a 5.5 Ib hammer impacting
on a 1/30 cu. ft. cylinder of sample after dropping 12
inches.  This apparatus would exert an impact of 165 ft-lbs/
cu. ft. on the sample.
           2
          v  = 2(acceleration of gravity)(distance)
             - 2(32.2 ft/sec2)(1 ft)
             =64.4 ft2/sec2
                              2
     Kinetic energy  =» 1/2 m v
     volume of sample  (1/30)
             = (.5)(5.5/32) (64.4)
                   .0333
             =165  ft-lbs/cu. ft.
                            33

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      A modification of this procedure was selected in order
 to quickly and inexpensively "age" the sample of waste.  The
 goal is to simulate the physical degradation which might
 take place after the waste has been placed in the disposal
 site and compacted by earthmoving equipment.
      The specific procedure selected was one based on a
 scaled down version of the 15-blow compaction procedure.
 The scaled down procedure uses a 0.73 Ib hammer  acting on a
 0.0022 cu.  ft.  sample with a 6 inch free fall.   This  device
 (Figure 3)  has  approximately the same compaction action as
 the larger unit.
                 2
                v  «* 2 a x
                   « (2) (32.2) (0.5)
                   * 32.2
  Kinetic energy   =  1/2 m TT
  Volume of  sample    (.0022)
                   =  (0.5)(0.73/32  (32.2)
                         C.0022)
                   =  165 ft Ibs/cu.  ft.
     With a  typical stabilized waste,  such as that obtained
by  lime addition  to flue gas desulfurization sludge, a
         .  sample  this  size weighs approximately 100 grams
This is a convenient  size for extraction using the equipment
described in the proposed regulation  (40 CFR 250.13).
     In order to  account for the cushioning  or energy dissi-.
pation resulting  from the compressiblity of  surrounding
wastes, a polymer  foam  sample holder was incorporated in
design.
                            34

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                Figure  3
                    6"
                             COMBINED
                             WEIGHT
                               .73 Lb.
                         •1.25 D
-SAMPLE              s
 /-POLYURETHANE FOAM
 z—•HOLDER
                   1.3 D

               '— 3.7 D
                              2.8
                            1
   COMPACTION TESTER
fc
 Polyurethane foam shall conform to requirements
 for Grade 21, performance Grade AD or BD,
 established in ASTM Standard D3453.
               35

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     Weeter and Phillips (5} evaluated this procedure using
a flue gas desulfurization sludge fixated by addition of
varying amounts of water.  The sludges chosen represented a
range of unconfined compressive strengths representative of
sludges of all types.  Three sludges were examined:
                                       21 day UCS*
                                        (Ib/in2)
Sample No.
A
B
C
Density
(Ibs/ft3)
50
120
101
                                          81
                                          586
                                         1450 *
     When subjected to a series of blows by the 0.73 Ib
hammer sample A cracked throughout the upper half of the
cylinder while the bottom half remained intact.  The pulver-
ized particles formed in the upper half of the cylinder
seemed to dissipate much of the energy exerted by the" hammer
after the third or fourth blow.  As a result, the following
blows had little  effect upon the remaining structure of the
cylinder.   This may be an approximation of what actually
occurs.  No visible change  in  structure was noted in speci-
mens B and  C after the SIP  procedure.
     One shortcoming  of the SIP  as  currently  formulated  is
the lack of any measure  of  weatherability.   Wastes  deposited
 in or on the land will be subjected to effects of water,
 freeze-thaw cycles,  and seasonal and daily temperature
 changes.  We intend to explore these factors and to devise,
 for use in future regulations, an improved procedure in
 which these additional factors are incorporated.
  * Uncontined Compressive Strength
                            36

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Leaching Media Composition
     Three landfill situations represent the extremes in
leaching media composition to which a waste might be sub-
jected in a sanitary landfill, as shown in Table 4. Depend-
ing on the relative amounts of the (potentially hazardous)
waste and municipal solid waste, and the extent of decomposi-
tion of the municipal waste, the appropriate leaching media
may range in composition from leachate modeled on actively
decomposing, municipal solid waste sanitary landfill leach-
ate to something approaching distilled water.  The latter
would take on leaching characteristics from the waste itself.
This would also represent the situation in which the waste
in question is disposed by itself.  The third possibility is
codisposal-.with another..induatrinl>waste^-wherfi..jbhfi.ja.ther_ .
waste controls the leaching media composition.
     As discussed earlier, in order to carry out the man-
dated enunciated in 1004(5) (B), the concept of improper mange-
ment has been adopted.  Based on this concept of a reasona-
bly worst case disposal situation, the use of the codisposal
situation as a model for developing the leaching media
composition was selected.
     For codisposal with mixed municipal refuse, a municipal
landfill leachate could be used.  However, municipal landfill
leachate has widely differing characteristics depending on
the refuse composition, state of decomposition, dimensions
                            37

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TABLE' 4 ' CLASSIFICATION  OF LANDFILLS AS RELATED TO
                    '  COMPOSITION
                 Waste Landfilled


             By itself, with relatively
             small  amounts of other
             wastes ,-or with-deeetnposed-
             v/astes

             With municipal v/astes
            With major amounts of other-
            industrial wastes
Leachate* CbtnpositTcm
  . Controlled  by
The «ast& its&lff
Municipal refuser £&~
composition. products.
Other industr-iaT
                                 38

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of the landfill, age, degree of channelling of moisture, and
both long-term and instantaneous climatic effects, etc.
Further, even for a given sample of such leachate, the
composition is very complex, precluding developing an exact
recipe from which leachate of both reproducible and realis-
tic composition can be produced.  Rather than attempt to
define a standard landfill, from which leachates representa-
tive of different landfill ages would conceiveably be obtained,
it was deemed more promising to examine the leaching character-
istics typical of actively decomposing municipal landfills,
and to model a synthetic leachate on the results.  Such a
synthetic municipal landfill leachate has been developed
(6), which simulates aggressive leaching conditions which
might be .obtained by- codisposal'-af-the- waster being1' tested" —   —*
with municipal refuse.  University of Wisconsin researchers
identified the following parameters to be of importance in
describing the leachate that is characteristic of a muni-
cipal waste landfill.
               pH
               completing capacity
               redox potential
               organic solvency
               ionic strength
During the aging cycle of a landfill, these paramenters will
vary in strength due to changes in the concentrations of
                           39

-------
materials producing them.  In order to understand and evaluate
the variations found in the parameters being considered for
the synthetic leachate, some understanding of the .processes
occurring in landfills is necessary.
     Consider a hypothetical landfill with no external
influences except for a constant water input; as the land-
fill ages, a succession of stages will occur.
     Initially little or no leachate is produced until the
landfill reaches field capacity (becomes saturated with
water).  The composition of any liquid which is mobilized
prior to saturation, due to compaction and squeezing, will
depend on the composition of the waste initially landfilled,
and may vary greatly.
     Three major- bacterial—processes--primarirly- Tespons*ibie-«>
for degrading refuse are shown in Figure 4.  Initially,
aerobic decomposition predominates.  This phase will gener-
ally be very short, given the limited amount of oxygen in
the landfill and the high biological oxygen demand (BOD)  of
he refuse.  During this phase, a large amount of heat is
produced, raising the landfill temperature well above ambient
temperature.  (Assuming an initial temperature high enough to
start the degradation processes.)   Leachate produced during
this phase would be expected to dissolve very soluble salts
(e.g., NaCl) landfilled with the refuse.
     As oxygen is depleted, decomposition caused by faculta-
tive anaerobic bacteria will predominate.  During this first
                            40

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                THEORETICAL DEGRADATION  CURVES
          pH
           o
           o
           a.

           I
           to
    VOLATILE
       AGIOS.
         ppm
         IE
           b
    OXIDATION
    REDUCTION
POTENTIAL.mV
                            max. -43.OOO ppm» ACETIC AGIO
                  salts solubillzed at law
                               pH
            AEROBIC
            PHASE
                                                 by
                                            decomposition
                                     ~-200
                    FIRST STA3S    SECOND 3TAG6
                  ANAERGSIC     ANAEROBIC  DEGRADATION
                    PHASE
                            TIME
Figure
              Theoretical degradation curves of a theoretical
              landfill.  From  (6)
                            41

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 stage  of  anaerobic  degradation,  large  amounts  of volatile
 fatty  acids  (e.g.,  acetic  acid)  and  carbon  dioxide  are
 produced.  These acids  reduce  the pH to  the range of  4.5 to
 5.  The low pH helps  to solubilize inorganic materials
 which, along with the high volatile  acid concentrations,
 produce a high ionic  strength  (specific  conductance).  The
 high volatile acid  concentrations also contribute to  the
 high Chemical Oxygen  Demand  (COD) often  found  during  this
 phase.  The oxidation-reduction  potential (redox)is reduced
 to below 0 mv (with respect  to a Standard Calomel Electrode))
 such that reducing  conditions prevail.
     The second stage of anaerobic decomposition occurs when
methane producing bacteria complement  the facultative anaer-
obes.   Methane bacteria-are  strict anaerobes~.and.j:equjL,re,
neutral pH levels.  Volatile acids produced  by facultative
anaerobes and other organic  matter are converted to methane
and carbon dioxide.  Thus, the volatile  acid concentration
is reduced and the  gas  composition becomes a mixture of
carbon dioxide and methane.  With the  neutral pH necessary
for the bacteria to live,  fewer  inorganic materials will be
solubilized,  and specific  conductance  will fall.  The redox
potential should be lower  than the potential during the
first stage of anaerobic processes, reflecting the low
potential needed for methane production  and  the higher pH.
Eventually, bacterial action may decrease as the substrate
                              42

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is depleted of oxygen and higher redox potentials may be
reestablished by oxygenated water.
     Environmental conditions may considerably alter the
degradation pattern.  The amount of water input has a very
important effect on the rate of degradation. Obviously, the
composition of the refuse landfilled also has important
effects as do landfilling practices and seasonal variations
in temperature.  To complicate matters further, different
microenvironments in the landfill may undergo different
stages of decomposition at the same time.  For example,
Emcon Associates found high volatile acid production, low
pH, and methane production occurring simultaneously.
Since the low pH is toxic to the methane producing bacteria,
it is apparent- that diff erent~areas~ o£~the,, landfill^had..--^,.. —
different and mutually exclusive conditions, with the
leachate reflecting both.
     The data used in evaluating the parameters of interest
come primarily from either the relatively few studies that
have conducted detailed analyses of leachates from a single
landfill (7,8), or from work by Chian et al.  (9) relating
leachate composition from different landfills to landfill
age.  Analysis of a single leachate sample from a landfill
is generally not very useful, since the concentration of a
given parameter can^not be related to the aging process in
the landfill.
                            43

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     Chian et al. (9) analyzed several classes of organic
compounds and related variations in their concentrations to
landfill age.  Figure 5, based on their work, shows the
variations of these classes as a percentage of the total
organic carbon with landfill age.  The age axis should be
regarded as approximate, since landfill degradation rates
vary with environmental conditions.
     There are two factors of importance in modeling pH and
redox potential; the measured value and the buffering capacity
that maintains that value.  The buffering capacity indicates
how resistant the measured value will be to change.  The
minimum pH found in leachate occurs during the period of
volatile acid production in first stage anaerobic decomposi-
tion. Chian et al. (.9) show that the pH and volatile acid
trends in real landfills follow the theoretical trends
fairly closely.  The pH commonly reaches four or five and is
heavily buffered by volatile acids.  Table 6 gives the pH
ranges reported by various authors in literature reviews.
As can be seen from the table, a pH of 4.5 is not uncommon
in leachates.  Furthermore, both the carbon dioxide and the
volatile acids achieve maximum buffering capacity near this
pH.  An "average" landfill probably does not maintain this
                                                           •
low a pH for an extended period of time, but, rather, main-
tains a pH of between 5 and 5.5.  The emphasis here,is
leachate aggressiveness, which warrants the use of the low
pH value.
                           44

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   IOO
o
o*
H
                                          CURVE  Key

                                  I TOTALS OF TOC ICENTrFlSO

                                  2 VOLATILE  AC!OS

                                  3 PROTEINS & AMtNO. AGIOS

                                  4 CARBOHYDRATES

                                  3 AROMATIC HYOROXYL.  COMPOt^OS

                            TIME, YEARS
Figure  5   The trends in the identified fractions of leachate TOC
           • vs. the age of the landfill.   (From Reference  f65.-)
                                 45

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     TABLE 6.   pH RANGES REPORTED BY VARIOUS AUTHORS FROM
               LANDFILL OR LITERATURE SURVEYS
          Source                          Range
     Chian et al. 19)                    3.7-8.5
     Steiner et al.   (10)                 4.0 - 8.5
     Clark et al. (11)                   1-5*- 9.5
     Encom Associates  (7)                3.0-8.5
     Pohland (12)                        4.9 - 8.4
*Site received acidic industrial wastes
                            46

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     In developing the extraction procedure  (EP) it was
necessary to devise a procedure for operationally maintain-
ing the pH at the selected value while taking into account
that a given disposal environment has only a finite buffering
capacity.  An additional factor which  complicated the
development of the EP was the need to keep the toxicity of
the extractant liquid low to permit the use of bioassay
                                        $p*-ct-e£
procedures to evaluate the toxicity of the migrating from
                                          s*.
the waste.
     The ultimate buffering capacity of real world leachates
is a question which has received little attention from the
research community.  However, data gathered at EPA's Boone
County Field Site (3) over a period of 7 years indicates
that leachate generated by decomposing municipal refuse
generates approximately 0.14 equivalents of acidity per kilo-
gram of dry refuse.  Furthermore the acidity is composed of
a mixture of volatile organic acids/ in which the predominant
species are acetic and propanoic acids.
     For modeling purposes acetic acid has been selected as
the acidification agent.  Since it is predominantly pH that
is being modeled, use of a single acid presents no problem.
     In order to calculate the buffering capacity of the
hypothetical disposal environment used in the improper dis-
posal model a site was modeled in which the waste in ques-
tion comprised 5% of the material in the site.
     Furthermore the remaining 95% of the material would be
                           47

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organic in nature and would decompose to produce acids in a
manner similar to municipal refuse.  This is a conservative
model but not a worst case model, since co-disposal with
highly acid waste is not accounted for.
     Using the above relationships one finds that: 1 gram of
waste could be exposed to approximately 2 milliequivalent of
acid.  Thus pH control and buffering capacity have been
accounted for in the EP by using a titration procedure to
maintain the extraction fluid at pH 5 with a limit on total
acid to be added set at 2.0 milliequavelents per gram of
solid material.  Using acetic acid as the acidulant this
calculates to 4 ml of 0.5N acetic acid per gram of waste
being extracted.
Extractant to Sample  r ^	............
     The ratio of waste to extractant used in a standardized
extraction procedure is important when the procedure is used
for waste characterization purposes.  The ratio selected,
coupled with the extractant-solid contact time, determines
whether saturated or unsaturated conditions will exist.  in
addition excessive extractant to solid ratios can lead to
dilution of migrating species thereby resulting in unreason-
ably low toxicant concentrations.
     The disposal model, since it is not based on any speci-
fic disposal site, does not offer any basis on which to set
a ratio.  However there are scientific and practical consider
ations which can be used to arrive at a ratio.
     The three factors which received primary consideration
are:
                             48

-------
     a.  If the sample:extractant ratio is very low, then
     sampling and analytical errors will be magnified.
     b.  If the sample:extractant ratio is very high it
     leads to problems with suppression of sparingly soluble
     species as well as difficulties in agitation and in
     separation of liquid from solid.
     c.  Evaluation of the extract using biological tests
     requires, in some cases, fairly large volumes of extract,
     Thus a procedure which maximizes the quantity of extract
     is desirable.
     As Table 2 shows, existing leaching tests use sample:
extract ratios anywhere from 1:1 to Is500.  Data  (6) indicate
that in most cases the experimental results at ratio between
1:5 and-l.:20,,are, close»to_.thQse_calculajted_assuiniiig a direct
concentration dependence on ratio.  Thus since no one ratio,
within this range, appeared to offer any particular advantage
relative to factors a and b, a 1:20 ratio was selected to
maximize factor c.
Agitation Methods
     In order to obtain reproducible results indicative of
the maximum toxicant concentration which might be expected
to occur, it is important that a uniform, nondestructive,
efficient agitation method be employed.  Ham  (6) evaluated
five agitation methods.  These were:
     1.  Continuous shaking using an oscillating
     shaker;
                            49

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      2.   Continuous mechanical stirring with a
      flat paddle;
      3.   Intermittent shaking by hand;
      4.   Swing type shaking (Pig. 6)  and
      5.   A rotating bottle agitator (Pig.  6).
      Ham found that none of the first three methods  provided
 an optimal solid-liquid contact for all wastes.   In  the
 continuous shaker  (employed in the ASTM procedures)  the
 solids often  remained at the bottom of  the flasks, particu-
 larly if  a slow shake speed was chosen,  with the  result  that
 those solids  on the bottom did not get  continuously  exposed
 to  "fresh"  extractant.   Ham also expressed concerns  with
 using continuous mechanical stirring  with  a flat  paddle
 because of  its  potential  for causing  abrasion especially
 with granular materials.   He observed that the waste and
 liquid tended to move at  the same speed  as the stirrer in
 the continuously stirred  flask,  with  the result that less
 than optimal mixing occurred.
     Observation of the mixing  action using a swing type
 shaker led  to the conclusion that this form of agitation
 does not  seem to provide  good mixing.  The  solid often
 remained  on the bottom and  on the side walls of the flask
without mixing.
     Their  conclusion was  that  in general  the different
agitation methods provide nearly  equivalent results when
cumulative  release using  a  series of extractions is the
                           50

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                    180° SWING SHAKER
                                       SLOWLY
                  ROTATING  DISK SHAKER


Figure  6   Diagram.of the swinq shaker and the rotating disc
           device
                           51

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parameter measured.  However, the rotator method seemed to
be the most effective agitation method both from visual
observations with different wastes and from some what higher
release rates.
     Thus in order to allow a waste tester to use available
equipment whenever possible, agitation has been defined in a
generic way, as follows:
          "an extractor which while preventing
          stratification of sample and extraction
          fluid also insures that all sample
          surfaces are continuously brought into
          contact with well mixed extraction
          fluid."
     During the development--of--*he -proposed regulations..™!*
was necessary to select an agitiation method which satisfied
the following criteria:
          1.  Was usable on a wide variety
          of waste types.
          2.  Permitted the pH of the solution to
          be continuously monitored and adjusted.
          3.  Resulted in minimum abrasion of
          particulate material.
          4.  Did not add to or remove any materials
          from the extraction solution.
     In order to satisfy these requirements an agitator of
the design shown in Figure 7 has been developed.  Adequate
                             52

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           Figure  7


k\\\\\\\\\\vji
/
t
t
c
1
4
j


.1
•«


JU -=—
\\^\\\\\\^

[ 1 J
.0
,




*


j
•
9.
.
'
1

i
,0
    WON CLOGGING SUPPORT BUSHING
1 inch BLADE AT 30° TO HORIZONTAL

        EXTRACTOR
             53

-------
agitation is obtained at rotational speeds of >_ 40 rpm.
Materials of construction that are being evaluated for their
acceptability for a variety of wastes types are 316 stain-
less steel and polytetrafluoroethylene.
Extraction Contact Time
     The liquid-solid contact time is important because it
must be long enough to insure the extraction of contaminants
which might be mobilized under environmental conditions.
However it also must not be overly long since this will
increase the testing costs.
     The Mitre survey (3) of existing leaching test methods,
indicates that there is no consensus within the environ-
mental community as to an appropriate contact time.  Their
data indicated - that~the--contac t~ .times ~ in „use.
can be broken down into:
          less than 24 hours            39%
          24 hours                      39%
          longer than 24 hours          21%
                            54

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     We  have  thus  elected  to  use  a  24  hour  contact  time
 since  the available  test procedures indicated it would be
 cost effective  from  the standpoint   both of efficiency of
 extraction and  testing costs*
     The objective of  the  extraction procedure is to prepare
 an extract of the  waste in which  the concentration  of the
 mobile contaminants  simulates the maximum concentration
 likely to occur in the real world.   Furthermore,  since the
 initial  extraction usually results  in  the maximum contami-
 nant concentrations, only  a single  extraction is required.
     During the development of the  extraction procedure,  a
 48 hour   procedure using two  extractions was studied in
 order  to minimize  surface  contamination effects.  Comments
.received from, various JLnduatry. groups. and i
 a major concern and that a more important consideration
 would be to lower testing costs.   Therefore the second
 extraction was dropped.
 post-Extraction Sample Handling .-
      The contamination scenario on which the extraction
 procedure is based uses transport of contaminants through
 the soil to an underlying aquifer as a model.   As was
 discussed under "Sample Preparation" only those particles
 less than 0.45 microns are likely to reach the aquifer.
 Thus as in the initial separation the solids are removed
 from the extract. Since in a disposal environment the liquid
 likely to reach the aquifer would be a combination of the
 liquid portion of the waste and the extract of the solid
                             55

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portion, the original liquid phase is added to the solid
phase extract prior to use in toxicity evaluations.   It
is this combined liquid which is defined as the extract.
     However, when analytical characterization is to be
employed, there may be times when it is easier to analyze
the two phases separately then combine them mathematically.
     As has been discussed earlier, the contamination model
selected for developing control threshold values is  based
on leaking  or leaching of toxicants from the disposal site
to a drinking water aquifer.  In order to set a threshold
level of a contaminant in the extraction procedure extract,
it is necessary to develop a numerical relationship  between
the concentration of a toxicant in the liquid entering the
aquifer and the concentration--at- the point' of-••humanr-or—••—•
environmental exposure.
Groundwater Dilution.
     Because the movement of a pollutant below the surface
of the land is governed by ground water flow, an understand-
ing of ground water behavior is essential to the determina-
tion of contaminant migration in an aquifer.  Generally,
recharge to an aquifer is provided by natural sources such
as rainfall and subsurface inflow or by artificial sources
such as seepage from liquid waste impoundments.  Water
entering the ground moves vertically through the unsaturated
zone then enters the saturated zone and travels in a pre-
dominantly horizontal manner in the direction of
                             56

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decreasing hydraulic gradient.  The flow pattern can be
altered by induced changes in gradient  (e.g. a pumping
well). A pollutant entrained in ground water flow may persist
throughout the entire sequence of travel but will undergo
             /The
attenuation, degree of attenuation depends on the properties
of the pollutant and the hydrogeologic conditions in the
aquifer.
      Change  in the composition of leachate from a landfill
is usually achieved through a series of reactions.  The
quality of leachate depends on the form and quantity of the
wastes from  which it originates, the disposal conditions,
and the physical and chemical properties of its constituents.
As the leachate migrates, constituent concentration may be
-affected .by-passage-through ..various media.
      During  percolation through the landfill interior, some
components will be removed by adsorptive and complexing
reactions, while others will be added by waste solubilization.
At the interface between the landfill and the underlying
strata, potential attenuating processes include precipitation,
filtration of particles, and adsorption on gel precipitates.
The existence below the landfill of an unsaturated zone with
a liquid and a gas phase increases the possiblity of attenua-
tion  or delay of contaminants.  Permeability is lower than
that  of an all liquid environment, and flow rates will probably
not be uniform, thereby allowing some solute dispersion.
Dilution is  not  significant, but attentuation by chemical
                             57

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and biochemical processes may occur.  The thickness of the
unsaturated zone is important in this regard.
     At the interface between the unsaturated and .saturated
zones, leachate movement changes from vertical flow to
predominantly horizontal flow.  Ground water flow is normally
laminar, i.e., characterized by parallel streamlines with/no^^1® or
mixing taking place between adjacent flow paths, although
turbulent flow involving mixing can occur during movement
through large fissures or in the immediate vicinity of a
pumping well.  The extent of vertical flow in the saturated
zone will depend on leachate density and the presence of
vertical fissures or superimposed beds of varying permeabilities.
     Leachate does not mix readily with ground water; it may
move as a slug/ a- plume-or*a-tnass-of'-xaegraded-vater.  "The
ground water flow pattern governs leachate migration, although
differences in density and miscibility can cause variation
in behavior between the plume of contaminated water and
native water.  The velocity of contaminant travel may be
less than,  equal to, or greater than that of ground water.
     Pollutants entrained in ground water flow tend to
become attenuated with time and distance.  Mechanisms involved.
include adsorption, dispersion, diffusion, precipitation,
and degradation. The most significant means of attenuation
in the saturated zone may be dilution of the leachate as it
follows tortuous flow paths through the aquifer.  Constitu-
ents of the leachate will be reduced at rates dependent on
                        the individual properties of each.
the local hydrogeologic framework andAlaachate will tend to
                             58

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be contained at sites
underlain by fine grained, compact materials with low hydraulic
conductivities  (slate, shale, soft clays).  Migration with
attenuation is favored in formations exhibiting intergranular
flow  (sands, sandstones, sandy clays, gravels) and formations
displaying marked fissure flow with an element of inter-
granular storage  (chalk) if the intergranular conductivity
is greater than the maximum recharge rate.  Rapid leachate
migration through coarse, unconsolidated gravel formations
and fissured rocks such as limestone and granite allows
little attentuation of pollutants.
     Distribution of contamination underground also varies
according to local aquifer conditions and the nature of the
pollutant.  -Where groundwater *£lowHLs Tirapidv^ ^3?eachate--€rom-a"—
point source will form a long thin plume.  Low flow rate
will contribute to lateral dispersion.  Distortion of the
shape of the plume can be caused by variations in permea-
bility and by the operation of pumping wells.  A plume
supported by a constant input of waste will ordinarily
stabilize.  The tendency of the enclave to become enlarged
with addition and dispersion of contaminants is counter-
balanced by attenuation mechanisms or discharge to surface
waters.  Changes  in the groundwater flow, recharge and waste
disposal rates can cause the plume to expand or contract.
The plume of a leachate constituent with greater suscepti-
bility to attenuation will be smaller than that of a persis-
tent contaminant  in the same zone.
                            59

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     Degree of pollutant attenuation within an aquifer is
basically dependent on site specific conditions/ but a
reasonable scenario utilizing an attenuation factor can be
constructed.
     The following assumptions have been made:
     1.  Disposal takes place in a "nonsecure"
     landfill.
     2.  The landfill is situated over a fresh water
     aquifer and in proximity to life-bearing surface
     waters.
     4.  A pumping well is located 500 feet downgradient
     from the landfill. (States with landfill design
     criteria specify landfill to water well distances
     ranging-frpm--500-feet to-1-mile.  The more con-.
     servative number was chosen for the purposes of
     this scenario.)
     Some insight into the process of pollutant dilution in
groundwater for the purposes of scenario construction can be
provided by modeling techniques.  A model is a simplified
representation of a real system, and difficulties are often
encountered in quantifying parameters and testing and verify-.
ing results under field conditions.  Modeling concepts must
be applied to a given situation with caution, but a model
can supply information on potential groundwater effects.  A
model to estimate leachate dilution in groundwater and down*
gradient well discharge has been devised at the Water Research
                                          (14)
Center of Medmenham Laboratory in England.     The model is
                             60

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based on the following assumptions:
     1.  Leachate of consistent composition is discharged
     from the entire landfill at a constant rate.
     2.  There is no chemical change in the leachate as it
     migrates through the aquifer.
     3.  The unsaturated zone is considered a delay
     mechanism only.
     4.  In the saturated zone, the aquifer is uniform and
     the natural groundwater gradient is constant.
     5.  Steady-state conditions exist.
Dilution factors have been calculated using the equation:
C (cfroundwater) =      I       Where C = pollutant concentration
C (Leacnate)I = UB/L
I ss leachate infiltration rate, U = groundwater flow rate,
B «* depth of mixing and L = -length-of-landfill->iir the direc—-->- -
tion of groundwater flow.  Employing average aquifer character-
istics and assuming a constant leachate production rate of
0.3 meter/annum, dilution factors beneath a landfill were
calculated for 3 types of aquifers.  Results are  given
below:
                      Dilution Factors
                                 Distance from Landfill
                            50 Meters             300 Meters
          AQUIFER           (164 ft.)             (984 ft.)
        Chalk                 15 - 50             100 - 250
        Sandstone              3-10             15-50
        Gravel               100 -200             250 - 500
                              61

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     The lowest dilution factor, 3x, has been calculated for
a contaminant migrating through a sandstone aquifer beneath
a landfill 50 meters in length.  Discharge of the contami-
nant to a well directly downgradient should result in this
degree of attenuation.  Any additional dilution would be
                  I
dependent upon how ast water was withdrawn from the well.  if
                  A
high pumping rates are employed water from outside the plume
may be drawn into the well thus diluting the contaminated
water.
     As previously mentioned, models depict idealized situa-
tions.  Actual field analyses reveal considerable variability
in pollutant dilution factors in ground water.  To illustrate
this, we have chosen to examine the behavior of chloride.
The chloride ion is a highly mobile and persistent contaminant-.	
It is readily leached from waste and is resistant to ion
exchange,  chemical reactions and sorption.   Attenuation of
chloride during migration is due to dispersion and dilution.
Some observed dilution factors for chloride at various dis-
tances from waste disposal sites are listed in Table 7.
                              62

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          Table 7 - Chloride Dilution Factors
          SITE
Illinois landfill  (15)
Llangollen, Del. landfill  (15)
Conn, landfill  (1)
Fly ash settling pond  (16)
DuPage County,  111. landfill  (17)
Winnetka, 111.  landfill  (17)
Tythegston landfill, England  (14)
                                        DISTANCE  DILUTION FACTORS
                                        650 ft.
                                        650 ft.
                                          200 ft.
                                          500 ft.
                                           32 ft.
                                          800 ft.
 4-5
  27
   2.3
8-9
  2
 13
2-3
                                          330 ft.
Approximate attenuation factors for hazardous constituents
of leachate also vary widely.  Table 8 illustrates data from
field analysis of several waste disposal sites.
        Table 8 - Pollutant Attenuation Factors
     SITE
Iowa landfill  (18)
Fly ash settling pond  (16)
Kings Kettle landfill,
  England  (14)
Coatham Stob landfill,
  England  (14)
                            Pollutant   Distance
                                                    Attenuation
                                                      Factor
Arsenic
Arsenic
400 ft.
500 ft.
12-13
4
                             Cyanide
                                          430 ft.
   50
                             Chromium     500 ft.
                             Phenol       adjacent
                             Nickel       adjacent
                             Phenol       adjacent
                             Zinc         adjacent
Because of the variability in observed attenuation factors, a
conservative approach has been taken in choosing a factor of
Mitco  (14)
Mi too  (14)
Mitco  (14)
Mitco  (14)
  100
 >23
 >170
 >1000
                            63

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 10 over a distance of 500 feet.   This factor  does  not
appear to be unreasonable when compared with available  data.
However, the value of 10 does not represent the  minimal
amount of dilution that can be expected.  For  instance,
leachate migrating from a disposal site in Islip, New York
was not attenuated by that amount until it had migrated a
         CIS)
half mile    .   Hydrogeologic conditions in the  aquifer
permitted rapid flow, thereby discouraging dilution.  Although
it is emphasized that there will  always be instances  of
lesser and greater attenuation, a factor of 10 should provide
a reasonable degree of protection to public health  and  the
environment while taking into consideration the  broad range
of hydrogeologic conditions at waste disposal  sites across
the country and the variety of contaminants likely  to be
released to the environment as a  result of land  disposal.
In addition to the health and environmental problems  which
result from contamination of groundwater, an additional area
of concern is potential damage to aquatic resources caused
by contamination of surface water supplies.
     Documentation of surface water degradation  caused  by
groundwater which became contaminated as a consequence  of
improper land disposal of wastes  is readily available.   in
once instance, a producer of organic arsenicals  disposed of
various sludges and untreated solid wastes in  a  landfill.
Field analyses later revealed high levels of arsenic  in the
sludge and soil at the disposal site and lower arsenic
                          64

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 levels  in  both  the underlying aquifers  and  the  nearby
 river.   Groundwater  samples  taken  from  a monitoring  well
 close to the  landfill exhibited  arsenic levels  as  high  as
 178 mg/1,  while water samples taken  from the  river immediately
 downstream from the  site contained 150  ug/1.  Data gathered  •
 by the  State  geological survey indicate that  movement of
 shallow groundwater  is carrying  the  pollutant from the
                      (18)
 landfill to the river    •   In Maine, contamination  has been
 detected in residential wells near a hazardous  waste disposal
 facility.   Pollution has also been found in a local  stream,
 and available hydrogeologic  data suggest that it resulted
 from migration  of the substance  through the shallow  aquifer
                     (19)
 to the  surface  water   •  Other studies describe  incidents
 of a similar  nature.  Liquids and  sludges deposited  in  an
 unlined surface impoundment  at a chemical plant site caused
 groundwater degradation, and the plume  reached  a stream
 adjacent to the site.  At this site  arsenic levels of 10,000
ppm were found  in the groundwater, and  40 ppm were detected
in the  stream.  Phenolic waste water placed in  clay-lined
lagoons  in Maryland migrated to  groundwater which then
traveled downslope and discharged  to a  freshwater pond  and
small stream.   In another instance, high concentrations of
copper,  chromium, and lithium were found in a lagoon con-
taining  untreated industrial sludge and liquid  wastes.  A
              f
nearby  stream showed signs of contamination due to discharge
                                                   (20)
of groundwater  tainted by material from the lagoon
                              65

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     Dilution factors for certain substances or specialized
situations have been determined by other groups.   EPA has
previously recognized the existence of such factors in the
establishment of effluent standards for endrin, toxaphene,
and benzidine.  The concentration of benzidine allowed in an
"end of pipe" discharge is lOOx the ambient water criterion.
Effluent may contain 30Ox the amount of toxaphene specified
by the ambient water criterion, and the expected dilution
                                                          (21)
factor for endrin is 375x upon discharge to surface waters.
                                                          A
A discharge location for an aquifer may be a point source, so
the effluent guidelines are applicable in part to the develop-
ment of a dilution factor for this contamination scenario.
     Information from a study on ocean dumping of dredged
material for the Army Corps of—Engineers indicates~tha,t^.
material discarded in that manner should be diluted by a
                              '   (22)
factor of 10 within a few minu-tes.  Leachage contaminated
groundwater will enter surface waters at a slower rate
than dredged material dumped into the ocean and,  in most
circumstances, should undergo greater dilution.
                            (11)
     In an Illinois landfill study, dilution factors were
calculated for ground to surface water discharge at several
locations.  Discharge from one landfill to a nearby drainage
ditch was diluted an estimated 45x.  This factor was considered
low because it did not take into account the water moving
downward below the landfill or the amount of dilution in the
area between the landfill and the ditch.  At another location.
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it was calculated tha chlorides migrating from a fill would
be reduced by a factor of 39 upon discharge to a creek.
Contaminated groundwater from a third landfill was expected
to be diluted 120x when discharged into a river with a low
flow rate; much greater dilution would occur at an average
flow rateP3J
     The dilution model discussed previously also estimates
the attenuation of leachate discharge from groundwater to a
stream.  The model predicts that a pollutant discharged from
a 300 m2 landfill into a stream immediately downgradient
will be diluted 50 fold due to base flow alone over a 1 km
stretch.  A "worst case" situation would exist if a surface
body water were fed entirely by contaminated groundwater,
but most groundwater entering surface waters should be diluted
by water already present and by discharge from other aquifers
     For the purposes of this scenario, a dilution factor of
100  has been chosen for groundwater discharge to surface
water.  The actual amount of dilution is subject to influ-
ences such as the characteristics of the pollutants/ hydro-
geologic conditions in the aquifer and physical and chemical
properties of the mixing zone and receiving waters.  For
this reason, establishment of a dilution factor is best
done on a site-specific basis.  However, this contamination
scenario is applicable nationwide and therefore must be
designed to protect various environments.  Available informa-
tion indicates that 10Ox is a conservative number, but there
will be instances in which less dilution occurs.   Additional
 background information on groundwater dilution theory was
 obtained from references 24 through 31.

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                      Toxicity
     Once the extract has been obtained it must be evaluated
to determine if its discharge would result in a human or
environmental health hazard.  As Figure 1 indicates a variety
of mechanisms are available for a toxic effect to occur.
The following sections will describe the various properties
of toxicity that will be addressed in either the proposed
regulations, the Advanced Notice of Proposed Rulemaking,
or in future proposals.
Genetic Activity
     Chemicals present in the environment have been impli-
cated in the high incidence of cancer in humans.  In order
to lessen human exposure to carcinogens it is necessary to
handle and. dispose^f= wastes containing- such .chemicals. in_ a_
manner appropriate for a hazardous material.  An additional
danger from which society requires stringent protection is
exposure to chemicals capable of damaging genetic material
(DNA).  There are a variety of mechanisms by which chemicals
can act to cause damage to genetic material.  A program of
waste control aimed at identifying and eliminating human
exposure to carcinogenic, mutagenic, and teratogenic com-
pounds requires rapid, inexpensive screening methods to
pinpoint dangerous materials.  In response to this problem,
a number of rapid and potentially inexpensive bacterial and
in yjtro cellular tests have been developed.  These tests
are designed to identify  mutagenic substances by detecting
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genetic changes in the test species.  Because of the variety
of types of DNA damage that must be looked for, no one
simple test will suffice.  Thus a battery of tests will be
employed to screen wastes for their ability to cause DNA
damage.  While these tests do not measure carcinogenicity
per se, there exists a correlation between positive responses
in these in vitro assays and ability to cause cancer in
whole organisms.
     It should be emphasized that short-term tests are only
indications of toxicological effects which may occur in
whole animals after long induction periods.  Their useful-
ness lies in their convenience; compounds demonstrating
activity in selected short-term tests would be expected to
be among the more dangerous threats to human and environ-
mental health.  Both economic and time considerations pre-
vent testing of wastes for genetic activity and carcinogen-
icity in whole animal systems. For control purposes, since a
choice must be made between testing in an imperfect system
and no testing at all, the imperfect option was chosen.
     In 1975 the Agency published proposed guidelines for
registering pesticides which contained the Agency's first
formal mutagenicity testing protocol.  Based on comments
received both in response to this proposal, and as a result
of a study conducted by the Science Advisory Board's Study
Group on Mutagenicity Testing, the 1975 proposal was
redrafted.  It is recommended that these new proposals,

                          69

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                           (32)
published  in February 1978     , be consulted for a more in-
depth discussion of the need  for including mutagenicity as a
toxic property of concern.
     Tests have been selected (Appendix III) on the basis of
low cost,  short performance time, and relevance to the task
of characterizing hazardous waste mixtures.  A further goal
is to use, wherever possible, test procedures and organisms
that are used in other regulatory activities of EPA, DHEW,
OSHA, and CPSC.
     Compounds are often non-mutagenic until acted upon by
the target organism's metabolic system.  In addition, the
reverse can occur; mutagenic  substances can undergo metabolic
inactivation.  For this reason wastes will be tested both
with and without activation.  Activation will be conducted
by incubating the waste extracts with organ homogenates
derived from mammallian species (i.e., rat liver).
     It is known that the common mutagenicity test may not
respond to several types of known carcinogens.   For example,
carcinogenic metals and chlorocarbons are not detected by
the popular Ames Salmonella assay.   In addition, while
teratogenicity is a very real concern, it appears that
short-term tests are not available for evaluating the tera-
togenic potential of a complex mixture.  To protect against
the danger of exposure to hazardous materials known to pass
through the screening,  a "controlled substances list" will
be included in the regulation.  Known hazards which are not
caught in the other sections of the criteria net will be
regulated by this section.
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Bioaccumulation and Persistence:
     Bioaccumulation can occur through either a physical or
a chemical process.  As a physical process it relies on the
preferential solubility of nonpolar organic compounds in fat
tissue relative to the more polar muscle tissue.  Further-
more, once a material becomes deposited in body fat, its
availability, metabolism, and subsequent elimination from
the body slows.  While many persistent organic materials
such as DDT, endrin, and PCBs are retained and biomagnified
through this mechanism, other materials such as mercury and
lead are retained through chemical processes.  As a chemical
process, bioaccumulation relies on the high affinity of some
metals for sulfhydryl and disulfide groups associated with
proteins.  Historically, the former mechanism has accounted
for the majority of environmental contamination problems.
Contamination by halogenated pesticides and flame retardants
has been of special concern.  Some recent notable examples
are polybrominated biphenyls, Mirex and Kepone. Recognizing
this, it appears that a partition test may be helpful in
identifying waste extracts containing organic compounds with
substantial bioaccumulative potential.
     Though this test procedure  (Appendix IV) would miss
materials which bioaccumulate through the chemical bonding
mechanism, this is not thought to be a significant problem.
Metals known to exhibit this type of bonding, but which are

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not identified by the analytical or the aquatic toxicity
phases of the criteria, could be included on the "controlled
substance list" used to also identify exceptions to the
genetic assay.
     While a partition test can indicate a material's pro-
pensity to bioconcentrate in an exposed organism, the
contaminant must be able to persist both in the environment
and in the organism for an appreciably long time.  Thus
before a waste is considered to be a hazardous waste because
of its bioaccumulativeness, the components suspected of
being persistent will be evaluated for environmental stab-
ility.  This procedure will be conducted by exposing the
extract to a mixture of microorganisms and allowing bio-
degradation to proceed for a specified length of time.
Specific procedures for conducting such a test are under
development in consultation with other EPA regulatory
groups.  One such procedure is described in Appendix V.
Other procedures found to give equivalent results will be
made available in the procedures manual to be published upon
promulgation.
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     In order to devise a definition which meets the objec-
tives previously described, namely:
     1.  is dynamic and applicable to both present and
     future wastes,
     2.  specifies control levels consistent with
     environmental goals formulated under other regu-
     latory authorities, and
     3.  does not impose a prohibitive economic burden on
     the regulated communityj
  twofold definition is desirable.  Such a definition would
allow a choice of using either analytical or biological
indicators.  The following discussions have been arranged
according to that part of the environment they are designed
to protect.
Human Toxicity:
Bioassay
     Classical chronic toxicity testing is a prolonged pro-
cedure.  Historically, potential danger to human health has
been determined through chronic feeding studies using whole
animals.  Usually this has meant feeding a rat, mouse, or
other mammal the suspected agent for 3 or more years and
                          73

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then examining the animal for histopathological effects.
This type of testing is prohibitively expensive and time
consuming.
     Recently a variety of short-term cellular bioassays
have been developed for assessing toxicological activity.
These short-term tests are still in the infancy of their
development.  The basis for these in vitro bioassays is the
general observation that toxic events which occur in single
cell tests have been found to also occur in the whole animal.
These In vitro bioassays are reported to correlate qualitatively
with in vivo bioassays.  Materials potent in one system gener-
ally are potent in the other, just as compounds which are
weakly active in one are weakly active in the other.
     The two major difficulties in defining a bioassay proto-
col using cellular bioassays are:
     1.  the lack of a quantitative correlation between
     cellular and whole animal toxicity, and
     2.  the fact that cellular bioassays are still in
     their infancy and there is scientific doubt as to
     whether the results are meaningful.
     Whole animal tests, by virtue of their completeness,
have an advantage because they take into account pharma-
codynamic distribution and metabolism in the organism.  This
is especially true with respect to transport of toxicants to
the active site in the body.  Cell cultures, on the other hand
can employ human cells and therefore iftight model some aspects of
human toxicity more accurately than a rodent bioassay.
                            74

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     Because of the prohibitive cost of whole animal testing
coupled with the uncertainty of the meaning of cytotoxicity
testing, bioassays suitable for RCRA use in indicating
potential human toxicity are not currently available.
Analytical
     The Safe Drinking Water Act of 1974 (Public Law 93-523),
was passed in order to assure that the public is provided
with an adequate supply of safe drinking water.  The Act
authorized the Environmental Protection Agency to establish
Federal standards to protect water supply systems from harm-
ful contaminants.  Under this authority the National Interim
Primary Drinking Water Regulations (NIPDWR) were promulgated
on December 24, 1975.  These regulations went into effect on
June 24, 1977 and became the standards by which to judge
whether or not a given water is safe to drink.  The levels
specified are based on the Public Health Service Drinking
Water Standards of 1962, as revised by the EPA Advisory
Committee on the Revision and Application of the Drinking
Water Standards.  Thus if through improper disposal, suffi-
cient contamination of an aquifer occurs such that drinking
water supplies exceed the above standards, sufficient damage
will have occurred so as to constitute a health hazard.
Exceeding the drinking water standards definitely indicates
degradation of water quality sufficient to constitute a
health hazard.
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                                Based on the groundwater
dilution model/ leachate reaching a drinking water aquifer
is expected to undergo a tenfold dilution.  Thus if the
extract from the waste contains any substance for which a
standard has been issued at a concentration ten times greater
than the standard the waste would be a hazardous waste.
     However for the vast majority of organic chemicals
drinking water standards based on long-term in-depth toxicity
studies are not available.  In order to arrive at an appropri-
ate threshold value for these substances it is first necessary
to determine what level of chronic exposure would not result
in a health hazard.  While such a task is beyond the ability
of science to accomplish, a consideration of the hazardous
waste definition protocol can simplify the problem.
     The initial simplification occurs by removal from con-
sideration of chemicals which are either mutagenic, terato-
genic, or oncogenic.  A second simplification results from
removal of bioaccumulative hazards.  These types of hazards
are identified through use of specific tests performed on
all extracts.  Finally, a third simplification can be made
by separating inorganic chemicals from organic species.
Inorganics can then be controlled through values based on
the aforementioned drinking water standards and soon to be
issued Water Quality Criteria.
     McNamara  (33) has studied the problem of calculating
chronic no-effect levels using acute toxicity data such as
                             76

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LD50 values.  He  found that, though it will err on the safe
side for many compounds, a reasonable approximation can be
obtained using  the relationship:
           no effect value «* Oral LD50/1000
     A similar  relationship was found for 90 day no-effect
dosages.   In this case the lifetime no-effect value can be
arrived at by dividing the 90 day value by ten.  These rela-
tionships  developed by McNamara have been incorporated in the
delisting  mechanism as well as being under consideration for .
use in future characteristics  (see ANPR).  Since in some
cases  lifetime  feeding studies have determined no effect
dosages directly, these values could then be used without
any application factor.
     Using this mechanism it is then possible to calculate a
threshold  value for any organic compound for which the human
no effect  value is either known or can be calculated.  This
•then creates another problem; that of obtaining human LD50
values.
     Experiences  obtained during pharmacological studies
with drugs indicate that  dose-effect relationships are
related to organism surface area.  Thus to approximate the
human  oral LD50,  given LD50 values for common laboratory
species, a relationship based on surface to weight ratios of
rats and mice to  humans has been considered.  For rats and
mice the appropriate conversion factors become:
                human = rat x 0.16
                mouse » x 0.066
                            77

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     In order to arrive at the threshold values to use in
assessing the extract toxicity the following considerations
have been employed.
     1.  Assume a 70 kg human consumes two liters of
     water a day, and that the water contains a substance
     with an oral human LD50 of a mg/kg.
     2.  In the event drinking water became contaminanted
     it is conceivable that persons could be drinking this
     water for much of their life.  Thus for safety the
     water would be considered to be hazardous if it con-
     tained a contaminant at a level greater than the
     lifetime no effect value for that compound.  This
     value is given by the McNamara relationship as .001
     times the LD50 value or .OOla mg/kg.
     3.  Furthermore since the person consumes 2 liters
     of water a day and weighs 70 kg it follows that the
     water could contain as much as:
          (70)(.00100 mg/1 - .035a mg/1
                2
     without being dangerous.
     4.  But, as described previously, since the leachate
     undergoes a 10 fold dilution before reaching the well,
     the extract could contain as much as 10 times this
     amount, or  (.35a mg/1) without exceeding the safe
     level.
     5.  Finally to obtain a one uses the relationships
     previously mentioned:
               a - oral rat LD50 times 0.16, or
               a = oral mouse LD50 times 0.066
     where all LD50 values are expressed in units of mg/lcg.
                           78

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Aquatic Toxicity
     Degradation of surface water quality has been found to
have occurred, in a number of instances, as a consequence of
improper land disposal of wastes.  Thus for the definition of
a- hazardous waste to be complete, it must address protection
of aquatic ecosystems.
Bioassay
     In order to do this using a bioassay approach,one or
more tests are needed which identify wastes posing a danger
both to the existing organisms in the exposed community as
well as to the ecosystem productivity.  Toward this end a
program is under way at the Oak Ridge National Laboratory to
develop such an assay using the water flea, Daphnia Magna.
This assay  (Appendix VI), which- currently requires. 28-days-to
conduct, measures both survival of the exposed organisms as
well as how well they reproduce.  Daphnids are exposed to an
extract of the waste at several stages of their life cycle,
including the sensitive primiparous  (or first egg-bearing)
instar.
     While our experience in using such a procedure has been
favorable, many questions remain which have to be answered
before such a test can be used for regulatory purposes.  Some
of these are:
     1.  What is the intra- and inter- laboratory
     reproducibility?
                            79

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     2.  What  is a toxicologically significant
     response?
     3.  Can the present 28  day procedure be shortened
     without losing sensitivity?  This is important
     because a 28 day test is very time consuming  and
     expensive.
     Answers to these questions are under study.   In addition,
through contacts with the WPCF, ASTM,  and other groups
alternate assays are being evaluated which  may offer advantages
in terms of less intensive use of laboratory personnel,
shorter test duration, less variability of  response, and
finally cost.
Analytical
     Under Section 304 (a) of the Clean Water Act (1977), EPA
can set water quality criteria which reflect the ambient
concentrations of pollutants necessary to protect  public
health, the aquatic ecosystem, and aquatic-related values
such as recreation and aesthetics.  Such criteria  are  based
upon chronic toxicity data showing the "no  effect" level for
sensitive organisms.
     Based on  the previous discussions, a leachate to surface
water dilution of 1000 fold  is anticipated.  Thus  extract
control values based on Water Quality Criteria will be set
at 1000 times  the criteria.  At the present time these
"Criteria" have not been  issued and thus these additional
control values have not been included in the present proposal.
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Phytotoxic ity
     Agriculture is one of the most productive resources in
the United States.  American farmers produce food for the
growing population of this country, including feed for
livestock, as well as for the people of many other nations
who are dependent on the United States for much of their own
food.  It is thus essential that this vital industry be
protected from exposure to materials which could be harmful
to crops.
     Many of the chemicals which are used or produced as
wastes by various industries have some effect on plant life.
These effects vary from plant to plant and from species to
species. In most cases, the mechanisms by which chemicals
cause these effects are unknown.  Since most of the effects
are harmful ones and are therefore capable of reducing crop
yield or saleability, it is important that an attempt be
made to prevent exposure of plants to as many harmful sub-
stances as possible.  It is for this reason that phytotox-
icity, or toxicity to plants, has been considered as a
property of toxicity in the definition of "hazardous waste."
     It is impossible to evaluate all of the effects that
just a single chemical may have on each kind of plant under
all of the widely differing conditions in the crop-raising
areas of the United States.  However, the potential exists
for great loss from these materials; and given this, it is
apparent that some kind of screening program is essential in
order to safeguard the crops as much as possible.
                            81

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     Phytotoxicants present in solid wastes which are improper-

ly managed at disposal can enter the plant environment

through use of groundwater or surface water for irrigation.

During irrigation, the plants absorb the toxicants through

the leaves, stems, or roots.   The importance of preventing

chemical contamination of groundwater and surface water can

be seen by realizing how much water from these sources is

used for irrigation. According to the U.S. Geological Survey,

          The quantity of water withdrawn for irrigation
          in the United States, Puerto Rico, and the
          Virgin Islands in 1975 was estimated at 160
          million acre-feet. . . .This was an average
          rate of 140 billion gallons per day, and the
          water was used on approximately 54 million
          acres of farmland.  This represents an in-
          crease in water use of about 10.9 percent
          over the 1970 estimate and an^ncrease in
          acreage of about 9.4 percent.
£.£.
     Plants may also- be- exposed=*o-£oxicant&- ixuwas.te^. j^-u.^^

specifically sewage, through land spreading.  Land spreading

of sewage sludge is becoming increasingly popular as a

method of disposing of waste from sewage treatment plants.

While this method of disposal has many advantages, serious

damage might result if sludge containing phytotoxic agents

is spread on land used for growing crops or for grazing.

Bioassay

     The search for new useful agricultural chemicals has

yielded a great deal of information on biologically active

compounds.  Some of this information is related to test

methodologies used in investigating the properties of

various chemicals, and some is related to the action of the


                            82

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chemicals themselves.  Most previous work has been concerned
with the influence that a single chemical, or a  small  group
of related chemicals, has on plants of one or two species.
     Because the sensitivity of different plant  species  to
various toxicants varies widely, an attempt has  been made to
balance the information available about a species against
its relative sensitivity to various toxicants, and against
the  economic importance of the plant in the United States.
In general, there is a fairly good correlation between the
information available and economic importance.   The most
popular (and therefore best-known) research plants are also
good field crops.  Thus, the choices have been limited to
wheat, tomato,  soybean, corn, radish and the like.
     There are- two .approaches-.to-rnarrowingi-the.-fdelds:; -size-   .v .^-.;.
of seed and classification of seed plants.  First, immediately
after germination  (emergence of the seedling from the  seed),
the main food available to the young plant is what was
stored in the seedling.  The less stored food there is,  the
sooner the plant must begin uptake of nutrients  from the
soil and/or water. For this reason, young small-seeded
plants, such as wheat and other grasses, lettuce, and
radishes, tend  to be more sensitive to toxicants in soil and
water than are  young large-seeded plants, such as corn,
soybean, kidney bean, and other beans.  Once the seedlings
are established, however, this does not apply.
     A second approach is a division between monocotyledons
and dicotyledons, plants displaying either one or two  "seed leaves,"
                              83

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respectively.  There doesn't seem to be a general relation-
ship between degree of sensitivity to toxicants and number
of seed leaves.  However/ both groups have economically
important members, and the groups are very different physio-
logically.  Therefore, it would be desirable to test both
types.  Corn, wheat and other grasses are monocotyledons,  •>
while tomatoes, lettuce, soybeans, and other beans are
dicoyledons.
     Also affecting the variability of conditions in the
real world are soil conditions such as pH and soil chemistry.
To eliminate these difficulties plants should be grown in
either a nutrient solution or a "standard" combination of
sterile vermiculite and peat moss.
     It is assumed that the irrigation water containing the
leachate will reach the plants through some sort of crop
sprinkling system, necessitating the use of a spray method
of application in the tests.  This introduces the question
of exposure factors, such as droplet size, which could not
be standarized with respect to actual farm conditions, since
these vary so widely.  However, they can and must be stan-
dardized in laboratory tests.  Since water-based toxicants
seem to "work better" when the droplets size is large (approxi-
mately 5 mm), this would be a "worst case" assumption and
would be used.
     The aim of the phytotoxicity criteria is to determine
if a waste might become a hazard to agriculture if disposal
was not made in an appropriate manner.

                            04

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Such a task is difficult even with extensive resources.
A major consideration in developing the tests, however, must
be cost effectiveness.  Thus, while an "ideal" test procedure
should evaluate the plants' responses to exposure throughout
a complete life cycle, the time/cost factors have eliminated
such an approach.
     In trying to determine whether a substance is  toxic to
plants by exposing plants to that substance, one would have
a better chance if several kinds of plants, each of which is
very sensitive to at least one of the possible modes of
action could be tested.  A battery of complementary tests
would provide the most useful information for regulatory
purposes.  This is the route that has been selected for
development  (Appendix -VI-I)'. " The battery • under^eve'lropmervt-r-
includes both germination and seedling growth assays and
employs three important crop species; soybean, wheat, and
radish.  Use of these test procedures though has been delayed
until such time as their reproducibility and utility can be
validated.
Analytical
     For purposes of the analytical option a list would be
published of chemicals which are known to be phytotoxic.
This list would include the level of each substance in the
extraction procedure extract at which the waste would enter
the Subtitle C control system.
              Regulatory Approach Selected
     It is our belief that the toxicity definition outlined
in Figure 1, and described on the previous pages, would
                           85

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substantially meet the goals set forth previously.  These
goals are twofold:
     1.  to have a definition which is dynamic and keyed
     to waste properties in such a manner that as new
     toxic agents enter the waste disposal network they
     are immediately covered.
     2.  To offer the regulated community a choice of
     cost effective testing schemes geared to the wide
     variety of waste types produced.
     However, we feel that use of this definition is pre-
mature at this time.  Two factors account for this decision.
     1.  The lack of validated bioassay procedures.
     2.  The lack of adequate data with which to deter-
     mine the_iinpact of, the definition .both, in -terms .of	..
     the cost of testing and the size of the hazardous
     waste class which would be so created.  This is
     especially important in view of the previously stated
     goal to keep testing costs low.
     Thus in order to carry out the mandate of RCRA and
implement a hazardous waste control program without further
delay,  a modified approach has been proposed.  This approach
makes use of the Detraction Procedure  to measure toxicant.
availability;combined with use of EPA National Interim
Primary Drinking Water Regulations NIPDWS in order to
determine maximum allowable environmental contamination
levels.  Furthermore, since there are many wastes which
                             86

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contain mobile toxic chemicals for which no NIPDWS are
available, an expanded use has been made of lists as identi-
fiers of hazardous waste.  These lists are described in a
separate Background Document.
     The analytical procedures which have been adopted are
those which have been developed by EPA and others for use in
characterizing industrial effluents and wastewaters.  These
methods are currently under active study at the EPA Environ-
mental Monitoring and Support Laboratory.  As new or improved
analytical procedures are developed they will be incorporated
into the manual of acceptable procedures to be published prior
to promulgation of these draft rules.
     In order to offer a means by which a generator can demon-
strate that a particular listed waste is in fact not hazardous
a means of identifying hazardous wastes other than those
identified through through use of DWS is needed.
     While use of the analytical, mutagenic, and bioaccumula-
tive tests have not been included in the hazardous waste
definition for the second of the aforementioned reasons, this
is not a problem when they are used for delisting purposes.
Thus these tests are available for generators to use in demon-
strating that a particular waste, listed because the Agency
has information that it poses a hazard due to its mutagenic,
oncogenic, teratogenic, or bioaccumulative activity, or it
contains mobile toxic organics, should in fact not be listed.
(Appendix VIII).
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                             Bibliography
 1     Geraghty and Killer,  Inc.,  The .Prevalence of Suh irface
       Migration of Hazardous Chenical Substances at Selected
       Industrial Waste Land Disposal Sites,  USEPA, C\  y,  1977 -


 2.  Miller, B.K,,  F.  DeLuca and  T.  Tessier,  Ground Water
     Contamination  in  the Northewast States,  Envircnciental"
     Protection Technology  Series, EPA 660/2-74-C56, 1974


 3.    Lowenbach,  W., Compilation  and Evaluation of Leaching Test
       Methods,  May 1978, U.S. Environmental  Protection Agency,
       Cincinnati,  OE 45268, EPA-600/2-78-095
 4'^ •  tfahlock,  J.L.,  et.  al.,  Pollutant Potential of Raw and
      Chemically  Fixed Hazardous Industrial Wastes and Flue
      Gas Desulfurization Sludge,  Interim Report, July 1976,
      U.S. Environmental  Protection Agency, Cincinnati, OK,
      EPA 600/2-76/182.


 5.   Weeler, D.W., and Phillips, H.L.,  Structural  and  Leaching
      Aspects of Testing Fixed Solid Wastes Via the Toxicant
      Extraction Procedure, 1978, Oak Pidge Rational Laboratory,
      Oak Ridge, TN 37830
 6    Ham,  R.,  Anderson, K.A., Stegnann, R., Stanfcrth, R.,
      Backaround Study on the Development of a Standard
      Leaching Test, August 1978, U.S. Environmental Protec-
      tion  Agency,  Cincinnati, OH  45268
 7.  Eracon Associates,  "Sonoma County Refuse Stabilization
     Study.  Third Annual Report," Department of Public Works,
     Sonoma County,  CA  (1974)  as reported in (£) >'


 8.  Qasim,  S.R., and Burchinal, J.C.,  "Leachate from Simulated
     Landfills," Jour. Water. Fpll. Control Fed., 42 (3), 371   -
     (1970)  as reported in  CO .<                   ~~~
     45268,  EPA-GOO/2-77-18Ga as reported in (!')••
10.  Steir.er, R.L., Fungardi, A.A.,  Schoenberger, P.J., sr^
     Purdon, ?.v;., "Criteria for Sanitary Landfill Deve
     r.c-r.t,1* Public V.'orks, 102 (3), 77, (1971) as repc-ted
     ir U)

                                88

-------
      C-»or>-, T.P. ard Fiskin, P., "Chemical Quality  -• id ,
   •   Tndicator Parana ters for Monitoring Landfill Leau.i.1te
         Illinois, " Environ. Geo. 1, 329,  (1977) as reported
      in  (!')-•                      .         ._.  _____    .  .


      Pohland, F.G.,  "Sanitary Landfill Stabilization with
12-   Leachate Recycle  and  Residual  Treatment," (1975), U.S.
      Environmental Protection Agency,  Cincinnati,  OH 45268,
      EPA- 6 00/2-7 5-04 3,  as  reported  in  (l')j
      Brunner, D., 1978, Personnel Communication


       Cooperative Programme of Research on the Behaviour of
14 •    Hazardous Waste in Landfill Sites.  Final report of the
       policy Reviev; Committee, J. Sumner, Chairman, London.,
      .Her Majesty's Stationery Office, 1S78


       Patelle,  Northwest Laboratories, Toxicological Criteria
15 *    for Defining Hazardous Wastes.  Report prepared for
       Minnesota Pollution Control, Agency, .Septemoer, 1976
      Theis, T.L.,   The Contamination of Groundwater by Heavy-
16 •   Metal4 from the Land Disposal of Fly Ash , Technical
      ^rogrLs  Report, June 1, "^-August 31  1976, Prepared
    •  f or USERDA Contract * E (11-1) --2727, 197G
»•
      22S?.SiSSSS»/"^5o5i6S; SM^M as reported
    .  in  CD.-

18.   unpublished Report, 1977 (Iowa)

19.   Unpublished Report, 1977 (Gray,  Maine)

20    Report to Congress, Waste Disposal Practices and  their
      Effects on Groundwater, USEPA, OSW/OSWMP,  Jan,  1977

21.  Federal Register, Wednesday, January 12,  1977
                                 89

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22    Lee et al.   Research  Study for the Development of Iredged
      Material Disposal  Criteria.  Prepared for U.S. Anny Engineer
      Waterways Experiment  Station.  Contract £ DAG'' B9-74-C-0024
      Nov. 1975.
23.   .Hughes,  G.M., R.A. Landon and R.N. FarvoLdsn, EySro-
      geology of Solid Waste Disposal Sites in Eortheasfeera
      Illinois,  CS-EPA, SW-12d, 1971
     Perlmutter,  N.M.  and p..  Lieber, Dispersal of Plating-
     Wastes  and  Sewage Contaminants in Grour.d Water g
     Surface Water,  South Farmingdaie-Massapegua.Area
     Nassau  County,  New York,  U.S. Geological Survey
     Supply  Paper,  1979-G,  197G
25.  Le Grand, H.E., Patterns of Contaminated Zones of Water
     in the Ground, Water Resources Research, Vol. 1, Ko. 1.
     1965
26.   Sealf,  M.R., J.W. Keeley and  C.J.  La Fevers, Groendwater
      Poilution in the South• Central  States,  Environmental
      Protection Technology Series, EPA-R2-73-268, 1373
27.   Zanoni/~A.E.V Grauhdwater Pollution
      Landfills - A Critical Review


28.   Pollution Prediction Techniques for-Waste Disposal
      Siting, P.cy F. Weston, Inc., Final Report, USE2S.  "
     "Contract Number 68-01-4368, Feb, 1978
29.  Kicmiel,  G.E.  and O.C.  Braids, Preliminary Findings of a
     Leachate Study on Two  Landfills in Suffolk County> R.Y.,
     Journal  of  Research of -the U.S. Geological Siirvey, Vol. 3,
     No. 3, May-June, 1975
30'    c^fff5i\' - A;*r' , "P?H^ion of Subsurface W,
                                                      fey
31.  van.der Leeden, Frits, L.A. Cerrillo and David V7_ Killer,
     Ground Water Pollution Problems in the Northwestern
     United States Ecological Research Series, EPA 660/3-75-
     018,  1975

32.  Federal Register,  Vol.  43, No. 163 - Tuesday,  August  22, 1978
     Toxic Pollutant Effluent Standards.

33.  McNamara,  B.P.,  New Concepts in Safety Evaluation,
     1976 John Wiley and Sons, New York

                                on

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                    Appendix  I
(d)   Toxic Waste
     (1)   Definition - A solid waste is a hazardous waste
     if,  according to the methods specified in paragraph
     (2), the extract obtained from applying the Extraction
     Procedure (EP)  cited below to a representative sample
     of the waste has concentrations of a contaminant that
     exceeds any of the following values:
                           91

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                                            Extract
                                             Level ,
Contaminant                          Milligrams per Liter

Arsenic ...............................        0.50
Barium ................................       10 .
Cadmium ...............................        0.10
Chromium. ... ......... . .................       0.50
Lead ...................................       0.50
Mercury ................................       0.02
Selenium ...............................       0.10
Silver .................................       0.50
Endrin (1, 2,3,4,10,10-hexa-                   0.002
  cloro-6 , 7-epoxy-l , 4 , 4a, 5 ,
  6, 7 , 8, 8a-octahydro-l,
  4-endo, endo-5, 8-di
  methane- naphthalene) .

Lindane (1,2,3,4,5,6-                         0.040
  hexachlorocyclohexane
  gamma isomer) .

Methoxychlor (1,1,1-                          1.0
  Trichloroethane) .
  2,2-bis (p-methoxyphenyl)
Toxaphene (CioH10Cls~                         0.050
  technical chlorinated
  camphene, GT—fH} percent- jr-.
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(2)   Identification Method
     (i)   Extraction Procedure
          (A)   Take a representative sample (minimum
          size 100 gins)  of the waste to be tested and
          separate it into its component phases using
          either the filtration method or the centri-
          fugation method described in this section.
          Reserve the liquid fraction under refrigera-
          tion at 1-5°C (34-41°F)  for use as described in
          paragraph (F)  of this section.
               (I)  Filtration Method
                      Equipment:
                    Millipore YY22 142 30 filter holder
                    (Millipore Corp., Beford, MA 01730)
                    equipped with an XX42 142 08 accessory
                    1.5 liter reservoir, or
                    Nuclepore 420800 142mm filter holder
                    (Nuclepore Corp., Pleasanton, CA  94566)
                    equipped with a 1.5 liter reservoir,
                    or equivalent filter holder.
                      Procedure:
                        1.  Using the filter holder place a
                    0.45 micron filter membrane  {Millipore
                    type HAWP142, Nuclepore type 112007, or
                    equivalent) on the support screen.  On
                    top of the membrane  (upstream) place a
                    93

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prefliter (Millipore AP25124, Nuclepore
P040, or equivalent).   Secure filter
holder as directed in manufacturer's
instructions.
    2.  Fill the reservoir with the
sample to be separated, pressurize to
no more than 75 psi (7 kg/cm2),  and
filter until no significant amount
of fluid (<_5 ml) is released during a
30 minute period.
    3.  After liquid flow stops, de-
pressurize and open the top of the
reservoir, invert the filter unit, re-
place filter pads as in step 1. above,
and resume filtering.  Save pads
for later use.  Repeat this step
until no more fluid can be removed
from the waste  at a pressure of 75 psi
 (7 kg/cm2).
    4.  Take the solid material, and
any pads used in filtration, and
extract as described in paragraph  (B)  .
Subtract tare weights of  filter
pads  in calculating the amount of
solid material. -
    94

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(II)  Centrifugation Method
       Equipment:
     Centrifuge te.g.  Damon-IEC catalog no.
     7165,  Damon-IEC Corp., Needham Heights,
     MA,  or equivalent)  equipped with a
     rotor for 600 ml to 1 liter containers
     (Damon-IEC catalog no. 976, or equiva-
     lent) .  For flammable material contain-
     ing wastes, explosion proof equipment
     is recommended.
       :.£• '-•'••
       Procedure;
         1.  Centrifuge sample for 30 minutes
     at 2300 rpm.  Hold temperature at
     20-40°C   (68-104eFr.
         2.  Using a ruler, measure the size
     of the liquid and solid layers, to the
     nearest mm (0.40 inch).  Calculate the
     liquid to solid ratio.
         3.  Repeat 1 and  2 above until the
     liquid:solid ratio calculated after
     two consecutive 30 minute  centrifuga-
     tions  is  within 3%.
         4.  Decant or  siphon  off the  layers
     and extract  the  solid as  described  in
     paragraph B.
     95

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(B)   Take the solid portion obtained in para-
graph (i)/ and prepare it for extraction
by either grinding it to pass through a
9.5 mm (3/8") standard sieve or by subjecting
it to the following structural integrity
procedure.
       Structural Integrity Procedure
            Equipment;
          Compaction Tester having a 1.25 inch
          diameter hammer weighing 0.73 Ibs. and
          having a free fall of 6 inches (Figure  1)
           Cone suitable device is the Associated
          Design and Manufacturing Company,
          Alexandria, Va. 22314, catalog no. 125).
             Procedure;
              1.  Fill the sample holder with the
          material to be tested.  If the waste
           sample  is a monolithic block/ then cut
           out a representive  sample from the block
           having  the dimensions of  a 1.3" dia.
           X 2.8"  cylinder.
              2.  Place  the  sample  holder into  the
           Compaction Tester  and apply  15 hammer
           blows to the  sample,
              3.   Remove the now compacted  sample
           from  the sample  holder and  transfer it to
           the extraction apparatus  for extraction.

              96

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(C)  Take the solid material from paragraph  (B),
weigh it and place it in an extractor.  A suitable
extractor will not only prevent stratification  of
sample and extraction fluid but also insure that
all sample surfaces are continuously brought
into contact with well mixed extraction fluid.
(When operated at greater than or equal to
40 rpm, one suitable device is shown in
Figure 2 and available as Part *3736 produced
by the Associated Design and Mfg. Co.,
Alexandria, VA  22314.)
(D)  Add to the extractor a weight of
deionized water equal to 16 times the weight
of solid material added to the extractor.  This
includes any water used in transferring the
solid material to the extractor.
(E)  Begin agitation and adjust the pH of the
solution to 5.0 + 0.2 using 0.5N acetic acid.
Hold the pH at 5.0 + 0.2 and continue agitation
for 24 j^ 0.5 hours.  If more than 4 ml of acid
for each gm of solid is required to hold the
pH at 5, then once 4 ml of acid per gm has been
added, complete the 24 hour extraction without
adding any additional acid.  Maintain the
extractant at 20-40°C (68-104°F) during
extraction,  it is recommended that a device
            97

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such, as the Type 45-A pH Controller manufac-
tured by Chemtrix, Inc./  Hillsboro, OR 97123,
or equivalent, be used for controlling pH.
If such a device is not available  then the
following manual procedure can be  employed.
     Manual pH adjustment
       1.  Calibrate pH meter in accordance  with
     manufacturer's specifications.
       2.  Add 0.5N acetic acid and adjust
     pH of solution to 5.0 + 0.2.   If more  than
     4 ml of acid for each gm of solid is
     required to hold the pH at 5, then once
     4 ml of acid per gm has been  added, complete
     the 24 hour extraction without adding  any
     additional acid.  Maintain the extractant
     at 20-40°C  (68-104°F) during  extraction.
       3.  Manually adjust pH of solution at
     15, 30, and 60 minute intervals  moving
     to the next longer interval if the pH
     did not have to be adjusted more than
     0.5 pE units since the previous  adjustment.
       4.  Continue adjustment procedure for  a
     period of not less than 6 hours.
       5.  Final pH after a 24 hour period
     must be within the range 4.9-5.2; unless
     4 ml of  acid per gram of solid has
     already  been  added.
                98

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                 6.   If the conditions of 5 are not met,
               continue pH adjustment at approximately
               one hour intervals for a period of not
               less than 4 hours.
     (F)   At the end of the 24 hour extraction period,
     separate the material in the extractor into
     solid and liquid phases as in paragraph  (A).
     Adjust the volume of the resulting liquid phase
     with deionized water so that its volume  is
     20 times that occupied by a quantity of  water
     at 4°C equal in weight to the initial quantity
     of solid material charged to the extractor
     (e.g., for an initial weight of 1 gin, dilute
     to 20 ml).  Combine this solution with the
     original liquid phase from paragraph  (A).
     This combined liquid/ and any precipitate which
     may later form, is the Extraction Procedure
     Extract*
(ii) Analysis - Analyses conducted to determine
conformance with Section 250.13(d)(1) shall be
made in accordance with the following or equivalent
methods:
     (A)  Arsenic - Atomic Absorption Method,
     "Methods for Chemical Analysis of Water  and
     Wastes," pp. 95-96, Environmental Protection
     Agency, Office of Technology Transfer,
     Washington, D.C.  20460, 1974.
                  99

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(B)  Barium - Atomic Absorption Method/
"Standard Methods for the Examination of
Water and Wastewater," latest edition,
or "Methods for Chemical Analysis of Water
and Wastes," pp. 97-98, Environmental
Protection Agency, Office of Technology
Transfer/ Washington, D.C.  20460, 1974.
(C)  Cadmium - Atomic Absorption Method,
"Standard Methods for the Examination of
Water and Wastewater," latest edition, or
"Methods for Chemical Analysis of Water and
Wastes," pp. 101-103, Environmental Protection
Agency, Office of Technology Transfer,
Washington, B.C.  20460, 1974.
(D)  Chromium - Atomic Absorption Method,"— —>
"Standard Methods for the Examination of Water
and Wastewater," latest edition, or "Methods
for Chemical Analysis of Water and Wastes,"
pp. 112-113, Environmental Protection Agency,
Office of Technology Transfer, Washington,
D.C.  20460, 1974
(E)  Lead - Atomic Absorption Method, "Standard
Methods for the Examination of Water and
Wastewater," latest edition, or "Methods
for Chemical Analysis of Water and Wastes,"
pp. 112-113, Environmental Protection Agency,
Office of Technology Transfer, Washington,
D.C.  20460, 1974.
               100

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(Fl  Mercury - Flameless Atomic Absorption
Method/ "Methods for Chemical Analysis of
Water and Wastes," pp. 118-126, Environmental
Protection Agency, Office of Technology Transfer,
Washington, D.C.  20460.
(G)  Selenium - Atomic Absorption Method,
"Methods for Chemical Analysis of Water and
Wastes," p. 145, Environmental Protection
Agency, Office of Technology Transfer,
Washington, D.C.  20460, 1974.
(H)  Silver - Atomic Absorption Method,
"Standard Method for the Examination of
Water and Wastewater," latest edition, or
"Methods for Chemical Analysis of Water and
Wastes," p. 146, Environmental Protection
Agency, Office of Technology Transfer,
Washington, D.C.  20460, 1974.
(I)  Endrin, Lindane, Methoxychlor, or
Toxaphene - as described in "Method for
Organochlorine Pesticides  in industrial
Effluents," MDQARL, Environmental Protection
Agency, Cincinnati, Ohio,  November 28, 1973.
 (J)  2, 4-D and  2,  4,5-TP  Silvex - as described
in "Methods for  Chlorinated Phenoxy Acid
Herbicides in Industrial Effluents," MDQAEL,
Environmental Protection Agency, Cincinnati,
Ohio,  November  28,  1973.

              101

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                         Appendix u .

     A solid waste is a hazardous waste if the extract obtained
from applying the "toxicant extraction procedure"  to a repre-
sentative sample of the waste has any of the following proper-
ties, according to the following test protocol.
     (1)   Contains more than one mg/liter of any compound
     on the Controlled Substances List in Appendix IVI or
     gives a positive response in any one of a set of required
     tests for mutagenic activity.  A total of three assays
     must be conducted.  One shall be chosen from group I,
     one from group II, and one from those listed in group
     III.
          Group I   Detection of gene mutations
                    1.  Point mutation in bacteria.
         Group II   Detection of gene mutations
                    1.  Mammalian somatic cells in
                    culture.
                    2.  Fungal microorganisms.
        Group III   Detecting effects of DNA repair or
                    recombination as an indication of
                    genetic damage
                    1.  DNA repair in bacteria (including
                    differential killing of repair
                    defective strains).
                    2.  Unscheduled DNA synthesis in human
                    diploid cells.
                              102

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                      3.  Sister-chromatid exchange in
                      mammalian cells.
                      4.  Mitotic recombination and/or gene
                      conversion in yeast.
     A result shall be considered positive for the mutagenic
activity assays if a ' .reproducible increase is observed over
negative control in the yeast and mammalian cell assays.  A
result shall be considered positive for the DNA repair
assay in bacteria if a reproducible difference in killing is
observed between the DNA repair-competent and DNA repair-
deficient strains.
                              103

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                Mutagenic Activity Detection

Group I - DETECTION OF GENS MUTATIONS

a.   Point Mutations in Bacteria

1.   Positive Controls
     All assays must be run with a concurrent positive control.
Positive control compounds or mixtures shall be selected to
demonstrate both the sensitivity of the indicator organism and
the functioning of the metabolic activation system.

2.   Negative controls
     A solvent negative control shall be included.

3.   Choice of Organisms
     The bacteria used shall include strains capable of detecting
base pair substitutions (both transitions and transversions)
and frame-shift mutations.  The known spectrum of chemical
mutagens capable of being detected by the strains shall be
considered when selecting the strains.  The strains  shall also
be highly sensitive to a wide range of chemical mutagens.
They may include strains whose cell wall, DMA repair,  or other
capabilities have been altered to increase sensitivity (Ames,
1975; McCann et al./ 1975).  Although sensitive bacterial
assays for forward mutations at specific loci or over some
portion of the entire genome may also be appropriate,  at
the present time the most sensitive and best-characterized
bacteria for _mutagenidty__testing are those capable  of
indicating reverse mutations at specific loci.

4.   Methodology

     (i)  General.  The test shall be performed in all respects
in a manner known to give positive results for a wide ranoe
of chemical mutagens at low concentrations.  Tests must be run
with and without metabolic activation.  The sensitivity
and reproducibility of the metabolic activation systems and
strains used shall be evaluated both by reference to past work
with the method and by the concurrent use of positive controls
     (ii)  Plate assays.  In general, the EP extract should
be tested by plate incorporation assays at various concentrations
Test conditions should minimize the possible effects due to
extraneous nutrients, contamination by other bacteria, and
high levels of spontaneous mutants.
     (iii)  Liquid suspension assays.  A few chemicals (e.g.
diethylnitrosamine and demethylnitrosamine) will give positive
results only in tests in which the test substance, the bacteria
and the metabolic activation system are incubated together in   '
liquid prior to plating, but not in a plate incorporation assav
(Bartsch et al., 1976).  Thus, tests shall be conducted in
liquid suspension as well as on agar plates.
     (iv)  Doses.  The highest test dose which does  not result
in excessive cell death shall be used.

                              104

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Group II - DETECTION OF GENE MUTATIONS

a.   Mammalian Somatic Cells In Culture

     1.   Choice of cell systems.
     A number or tests in mammalian somatic cells in culture
are available in which specific locus effects may be detected in
response to chemical exposure  (Shapiro et al. , 1972; Chu, 1971).
The cell line used shall have demonstrated sensitivity of chemical
induction of specific-locus mutations by a variety of chemicals.
The line shall be chosen for ease of cultivation, freedom from
biological contaminants such as mycoplasmas, high and reproducible
cloning efficiencies, definition of genetic detection, loci, and
relative karyotypic stability.  The inhirent capabilities of the
test cells for metabolic activation of promutagens to active
mutagens shall also be considered, as, well as the use of metabolic
activation systems similar to those used with microorganisms.
     2.   Methodology.
      (i)  General"The test shall be performed in all respects
in a manner known to give positive results for a wide range of
chemical mutagens.  The sensitivity of the system, metabolic
activation capability, and its reproducibility must be evaluated
by reference to past work and by the concurrent use of positive
controls.  Culture conditions which may affect the detection of
mutations and give falsely high or low figures for reasons
other than chemical induction shall be avoided.  Definition of
detected genetic loci studies and verification that the observed
phenotypic changes are indeed genetic alterations should be
presented.                                                        ,

b.   Mutation In Fungi

     1.   Controls
     All considerations discussed under Group I, a. are
applicable.
     2.   Choice of Organisms
     The fungi used shall include strains capable of detecting
base pair substitutions (both transitions and transversions)
and frame-shift mutations.  More inclusive assay systems, such
as those designed to detect recessive lethals, are also accept-
able.  The known spectrum of chemical mutagens capable of being
detected by the strains shall be considered when selecting the
strains.  The strains shall also be highly sensitive to a wide
range of chemical mutagens.  Strains altered in DMA repair or
other capabilities with the intent to increase sensitivity may
be used, subsequent to validation.  Either forward or reverse
mutation assays may be applied.
     3.   Methodology
      (i)  General;  All considerations discussed under Group I
af 4,  (i) are applicable.  Care should be taken to investigate
stage sensitivity, i.e. replicating versus non-replicating cells
as well as possible requirement for post-treatment growth.
      (ii) Plate Assays;  While spot tests and plate incorporation
assays are useful for preliminary testing, they shall not be
considered conclusive.


                              105

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Group III - DETECTING EFFECTS ON DNA REPAIR OR RECOMBINATION AS AN

     INDICATION OF GENETIC DAMAGE

a.   DNA Repair In Bacteria

     1.    Controls
     All considerations discussed under Group I are applicable.
     2.   General
     (i)  When the DNA of a cell is damaged by a chemical mutagen,
the cell will utilize its DNA repair enzymes in an attempt to
correct the damage.  Cells which have reduced capability of
repairing DNA may be more susceptible to the action of chemical
mutagens, as detected by increased cell death rates.   For
suspension tests using DNA repair-deficient bacteria,  the
positive control should be similar in toxicity to the  test
mixture.
     (ii)  The DNA repair test in bacteria determine if the
test substance(s) is more toxic to DNA repair-deficient cells
than it is to DNA repair-competent cells.  Such differential
toxicity is taken as an indication that the chemical interacts
with the DMA of the exposed cells to produce increased levels
of genetic damage.
     3,   Choice of organisms
     Two bacterial strains, with no known genetic differences
other than DNA repair capability/ shall be used.  The  strains
selected shall be known to be capable of indicating the activity
of a wide range of chemical mutagens.  The spectrum of chemical
mutagens and chemical mixtures capable of being detected by the
strains and procedures used shall be reported.
     4.   Methodology
     (i)  Plate test   The EP extract should be tested by
spotting a quantity on an agar plate which has had a lawn of the
indicator organisms spread over it.  After a suitable  incubation
period, the zone of inhibition around the spot shall be measured
for each strain and compared for the DNA repair-competent and DNA
repair-deficient strains.  If no discrete zone of inhibition is
seen with either strain/ then the results of the tests are not
meaningful.
     (ii)  Liquid suspension test.  The liquid suspension test
shall also be performed by comparing the rates at which given
concentrations of the test substances will kill each of the two
indicator strains when incubated in liquid suspension.  Conditions
should be adjusted so that significant killing of the  DNA repair-
competent strain occurs, if this is possible.  Methodology is
discussed in Kelly et 
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      (iii)  Doses.  The dose level of test substances used in
the plate or suspension test shall be adjusted so that signifi-
cant  toxicity to the DNA repair-competent strain is measured.
In the plate test, this means that a zone of inhibition must
be visible; in the suspension test/ significant loss of cell
viability must be measured.  This may not be possible if the
test  substance is not toxic to the bacteria or if, 'in the plate
test/ it does not dissolve in and diffuse through the agar.
The same dose must be used in exposing the DNA repair-competent
and repair-deficient strains.
                           107

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b.   Unscheduled DNA Synthesis In Human Diploid Cells

     1.   General
     DNA damage induced by chemical treatment of a  cell  can be
measured as an increase in unscheduled DNA synthesis which
is an indication of increased DNA repair.   Unrepaired  or
misrepaired alterations may result in gene mutations or  in
breaks or exchanges which can lead to deletion and/or  duplication
of larger gene sequences or to translocaticns which may  affect
gene function by position effects (Stich,  1970; Stoltz et al. ,
1974).
     2..   Methodology
      (i)   General"Primary or established cell cultures
with normal repair function shall be used.  Standardized human
cell strains from repositories are recommended.  Controls should
be performed to detect changes in scheduled DNA synthesis at
appropriate sections in the experimental design. The  media
conditions shall be optimal for measuring repair synthesis.
      (ii) Dose.  At least five dose levels shall be used and
the time in the cycle of cynchronour or non-proliferating
cells at which explosure takes place shall be given.   The
maximum compound dose shall induce toxicity, and the dosing
period with the test substance shall not be less than  sixty
minutes.

c.   Sister Chromatid Exchange In Mammalian Cells With And  Without

     Metabolic Activation

     1.   Controls;	  -•• --
     All considerations discussed under Group I a.  are
applicable.
     2.   General
     Cytological techniques are available to evaluate  the genetic
damage induced by chemicals.  In the past few years a technique
has been developed  for  identifying  sister chromatid exchanges
much  more  simply  and efficiently  than by  the  autoradiographic
method.  The  method utilizes  the  fact  that  a fluorescent stain
Hoechst 33258 binds to thymidine-containing DNA but not, or
 far less efficiently,  to BrdUrd-substituted DNA.   This  means  that
 the order of fluorescence would be brightest for DNA  unreplicated i»
 BrdUrd, intermediate for DNA after one round of replication in
 BrdUrd, and least for DNA following two rounds of  replication in
 BrdUrd.  Thus a sister chromatid exchange can be seen as a switch
 of fluorescence pattern at the point of exchange.  Perry and Tftjlff
  (Nature 251, 156-158 (1974))  combined Hoechst staining  with Gierosa
 staining such that the brightly fluorescing regions stain  darkly
 with Giemsa, and the dully fluorescent regions hardly stain
 at all.
       3.   Choice of Organisms
      Chromosomal preparations of human peripheral  blood leukocytes
 or Chinese hamster ovary cells shall be used.
                             108

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     4.   Methodology
     (i)  General";  The test method must be capable of  detecting
sister chromatic! exchanges.  Procedures reported by Perry  and
Wolff  (Nature 251, 156-158  (1974) and Moorhead et  al.   (Exp. cell
Res. 20, 613-616  (I960)) are recommended.  Metabolic  activation
with rat liver S-9 mix should be incorporated whenever  it  is
appropriate.
     (ii) Doses;  Test substances shall be tested  to  the highest
dose where toxicity does not interfere with the test  procedure.
                           109

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d.   Mitotic Recombination and/or Gene Conversion In Yeast

     1.   Controls
     All considerations discussed under Group I are applicable.
     2,   General
     One can effectively study the chromosomes of eukaryotic
microorganisms by employing classical genetic methodologies
which depend upon the behavior and interaction of specific
markers spaced judiciously within the genome.  These methods
have been developed over several decades and have been applied
in recent years to the study of induced genetic damage
(Zimmerman, 1971, 1973/ 1975; Brusick and Andrews, 1974).
     3.   Choice of organisms
     Diploid strains of yeasts that detect mitotic crossing-
over and/or mitotic gene conversion shall be used.  Additionally
as appropriate strains are developed, monitoring for induced
non-disjunction and other effects may be possible.  Mitotic
crossing-over shall be detected in a strain of organism in
which it is possible, by genetic means, to determine with
reasonable certainty that reciprocal exchange of genetic
information has occurred.
     Strains employed for genetic testing shall be of proven
sensitivity to a wide range of mutagens.
     4.   Methodology^
     (i)  General.
     In general/ wastes shall be tested in liquid suspension
tests.
                            110

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                         Appendix  in

                  Controlled Substance List

NOTE:  Compounds and classes which have been reported to be
either mutagenic, carcinogenic, or teratogenic and which would
not give a positive indication of activity using the prescribed
tests.  Where a class of compounds is listed, inclusion on this
list does not mean that all members of the class have been shown
to be either mutagenic, carcinogenic, or teratogenic.  Demon-
stration that specific, class members contained in the waste
have not been shown to be either mutagenic, carcinogenic, or
teratogenic/ will be sufficient for a demonstration of non-
hazard by reason of mutagenic activity (M).

                    Aloperidin
                    Amantadine
                  4-Aminoantipyrin acetamide
                    Aminopterin
                  3-Amino-l,2,4-triazole
                  6-Azauridine
                    Azo dyes
                    Benzene
                    Bisulfan
                    Carbon tetrachloride
                    Chloroquine
                    Chlorambucil
                    Cobalt salts
                    Colchicine
                    Coumarin derivatives
                    Cycasin
                    Cyclophosophamide
                    Dextroamphetamine sulfate
                    Diazepam (Valium)
                    Diethylstilbesterol
                    D ime thy 1 ami no a zob e n ze ne
                    DimethyInitrosamine
                    Diphenylhydantoin
                    Ethionine
                    Grisefulvin
                  1-Hydroxysafrole
                    Maleic Hydrazide
                    Methotrexate
                    Methylthiouracil
                    Mytomycin-C
                  d-Penicillamine
                    Phenylalanine
                    Phorbol esters
                    Quinine
                    Resperine
                  p-Rosanilin
                    Safrole
                    Serotonin
                    Streptomycin
                    Testosterone
                    Thioacetamide thiourea
                    Trimethadione
                  d-Tubocurarine


                              111

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                   Appendix  IV
          Bioaccumulation Potential Test
 (a)  General
Reverse-phase liquid chromatography is a separation process
in which chemicals are injected onto a column of fine
particles coated with a nonpolar (water insoluble)  oil and
then eluted along the column with a polar solvent such as
water or methar.ol.  Recent developments in this field have
produced a permanently bonded reverse-phase column in which
long-chain hydrocarbon groups are chemically bonded to the
column packing material which leads to a more reproducible
separation.  The chemicals injected are moved along the
column by partitioning between the mobile water phase and
the stationary hydrocarbon phase.  Mixtures of chemicals can
be eluted in _order_of, tbeix^hydrophobicity,.,. with.vate resoluble
chemicals eluted first and the oil soluble chemicals last
in proportion to their hydrocarbon/water partition coeffici
Calibration of the instrument using compounds of known oc-t    1'
water partition coefficient allows  this procedure to be u
to determine whether an unknown mixture contains compound
with octanol/water partition coefficients above a designat
level.
Specific correlations exist between octanol/water partiti
coefficients and bioconcentration in fish.   This test thu
offers a rapid, inexpensive method of identifying those
mixtures which contain compounds which pose a potential
bioaccurr.ulative hazard.
                     112

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Compounds with log P 3.5, but which readily biodegrade
would not be expected to persist in the environment long
enough for accumulation to occur.  Thus a degradation
option has been included in order to exempt these sub-
stances from the hazardous waste control system.

(b)  Chromatography Conditions
A liquid chromatograph equipped with a high pressure
stopflow injector and a 254 nm ultraviolet detector with
an 8 ul cell volume and 1 cm path length is employed. The
column is a Varian Preparative Micropak C-H (Catalog number
07-000181-00), or its equivalent, consisting of a 250 mm
X 8 mm (i.d.) stainless steel cylinder filled with 10
micron lichrosorb to which octadecylsilane is permanently
bonded.
The column is operated at ambient temperature.  The solvent
consists of a mixture of water and methanol (15:85, v/v)
which is pumped through the column at 2.0 ml/minute.

(c)  Retention Volume Calibration
Chemicals are dissolved in a mixture of acetone and cyclohexane
(3:1, v/v).  For preparing the calibration curve the quantity
of individual chemicals in the solution is adjusted to give
a chromatographic peak of at least 25 percent of the recorder
scale.  Acetone produces a large peak at approximately 2.6
minutes.
                        113

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Six chemicals for which Log P has been reported are used
to calibrate the elution time in units of Log P.   The
calibration mixture is summarized in Table 1 and includes
benzene/ bromobenzene, biphenyl, bibenzyl, p,pf-DDE, and
2,4,5,2',5'-pentachlorobipheny1.

(d)  Sensitivity Calibration
The mixture is chromatographed and a calibration curve prepared
daily to eliminate small differences due to flow rate or
temperature and to follow the retention properties of the
column during prolonged use.  The calibration is made by
plotting Log P vs the logarithm of the absolute retention
time (log RT).  Figure 1 is an example of such a calibration
curve.

(e)  Test Procedure
     (1)  Prepare a calibration curve as described above.
     (2)  Calculate the geometric mean of the instrumental
          response to the chemicals listed in Table 1 with
          the exception of the acetone.  This value, expressed
          in ug/25% full scale deflection, is designated
          the Instrumental Sensitivity  (IS).
      (3)  Extract X liters of the Extraction Procedure
          extract to be tested, using dichloroir.ethane,
          and concentrate the extract to a quantity
          suitable for•injection onto the column.
                        114

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               The quantity X is determined by the instrumental



               sensitivity and is given by the relationship:



               X in liters = IS in raicrograms.



           (4)  Analyze the extract using the now calibrated



               chromatograph.  A positive response is defined as



               an instrumental response greater than or equal to



               25 percent full scale detector response in the



               region of Log P greater than or equal to 3.5.



           (5)  If a positive response is indicated in step  (4),



               then subject a sample of the waste to a biode-



               gradation assay and then retest.  If a positive



               response with the degraded waste is not obtained,



               then the waste is not considered to be hazardous by



               reason of bioaccumulativeness.





                           TABLE I



Partition Coefficients for Chemicals Used for Calibration



                                             Log P



     Acetone                                 0.55



     Benzene                                 2.13



     Bromobensene                            2.99



     Biphenyl                                3.76



     Eibenzyl  •                              4.81



     p,p''-EDE                                5.69



     2,4, 5,2',5'-Pentachlorobipheny1         6.11
                           115

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    7.or
                                Figure 1
    6.0
    S.O
 O
 c
 CD
+*
 O
O
4.0 -
                                        O PCS (5-C1)


                                       DDE
                                       Bibenzyl
O /Biphenyl
 03
 O
     3.0
    2.0
                          Bromobeozene
                      O/ Benzene
     1.0
                  O Acetone
                      J	L
                                1.0
                    Log Retention Time (minutes)
                                                    2.0
                            116

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                          Appendix  v
     Test procedures for biodegration are designed to rapidly
estimate the relative importance of biodegradability as a
persistence factor in natural environments.  The tests evaluate
biodegradation rates in comparison with standard reference
compounds.
     Methods commonly used include a shake flask procedure
that follows the loss of dissolved organic carbon  (DOC) using
organic carbon analysis, a respirometric method with analysis
for either oxygen uptake or carbon dioxide evolution resulting
from microbial activity/ and an activated sludge test.
     One shake flask procedure acceptable for use in the screen-
ing test for biodegradability is based on the Presumptive Test
of the Soap and Detergent Association (1965) and the Modified
OECD Screening Test  (1971).
     The shake flask method is conducted in a mineral salts
basal medium with a weak inoculum and relatively low test
substrate concentration and serves as a simple model of surface
water.  The determination of biodegradation is made by measuring
the loss of bioaccumulative response adter allowing degradation
to proceed for 21 days.
     Poorly soluble and insoluble materials present special
problems in biodegradability tests.  Insoluble materials should
be dispersed into the systems using a minimal volume of organic
solvent if solvent is necessary.
                           117

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      (. a) Method Description


     Microorganisms are inoculated into flasks that contain


a well-defined microbial growth medium  (basal medium) and the


test compound.  Aeration is accomplished by continuous shaking


of the flask.  Following four adaptive transfers, biodegra-


dation is determined by measuring the reduction  (if any) in
                V.

concentration of bioaccumulative species at the end of the test:

period.


      ( b) Basal Medium


     The composition of the basal medium shall be as follows.

     o Water:  High-quality (ASTM Type II or better, ASTM,


1974) water, from a block tin or an all-glass still, containing

less than 1 mg/1 total organic carbon (TOG).


       Phosphate Buffer Solution:  Dissolve 8.5 g potassium


dihydrogen phosphate, KK^PC^;  21.75 g dipotassium hydrogen

phosphate, K2HPC>4; 33.4 g disodium hydrogen phosphate


heptahydrate, Na2HP04*7H20; and 10 g ammonium chloride,


NH4C1, in about 500 ml of distilled water and dilute to 1 1.


       Magesium sulfate solution:  Dissolve 22.5 g MgS04*7H2O

in distilled water and dilute to 1 1.


       Calcium Chloride Solution:  Dissolve 27.5 g anhydrous

Cacl2 in distilled water and dilute to 1 1.


       Ferric Chloride Solution:  Dissolve 0.25 g FeCl3*6H2o

in distilled water and dilute to 1 1.
                          118

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       Trace Element Solution:  Dissolve 39.9 mg
57.2 mg H3B03/ 42.8 mg ZnS04'7H2O and 34.7 mg (NH4)6Mo7024
in distilled water and dilute to 1 1.
       Yeast Extract Solution:  Dissolve 15 mg of Difco yeast
extract in 100 ml distilled water.  Prepare immediately
before use.
       To each liter of water add 1 ml of each above solution
except the yeast extract solution.  Dispense in 500 ml or
1000 ml portions into 1-liter or 2-liter narrow mouth
Erlenmeyer flasks.  Stopper the flasks with cotton plugs or
the eqivalent to reduce evaporation and contamination.  Flasks
and contents that will not be used on the day of preparation
shall be sterilized by autoclaving at 120°C for 20 minutes.
Immediately before use, 1 ml of yeast extract solution shall
be added to each flask.
      ( c) Microbial Culture
     The microbial culture used as the initial inoculum shall
be prepared as follows:
       Secondary Effluent Culture:  Obtain a sample of
secondary effluent of good quality from a sewage treatment
plant dealing with a predominantly domestic sewage.  Filter
through a glass wool pad.  Retain the filtrate.
       Soil Culture:  Obtain 100 g of garden soil  (not sterile)
                   l,ter
and suspend it in 1 /s of chlorine-free tap water.  Do not
sue soils that are largely clay, sand, or humus.  Stir the
suspension to thoroughly mix the contents and to break up
any clumps.  Allow thesolids to settle for 30 minutes.
                             119

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Filter through a glass wool pad.  Retail the filtrate.
       Mixed Culture Inoculum:  Mix 100 ml of secondary
effluent filtrate with 50 ml of soil suspension filtrate and
use to inculate the shake flasks within 24 hours of the time
of collection of the secondary effluent and soil.
     ( d) Linear Alkylate Sulfonate (LAS);  Obtain a sample
                                  t:,
of LAS (Standard LAS may be obtained from the U.S. Environ-
mental Protection Agency; Environmental Monitoring and
Support Laboratory; Cincinnati/ Ohio  45268.) or n-dodecyl
benzene sulfonate, sodium salt.  Based on the percent of
active LAS in the sample, calculate the quantity required to
provide 25mg of organic carbon.  For 100% sodium n-dodecyl
benzene sulfonate this value is 40.3 mg.
     ( e) Test Mixture;  Calculate the quantity of test
mixture which will supply 25 mg of organic carbon.  If the
test mixture is readily soluble in water,  it may be more
convenient to prepare a solution in distilled water con-
taining 25 mg of organic carbon per ml of solution.
     ( f) Procedure;
     A.   Add sufficient test compound  (or a solution as
described above) to a test flask, containing basal medium, so
that the test compound provides 25 mg of organic carbon per
liter of basal medium.
     B.   Add sufficient LAS to a control flask to provide 25  mg
of organic carbon per liter of basal medium.
                          120

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     C.   Using the mixed microbial inoculum, inoculate flask
with 1 ml of inoculum per liter of basal medium.
     D.   Place the flask on a reciprocating shaker operating
at about 128 two-to four-inch strokes per minute or, a
gyratory shaker operating at 225 to 250 one-to two-inch re-
volutions per minute.  Incubate in the dark at 22±.3°C.
     E.   Adaptation:  The first flask  (as described above)
normally will be prepared on a Tuesday.  Adaptive transfers
shall be made on the following Friday and again on Monday,
Wednesday, and Friday of the following week.  This schedule
is set up for the convenience of laboratories not operating
on weekends.  On each transfer day, transfer 1 ml of the 48-
to 72-hour culture into each liter of fresh basal medium,
plus test compound, and basal medium plus reference compound.
     Growth of culture within each flask will-be-Indicated	—
by an increasingly hazy or cloudy appearance in the liquid
medium and also may be indicated by the deposit of microbial
cellular matter along the upper walls of the shake flasks,
at the "high water" mark.  If the test medium stays clear in
the test mixture flask, this may indicate that the test
compound is present at a toxic or an inhibitory concentration.
In this case, the test procedures should be restarted with
the test compound at a lower concentration.  If both the
test compound and control flasks remain unclouded, it may
indicate a defective inoculum or the possibility that "some
other toxic material was introduced inadvertently.
                          121

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     F.   On the thirteenth day following the initial inoculation,
and approximately 72 hours after the final adaptive transfer,
another transfer shall be made into the test flasks.  The
procedure is the same as for the adaptive transfers, except
that there now will be duplicate preparations for controls
and test flasks.  There also will be two flasks with basal
medium plus test compound but with no inoculum.
     G.   Following the transfer of inoculum from blank to blanks
and test flask to test flask, the flasks shall be incubated
for 21 days.  At the end of the incubation period the contents
of the blank and test flask shall be analyzed.
     H.   Homogenize the material in the flask to be analyzed
and remove an aligust sufficient to contain the same amount of
waste extract as used in the original evaluation of the waste
using the partition coefficient-test.•- 	
     I.   Evaluate the sample as described in the Bioaccumulation
Potential Test  Appendix IV    If a positive result is obtained
then the waste is considered to be a hazardous waste.  If after
analyzing the blanks, a positive result in the BPT is not
obtained then the assay for persistence is invalid and must be
rerun.
                            122

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                      Appendix VI
           Daphnia Magna Reproduction Assay

(a)   Method
     (1)   Tests are run at only one dilution of the neutralized
          extract.
     (2)   First instar £. magna,  12 hours + 12 hours old are
          utilized.
     (3)   One D.  magna is placed  in 50 ml of extract solution
          in a 100 ml glass beaker with a watch glass.
     (4)   Temperature is maintained at 20.0 + 0.5°C in an
          environmental chamber under 12-hour light/dark
          lighting regime.
     (5)   Dilution water is either filtered spring or well
          water (pH 7.8; alkalinity, 119 mg/1; hardness, 140
          mg/1).
     (6)   All tests are run with ten replicates, and a set
          of ten controls.  Test  organisms are transferred
          to freshly prepared test solution in clear beakers
             •
          and fed two ml of prepared food every Monday, Wednesday,
          and Friday, and the number of young in each beaker
          are counted.
     (7)   Test duration is 28 days or until all animals have
          died,  whichever comes first.
(b)   Handling
     (1)   Organisms should be handled as little as possible.
                             123

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      (2)  Smooth glass tubes with rubber bulbs should be used
          for transferring daphnids.
      (3)  Food should be added to freshly prepared test
          solution in 100 ml beakers before animals are
          transferred.
 (c)  Food
      (1)  Food mixture of 1 mg/ml per animal used.
      (2)  1 mg/ml preparation:
          (i)       Enough Ralston Purina Micro-Mixed Trout
                    Chow is ground and then mixed at high
                    speed with distilled water in a blender
                    to produce 10 mg/ml concentration.
          (ii)       The mixture is then screened to remove
                    unground particles, and refrigerated.
          (iii)      The mixture is diluted with distilled
                    water to 1 mg/ml when needed.
 (d)  Results
     Comment is specifically requested concerning what bio-
logical measures to use in defining a significant change
             •
             't '
growth or reproduction.  Currently under study are the
following indicators:
     1.   Average survival time during test period (days) .
     2.   Average age at first brood release (days).
     3.   Average number of broods of young per adult.
     4.   Average number of young produced per adult.
     5.   Average number of young per brood.
                          124

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                      Appendix  vil
               Terrestrial Plant Assays
(a)   Seed Germination Bioassay Protocol
     (1)   Seeds (radish,  Raphanus sativus 'Early Scarlet Globe1)
          sieved to reduce germination and growth variability.
          Mesh size:  2.36 mm, 2.00  mm, 1.70 mm (U.S.A. stand-
          ard testing sieves).  One  size category used per
          bioassay.
     (2)   100 ml extract  solution diluted 1:10 put in chamber
          (Figure 2), blotter paper  placed upright to absorb
          solution.
     (3)   150 radish seeds placed in position; saturated paper
          laid over them  and gently  pressed until impression
          seen.
     (4)   Second Plexiglas sheet positioned so seeds and
          blotter paper sandwiched between;  Plexiglas taped
          securely on sides and top  (see Figure 2).
     (5)   Unit then put in germination chamber.
     (6)   Environmental chamber (temperature 25* C, no ilium-
             *'
          ination) houses germination chamber for 48 hrs.
     (7)   Length of hypocotyl measure after incubation.
     (8)   Standard T-test used to compare dosed seeds to
          control.
                           125

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(b)   Seedling Growth Study Protocols
     (1)   Seedling growth studies  are  run using wheat
          (Triticum aestivum)  and  soybean  (Glycine max) .
     (2)   The seeds are  soaked for approximately 3 hours  in
          deionized water.
     (3)   200 ml  of soluble plant  food with trace elements
          (1  tblsp per gal  water)  is added to approximately
          one liter of sand (acid-washed quartz sand to pass
          60  mesh sieve,  leached by triple rinse in distilled
          water)  in which the  seeds are planted, 25 soybean
          and 50  wheat seeds per container.
     (4)   When the seeds  have  sprouted (about 72 hrs) the
          extract diluted 1:10 is  added in droplets.  Constant
          pressure is applied  via  compressed air tank to  test:
          solution in a plastic bottle.  Solution is forced
          through tygon tubing to  a polyethylene nozzle
          (inverted buchner funnel) .   The volume is regulated
          with a  screw clamp adjusted  to a flow rate of 6
          ml/sec.   This design is  simple and disposable or
          acid washable in  order to assure ready availability
          of  component parts which are easily cleaned between
          test runs.
     (5)   Seedlings are exposed daily  to a dose sufficient
          to  restore loss by evapotranspiration.
                          126

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      (6)  At the end of 2 weeks of exposure, plants are
          harvested and the following parameters are measured:
          (i)       root biomass
          (ii)      shoot biomass
          (iii)     gross pathology  (i.e., necrosis, chlorosis)
(c)  Results
     Comments are specifically requested concerning the sig-
nificance of these indicators as measures of damage.
                         127

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 Figure 2
                            COVER
                           INDENTATION
                           FOR SEEDS
                           SEED
                           BLOTTER PAPER
                           PLEXIGLAS
                           PLEXIGLAS
                           TROUGH
                           LEACHATE
128

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                     Appendix VIII
             Demonstration of Non-Inclusion  in  the
             Hazardous Waste System

 (a)  Any person wishing to demonstrate to  EPA that  a solid
waste from an individual facility, whose waste  is listed in
Section 250.14(a) or  (b), is not  a hazardous waste  may do so
by performing the tests described below on a representative
sample of the waste  for those characteristics or properties
indicated by the codes  (i,e., (I),  (C),  (R),  (N),  (T),  (A),
 (O), CM) , (B)) following the waste listing.   A  certification
of the test results  shall be submitted to  the EPA Administra-
tor by certified mail with return receipt  requested.  The
results of the tests must show the waste is  non-hazardous
for each characteristic or property  indicated.
     (1)  Waste designated as ignitable  (I)  must be shown by
     the Section 250.13(a) ignitable characteristic method
     not to meet the Section 250.13(a) definition.
     (2)  Waste designated as corrosive  (C)  must be shown
     by the Section  250.13(b) corrosive characteristic
     method not to meet the Section  250.13 (b) definition.
     (3)  Waste designated as reactive  (R) must be  shown by
     the Section 250.13(c) reactive  characteristic  method
     not to meet the Section 250.13 to) definition.
     (4)  Waste designated as toxic  (T) must be shown  by
     the Section 250.13(d) toxic  characteristic method
     not to meet the Section 250.13 (d) definition.
     (5)  Waste designated as radioactive  (A) must  be
     shown to have either of the  following properties:
                            129

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     (i)  An average radium-226 concentration less
     than 5 picocuries per gram for solid waste or
     50 picocuries (radium-226 and radium-228 combined)
     per liter for liquid waste as determined by
     either of the methods cited in Appendix VIII
     of this Subpart; or
     (ii)  A total radium-226 activity less than
     10 microcuries for any single discrete source.
(6)  Waste designated as mutagenic (M),  bioaccumula-
tive (B), or toxic organic (O) must be shewn to have
an Extraction Procedure extract (see Section 250.13(<2) (2))
with none of the following properties:
     (i)  Mutagenic  (M) :  Contains more than one mg/liter
     of any compound on the Controlled Substances List
     in Appendix IX of this Subpart or gives a positive
     response in any one of a set of required tests for
     mutagenic activity.  A total of three assays must
     be conducted.  One shall be chosen from group I,
     one from group II, and one from those listed in
     group III.  Test protocols are defined in
     Appendix X of this Subpart.
          Group I   Detection of gene mutations
                    1.  Point mutation in bacteria.
         Group II   Detection of gene mutations
                    1.  Mammalian somatic cells in
                    culture.
                     2.  Fungal microorganisms.
                        130

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          Group III  Detecting effects of DNA repair or
                     recombination as an indication of
                     genetic damage
                     1.  DNA repair in bacteria (including
                     differential killing of repair
                     defective strains).
                     2.  Unscheduled DNA synthesis in human
                     diploid cells.
                     3.  Sister-chromatid exchange in
                     mammalian cells.
                     4.  Mitotic recombination and/or gene
                     conversion in yeast.
(ii)  Bioaccumulative (B):   Gives a positive result
in the Bioaccumulation Potential Test, defined in
Appendix XI of this Subpart; •---•-..
                       131

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           (ill)  Toxic Organic  (O }:  Contains any organic

          substance which has a calculated human LD50* of

          less than 800 nig/kg, at a concentration in mg/1

          greater than or equal to  0.35 times its LD50

          expressed in units of mg/kg.  For purposes of

          this Subpart, metallic salts of organic acids

          containing 3 or fewer carbon atoms are considered

          not to be organic substances.
"Procedure for Calculating Human LD50 Value:

     The LD50 value to be used will be that for oral exposure
to rats.  Where a value for the rat is not available/ mouse
oral LD50 data may be employed.  Where an appropriate LD50
value for the rat or mouse is listed in the NIOSH Registry
of Toxic Effects of Chemical Substances ("Registry"), this
value may be used without validation.If other values are
used, they must be supported by specific and verified labora-
tory reports.  The appropriate conversion factors to use in
calculating LDSOs are:

          Rat    x .16  = human

          Mouse  x .066 = human

Example:  Tetraethylenepentaraine

          Listed oral rat LD50 is 3990 mg/kg
          calculated human LD50 is 3990 x 0.16
          = 638 mg/kg; 638 x 0.35 = 223 mg/1

          Thus if the EP extract contains more
          than 223 mg/1 of tetraethylenepentamine
          the waste is hazardous.
                         132

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BD-5
                          DRAFT
                   BACKGROUND DOCUMENT
         RESOURCE CONSERVATION AND RECOVERY ACT
         SUBTITLE C - HAZARDOUS WASTE MANAGEMENT
      SECTION 3001 - IDENTIFICATION AND LISTING OF
                     HAZARDOUS WASTE
         SECTION 250.14 - HAZARDOUS WASTE LISTS
                                        DECEMBER 15, 1978
          U.S. ENVIRONMENTAL PROTECTION AGENCY
                 OFFICE OF SOLID WASTE

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      This document  provides  background information  and
 support  for  regulations  which have  been designed  to identify
 and  list hazardous  waste pursuant to  Section  3001 of the
 Resource Conservation  and Recovery  Act of  1976.   It is being
 made available as a draft to support  the proposed regulations.
 As new information  is  obtained, changes may be made in the
 background information and used as  support for the  regulations
 when promulgated.
      This document  was first drafted many  months  ago  and has
 been revised to reflect  information received  and  Agency
 decisions made since then.   EPA made some  changes in  the
 proposed regulations shortly before their  publication in the
 Federal Register.   We  have tried to ensure that all of those
 Decisions are reflected  in this document.  If there are any
 inconsistencies between  the  proposal  (the  preamble and the
regulation)  and this background document,  however, the
Proposal is controlling.
     Comments in writing may be made to:
          Alan S. Corson
          Hazardous Waste Management Division (WH-565)
          Office of Solid Waste
          U.  S.  Environmental Protection Agency
          Washington,  D.C.  20460

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              Waste Listing Background Document
Introduction
     Subtitle C of the Solid Waste Disposal Act, as amended
by the Resource Conservation and Recovery Act of 1976 referred
to herein as (Pub. L. 94-580 or") the "Act" , creates a regulatory
framework to control hazardous waste.  Congress has found
that such waste presents "special dangers to health and
requires a greater degree of regulation than does non-hazardous
solid waste"  (Section 1002 (b)(5) of the Act).

     This rule is one of a series of seven being developed
and proposed under Subtitle C to implement the hazardous
waste management program.  It is important to note that
the definition of solid waste  (Section 1004(27) of the Act)
encompasses garbage, refuse, sludges, and other discarded
materials including liquids, semi-solids, and contained gases
(with a few exceptions)  from both municipal and industrial
sources.  Hazardous wastes, which are a sub-set of all solid
wastes and which will be defined by regulations under
Section 3001 of the Act, are those which have particularly
significant impacts on public health and the environment.
                                                      *
     Subtitle C creates a management control system which,
*~r those wastes defined as hazardous, requires "cradle-

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                               -2-
to-grave" cognizance including appropriate monitoring,
recordkeeping, and reporting throughout the system.
Section 3001 of the Act requires EPA to define criteria
and methods for identifying and listing hazardous wastes.
Those wastes which are identified as hazardous by these
means are then included in the management control system
constructed under Sections 3002 - 3006 and 3010.   Those
that are excluded will be subject to the requirements for
non-hazardous solid waste being carried out by States
under subtitle D under which open dumping is prohibited
and environmentally acceptable practices are required.

     Section 1004(5) defines a hazardous waste as that
which may -
     "(A) cause, or significantly contribute to an increase
     in mortality or an increase in serious irreversible,
     or incapacitating reversible, illness; or
      (B)  pose a substantial present or potential hazard to
     human health or the environment when improperly treated
     stored, transported, or disposed of, or otherwise
     managed."

   •  Section  3001(b) requires EPA to promulgate regulations
identifying those characteristics of hazardous waste and
to list  particular  hazardous wastes.

                             1

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                               -3-
The Problem
     The purpose of the hazardous waste list as required
by Section 3001 of the Act is to identify those wastes
which present a hazard to human health and the environment,
The wastes so identified are considered hazardous  (unless
demonstrated otherwise as specified in Section 250.15 of
the proposed regulation) and subject to the Subtitle C
regulations.  A solid waste, or source or class of solid
waste is listed if the waste:
           (1)  possesses any of the characteristics
               identified in proposed 40 CFR S250.13,
               and/or
           (2)  meets the statutory definition of
               hazardous waste:  "The term 'hazardous
               waste1 means a solid waste, or
               combination of solid wastes, which
               because of its quantity, concentration,
               or physical, chemical, or infectious
               characteristics may-
                    : *(A) cause, or significantly
               contribute to an increase in mortality
               or an increase in serious irreversible,
               or incapacitating reversible, illness; or
                    • ~(B) pose a substantial present or
               potential hazard to human health or the

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                                -4-
               environment when improperly treated,
               stored, transported,  or disposed  of,
               or otherwise managed."

     As may be noted, one branch of  the statutory  definition
of hazardous waste relies on judgments of the  overall  character
and risk of the waste when improperly  managed.   Over the
past several years, EPA has documented several hundred cases
of damage to human health or the environment resulting from
improper management of waste.  Damage  cases such as these
can be, and in many cases have been, used as the basis for
listing of certain hazardous waste.
                 i
     fhe agency considered several approaches  for  formulating
the list.  The approaches can be broken down into  three
main types:
          o    Substance Lists (such as dioxin,  beta
                 5                               	— ••'	
               napthalamine, etc.)
          o    Process Waste Stream Lists (these  can ranqe
               from the very specific:   e.g.  1,1  - dichlorV-
               ethylene distillation residues,  to the
               more general', e.g.  chlorinated organic
               distillation residues, to the  very broad-
               e.g. chlorinated solvents).

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                              -5-
          o    Chemical Class Lists (these can range from
               the specific:  e.g.  polynuclear aromatic,
               to the more general:  e.g. alkylating agents).

     Testing of pure substances or commercial products is
the traditional approach used by regulatory agencies which
control these pure substances or commercial products.  The
purpose of the Act, however, is to control waste materials.
These are not normally pure substances (except in the case
of spoiled or contaminated batches).   Wastes may come from
several stages within a production process, or a plant may
mix wastes from several processes prior to deposition.

     Pure substance listings work well for many agencies,
since their responsibilities lie with some aspect of the
pure substance.  The Department of Transportation,  (DOT)
for example, uses this approach.  Benzene, is listed by
DOT as a flammable liquid.  A transporter knows, after
consulting the DOT listing, that benzene must be handled
according to the DOT flammable liquid regulations.  Benzene,
however, is rarely disposed as benzene.  Rather, it might
be contained in still bottoms or heavy ends.

     In order for a regulation to be effective, it should  b*
structured so that it reflects the organization of the regulated
community.  Since waste process streams are often the units

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                              -6-
of  the  solid waste regulated by the Act, these same waste
process streams can be used to provide a ready means of
identification.
.      c
v.	 -It is more informative  (for identification purposes)
to  list "still bottoms from XYZ process - flammable" than
it  would to list "benzene - flammable".  Likewise, there
are certain waste classes, such as chlorinated solvents
which, if classified as wastes, could be unambiguously
identified by such a designation.  If these classes also
meet  the criteria" T for listing                then the
classes have also been included.

      Finally, there are certain pure substances selected  for
listing, but only for those cases where the substance
(or container) is being discarded. (This includes spin
clean-up debris or material from any of the tested
substances.)  The pure substances on the list were chosen
from  the DOT poison A, poison B and ORM-A lists, the priority
pollutants, and the cancelled and selected RPAR pesticides
Those compounds which are included by the hazardous waste
characteristics in Section 250.13 of the proposed
           or
regulation ^regulated by the Agency under other authority
were  not included; similarly the three lists were screened

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                              -7-



to minimize duplication.






     For background information concerning the listed



wastes the Agency is relying on several sources of data.



These include industry studies undertaken by the Agency/



damage incidents compiled by the Agency, and waste infor-



mation compiled by State Agencies.  Most of these sources
        ^

give information concerning the chemical and physical



properties of the wastes and the identity and sometimes



concentration of the constituents of the wastes.  For the



ignitable, reactive and corrosive characteristics, this



information is adequate to assess, with high degree of



certainty, that the waste stream will meet the 3001



characteristics and thus pose a hazard to the public



health and the environment.






     For toxicity, however, the situation is much more



complex.  As has been discussed in the Section 3001 preamble


to the regulation and in the toxicity background document,



the Agency is not so much concerned about the concentration



and identity of the toxic constituents in the waste as it



is about the identity and concentration of the toxic



constituents which might be expected to be available to



the environment under improper management conditions.  The

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                              -8-

primary pathway by which toxics are made available to
the environment is through leachate and run-off under
storage and disposal conditions.  The specific identity
and concentration of the toxics found in the leachate
or run-off is highly dependent upon the conditions of
storage and disposal/ as well as climatological and other
such factors.  In fact, these can only be precisely assessed
empirically  (i.e. the exact conditions (which may vary
widely) must be reproduced and the leachate and run-off
continually analyzed); any other type of assessment is
only an approximation.

     Therefore, it is not possible to determine with
absolute certainty from the qualitative and quantitative
information available whether the wastes will leach
toxic contaminants under actual waste management conditions
or in some cases, even if they will fail the toxicity
characteristic .  However, the Agency does have evidence
to indicate that industrial wastes as presently managed
and disposed often leach into and contaminate the
groundwater.  The Geraghty and Miller report indicated
that in 98% of 50 randomly selected on-site industrial
waste diposal sites, toxic heavy metals were found to
be present,  and  that these heavy metals had migrated

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                              -9-
from the disposal sites in 80% of the instances.  Selenium,
arsenic and/or cyanides were found to be present at 74% of
the sites and confirmed to have migrated at 60% of the sites.

     At 52% of the sites toxic inorganics (such as arsenic,
cadmium, etc.) in the groundwater from one or more
monitoring wells exceeded EPA drinking water limits (even
after taking into account the upstream  (beyond the site)
groundwater concentrations/

     Geraghty and Miller also found that, in a majority of
the 50 sites examined, organic contamination of the groundwater
above background levels was observed.  In 28 (56%) of these
sites chlorinated organics attributable to waste disposal
were observed in the groundwater.   (Specific identification
of these organics was not always undertaken in this work,
however, other incidents and reports  (2 through 8) do
qualitatively identify leached organic contaminants in
groundwater.)

     Since leaching can only confidently be assessed
empirically and because this work  gives empirical evidence
that most industrial sites do leach toxic, mutagenic or
carcinogenic  substances in substantial quantities, the
                           II

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                               -10-






Agency has used these source  documents  so that if they



indicate a particular waste has  high  concentrations of



toxic, mutagenic or carcenogenic constituents, the



waste was listed as hazardous.   (This assumes that the



toxicants will  be released if the waste is improperly



managed.)
                            II

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                                                 IS
The following discussions of each of the wastes l««Ated in Section 250.14


of the Act will seem repetitious if read together.   The discussions


were organized so that each separate one could be read separately


without reference to the other listings.
                                    ft

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                       General References
(1)   "The Prevalence of Subsurface Migration of Hazardous  Chemical
     Substances at selected Industrial Waste Disposal  Sites",   Geraghty
     and Miller,  SW-634,  Office of Solid Waste, USEPA,  1978.

(2)   "Hazardous Waste Disposal Damage Report",  SW-151.2, Office of
     Solid Waste,  USEPA 1977

(3)   "Hazardous Wastes in Landfill Sites" Dept  of the  Environment.
      Great Britain ISBN 0 11 751257 5.

(4)   "Effects of Disposal of Industrial Waste within a Sanitary Landfill
     Environment"  D.R. Streng-Residual Management by Land  Disposal
     EPA - 600/9 76-015.

(5)   "Problems Associated with the Land Disposal of an Organic Industrial
     Waste Containing HCB" W.J. Farmer et. al,  ibid.

(6)   "Pilot-Scale  Studies of the Leaching of Industrial Wastes in'
     Simulated Landfills' Jr. R. Newton - Water Pollution  Control,
     468, (1977)

(7)   Great Britain, Department of Environment,  NATO/CCMS,  Report on
     landfill Research and Practice.

     "Effect  pf pH on Removal of Heavy Metals  from Leachate by
     Clay Minerals" - R.A. Griffin et. al, ibid.

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  Waste chlorinated hydrocarbons from degreasing
  operations (I,T,Q)
     .This waste is classified as hazardous because  of' its

ignitable and toxic characteristic.  According to the informatioa

EPA has on  this waste stream it meets the RCRA §250.13a     and

§250.13d characteristics identifying ignitable and  toxic waste.

     EPA bases this classification on the following information.
      «*«ora Inc.  Assessment of Industrial Hazardous
                   * " Special Machinery Manufacturing
                   256-981 Contract # 68-01-3193  Mar '77

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                                             TABLE 'I'
                            LABORATORY ANALYSIS OF DEGREASER SOLVENT SAMPLES
                                     FROM SIC 355 MACHINE SHOPS
Sample

 "1
13.2
11.8
5.5
6.0
Water
93
<0.2
Flash
Point
No
Flash
27(1)
(81)
Heave Metals Concentration, ppm
Cd
0.02
0.06
Cr .
0.9
0.6
0.5
0.04
Cu
2.8
1.4
1.1
0.2
Fe
55
20
40
1.0
Pb
1.2
1.0
1.3
4.0
Zn
3.6
1.6
3.0
                                                                                      As Received
                                                                                      As Water Leached

                                                                                      Ae Received
                                                                                      As Water Leached
1 This is the flash point of  a solvent which accounted for about 55 percent of the sample;   trichloro-
  ethylene, which made up the balances of the sample, does not flash.
2
  This is within margin of error of  analysis oiethod.
Source:
          W,apora,  Inc.  Assessment of Industrial Hazardous
          Waste  Practices -  Special Machinery Manufacturing
          Industries  PB 256-981 Contract  # 68-01-3193  Mar  '77

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      The National  Interim Primary Drinking r.~ater regulations
 (NIPDWF.) set  limits  for chemical cor.tair.inati.on of Drinking VTat
                                                    I
 The  'substances  listed represent hazards  to human health.
 In arriving at  these specific -limits,  the total environ-
 mental  exposure of man to a  stated  specific toxicant has
 been considered.   (For a complete treatment of the  data
 and  reasoning used in choosing the  substances and  specified
 limits  please refer  to the NIPDWF. Appendix A-C
.Chemical Quality,  EPA-6570/9 - 76 - 003).
      A  primary  exposure route to the public for toxic
 contaminents  is through drinking water.  A large percentage
 of drinking water  finds its  source  in  groundwater.   EPA has
 evidence to indicate that industrial wastes as presently
 managed and disposed often leach    into  and contaminate,  the
 groundwater.  The  Geraghty and Miller  report  indicated that
 in 98%  of  50  randomly selected en-site industrial waste
disposal  sites,  toxic heavy metals had migrated from, the disposal
sites "in  80% of  the  instances.  Selenium, arsenic  and/or
cyanides  were  found  to be present at 74% of the sites and
confirmed to have migrated at 6C% of the sites.
    • At 52% of the sites toxic inorganics  (such as arsenic
riadmiuia etc.)  in the groundwater from one cr more  monitoring
wells  exceeded EPA drinking water liniit.s (even after taking
into account the upstream  (beyor.d the site) ground vreter
concentrations) .

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     Gerhity and Miller"" also found that in a majority of the
fifty sites examined organic contamination of th^ ground-water
above background levels was observed.  In 28 C56S)  of these
sites chlorinated organics attributable to waste  disposal .
were observed in the groundwater.  While specific identifi-
cation of these organics was not always undertaken, in. t-fris
work, (other incidents and reports 2 through. S <3o c^ualitativd
identify leached organic contaminants in gronndwater)  it
certainly serves to demonstrate that organic contamination
of groundvater frequently results from industrial waste

  disposal.   Since  the Administrator has determined "that th
  •presence  in drinking water of  chloroform and other trihala
  -and synthetic  organic  chemicals may have an. adverse effect
  the health  of  persons..."* and, as noted above, because mt
  drinking  water finds its source as groundwater, the preseni
  of available toxic organics  in waste as a critical factor;
  determining if a  waste presents a hazard when ntartaged.  (Pi
  a discussion of how the toxicity  and concentration of orga
  contaminants  in waste  are considered in the hazard determi
  tion  see  Toxicity background document.)

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Because of the toxic inorganics and organics which may be in this





waste/ and the potential of these to migrate as explained above.



And because- of the potential flammability of this waste, this
waste is hazardous.

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   VTas.te non-halo-genated solvent  (such as nothanol,
   acetone, isopropyl alcohol, polyvinyl alcohol,
   stodcard solvent ar.d methyl ethyl ketone)  and
   solvent sludges fron cleaning, compounding mill-   . .
   iitg and other processes (I/O)


     This waste is classified as hazardous because of its
        at\
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         •As is evident from above this waste stream has a flash
                o                                      \
    point:of 14C0F or below.  Ignitables with flash poxnts less
    than'140°F can become a problem while they are landfilled.
    During and after the disposal of an ignitable waste,  there
    are many available external and internal energy sources
    which can provide an impetus for combustion, raising
    temperatures of waste to their flash points.  Disposal of
    ignitable wastes may result in fire that will cause damage directly
    from heat and smoke production or may provide a vector
    by which other hazardous waste can be dispersed.
         Ignitable waste tend to be highly volatile and the
    evaporation of these volatiles contribute to poor air quality.
    (Refer to ignitability background document for further
    detail).  „.-,•.'..,.
   The following examples  of  such wastes have been described in
                                                                    *
    The Handbook of Industrial Waste Composition  in  California-1978;

            I* semiconductor manufacture solvent containing
              20% toluene,  50% isopropyl alcohol,  10% xylene,
              10% methyl ethyl ketone,  and 10% tetra ethyl ketone
           3.- wash solvents containing 5% freon TE,  5%  freon
              TF, 1% isopropyl alcohol,  2% acetone,  10% methyl
              ethyl ketone, and 10% paint thinner.
       D  Handbook of Industrial Waste Composition in California  1978
'^California Department of Health.
                              ^\

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3.  semi conductor wash solvent containing 60-80%
   alcohol, J-100, xylene, hexamethyl disilazane,
   bu±ylalcohol, acetone,  and water
     wash solvents containing 30% freon TMS,  10%
                     «
     acetone,  and 10% alcohol
 '5;  v;ash solvent containing 25% water,  30% VG-solvent,
     20%  alcohol, and 25% J-100 stripper
                         2000 gal

 * cleaning solvent containing 30%  "photo material",
    15% freon X,  15% acetone,  10% solder oil,
    10% MC955, and 20% Trico  III  (2-propanol)'
                             VX.

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          A primary exposure  route to the public for -toxic
contaminants is through drinking water.  A large percentage
of drinking water finds its source in groundwater-   EPA has
evidence to indicate that industrial wastes as presently
managed and disposed often leach •.«• into and contaminate. • the
                                          T.
groundwater.  The Gerhity and Miller report  indicated, that
in 98% of 50 randomly selected on-site industrial, waste dis-
posal sites, toxic heavy metals were found to be present, and
that these heavy metals had migrated frora the disposal, sites
in 80% of the instances.  Selenium, arsenic and/or  cyanides
were found to be present at 74% of the sites and confirmed
to have migrated at 60% of the sites.
     At 52% of the sites toxic inorganics (such as  arsenic,
cadmium, etc.) in the groundwater from, one or more  monitoring
Wells 'exceeded EPA drinking water limits (event after taking
into account the upstream (beyond the site) groundwater
concentrations)..
  - .  Gerhity and Miller  also found that in a majority of the
fifty sites examined organic  contamination of the> groundwater
above background levels was observed.  In 28 (56%)  of these
sites chlorinated organics attributable to waste disposal
were observed in the groundwater.  While specific identifi-
cation of these organics was  not always undertaken  in this
work, (other incidents and reports 2 through 8 do qualitatively
identify leached organic contaminants in groundwater}  it
certainly serves to demonstrate that organic contamination,
of groundwater frequently results from industrial' waste

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 disposal.  Since the Administrator has determined r ' .iat the
•presence in drinking water of chloroform and other trilisiloraethanes
 and synthetic organic chemicals may have an adverse effect on
 the health of persons..."* and, as noted above,  because much
 drinking water finds its source as groundwatex,  the presence
 of available toxic organics in waste as a critical factor in.
 determining if a waste presents a hazard when managed.  (Foir
 a -discussion of how the toxicity and concentration of organic
 contaminants in waste are considered in the hazard detencina—
 tion see Toxicity background document.)
  Because of the toxicity of many  of the organics (e.g.
  acetone, paint thinners, strippers) listed above and the  toxicity
  of other non-halogenated organic solvents, and the potential of
  these  to migrate, this waste is hazardous.

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                Waste lubricating oil  (T,0)
     This, waste is classified as hazardous because of' its
                                                     \


ignitable and toxic characteristic.   According to the information



EPA has on this waste stream it meets the RCRA §250.13a    and



§250.13d characteristics identifying ignitable and toxic waste.



     EPA bases this classification on the following  information.










 Lubricating  oils are similiar to hydraulic oils and may likewise



 be contaminated with toxic heavy metals(see section "Hydraulic




 or  cutting oil waste" this document) . Also  these may contain







 toxic organic additives-  and contaminants s.a. phenols.

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       The National  Interim  Primary  Drinking Crater P.eg-o.
      3WFO  set limits  for  chemical contamination of ft finking vrate^.
                            i                        • V
 The substances listed  represent hazards to human hJaltii.
 In  arriving at these specific -limits, the total environ—
 Cental exposure of man'to  a  stated  specific toxicant  has'
 been considered.   (For a complete  treatment of the data
 and reasoning used in  choosing the  substances and specified
 limits please refer  to the NIPDWF. Appendix A-C
•'.Chemical Quality,  EPA-6570/9 -'76 - 003).
      A primary exposure  route to the public for toxic
 contaminants is through  drinking water. .A large percentage
 of  drinking water  finds  its  source  in groundwator.  EPA, has
 evidence to indicate that  industrial wastes as presently
 managed and disposed often leach    into and contaroincCtc  the
 groundwater.   The  Geraghty and Miller report  indicated that
 in  98% of 50 randomly  selected en-site industrial vaste
 disposal sites,  toxic  heavy metals had migrated froci  the disposal
 sites'in 80%  of the  instances.  Selenium, arsenic and/or
 cyanides vere found  to be  present at 74% of the sites? and
 confirmed to have  migrated at 60% of the sites.
     • At 52% of the sites toxic inorganics (such as arsenic
' -ca.dir.iuia etc.)  in the groundwater from one cr more ir.onitorir.g
 veils  exceeded EPA drinking water limits (even after  tskincr
 into account the upstream  (beyond the site)  grouncTvrater
 concentrations).

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      Gerhity and Miller also found that in. a. xaajoritry or
fifty sites  examined organic contamination o£ tih^ grotindwatercr
above background levels was observed.  In 22 C56^> "of  tliese-
sites chlorinated organics attributable to waster disposal.
were  observed in the groundwater.  While specific iderttifi—
cation of these  organics was not always undertaJcen In.
vork,  (other incidents  and reports 2 through. S <3o
identify leached organic contaminants in grotmolwater} £
certainly serves to demonstrate that organic coataminatLort
of groundvrater frequently results from industrial v
  disposal.   Since the  Administrator has deterctizieci ^
         *                               •     •    .    •
  •presence in. drinking  water  of chloroform, and oth.es:
  and synthetic organic chemicals may have -an, adverse; effect: orx
  •the health of persons..."*  and, as noted ahove> because ruach.
  drinking v;ater finds  its source as groundwaterv thes presence
  of available toxic organics in waste as  a  critical factor1 in
  determining if a waste presents, a hazard %x7hen,  xcraiiagecl«  CS^oor
  a discussion of how the toxicity and concentration, of organic
  contaminants in waste are considered in  the IiazarcL cLetensina.—
  tion see Toxicity background document.)

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Beoause of the toxic inorganics  and organics which may  be in. this





waste, and the potential of these  to migrate as explained above.





        waste is hazardous.

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                                                              I* T
                                                             6
          Vlaste hydraulic or cutting oil  (T>0)
     This waste  is  classified as  hazardous because of its

toxic characteristic.   According  to the information EPA has

on this waste  stream it meets the RCRA §250.13d

characteristic identifying  toxic  wastes.

     EPA bases this classification on the following information.

          Data

               Lapping  compound mineral seal  oil based


               Contaminant                    Cone, mg/1

                     Cd                             0.30

                     Cu                         2,570.0

                     Fe                           105.0

                     Pb                            73.0

                     Zn                           458.0


                     Lapping compound kerosene base

          f.p. = 128*F


          Contaminants                  Cone, mcr/1

               Pb                             0.5

               Fe                           270.0


     Also these oils may contain  toxic  organic additives and

     contaminents ,such as  phenols,bactericides and chlorinated

     organics.


     The data  presented are available from:

     Wapora, Inc.  Assessment of  Industrial Hazardous
     Waste Practices - Special  Machinery Manufacturing
     "industries  PB 256-981 Contract £ 68-01-3193 Mar '77

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      The National Interim Primary Drinking vrater  Regulations



 .(KIPDWF.)  set limits for chemical contamination of Drinking Water.



 The substances listed represent hazards to human  hJalth.



 In arriving at these specific -limits,  the total environ-



 mental exposure of man'to a stated specific toxicant has'



 been considered.  (For a complete treatment of the data



 and reasoning used in choosing  the substances  and specified



 limits please refer to the NIPDWF. Appendix A-C



''.Chemical Quality, EPA-6570/9 -  76 - 003).



      A primary exposure route to the public for toscic



 contarainents is through drinking water.  A large  percentage



 of drinking water finds its source in groundwater.  EPA



 evidence to indicate that industrial wastes as presently-



 managed and disposed often leach   into and contaEiincxuL



 groundx*ater.  The Geraghfcy and  Miller report  indicated



 in 98% of 50 randoialy selected  en-site industrial vaste



 disposal sites, toxic heavy metals had migrated from the disposal



 sites*in 80% of the instances.   Selenium, arsenic and/or



 cyanides were found to be present at 74% of the sites and



 confirmed to have migrated at 60% of the sites.



    •  At 52% of the sites toxic  inorganics (such as arsenic



 •cadmium etc.)  in the groundwater from one cr nore son



 veils exceeded EPA drinking water lin-its (even after
 into account the upstream (beyond the site) grour.dvrater



 concentrations) .

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     Gerhity and Miller  also found that in. a majority o£

fifty sites examined organic contamination of
   ^
above background levels was observed.  In 28 C5o4> of; tnese-

sites chlorinated organics attributable to waster disposal. .

were observed in the groundwater.   While specifics identifi-

cation of these organics was not always undertaken, in. E^^S,

work, (other incidents and reports 2 through, ff clo qualitatively*

identify leached organic contaminants in grotmoVwater}  it

certainly serves to demonstrate that organic contamination,

of. groundwater frequently results  front industrial v/aste


   disposal.   Since  the Administrator has determined,  *-t!iat

  -presence  in drinking water of chloroform and other

   and synthetic organic  chemicals may have an. adverse^ effect on.

   the health of persons..."* and, as noted above-, because mach.

   drinking  vrater finds  its source as groundwater;^ tb.es presence

   of available  toxic organics  in waste  as  a critical, factor- izr

   determining if a waste presents a hazard .when, roanasea.-   (Far-

   a discussion  of how the toxicity  and:  concentration, o£ organic

   contaminants  in waste are considered  in the- Iiazard. determina-

   tion  see  Toxicity background document.)

-------
Because of the toxic inorganics and organics which may- be in. this





waste, and the potential of these to migrate as explained above-.




        waste is hazardous.
                        31-

-------
Paint wastes (such as  used  rags, slops, latex •
sludge/ spent solvent)  (T,I,O)

     This waste  is classified as hazardous because ot its

ignitable and  toxic characteristic.  According to the information

EPA has on  this  waste  stream it meets the RCRA §250.13a     and

§250.13d characteristics identifying ignitable and toxic waste.

     EPA bases this classification on the following information.

      (1) Wapora  Inc. has tested a sample of lacquer equipment

clean-up waste acetone base and drip varnishing equipment clean-

up waste/ xylene base  and  found the following:


(Acetone based lacquer equipment cleanup wastes)

contaminant                      cone. mg/1


   Pb                              178.00

f .p =  70°F


(xylene base drip varnishing equipment clean-up waste)

contaminant                       cone. mg/1


   Cr                               390.00

   Cu                                37.00

   Fe                               360.00

   Pb                               582.00

   Zn                              1996.00


f.p =  80-100°F

     The data  presented are available from:

     Wapora.   Assessment of Industrial Hazardous Waste Practices:

Paint  and Allied  Products  Industry, Contract Solvent Reclaiming

Operations, and  Factory Application of Coatings.  OSW. PB - 251

699. 1976.
                       j ~

-------
     As is evident from above this waste stream has  a  flash
point of below 140°F.   Ignitables with flash points  less  than
          140°F can become a problem while they are  landfilled.
During and after the disposal of an ignitable waste, there are
many available external and internal energy sources  which can
provide an impetus for combustion, raising temperatures of waste
to their flash points.  Disposal of ignitable wastes may  result
in fire that will cause damage directly from heat  and  smoke
production or may provide a vector by which hazardous  substances
can be dispersed.
     Ignitable waste tend to be highly volatile and  the evaporation
                                 e
of volatiles themselves contribut-   • to poor air quality.  (Refer
to.ignitability background document for further detail).
     The National Interim Primary Drinking Water Regulations
(NIPDWR) set limits for chemical contamination of  Drinking Water
The substances listed represented hazard to human  health.  in.
arriving at these specific limits, the total environmental exposur
of man to a stated specific toxicant has been considered.  (For a
complete treatment of the data and reasoning used  in choosing th
substances and specified limits please refer to the  NIPDWR
Appendix A-C Chemical Quality, EPA-6570/9 - 76 - 003).
     A primary exposure route to the public for toxic  contaminent
is through drinking water.  A large percentage of  drinking water
finds it source in groundwater.  EPA has evidence  to indicate th
industrial wastes as presently managed and disposed  often leach
into and comtaminents the groundwater.  The Geraghty and  Milie
report1 indicated that in 98% of 50 randomly selected  on-site
industrial waste disposal sites, toxic heavy metals  were  found *

-------
be present, and that these heavy metals had migrated from the
disposal sites in 80% of the instances.  Selenium, arsenic and/or
cyanides were found to be present at 74% of the sites and confirmed
to have migrated at 60% of the sites.
     At 52% of the sites toxic inorganics (such as arsenic, cadmium
etc.) in the groundwater from one or more monitoring wells exceeded
EPA drinking water limits (even after taking into account the
upstream (beyond the site) groundwater concentrations).
     Arsenic, barium, cadmium, chromium, lead mercury, selenium,
and silver are toxicants listed by the NIPDWR at concentrations
of 0.05, 1.00, 0.010. 0.05, 0.05, 0.002, 0.01, and 0.05, mg/1
respectively because of their toxicity.  As explained in the RCRA
toxicity background documents these concentrations convert to
0.5, 10.0, 0.1, 0.5, 0.5, 0.02, 0.01, and 0.5, mg/1 respectively
in the  EP extract.
     This waste has been shown to contain chromium and lead at
concentrations of 390.0 and 582.0 mg/1 respectively, according to
PB - 251 - 669, Assessment of Industrial Hazardous Waste Practices:
Paint and Allied Products Industry, Contract Solvent Reclamining
Operations, and Factory Application of Coatings.
     Also the "Handbook of Industrial Waste Compositions in
California" - 1978  (Reference 9) indicated the fol^ojlng composi-
tions for these types wastes:

-------
California manifest           (Ref. 9, p. 40)





    equipment cleaning solvent and paint sludge



    containing 90% pigments, 3% water, and 7%



    alcohols, aromatics, and aliphatic hydrocarbons,



    ketones





California manifest           (Ref. 9, p. 40)





    solvent and paint sludge containing 62%



    aromatic hydrocarbons, 32% epoxy resins,



    6% urea - formaldehyde





California manifest           (Ref. 9, p. 41)





    solvent and paint sludge containing 0-30% ketones,



    0-4% polymer alkyd acrylic resin, 0-40% aliphatic



    and aromatis hydrocarbons, 25-45% extenders and



    inert organic solids, & Ti 02





California manifest           (Ref. 9, p. 41)





    waste solvent containing 0.1 - 12% cobalt salts,



    0.1 - 9% manganese salts, and 0.1 - 12% zirconium



    naphenic acid





California manifest           (Ref. 9, p. 10)





    waste cleaning solvent containing 50%



    naphtha and  50%  acetone

-------
 California manifest           (Ref.  9,  p.  10)

     waste solvent containing toluene, methyl
     ethylketone,  acetone;  and xylene

 California manifest           (Ref.  9,  p.  40)

     solvent and paint sludge containing 2%
     methylethyl ketone and NaOH

 California manifest           (Ref.  9,  p.  40)

     waste solvent containing 30%  acetone/
     20% isophorone,  and 20% ethyl amyl
     ketone

 California manifest           (Ref.  9,  p.  40)

     paint sludge  containing 10% cuprous oxide,  2.5%
     iron oxide, 2.5%  lead  pigment, 0.5% chromium
     pigment,  10%  titanium  pigments and  talc, and  68% xylene,
     ketones,  mineral  spirits,  alkyl/Epoxy  resins

California manifest            (Ref.  9,  p.  40)

     paint sludge  and  solvent containing 2% methyl
     ethyl ketone  & NaOH

California manifest            (Ref.  9,  p.  41)

     waste solvent containing 30-50%  epoxy resin &
     50-70% amine  type  solvents

-------
     These wastes contain significant amounts of the following
ignitible substances:
     Naphtha - flash point =  0°F.
     Acetone - flash point =  0°P.
     Toluene - flash point =  40°F.
     Methyl ethyl ketone - flash point =  21°F.

Reference: Fire Protection Handbook,   National
           Fire Protection Association, 1962.

     Because of the flash points of many of the solvents and
the toxicity of the pigments and solvents typically used (benzene
xylene etc.) in paint manufacture,  this waste is to be considered
hazardous.

-------
      Water - based paint wastes (T)

      This waste stream is classified as hazardous because of its

 toxic properties.   According to the  data EPA has on this waste

 stream it meet the RCRA §250.13d characteristic identifying

 a toxic hazardous  waste.

      EPA bases this classification on the following information.

      (1)  Wapora Inc.  has tested a sample of water-based paint

 waste and has found the following.


 contaminent                                cone.
 Inorganic pigment*                          2.5%

 Ti02                                         4.5%

 Binders                                     20.0%

 Fungicides,  Germicides,
      Mildewcides
                                             100-150  mg/1


      *hazardous  pigments used  in paint  industry  include:

       lead carbonate,  lead  silicate, red lead, antimony

       oxide,  zinc  oxide, cadmium lithopone,  chrome yellow,

       molybdate  orange, strotium chromate, chrome green,

       chromium oxide and phthalocyanine green.


      The  data presented above  are available  from:

      Wapora  Inc. Assessment of Industrial Hazardous Waste

Practices: Paint and Allied Products Industry, Contract Solvent

Reclamining  Operations, and Factory Application of Coatings.

PB -  251  669. 1976

-------
     The National Interim Primary Drinking Water Regulations
(NIPDWR) set limits for chemical contamination of Drinking Water.
The substances listed represent hazards to human health.  In arriving
at these specific limits, the total environmental exposure of man
to a stated specific toxicant has been considered.  (For a complete
treatment of the data and reasoning used in choosing the substances
and specified limits please refer to the NIPDWR Appendix A-C
Chemical Quality, EPA-6570/9 - 76 - 003).
     A primary exposure route to the public for toxic contaminents
is through drinking water.  A large percentage of drinking water
finds it source in groundwater.  EPA has evidence to indicate
that industrial wastes as presently managed and disposed often
leaches into and contaminents the groundwater.  The Geraghty and
Miller report^ indicated that in 98% of 50 randomly selected
on-site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated from
the disposal sites in 80% of the instances.  Selenium, arsenic
and/or cyanides were found to be present at 74% of the sites and
confirmed to have migrated at 60% of the sites.
     At 52% of the sites toxic inorganics  (such as arsenic, cadmium
etc.) in the groundwater from one or more monitoring wells
exceeded EPA drinking water limits (even after taking into account
the upstream (beyond the site) groundwater concentrations).
                            and 9olot>U*4 oF wi*»«i
     Because of the toxicity*of the         pigments used by the
paint industry* and the toxicity of many biocides this waste is to
be considered hazardous.

-------
      Because of the toxicity and solubility of many of the

pigments  commonly used in water based paints, this waste is to

be considered hazardous.
*Versar, Inc  Assessment of Industrials Hazardous
 waste Practices, Inorganic Chemicals Industrys
 wContract  # 68-01-2246 and references cited therein, and

 Wapora, Inc. Assessment of Industrial Hazardous
 Waste Practices-Paint and Allied Products Industry
 Contract Solvent Reclamining Operations and Factory
 Application of Coatings. 1976 and refernces cited therein.

-------
Tank Bottoms, leaded (T)



     This waste is classified as hazardous because of its toxic



characteristic.  According to the information EPA has on this



waste stream it meets RCRA §250.13d characteristic identifying



toxic waste.



     EPA bases this classification on the following information.



     According to "The Handbook of Industrial waste compositions



in California" - 1978, this waste stream has been shown to have



the following chemical characteristic



WASTE                    COMPONENTS                   PAGE
Tank Bottom Sediment
  load size: 100 bbl
Tank Bottom Sediment
400 ppm ammonia              54



258 ppm sulfide



 2%  phenol



     water, pH 10









 5%  gasoline             141



traces inorganic, organic



lead,: Balance: water,  dirt,



iron oxide
  load size: 100 bbl

-------
      The  National  Interim  Primary Drinking Water  Regulations



 (NIPDWR)  set  limits  for chemical contamination of Drinking Water.



The  substances  listed represent hazards to human  health.  In



arriving  at these  specific limits, the total environmental



exposure  of man to a stated specific toxicant has  been considered.



(For a complete treatment of the data and reasoning used in



choosing  the  substances and specified limits please refer to the



NIPDWR Appendix A-C Chemical Quality, EPA-6570/9  - 76 - 003).



      A primary exposure route to the public for toxic contami-



nants is  through drinking water.  A large percentage of drinking



water finds its source in groundwater.  EPA has evidence to



indicate  that industrial wastes as presently managed and disposed



often leaches into and contaminents the groundwater.  The



Geraghty  and  Miller report1 indicated that in 98%  of 50 randomly



selected  on-site industrial waste disposal sites,  toxic heavy



metals were found  to be present, and that these heavy metals



had  migrated  from  the disposal sites in 80% of the instances.



Selenium, arsenic  and/or cyanides were found to be present at



74%  of the sites and confirmed to have migrated at 60% of the



sites.



      At 52% of the sites toxic inorganics (such as arsenic,



cadmium etc),  in  the groundwater from one or more monitoring



wells exceeded EPA drinking water limits  (even after taking into



account the upstream (beyond the site) groundwater concentrations).



      Lead is  one of the toxicants listed by the NIPDWR at a



concentration of .05mg/l because of its toxicity.  As explained



in the RCRA toxicity background document this converts to a .5mg/l

-------
level in the EP extract.



     As demonstrated earlier this waste has been shown to contain



both organic and inorganic lead.



     Because of the toxicity of lead this waste stream is to be



considered hazardous.



     A primary exposure route to the public for toxic contaminents



is through drinking water.  A large percentage of drinking water



finds its source in groundwater.  EPA has evidence to indicate



that industrial wastes as presently managed and disposed often



leaches into and contaminates the groundwater.  The Geraghty and



Miller report  indicated that in 98% of 50 randomly selected on-



site industrial waste disposal sites/ toxic heavy metals were found



to be present, and that these heavy metals had migrated from the



disposal sites in 80% of the instances.  Selenium, arsenic and/or



cyandies were found to be present at 74% of the sites and con-



firmed to have migrated at 60% of the sites.



     At 52% of the sites toxic inorganics (such as arsenic,



cadmium, etc.) in the groundwater from one or more monitoring



wells exceeded EPA drinking water limits (even after taking



into account the upstream (beyond the site)  groundwater



concentrations)..



     Geraghty and Miller  also found that in a majority of the



fifty sites examined organic contamination of the groundwater



above background levels was observed.  In- 28  (56%) of these



sites chlorinated organics attributable to waste disposal were



observed in the groundwater.  While specfic identification



of these organics was not always undertaken in this work,



(other incidents and reports  (Reference 2 through 8) do qualitative

-------
identify leached organic contaminants in groundwater) it


certainly serves to demonstrate that organic contamination


of groundwater frequently results from industrial waste disposal.


Since the Administrator has determined "that the presence in


drinking water of chloroform and other trihalomethanes and


synthetic organic chemicals may have an adverse effect on the


health of persons..."* and, as noted above, because much drinking


water finds its source as groundwater, the presence of available


toxic organics in waste as a criterical factor in determining if


a waste presents a hazard when managed.   (For a discussion of how


the toxicity and concentration of organic contaminants in waste


are considered in the hazard determination see Toxicity


background document.)


     Tank bottom sediments have been found to contain 2% phenol -


oral rate LD50 = 414 mg/kg.  Because of the toxicity of phenols

          "is
this waste* considered hazardous.
           n

     Tank bottom sediments also have been found to contain 5%


gasoline, a DOT flammable liquid with a flash point of ~45° F.
  Interim Primary Drinking Water Regulations,"
  p. 5756, Federal Register, 2/9/78

-------
     Ignitables with flash points less than 140°F can become



a problem while they are landfilled.  During and after the disposal



of an ignitable waste, there are many available external and



internal energy sources which can provide and impetus for



combustion, raising temperatures of waste to their flash points.



Disposal of igitable wastes may result in fire that will cause



damage directly from heat and smoke production or may provide



a vector by which other hazardous waste can be dispersed.



     Ignitible wastes tend to be highly volatile and the



evaporation of these volatiles contributes poor air quality.



 (Refer to  ignitability background document for further detail) .

-------
  Spent or waste cyanide solutions  or sludges  (R,T)






 Reactive wastes as defined by Section 250.14  of RCRA pose a threat



 to human health and the environment,  either through  the physical




 consequences of their reaction (i.e.,  high pressure  and/or heat generation)




 or through the chemical consequences of their reaction  (i.e.,  generation



 of toxic fumes).






 Wastes containing cyanide  salts  may undergo solvolysis,  under  mildly



 acid conditions to generate HCN  gas.   HCN  gas* is an intensly  poisonous



 gas even when mixed with air.  High concentration produces tachypnea



 (causing increased intake  of cyanide);  then dyspnea,  paralysis, unconsciousness,



 convulsions and respiratory arrest.   Exposure to 150 ppm for 1/2 to 1




 hour may endanger life.  Death may result  from a few minutes exposure



 to  300 ppm.   Average fatal  dose: 50 to  60  mg.
Bequ\a^e  of  this potential danger cyanide bearing wastes are considered



hazardous wastes.










*Merck Index, Eighth Edition, p. 544

-------
                    Etching Acid solutions or sludges (T,C)






  This waste is classified as hazardous because of its corrosive



and toxic characteristics.  According to the information EPA has



about this waste stream it meets both the RCRA S250.13a.2 and




S250.13a.4 characteristics identifying corrosive and toxic wastes.






EPA bases this classification on the chemical compositions indicated



by the listings from the California Manifest System:

-------
                                   Etching Acid

                               Industrial Waste Descriptions
Industry
Process
Generic Name
Components and Typical Load. Size
3674

Semi-
conductors
3674
Semi-
conductors
3674
Semi-
conductors
Photo
Resist
Stripping
Photo
Resist
Stripping
Cleaning
Acid
Solution
Acid
Solution
Unused
Photo Resist
Stripper,
Acid Solution
    sulfuric acid
 1% chromic acid
 1% perchloric acid
                                                                        5 cu. yds.
                                                                          (cartons)
712 D Photo Resist Stripper
                        172 gal.
30-50% sulfuric acid
 3-5 % chromic acid     185 gal.
*From
Handbook of  Industrial Waste Compositions
in California  1978
Storm, D, Dept. of Health California

-------
Industry
Process
Generic Name
Components and Typical Load Size
3679
Microwave
Components





3679
Circuit
Boards

3679
Microwave
Components

3679
Printed
Circuits



3661
Telephone
and Tele-
graph
Apparatus ,
Telephones
Unspecified




PCB
Chemical
Etching





Circuit
board
fabrication

Chemical
machinery


PCB etching
(printed
circuit
board
etching)

Copper
etching



Copper




Acid
Solution






Acid
Solution


Acid solution
and solvent


Acid solution





Acid
Solution



Acid




40-60% water
15-30% sulfuric acid
10-20% chromic acid
3-5 % copper
Balance: other metals,
proprietary
PH 2 i dry.

5-8% Nitric acid
sulfuric acid
5-8% Fluorboric acid 2310 gal.

a) Aluminum etch i drtB
b) Trichlorecethane 5 drums
c) Machine oil 9 drums

90-95% ferric chloride
Balance: water
PH 0 4700 ».
^


7-13% chromic acid
13-20% sulfuric acid
water 1000 gal.


sodium chloride
hydochloric acid
Sodium chlorate
c°PPer 180 gal.

-------
 Industry
Process
Generic Name
  Components and Typical Load Size
3361
Cameras
Unspecified
3711
Automobile
Assembly
Unspecified
3721
Aircraft
Unspecified
Etching
Photo-
graphic
Etching
Etching
Metal
etching
and
finishing
Metal
Etching
Titanium
chemical
milling
Acid
Solution

Alkaline
Solution
Alkaline
Solution
Acid
Solution
Acid
Solution
Acid
Solution
 5-15% hydroflouric acid  4800 gal,
2700 ppm potassium
         potassium ferricyanide
         ferric cyanide
         water
         pH 10-11          400 gal,
         sodium hydroxide
         Alodine 1200 and 1000
         pH 10            1500 gal.
         Iridate #14
         Deoxidizer Al-901
         Etchlaume #14    1400 gal,
   3  %  hydrofl|pjlric and nitric
         acid
  97  %  water            100 bbl.

5-15 % nitric acid
1- 8%  hydrofXgpric acid
1- 5%  titanium
        pH  1             2400 gal,
                                         51

-------
As is evident from the California Listings jEtching Acid solutions or sludges


have been shown to have low pH or high pH's (unless neutralized).  Liquid
waste streams with such acidic. (caustic)  character present an environmental
                              A

risk for several reasons.  Very low or high pH liquid waste if disposed in


a sanitary landfill would leach high concentrations of toxic heavy metals


(such as lead) from ordinary municipal trash.   These heavy metals would

                                                          or
otherwise remain bound in the waste matrix.  Highly acidic, (caustic) liquid


wastes also present a handling risk because of their corrosive properties.


OSW has in its files many damage incidents resulting from the mismanagement


of highly acidic or caustic wastes.  These include: several deaths and


many serious illnesses resulting from the inhalation of toxic gases


formed by the reaction of acidic wastes with wastes containing sulfide


or cyanide salts, contamination and degradation of groundwater and wells


from improper disposal of acidic and caustic wastes, severe burns from


handling and contact with acidic and caustic wastes and several incidents


of fish kills from discharge of acidic and caustic wastes.  (Refer to


corrosivity and reactivity background documents for further information) .




The National Interim Primary Dunking Water Regulations (NIPDWR)  set limits


for chemical contamination of Drinking Water.   The substances listed


represent hazards to human health.  In arriving at these specified limits


the total environmental exposure of man to a stated specific toxicant


has been considered.   (For a complete treatment of the data and reasoning


used in choosing the substances and specified limits please refer to the


NIPDWR Appendix A-C Chemical Quality, EPA-6570/9-76-003) .




A primary exposure route to the public for toxic contaminants is through

-------
drinking water.  A large percentage of drinking water finds its source



in groundwater.  EPA has evidence to indicate that industrial wastes as



presently managed and disposed often leaches into and contaminates the



groundwater.  The Geraghty and Miller report1 indicated that in



98% of 50 randomly selected on-site industrial waste disposal sites,



toxic heavy metals were found to be present, and that these heavy metals



had migrated from the disposal sites in 80% of the instances.  Selenium,



arsenic and/or cyanides were found to be present at 74% of the sites



and confirmed to have migrated at 60% of the sites.






At 52% of the sites toxic inorganics (such as arsenic, cadmium etc.)



in the groundwater from one or more monitoring wells exceeded EPA



drinking water limits (even after taking into account the upstream



(beyond the site) groundwater concentrations).

-------
     Waste paint and varnish remover or stripper  (I,
O)
  This waste stream willbe similiar  in  composition  to "
Paint wastes (such as used rags,  slops,  latex
sludge, spent solvent) (T,I,0)
  and present similiar hazards. Please refer to the  section

  discussing tnj_s waste streaml
                           5M

-------
Solvents and solvent recovery still bottoms  (non-halogenated)
                    
-------
     The National Interim Primary Drinking Water  Regulations
(NIPDWR) set limits for chemical contamination of Drinking Water-.
The substances listed represent hazards to human  health.
In arriving at these specific limits,  the total environ-
mental exposure of man to a started specific toxicant has
been considered.   (For a complete treatment of the data
and reasoning used in choosing the substances and specified
limits please refer to the NIPDWR  Appendix AC Chemical
Quality, EPA-6570/9 - 76 - 003).
     A primary exposure route to the public for toxic
contaminants is through drinking water.  A large  percentage
of drinking water finds its source in groundwater.  EPA has
evidence to indicate that industrial wastes as presently
managed and disposed often leaches into and contaminates the
groundwater.  The Geraghty and Miller report  indicated that
in 98% of 50 randomly selected on-site industrial waste
disposal sites, toxic heavy metals had migrated from the disposal
sites in 80% of the instances.  Selenium, arsenic and/or
cyanides were found to be present at 74% of the sites and
confirmed to have migrated at 60% of the sites.
     At 52% of the sites toxic inorganics  (such as arsenic
cadmium etc.) in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits  (even after taking
into account the upstream  (beyond the site) groundwater
concentrations).
     Aresenic, barium, cadmium, chromium, lead, mercury
selenium, and silver are toxicants listed by the NIPDWR at

-------
  concentrations of 0.05, 1.00, 0.010, 0.05, 0.05, 0.002,
  0.01, and 0.05 mg/1 respective because of their toxicity.
  As explained in the RCRA toxicity background documents these
  concentrations convert to 0.5, 10.0, 0.1, 0.5, 0.5, 0.02,
  0.1, and 0.5 mg/1 respective in the EP extract.
       This waste has been shown to contain lead and chromium at
  1113.5 and 227.5 mg/1 levels, respectively, according to
  PB251669, Assessment of Industrial Hazardous Waste Practices:
  Paint and Allied Products Industry, Contact Solvent Reclaiming
  Operations, and Factory Application of Coatings.  For this
  reason it is classified as toxic according to RCRA S250.13(d).
       Geraghty and Miller^- also found that in a majority of the
  fifty sites examined organic contamination of the groundwater
  above background levels was observed.  In 28  (56%) of these
  sites chlorinated organics attributable to waste disposal
  were observed in the groundwater.  While specific identifi-
  cation of these organics was not always undertaken in this
  work, (other incidents and reports  (references 2 through 8)
  do qualitatively identify leached organic contaminants in
  groundwater), it certainly serves to demonstrate that organic
  contamination of groundwater frequently results from industrial
7~ waste disposal. Since the Administrator has determined "that
 the presence in drinking water of chloroform and other tri-
 halomethanes and synthetic organic chemicals may have an adverse
 effect on the health of persons..."*  and,  as noted above,
 because much drinking water finds its source as groundwater,
 the presence of available toxic organics in waste is a critical

-------
factor in determining if a waste presents a hazard when managed.
(For a discussion of how the toxicity and concentration of
organic contaminants in waste are considered in the hazard
determination see Toxicity background document.)
     Solvent recovery still bottoms has been found to contain
organic solvents at about 25% of feedstock according to Wapora
Inc. in Assessment of Industrial Hazardous Waste Practices
Paint and Allied Products Industry, Contact Solvent Reclaiming
Operations and Factory Applications of Coatings,  PB-251-669
pps 206 to 211.  Some of the solvents used in industry have
been shown to be mutagenic.
     As is evident from the Wapora information this waste
stream also has a flash point of 140°F or below.   Igni tables
with flash points less than 140°F can become a problem
while they are landfilled. During and after the disposal of
an ignitable waste, there are many available external and
internal energy sources which can provide an impetus for
combustion, raising temperatures of waste to their flash
points.  Disposal of ignitable waste may result in fire that
will cause damage directly from heat and smoke production or
may provide a vector by which other hazardous waste can be
dispersed.
     Ignitable wastes tend to be highly volatile and the
evaporation of volatiles contribute to poor air quality.
(Refer to ignitability background document for further deta'll

-------
            WASTE OR OFF-SPEC TOLUENE DIISOCYANATE

      The Administrator has determined that this waste is a
 hazard to human  health and the environment if  improperly managed.
 Toluene diisocyanate  (TDI) is a pressure generating compound  that
 reacts with water,  resulting in evolution of carbon dioxide.  Con-
 tact with concentrated alkaline compounds such as sodium hydroxide
 may cause run-away  polymerization.  It  is also listed as a. DOT
 Poison B; it  is  a strong  sensitizing agent and can cause skin
                                                          *
 irritation, allergic eczema and bronchial asthma in humans.
      There have  been several damage incidents  associated with dis-
 posal of toluene diisocyanate.  In California  in 1978, a drum
 containing TDI was  picked up by a scavenger waste hauler and
 placed in an  unprotected  storage area.  After  having been exposed
 to  rain, the  drum was removed to the Simi Class I Landfill where
 it  exploded,  hospitalizing several people.  In Detroit in May of
 1978, a tank  truck  waiting to dispose of a quantity of TDI
 experienced a boil-over.  The resulting fumes  caused nine people
 to  be hospitalized.
      These damage  incidents illustrate  the hazards created by
 improper treatment, storage or disposal of waste TDI.  in view of
 the above information we  feel that the  waste poses a threat to
 human health  and the environment.
*  The. M*rck

-------
Leachate from hazardous waste landfills (T,0,M,B)






Because of the toxicities of the process wastes, generic wastes and



waste materials listed by Section 250.14 of the Act, (see individual




background section for each waste listed)  and the toxicity of those



wastes which meet the 250.12 toxicity characteristics (see toxicity



background document), any leachate resulting from these wastes



is considered a hazardous waste.

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                       ELECTROPLATING
       Electroplating Waste Water Treatment Sludge (T)

     This waste stream is hazardous because of its toxic properties,
According to data EPA has on this waste stream, it meets the RCRA
§250.13a(4) characteristic identifying a toxic hazardous waste.
     The National Interim Primary Drinking Water Regulations
(NIPDWR) set limits for chemical contamination of drinking water.
The  substances listed represent hazards to human health.  In
arriving at these specific limits, the total environmental ex-
posure of man to a stated specific toxicant has been considered.
(For a complete treatment of the data and reasoning used in choos-
ing  the substances and specified limits please refer to the
NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 - 76 - 003) .
     A primary exposure route to the public for toxic contaminants
is through drinking water.  A large percentage of drinking water
finds its source in groundwater.  EPA has evidence to indicate
•that industrial wastes as presently managed and disposed often
leach into and contaminate the groundwater.  The Geraghty and
Miller report^ indicated that in 98% of 50 randomly selected on-
site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated
from the disposal sites in 80% of the instances.  Selenium,
arsenic and/or cyanides were found to be present at 74% of the
sites and confirmed to have migrated at 60% of the sites.
                            Cl

-------
     At 52% of the sites toxic inorganics (s.a. arsenic,

cadmium etc.)  in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream (beyond the site)  groundwater con-

centrations) .

     Examples and quantities of toxic constituents of electro-

plating wastewater treatment sludges are listed below.

     I.   Hydroxides of  (1)   chromium  -  330,000 ppm

                         (2)   cadmium   -   20,000 ppm

                         (3)   lead      -   20,000 ppm


          Reference:  Battelle.  Cross - Media Impact of the
                      Disposal of"Hazardous Waste from Metals,
                      Inorganic Chemicals and Related industries
                      Vol. 1, p. 13, Nov. 1977.           '	"—'

     II.   (1)   Neutralized hydroxide:  0.5-1% chromium hydroxide

          sludge  (p. 122)

           (2)   Lime sludge (p. 113)  :  cadmium   -  630 ppm

                                       chromium  - 9500 ppm

                                       lead      -  770 ppm

           (.31  Plating sludge  (p.133): chromium  -  1-5%

                                       cadmium   -  0-1%


          Reference:  Storm, D.L. Handbook of Industrial Waste
                      CompositionsTn California - 1978T
                      California Department of Health ^Services
                      Hazardous Materials Management Section
                      Nov. 1978

     On the basis of this information we feel that this waste

 stream poses  a threat to human health and the environment.

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Material which is within the scope  of Section  250.10(b)
and is normally shipped using a name  listed in Appendix  III
(Pesticides), Appendix IV (DOT Poison A,  Poison B, ORM-A Materials'),
or Appendix v (Priority Pollutants)  (T.O.M)
Off-specification material which is  within  the scope  of
Section 2S0.10(b) and,  if met  specification would
shipped using a name listed in Appendix  ill,  IV, or
V (T.O.M) ,
Spill  clean-up  residues and debris from spills of materials which
appear-in Appendix  III, IV, or V  (T,0,M)
 Containers,  unless  triple  rinsed, which have contained materials
 normally shipped using  a name  listed  in Appendix III, IV, or
 V  (T,Q,M)

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Introduction:  Selected Cancelled and RPAR Pesticides



This listing contains cancelled pesticides and those pesticides with


Rebuttable Presumptions Against Their Registration that have sufficient


data at this time to conclude that they should be disposed of within


the Hazardous Waste Management System.  Pesticides that are listed


elsewhere in the Sec. 3001 listing have been excluded from this


listing to minimize duplication.  Although this list is made up of


pesticides, our intent was not to regulate pesticides as a class.


Rather we are regulating organic chemicals that are disposed of on


land and have sufficient toxicological data to justify their inclussion


in the  Hazardous Waste Management System.



The intended use determines if an organic chemical substance is called


a pesticide.  The large number of organic chemicals regulated herein

                                                               CO
that are used as pesticides is an artifact of the available toxilogic


data.  Pesticides are used on crops for human consumption with the


intent to kill or control the pest while not hurting the human consumer


of the food.  Hence, there has been a large volume of toxicological


testing done on these organic chemicals.  Because of this relative


abundance of good toxicological data for pesticides and the paucity


of data for other organic chemical substances, we have included what


could appear like a disproportionate number of pesticides on the


Hazardous Waste list.



The listing of Hazardous Wastes is limited by the availability of data


A group of organic chemicals with this much toxicological data cannot


be ignored.  Unfortunately although we have a large quantity of toxicologic

data for these chemicals we do not have data on the behavior of these

-------
 substances under waste  management  conditions or their behavior when

 subjected to the extraction procedure test.  Little  information  is

 available to precisely  estimate  the  amount of  a particular chemical

 substance that can be expected to  be solubilized  in  the environment.


 Although information concerning  the  behavior of these materials  under

 waste management is only  partially available,  the Agency has  decided to

 regulate these materials  because of  their toxicity and the long  history

 of mismanagement of waste pesticide  and pesticide containers  resulting

 in human, animal and fish fatalities; as well  as  cases of serious

 illness.   Because of these reported  damage incidents (and the inherent

 toxicity of the substances) these  substances fall within the  statutory

 definition of hazardous waste  (Section 1004 of the Act).


 The Agency intends an upgrading  and  amending   4his  listing and

 w||l;  be investigating  the hazards associated  with the management

 of many other organic chemicals  (some of which are classed as pesticides)

 as more chemical,  toxicologic and  physical information becomes available.


 Four forms of the listed  pesticides  are included  in  the regulation.  The

 four forms are;  the pesticide itself, listed as


      Material which is  within the  scope of Section 250.10(b)
      and is normally shipped using a name listed  in  Appendix  III
      {Pesticides),  Appendix IV (DOT  Poison A,  Poison B, ORM-A Materials),
      or Appendix v (Priority Pollutants) (T,0,M)

The off-specification pesticide, listed as


      Off-specification  material  which is within the  scope of
      Section 250..10(b)  and, if met specification  would
      shipped using a name listed in  Appendix III, IV, or
      V (T,0,M)

-------
Spill clean up materials resulting from a spill of the pesticide, listed

as


     Spill clean-up residues and debris from spills of materials which
     appear in Appendix III, IV, or V (T,0,M)


And the unrinsed containers that contained the pesticide, listed as


     Containers, unless triple rinsed, which have contained materials
     normally shipped using a name listed in Appendix III, IV, or
     V (T,0,M)


Disposal of Pest icicle Material


Remaining stocks of certain cancelled pesticides can only be used for

certain uses.  Some holders of the cancelled pesticide who do not

have an approved application for the cancelled pesticide will find

disposal easier than finding some one to use it on an approved application.

Thus, there will be people interested in disposing of pure pesticide.


Our files on damage cases from improper disposal of Hazardous Wastes

include many incidents of damage due to the indiscriminate disposal

of pesticides.


A few examples;


YEAR            INJURY                         CAUSE


1972            3 children hospitalized:      mother found old oil can by road
                comatose and respiratory      poured on ground (methyl na-rai-h-!««->
                difficulty in Batesville,                              F*ratnionj
                MS


1972            child ill in Salt Lake, UT    found powdered pesticide with
                                              no label, broken, and sat  in
                                              spilled powder

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YEAR                   INJURV                         CAUSE


1975                   child comatose in hospital     played with bags contained
                       2 days in Nash Co., NC         Di-syston pesticide


                       organophosphate poisoning      spillage pesticide can as
                       child in Robeson, NC           thrown in woods
Disposal  of off-specification pesticides


A pesticide batch  can be off-specification  due to a high concentration of
  ; I
contaminants or congenerated highly toxic species exceeding the allowable

limits  for the materials market as a pesticide.  For example 2,4,5,-T

can be  produced with varying levels of dioxi|\ depending on temperature

control during the reaction.  Bad batches could be bad because of a

high  concentration of dioxin in the pesticide.  Specific regulation

or analysis of each bad batch to determine if it was toxic enough

to require more costly disposal would be extremely expensive.

For infrequent waste streams such as bad batches, controlling the disposal

by blanket inclusion of all bad batches of these pesticides is prefered

as it has the lowest total resource requirements for industry and EPA.


Our files on damage cases from improper disposal of Hazardous Wastes

include incidents  of damage due to the toxic effect of cogenerated

highly  toxic species present in the waste.


For example:


YEAR                     INJURY                      CAUSE


1971                     people ill and 1            waste oil sprayed on arena

                         hemmoraging of kidney,      to keep down dust (contained
                         60 horses dead, deformed    TCDD)

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YEAR                      INJURY                          CAUSE


                          foals and dead pets in
                          Verona, MO


1974                      2 girls sick, 1 physically      oiling down horse
                          impaired, 35 exposed in         arena (dioxin content)
                          Bloomfield and Mosco Mills,
                          MO


Disposal of spill clean up material from a pesticide spill


Spill clean up materials of these substances are included on the

Hazardous Waste list due to the toxic effectsjbf the substance.   The

mixing of these substances with earth does not mitigate the effect

of these substances when disposed of on the land.  If it is mobile

thru the soil disposal environment, co-disposing of these substances with

the earth picked up at the spill site will not materialy affect the

potential hazard of migration of the substance to ground water.


Disposal of unrinsed containers


Unrinsed containers have the potential for rainfall washing out the

contents into the environment.  Triple rinsing removes the water

solvable material and thus reduces significantly the amount of material

available for flushing out by rainfall.


Our files on damage cases from improper disposal of hazardous wastes

include many incidents where the unrinsed, used container has caused

problems.


For example

-------
YEAR
INJURY
CAUSE
 1968



 1968



 1969


 1972



 1972


 1974


 1974
2 boys ill and 1 died of
dermal poisoning in
Dunning, NE
old drum top cut out for trash
and filled with water to play
in (Parathion)
abdominal pains, vomitting  pesticide container disposal
required hospitalization    near well (Lindane)
in Neshanic Station, NJ
14 cattle dead in Jerome
ID

2 yr. old hospitalized
for organophosphate
poisoning in Hughes,  AR

2 children die in
Memphis, TN
ate from empty Di-Syston bags
which blew into pasture

playing in empty pesticide
drums, mayor bought for
trash containers (parathion)

emptied container in backyard
(parathion)
2 yr. old ill in Oak City   drank from empty can
UT

8 cattle dead in
Elizabeth City,  NC
(Furodan)

farmer burned old pesticide
containers
Cas)
Examples  of the types of pesticide related materials that are typically

disposed  of are illustrated in Figure 1.  As is evident from the figure,

this type of material can be extremely toxic.

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    Figure  1
              Sample  Pesticide*  -  related  waste  material  disposed  of to
              California  Class  1 sites   (1978)
Industry Process Generic Name
2879
Pesticides






2879
Pesticide
Formulation





2879
Pesticides


2879
Pesticides

2879
Pesticides




Pesticide
production
and research





Pesticide
Blending






Unspecified



Off -spec
Aerosol Cans


Unspecified




Pesticide
wastes






Pesticides






Pesticides



Tomato
Blossom
Fruit
Set

Pesticides



Components $ Typical Load Siz

a) solvents 7 tons

b) off-spec pesticides 17 tons
c) rinse water and
pesticides 5 tons
d) empty unrinsed .
containers 25 tons

2-50% organo phosphates
2-50% chlorination hydrocarbons
2-50% carbanates
2-30% organic metals
£-60% clays
2-60% solvents 7 cu
yds

22% DBCP
6.5% Malthion
81.5% petroleum oil Q.5 ton

42% beta-naphoxyacetic acid
523 gal.


a) dinitrophenol
solution 46 gal
b) miscellaneous
insecticides 5 tons
*Taken from "Handbook of Industrial Waste Compositions
in California" D.L.  Storm, Dept.  of Health,  California 1978

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 . astry
                   Process
                 Generic Name
                      Components 5 Typical Laad Size
2879
Pesticides
2879
Pesticides
2879
Pesticides
Intermediates
Production
Floor
Sweeping


Unspecified
                                    Unspecified
                                    Pesticides
Off-spec
Chemicals
2879
Pesticides
Unspecified
Alkaline
Solution
and
Solvent
                   50-60%  tetrahydrophthalamide
                   40-50%  water               37 drums
                   85-95%  difolatan fungicide
                    5-15%  floor sweepings     30 drums
a)
b)
c)
d)
sulfur
empty bottles
paint solvent
mixed pesticides
from dust collector
                                                                                    14  tons
 5%  methylene chloride
85%  water
10%  miscellaneous
     chemicals  and
     pesticides        1600 gal.

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A primary exposure route to the public for toxic contaminants is through



drinking water.  A large percentage of drinking water finds its source



in groundwater.  EPA has evidence to indicate that industrial wastes as



presently managed and disposed often leaches into and contaminates the




groundwater.  The Geraghty and Miller report1 indicated that in 98% of 50




randomly selected on-site industrial waste disposal sites, toxic heavy



metals were found to be present, and that these heavy metals had migrated



from the disposal sites in 80% of the instances.  Selenium,



arsenic and/or cyanides were found to be present at 74% of the sites



and confirmed to have migrated at 60% of the sites.






At 52% of the sites toxic inorganics (such as arsenic, cadmium, etc.)



in the groundwater from one or more monitoring wells exceeded EPA




drinking water limits (even after taking into account the upstream



(beyond the site) groundwater concentrations).






Geraghty and Miller  also found that in a majority of the fifty sites



examined organic contamination of the groundwater above background




levels was observed.  In 28 (56%) of these sites chlorinated organics



attributable to waste disposal were observed in the groundwater.  While



specific identification of these organics was not always undertaken




in this work,  (other incidents and reports (References 2 through 8) do




qualitatively identify leached organic contaminants in groundwater),



it certainly serves to demonstrate that organic contamination of




groundwater frequently results from industrial  waste disposal.  Since




the Administrator has determined "that the presence in drinking water




of chloroform and other trihalomethanes, and synthetic organic chemicals



may have an adverse effect on the health of persons ..."* and, as noted

-------
 above, because much drinking water finds its source as groundwater,  the



 presence of available toxic organics in waste is a critical factor in



 determining if a waste presents a hazard when managed.  (For a discussion



 of how the toxicity and concentration of organic contaminants in waste



 are considered in the hazard determination see Toxicity background document)
*•• Interim Primary Drinking  Water  Regulations,"



 < 5765,  Federal  Register, 2/9/78

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A brief description of the toxic effects that caused the pesticides to be

listed follows:
Pesticide
Toxic effects
ARAMITE

BAAM (AMITRAZ)

BENOMYL
CHLORANIL



CHLOROBENZILATE



DBCP




DIALLATE

DIMETHOATE
EBDC's


KEPONE

MALEIC HYDRAZIDE



MIREX

MONURON

OMPA (Octamethylpyro-
phosphoramide)

PCNB
 Oncogenicity

 Oncogenicity in mice.

 Reductions in non-target species
 (earthworms); mutagenicity (multitest);
 teratogenicity in rats; reproductive
 effects Cspermatogenic reduction in
 rats); hazard to wildlife (aquatic
 organisms).

 Possible oncogen
 (Innes-Bionetic Study)

 Oncogenicity in mice
 Testicular Effect in Rats

 Oncongenictiy in mice and rats;
 reproductive effects in test
 animals and possibly in humans.

 Oncongenicity in mice and rats.

 Oncongenicity in rats; mutagenicity
 in bacteria, yeast, fungi and mice;
 fetotoxicity and reproductive effects
 in mice.

 Oncongencity in mice and rats; Teratogenicitv
 in rats; hazard to wildlife (aquatic organisms).

 Oncongenicity in mice and rats.

 Oncongenicity in mice, mutagenicity
 in plants, flies, rats; reproductive
 effects in rats.

 None presented pesticide has been cancelled

 Oncongenicity in mice and rats.

 Oncongencity
 Oncongenicity in mice

-------
Pesticide
 Toxic  effects
PHENARSAZINE CHLORIDE



POLYCHLORINATED TERPHENYLS


PRONAMIDE

STROBANE

2,4,5-T



1080/1081


THIOPHANATE METHYL


TRYSBEN
 None presented  pesticide was
 voluntarily  cancelled
None presented pesticide has been
cancelled

Oncongenicity in rats

Possible oncogenicity

Possible oncogenicity and
teratogenic and fetotoxic
effects due to dioxin contaminants

Fatalities in non-target mammalian
species and endangered species.

Mutagenicity and reduction of
non-target species (earthworms)

Oncongenicity due to nitrosamine
contaminants

-------
More complete toxicological descriptions can be found in the Federal




Register Publication.  The dates of the Federal Register Notices for



each listed pesticide are given below.
                                       Federal Register Date
Pesticide
Aramite



BAAM



Benomyl




Benzac




Chloranil



Chlorobenzilate



DBCP




Diallate




Dimethoate



EBDC



Kepone




Maleic Hydrazide



MIREX



Monuron




OMPA



PCNB




Phenarzine Chloride




Pol/chlorinated Terphenyls




Pronamide



Strobane




2,4,S-T
                                        4/12/77




                                        4/6/77




                                        12/6/77




                                        8/8/77




                                        1/19/77




                                        5/26/76




                                        9/22/77




                                        5/31/77




                                        9/12/77




                                        8/10/77




                                        7/27/77




                                        10/28/77




                                        Cancelled




                                        8/16/77




                                        5/28/76




                                        10/13/77




                                        11/21/77




                                        Cancelled




                                        5/20/77




                                        6/28/76




                                        4/21/78

-------
1080/1081                               12/1/76




Thiophonate Methyl                      12/7/77




Trysben                                 2/9/78

-------
         Waste Rock & Overburden From Uranium Mining


     In the Administrator's judgment this waste stream poses

a potential radiological hazard.  Our information indicates that

waste rock and overburden contain the following:

          lOpCi/gr average activity of Radium -226.
          Reference:  Background document - Identification
          and Listing of Hazardous Radioactive Waste
          Pursuant to the Resource Conservation and
          Recovery Act of 1976.  December, 1978.

     Large volume wastes containing elevated Radium  -226

concentrations dispersed throughout a non-radioactive medium

present an environmental problem because of potential hazard

to the health of those chronically exposed to such wastes.

     Radium-226 is a naturally - occurring radionuclide.  The

extraction and processing of certain ores enriched in radium

result in its redistribution, thereby creating opportunities

for environmental contamination and exposure of the  public to

hazardous levels of radioactivity.  Radium-226 is relatively

abundant and has a half-life of 1620 years.  Its radiotoxic

properties have been extensively studied in relation to increased

incidence of occupationally - related bone cancer and aplastic

anemia.  The major health hazard is due, however, to inhalation

of the decay products of Radium-226.  Radon-222,  the first

generation decay product, is a noble gas.  Radon-222, decays to

several daughter products which, upon inhalation, deposit

in and irradiate the lung by emission of alpha particles.  Studies

link exposure of this nature with an increase in lung cancer

induction.  External exposure to gamma radiation emitted by rad

-------
decay products has also been implicated in serious genetic abnormal-

ities and increased incidence of cancer.   (See background document

for more information).
                                             of ^***«. rocK and
     Radon-222 emanates continuously from the piles.    creat-
                                                    /»»
ing a hazard to public health.

-------
CHLORINATOR RESIDUES AND CLARIFIER SLUDGE FROM ZIRCONIUM EXTRACTION
     If improperly managed,  these wastes present a  potential
hazard to human health and the environment.   The principal hazards
associated with the chlorinator residues and clarifier  sludge
from zirconium extraction are direct exposure to gamma  radiation
and contamination of surface and ground waters due  to high con-
centrations of soluble Radium-226.  Our information indicates
that the wastes contain 150-1300 pCi'/gr of Radium-226.
     Radium-226 is a naturally-occurring radionuclide with a
half-life of 1620 years.  It is relatively abundant in  the
environment.  The extraction and processing  of certain  ores
enriched in radium result in the redistribution of  the  radionuclide
thereby creating opportunities for environmental contamination
and exposure of the public to hazardous levels of radioactivity,
     The ratio toxic properties of Radium-226 have been  extensively
studied in relation to an increased incidence of occupationally
related cancer.  Radium has  chemical characteristics similar to
calcium and will concentrate in bone after ingestion.   Decay by
alpha emission follows.  External exposurer  to gamma radiation
emitted by radium decay products has also been implicated in
increased incidences of cancer and serious genetic  abnormalities
(See Background Document for additional information)
     Reference:  Radioactivity Background Document
                 RCRA §3001. Dec. 1978

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 Overburden and Slimes From Phosphate Surface Mining

     In the Administrator's judgment, these wastes pose a
potential radiological hazard.  Our information indicates that
overburden and slimes contain the following:
          Mine overburden: 5-10 pCi/gr. average Radium-226 activity
          Slimes:  35-45 pCi/gr. average Radium-226 activity
     Large volume wastes containing elevated Radium - 226 concen-
tractions dispersed throughout a non-radioactive medium present
an environmental problem because of potential hazard to the health
of those chronically exposed to such wastes.
     Radium-226 is a naturally - occurring radionuclide.  The
extraction and processing of certain ores enriched in radium result
in its redistribution, thereby creating opportunities for environ-
mental contamination and exposure of the public to hazardous
levels of radioactivity.  Radium - 226 is relatively abundant
and has a half-life of 1620 years.  Its radiotoxic properties
have been extensively studied in relation to increased
incidence of occupationally - related bone cancer and aplastic
anemia.  The major health hazard is due, however, to inhalation
of the decay products of Radium-226.  Radon-222, the first
generation decay product, is a noble gas.  Radon-222 decays to
several daughter products which, upon inhalation, deposit in and
irradiate the lung by emmission of alpha particles.  Studies
link exposures of this nature with an increase in lung cancer
induction.  External exposure to gamma radiation emitted by radon
decay products has also been implicated in serious genetic
abnormalities and increased incidence of cancer.
(See background document for more information)

-------
      Studies conducted on reclaimed land  containing  these  wastes


reveal the existence of a potential public  health  problem  due to


elevated air concentrations  of radon decay  products  in  some


structures built on the reclaimed land.   Chronic exposure  to the


radiation levels in these structures could  result  in approximately

doubling the lifetime risk of developing  lung  cancer to the exposed


person.   In Florida, as many as 4000 existing  structures may require

evaluation to determine whether remedial  action is necessary.
                                                         ^

The application of radiation control measures  is strongly
            _£/*-f*
recommended orr*the construction of new buildings,  especially


dwellings.  These same studies indicate a correlation between a


soil concentration of Radium-226 greater  than  5 pCi/gr.  and


the elevated radon progeny levels in structures built on such


     .   (See background for additional information).


      Reference:  Background  document - Indentification


                  and Listing of Hazardous Radioactive

                  Waste Pursuant to the Resource

                  Conservation and Recovery  Act


                  of 1976. December, 1978.

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        Waste Gypsum From Phosphoric Acid Production


      In the Administrator's judgment, this waste stream poses

a potential radiological hazard.  Our information indicates

that  gypsum from phosphoric acid production contains the

following:

           20-30 pCi/gr average Radium-226 activity.
           Reference: Background document - Identification
           and Listing of Hazardous Radioactive Waste Pursuant
           to the Resource Conservation and Recovery Act or
           1976.  December, 1978.

      Large volume wastes containing elevated Radium-226 concentra-

tions dispersed throughout a non-radioactive medium present an

environmental problem because of potential hazard to the

health of  those chronically exposed to such wastes.

      Radium-226 is a naturally - occurring radionuclide.  The

extraction and processing of certain ores enriched in radium result

in its distribution, thereby creating opportunities for environ-

mental contamination and exposure of the public to hazardous

levels of  radioactivity. Radium-226 is relatively abundant and has
                   years
a half life of 1620.  Its radiotoxic properties have been
                   \
extensively studied in relation to increased incidence of

occupationally related bone cancer and aplastic anemia.  The major

health hazard is due, however, to inhalation of the decay products

of Radium-226.  Radon-222, the first generation decay products^

is a  noble gas.  Radon-222  decays to several daughter products

which/ upon inhalation, deposit in and irradiate the lung by

emission of alph particles.  Studies link exposure of this nature
                ^
with  an increase in lung cancer induction.  External exposure to

gamma radiation emitted by radon decay products has also been

-------
implicated in serious genetic abnormalities and increased incidence



of cancer.  (See background document for more information).



     Because Radon-222 emanates continuously from the gypsum



piles, the waste creates a hazard to human health.

-------
Slag  and  Fluid Bed Prills From Elemental Phosphorus Production




      In the Administrator's judgment, this waste stream poses


a potential radiological hazard.  Our information  indicates


that  slag and fluid bed prills contain the following:


           Slag:  20-60 pCi/gr. average Radium-226 activity

           Fluid  bed prills: 10-15 pCi/gr. average Radium-226 activity.


      Large volume wastes containing elevated Radium-226 concentra-


tions dispersed  throughout a non-radioactive medium present an


environmental problem because of potential hazard to the health


of  those  chronically exposed to such waste.


      Radium-226  is a naturally - occurring radionuclide.  The


extraction and processing of certain ores enriched in radium


result in redistribution, thereby creating opportunities for


environmental contamination and exposure of the public to hazardous


levels of radioactivity.  Radium-226 is relatively abundant and has


a half-life of 1620 years.  Its radiotoxic properties have been


extensively studied in relation to increased incidence of


occupationally - related bone cancer and aplastic anemia.  The


major health hazard is due, however, to inhalation of the decay


products  of Radium-226.  Radon-222, the first generation decay


product,  is a noble gas.  Radon-222 decays to several daughter


products  which,  upon inhalation, deposit in and irradiate the


lung  by emission of alpha particles.  Studies link exposures


of  this nature with an increase in lung cancer induction.  External


exposure  to gamma radiation emitted by radon decay products has


also  been implicated in serious genetic abnormalities and


increased incidece of cancer.   (See background document for
                A

more  information).

-------
     Radon-222 emanates continuously from these wastes.


A Radium-226 activity level exceeding 5 pCi/gr in the soil of


land reclaimed from phosphate mining activites correlates with


significant elevation of radon progeny levels inside structures


built on such land and, on that basis, creates a hazard to human


health.  (See background document for additional information) .

                                         S
     Reference:  Background document - I/identification
                                        <~t

                 and Listing of Hazardous Radioactive


                 Waste Pursuant to the Resource


                 Conservation and Recovery Act of


                 1976.  December, 1978.

-------
                          TEXTILES
Wo°l Fabric Dyeing and Finishing Wastewater Treatment Sludges

     This waste  stream is hazardous because of its toxic pro-
perties.  According to data EPA has on this waste stream, it
meets  the RCRA §250.13a(4) characteristic identifying a toxic
hazardous waste.
     The .National Interim Primary Drinking Water Regulations
(NIPDWR) set  limits for chemical contamination of drinking water.
The substances listed represent hazards to human health.  In
arriving at these specific limits, the total environmental ex-
posure of man to a stated specific toxicant has been considered.
(For a complete  treatment of the data and reasoning used in choos-
ing the substances and specified limits please refer to the
NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 - 76 - 003).
     A primary exposure route to the public for toxic contaminants
is through drinking water.  A large percentage of drinking water
finds  its source in groundwater.  EPA has evidence to indicate
that industrial wastes as presently managed and disposed often
leach  into and contaminate the groundwater.  The Geraghty and
Miller report indicated that in 98% of 50 randomly selected on-
site industrial waste disposal sites, toxic heavy metals were
found  to be present, and that these heavy metals had migrated
from the disposal sites in 80% of the instances.  Selenium,
arsenic and/or cyanides were found to be present at 74% of the
sites  and confirmed to have migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (s.a. arsenic,

cadmium etc.)  in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream  (beyond the site)  groundwater con-

centrations) .

     The following table compares the concentrations of con-

taminants found in wool fabric dyeing and finishing wastewater

treatment sludges to the limits established by the NIPDWR.

                         Drinking Water
Parameter                Limit (ppm)
Arsenic
Barium
Cadium
Mercury
Reference:
0.05
1.00
0.01
0.002
Versar, Inc. Assessment
Waste Practices, Textile
June, 1976 p. 3-23.

<170
17
<1.7
of Industrial Hazardous
Industry PB# £li8-9S3, '

     The above data suggest that the waste presents a hazard  to

human health and the environment.

-------
       a,                 TEXTILES
Woven Fabric Dyeing  and Finishing Wastewater Treatment Sludges

      This waste  stream is classified as hazardous because of its
toxic properties.  According to data EPA has on this waste stream,
it meets the RCRA  250.13a{4) characteristic identifying a toxic
hazardous waste.
      The National  Interim Primary Drinking Water Regulations
(NIPDWR)  set limits  for chemical contamination of Drinking Water.
The  substances listed represent hazards to human health.  In
arriving at these  specific  limits, the total environmental ex-
posure of man to a stated specific toxicant has been considered.
(For a complete  treatment of the data and reasoning used in choos-
ing  the substances and specified limits please refer to the
NIPDWR Appendix  A-C  Chemical Quality, EPA-6570/9 - 76 - 003) .
      A primary exposure route  to the public for toxic con-
taminents is through drinking  water.  A large percentage of
drinking water finds its source in groundwater.  EPA has evidence
to indicate that .industrial wastes as presently managed and dis-
                                     tfc-
posed often leach    into and contamina    the groundwater.  The
Geraghty and Miller  report1 indicated that in 98% of 50 randomly
selected on-site industrial waste disposal sites/ toxic heavy
metals were found  to be present, and that these heavy metals had
migrated from the  disposal  sites in 80% of the instances.  Selenium,
arsenic and/or cyanides were found to be present at 74% of the
gites and confirmed  to have migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (s.a.  arsenic,
cadmium etc.) in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits (even after taking into
account the upstream (beyond the site)  groundwater concentrations) .
     The following table compares the concentrations of contaminants
found in woven fabric dyeing and finishing wastewater treatment
sludges to the limits established by the NIPDWR.
Parameter
Drinking Water
Limit (ppm)
Arsenic
Barium
Cadmium
Chromium
Lead
Reference:

0.05
1.0
0.01
0.05
0.05
Versar, Inc. Assessment of Industrial
Waste Practices, Textile Industry PB#
June, 1976 p. 3-37
1
39
4.4
1,196
36
Hazardous
2^—953 '"

     The above data suggest  that the waste presents a hazard to
human health and the environment.

-------
                          TEXTILES
Knit Fabric Dyeing  and Finishing Wastewater Treatment Sludges

      This waste stream is classified as hazardous because of its
toxic properties.   According  to data EPA has on the waste stream,
it meets the RCRA s250.13a(4) characteristic identifying a toxic
hazardous waste.
      The National Interim Primary Drinking Water Regulations
(NIPDWR)  set limits for chemical contamination of Drinking Water.
The  substances  listed represent hazards to human health.  In
arriving at these specific limits, the total environmental ex-
posure of man to a  stated specific toxicant has been considered.
(For a complete treatment of  the data and reasoning used in choos-
ing  the substances  and specified limits please refer to the
NIPDWR Appendix A-C Chemical  Quality, EPA-6570/9 - 76 - 003) .
                                                              a-
      A primary  exposure route to the public for toxic contaminants
is through drinking water.  A large percentage of drinking water
finds its source in groundwater.  EPA has evidence to indicate
that industrial wastes as presently managed and disposed often
                          -tt.
leach   into and contamina    tr-.  groundwater.  The Geraghty and
Miller report1  indicated that in 98% of 50 randomly selected on-
site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated
from the disposal sites in 80% of the instances.  Selenium, arsenic
and/or cyanides were found to be present at 74% of the sites and
confirmed to have migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (s.a. arsenic,

cadmium etc.)  in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream (beyond the site)  groundwater con-

centrations) .

     The following table compares the concentrations of con-

taminants found in knit fabric dyeing and finishing wastewater

treatment sludge to the limits established by the NIPDWR.
                         Drinking Water
Parameter                Limit (ppm)               Ave. Cone.
Arsenic
Cadmium
Chromium
Lead
Mercury
Reference:

0.05 <<4.8
0.01 <4.5
0.05
0.05
0.002
Versar, Inc. Assessment of Industrial
Waste Practices, Textile Industry PB#
June, 1976 p. 3-49.
33
< 52
1.4
Hazardous
^btJ-9^3

     The above data suggest that the waste presents a hazard  to

human health and the environment.

-------
                          TEXTILES
Yarn  and  stock dyeing and finishing wastewater treatment sludges.
      This waste  stream is classified as hazardous because of its
toxic properties.  According to data EPA has on the waste stream,
it meets  the RCRA  §250.13a(4) characteristic identifying a toxic
hazardous waste.
      Our  information indicates that the waste contains chromium,
lead  and  mercury.
      The  National  Interim Primary Drinking Water Regulations
(NIPDWR)  set limits for chemical contamination of drinking water.
The substances listed represent hazards to human health.  In
arriving  at these  specific limits, the total environmental ex-
posure of man to a stated specific toxicant has been considered.
(For  a complete  treatment of the data and reasoning used in
choosing  the substances and specified limits please refer to the
NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 - 76 - 003).
      A primary exposure route to the public for toxic contaminants
is through  drinking water.  A large percentage of drinking water
finds its source in groundwater.  EPA has evidence to indicate
that  industrial wastes as presently managed and disposed often
leach into  and contaminate the groundwater.  The Geraghty and
Ciller report1 indicated that in 98% of 50 randomly selected on-
site  industrial waste disposal sites, toxic heavy metals were
found to  be present, and that these heavy metals had migrated
from  the  disposal  sites in 80% of the instances.  Selenium,
arsenic and/or cyanides were found to be present at 74% of the
sites and confirmed to have migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (s.a. arsenic,

cadmium etc.)  in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream (beyond the site)  groundwater con-

centrations) .

     The following table compares the concentrations of con-

taminants found in yarn, stock dyeing and finishing wastewater

treatment sludge to the limits established by the NIPDWR.
Parameter

Chromium
Lead
Mercury
Drinking Water
Limit (ppm)

     0.05
     0.05
     0.002
Ave. cone, (ppm)

          31
         1660
         0.66
     Reference:  Versar, Inc.  Assessment of Industrial
                 Hazardous Waste Practices,  Textile
                 Industry!PB#258-953. June 1976
                 p. 3-73.
     The above data suggests that the waste presents a hazard

to human health and the environment.

-------
                          TEXTILES
   Carpet Dyeing and Finishing Wastewater Treatment Sludges

     This waste stream is classified as hazardous because of its
toxic properties.  According to data EPA has on this waste stream,
it meets the RCRA §250.13a(4) characteristic identifying a toxic
hazardous waste.
     The National Interim Primary Drinking Water Regulations
(NIPDWR) set limits for chemical contamination of drinking water.
The  substances listed represent hazards to human health.  In
arriving at these specific limits, the total environmental ex-
posure  of man to a stated specific toxicant has been considered.
(For a  complete treatment of the data and reasoning used in
choosing the substances and specified limits please refer to
the  NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 - 76 - 003).
     A  primary exposure route to the public for toxic contaminants
is through drinking water.  A large percentage of drinking water
finds its source in groundwater.  EPA has evidence to indicate
that industrial wastes as presently managed and disposed often
leach into and contaminate the groundwater.  The Geraghty and
Miller  report  indicated that in 98% of 50 randomly selected on-
site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated
from the disposal sites in 80% of the instances.  Selenium,
arsenic and/or cyanides were found to be present at 74% of the
sites and confirmed to have migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (s.a. arsenic,

cadmium etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream (beyond the site)  groundwater con-

centrations) .

     The following table compares the concentrations of con-

taminants found in the waste to the limits established by the

NIPDWR.

                         Drinking Water
Parameter                Limit (ppm)               Ave. Cone, (ppml

Arsenic                       0.05                     10
Cadmium                       0.01                     10
Chromium                      0.05                    112
Lead                          0.05                    110

     Reference:  Versar, Inc.  Assessment of Industrial Hazardous
                 Waste Practices.  Textile Industry*PB& 956-063-—
                 June 1976.p.3-61.

     The above data suggest that the waste presents a hazard to

human health and the environment.

-------
                          TEXTILES
           WOOL  SCOURING WASTEWATER TREATMENT SLUDGES
      This  waste stream is classified as hazardous because of its
toxic properties.  According to data EPA has on this waste stream,
it meets the  RCRA  §250.13a(4) characteristic identifying a toxic
hazardous  waste.
      Our information indicates that the waste contains the following
toxic substances:  Barium, Cadmium, Chromium, Lead.
      The National  Interim Primary Drinking Water Regulations
(NIPDWR) set  limits for chemical contamination of drinking water.
The  substances  listed represent hazards to human health.  In
arriving at these  specific limits, the total environmental exposure
of man to  a stated specific toxicant has been considered.  (For
a complete treatment of the data and reasoning used in choosing
the  substances  and specified limits please refer to the NIPDWR
Appendix A-C  Chemical Quality, EPA-6570/9 - 76 - 003).
      A primary  exposure route to the public for toxic contaminants
is through drinking water.  A large percentage of drinking water
finds its  source in groundwater.  EPA has evidence to indicate
that industrial wastes as presently managed and disposed often
leach into and  contaminate the groundwater.  The Geraghty and
Miller report1  indicated that in 98% of 50 randomly selected on-
site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated
from the disposal  sites in 80% of the instances.  Selenium,
arsenic and/or  cyanides were found to be present at 74% of the
sites and  confirmed to have migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (s.a. arsenic,

cadmium etc.)  in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream (beyond the site)  groundwater con-

centrations) .

     The following table compares the concentrations of con-

taminants found in the waste to the limits established by the

NIPDWR. '

                         Drinking Water
Parameter                Limit (ppnp	      Ave. cone, (ppm)

Barium                        1.0                  59
Cadmium                       0.01                 1.2
Chromium                      0.05                 19
Lead                          0.05                 28

     Reference:  Versar, Inc.  Assessment of Industrial
                 Hazardous Waste Practices,  Textile
                 Industry. PB# 258-953. June. 1976 p.3-14.

     The above data suggest that the waste presents a hazard

to human health and the environment.

-------
812      Mercury bearing sludges from brine treatment from
         mercury cell process in chlorine production (T)
         The National Interim Primary Drinking Water Regulations
    (NIPDWR) set limits for chemical contamination of Drinking
    Water.  The substances listed represent hazards to human
    health.  In arriving at these specific limits, the total
                   x
    environmental efposure of man to a stated specific toxicant
    has been considered.   (For a complete treatment of the data
    and reasoning used in choosing the substances and specified
    limits please refer to the NIPDWR Appendix A-C Chemical
    Quality/ EPA-6570/9 - 76 - 003).

         A primary exposure route to the public for toxic con-
    taminents  is through drinking water.  A large percentage
    of drinking water finds its source in groundwater.  EPA has
    evidence to indicate that industrial wastes as presently managed
    and disposed often leaches into and contaminents the groundwater,
    The Geraghty and Miller report1 indicated that in 98% of 50
    randomly selected on-site industrial waste disposal sites,
    toxic heavy metals were found to be present, and that these
    heavy metals had migrated from the disposal sites in 80% of
    the instances.  Selenium, arsenic and/or cyanides were found
    •to be present at 74% of the sites and confirmed to have
    migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (such as arsenic,

cadmium etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream  (beyond the site)  groundwater

concentrations).


                                                      ••

     Mercury is one of the toxicants listed by the NIPDWR at

a concentration of .002mg/l because of its toxicity.  As

explained in the RCRA toxicity background document this

converts to  .02mg/l level in the  EP extract.



     This waste has been shown to contain as high as lOOppm

 (approximately 100mg/l) mercury according to the following

report:
          Versar, Inc. "Assessment of Industrial  Hazardous
          waste Practices, Inorganic Chemicals Industry
          "Contract # 68-01-2246 p.5-8
     Because of this the Agency feels that this waste stream

could pose a threat to human health and the environment.
                         ICO

-------
j>612      Sodium calcium sludge from production of chlorine by

          Down Cell process  (R)
          Reactive wastes as defined by Section 250.14 of RCRA



     pose a threat to human health and the environment, either



     through the physical consequences of their reaction  (i.e.,



     high pressure and/or heat generation) or through the chemical



     consequences of their reaction  (i.e., generation of toxic



     ftomes).







          According to  "Assessment of Industrials Hazardous



     waste Practices, Inorganic Chemicals Industry  'Contract



     #68-01-2246 Versar Inc. p. 5-lljthis waste stream contains



     a mixture of sodium cal/S^cjum metal.  These metals in their


            A                 V

     element state react very Vigorously with water to produce
            r


     hydrogen gas.  For this reason this waste is extremely



     hazardous and must be disposed of under carefully controlled



     conditions to avoid explosions or fires.
                              I0\

-------
2812      Mercury bearing sludges from brine treatment from
          mercury cell process in chlorine production (T)



          The National Interim Primary Drinking Water Regulations

     (NIPDWR) set limits for chemical contamination of Drinking

     Water.  The substances listed represent hazards to human

     health.  In arriving at these specific limits, the total
                    X
     environmental exposure of man to a stated specific toxicant

     has been considered.  (For a complete treatment of the data

     and reasoning used in choosing the substances and specified

     limits please refer to the NIPDWR Appendix A-C Chemical

     Quality, EPA-6570/9 - 76 - 003).




          A primary exposure route to the public for toxic con-

     taminents is through drinking water.  A large percentage

     of drinking water finds its source in groundwater.  EPA has

     evidence to indicate that industrial wastes as presently managed

     and disposed often leaches into and contaminents the groundwater.


     The Geraghty and Miller reportl indicated that in 98% of 50


     randomly selected on-site industrial waste disposal sites,

     toxic heavy metals were found to be present, and that these

     heavy metals had migrated from the disposal sites in 80% of

     the instances.  Selenium, arsenic and/or cyanides were found

     to be present at 74% of the sites and confirmed to have

     migrated at 60% of the  sites.

-------
          At 52% of the sites toxic inorganics (such as arsenic/
     cadmium etc.) in the groundwater from one or more monitoring
     wells exceeded EPA drinking water limits (even after taking
     into account the upstream  (beyond the site)  groundwater
     concentrations) .

          Mercury is one of the toxicants listed by the NIPDWR
     at a concentration of . 00 2mg/j. because of its toxicity.  As
     explained in the RCRA toxicity background document this
     converts to a . 02mg/l level in the  EP extract.

          This waste has been shown to contain free mercury afld
     mercury sulfide*.  Because of the extreme toxicity of
     mercury this waste stream could be hazardous under management
                                                       A
     conditions .
*Versar / Inc •  Assessment of Industrial  Hazardous Waste Practices,
               Inorganic Chemicals Industry  "Contract #68-01-2246
               p5-8
                             103

-------
2812      Waste water treatment sludge from diaphragm cell
          process in production of chlorine (T)
          The National Interim Primary Drinking Water Regulations

     (NIPDWR) set limits for chemical contamination of Drinking

     Water.  The substances listed represent hazards to human

     health.  In arriving at these specific limits, the total

     environmental exposure of man to a stated specific toxicant

     has been considered.  (For a complete treatment of the data

     and reasoning used in choosing the substances and specified

     limits please refer to the NIPDWR Appendix A-C Chemical

     Quality, EPA-6570/9 - 76 - 003).



          A primary exposure route to the public for toxic con-

     taminents is through drinking water.  A large percentage

     of drinking water finds its source in groundwater.  EPA has

     evidence to indicate that industrial wastes as presently managed

     and disposed often leaches into and contaminents the groundwater.

     The Geraghty and Miller report1 indicated that in 98% of 50

     randomly selected on-site industrial waste disposal sites,

     toxic heavy metals were found to be present, and that these

     heavy metals had migrated from the disposal sites in 80% of

     the instances.  Selenium, arsenic and/or cyanides were found

     to be present at 74% of the sites and confirmed to have

     migrated at 60% of the sites.

-------
          At  52% of the sites toxic inorganics  (such as arsenic,

     cadmium  etc.) in the groundwater from one or more monitoring

     wells exceeded EPA drinking water limits  (even after taking

     into account the upstream  (beyond the site) groundwater

     concentrations) .



          Lead  is one of the toxicants listed by the NIPDWR at

     a concentration of .05mg/l because of its toxicity.  As

     explained  in the RCRA toxicity background document this

     converts to a .5mg/l level in the  EP extract.



          This  waste has been shown to contain lead carbonate

     in soluble concentrations to 1.7mg/l*.  Because of the
                                                          4

     toxicity and solubility of these constituents and because of

     the ability of lead to bioaccumulate^these waste streams are

     considered hazardous.
*Versar/ Inc•  Assessment of Industrial.^ Hazardous
               waste Practices, Inorganic Chemicals Industry
               "Contract # 68-01-2246

-------
2812      Chlorinated hydrocarbon bearing wastes from diaphragm
          cell process in chlorine production (0,M)


          A primary exposure route to the public for toxic con-

     taminants is through drinking water.  A large percentage

     of drinking water finds its source in groundwater.   EPA has

     evidence to indicate that industrial wastes as presently

     managed and disposed often leaches into and contaminates the

     groundwater.  The Geraghty and Miller report1 indicated that

     in 98% of 50 randomly selected on-site industrial waste dis-

     posal sites, toxic heavy metals were found  to be present, and

     that these heavy metals had migrated from the disposal sites

     in 80% of the instances.  Selenium,  arsenic and/or cyanides

     were found to be present at 74% of the sites and confirmed to

     have migrated at 60% of the sites.



          At 52% of the sites toxic inorganics (such as arsenic,

     cadmium, etc.) in the groundwater from one  or more monitoring

     wells exceeded EPA drinking water limits (even after taking

     into account the upstream (beyond the site)  groundwater

     concentrations).



          Geraghty and Miller1 also found that in a majority of ^&

     fifty sites examined organic contamination of the groundwater

     above background levels was observed.  In 28 (56%)  of these

     sites chlorinated organics attributable to waste disposal

     were observed in the groundwater.  While specific identification

-------
of these organics was not always undertaken in this work/
(other  incidents and reports  (References 2 through 8) do
qualitatively identify leached organic contaminants in
groundwater) it certainly serves to demonstrate that organic
contamination of groundwater frequently results from industrial
waste-disposal.  Since the Administrator has determined "that
the presence in drinking water of chloroform and other tri-
halomethanes and synthetic organic chemicals may have an
adverse effect on the health of persons..."* and, as noted
above,  because much drinking water finds its source as
groundwater, the presence of avialable toxic organics in
waste as a critical factor in determining if a waste presents
a hazard when managed.   (For a discussion of how the toxicity
and concentration of organic contaminants in waste are con-
sidered in the hazard determination see Toxicity background
document.)

     This Waste Stream has been found to contain Chlorinated
orpanics   in concentrations ranging from,l to l.Omg/1.
Because of the toxicity of this class of organics this waste
stream  is to be considered hazardous.
*"Interim Primary Drinking Water Regulations,"
  p. 5756, Federal Register, 2/1/78
**Versarf Inc. Assessment of Industrial  Hazardous
  waste Practices, Inorganic Chemicals Industry""
  ^contract  #  68-01-2246 p. 5 - 7
                      (Of

-------
2816      Chromium bearing wastewater treatment  sludge  from
          production of chrome green pigment  (T)
          The National Interim Primary Drinking Water  Regulations

     (NIPDWR) set limits for chemical  contamination  of Drinking Water

     The substances listed represent hazards  to human  health.   in

     arriving at these specific limits,  the total  environmental

     exposure of man to a stated specific  toxicant has been con-

     sidered.  (For a complete treatment of the data and  reasoning

     used in choosing the substances and specified limits please

     refer to the NIPDWR Appendix A-C  Chemical Quality, EPA-6570/9 -

     003).



          A primary exposure route to  the  public for toxic con-

     taminants is through drinking water.  A  large percentage of

     drinking water finds its source in groundwater.   EPA has

     evidence to indicate that industrial  wastes as  presently

     managed and disposed often leaches into  and contaminants the

     groundwater.  The Geraghty and Miller report1 indicated

     in 98% of 50 randomly selected on-site industrial waste

     disposal sites, toxic heavy metals were  found to  be  present

     and that these heavy metals had migrated from the disposal

     sites in 80% of the instances.  Selenium, arsenic and/or

     cyanides were found to be present at  74% of the sites and

     confirmed to have migrated at 60% of  the sites.

-------
     At 52% of the sites toxic inorganics (s.a. arsenic,
cadmium etc.) in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits (even after taking
into account the upstream (beyond the site)  groundwater
concentrations).

     Chromium is one of the toxicants listed by the NIPDWR
at a concentration of .05mg/l because of its toxicity.  As
explained in the RCRA toxicity background document this con-
verts to a .5mg/l level in the  EP extract.

     This waste has been shown to contain chromium.
     Because of the toxicity of chromium, This waste
is considered hazardous.

-------
2816      Chromium bearing wastewater treatment sludge and
          other chromium bearing wastes from production of
          chrome oxide green pigment (anhydrous &  hydrated)
          (T)
          The National Interim Primary Drinking Water Regulations

     (NIPDWR) set limits for chemical contamination of Drinking Water.

     The substances listed represent hazards to human health.   in

     arriving at these specific limits,  the total environmental

     exposure of man to a stated specific toxicant has been con-

     sidered.  (For a complete treatment of the data and reasoning

     used in choosing the substances and specified limits please

     refer to the NIPDWR Appendix A-C Chemical Quality,  EPA-6570/9 -

     003).



          A primary exposure route to the public for toxic con-

     taminants is through drinking water.  A large percentage of

     drinking water finds its source in groundwater.  EPA has

     evidence to indicate that industrial wastes as presently

     managed and disposed often leaches into and contaminants the

     groundwater.  The Geraghty and Miller reportl indicated that

     in 98% of 50 randomly selected on-site industrial waste

     disposal sites, toxic heavy metals were found to be present

     and that these heavy metals had migrated from the disposal

     sites in 80% of the instances.  Selenium, arsenic and/or

     cyanides were found to be present at 74% of the sites and

     confirmed to have migrated at 60% of the sites.
                            110

-------
     At 52% of the sites toxic inorganics (such as arsenic,
cadmium etc.) in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits  (even after taking
into account the upstream  (beyond the site)  groundwater
concentrations).

     Chromium is of the toxicants listed by the NIPDWR at a
concentration of .05mg/l because of its toxicity.  As
explained in the RCRA toxicity background document this
converts to a .5mg/l level in the TEP extract.

     These wastes have been shown to contain* chromic
oxidB (0^03) and chromium hydroxide (CrOH3).  These
chromium compounds will be soluble under mildly acidic
conditions.  For this reason these waste streams are
considered hazardous.
*Versar, Inc. Assessment of Industrial  Hazardous
waste Practices, Inorganic Chemicals Industry
"Contract # 68-01-2246
                         u\

-------
2816      Ferric ferrocyanide bearing wastewater treatment
          sludges from the production of iron blue pigments
          (R)
          Reactive wastes as defined by Section 250.14 of RCRA pose

     a threat to human health and the environment,  either through

     the physical consequences of their reaction (i.e., high

     pressure and/or heat generation) or through the chemical con-

     sequence of their reaction (i.e., generation of toxic fumes).



          This waste stream contains* ferric ferrocyanides.  Upon
     action of and this compound will give off hydrocyanic acid.  Also
             •

     acid bailor neutral solutions of this compound will liberate

     hydrocyanic acid under strong irradiation.
     *Versar, Inc.  Assessment of Industrial  Hazardous
     waste Practices, Inorganic Chemicals Industry
     "Contract #68-01-224b

-------
2816      Mercury bearing wastewater treatment sludges from
          the production of mercuric sulfide pigment (T)
          The National Interim Primary Drinking Water Regulations
     (NIPDWR) set limits for chemical contamination of Drinking Water,
     The substances listed represent hazards to human health.  In
     arriving at these specific limits, the total environmental
     exposure of man to a stated specific toxicant has been con-
     sidered.   (For a complete treatment of the data and reasoning
     used in choosing the substances and specified limits please
     refer to the NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 -
     003).

          A primary exposure route to the public for toxic con-
     taminants is through drinking water.  A large percentage of
     drinking water finds its source in groundwater.  EPA has
     evidence to indicate that industrial wastes as presently
     managed and disposed often leaches into and contaminants the
     groundwater.  The Geraghty and Miller reportl indicated that
     in 98% of 50 randomly selected on-site industrial waste
     disposal sites, toxic heavy metals were found to be present,
     and that these heavy metals had migrated from the disposal
     sites in 80% of the instances.  Selenium, arsenic and/or
     cyanides were found to be present at 74% of the sites and
     confirmed to have migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (such as  arsenic,

cadmium etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream (beyond the site)  groundwater

concentrations).


          Mercury is one of the toxicants listed by the NIPDWR

at a concentration of .002mg/l because of its toxicity.  As

explained in the RCRA toxicity background doucment this

converts to a .02mg/l level in the  EP extract.



     This waste stream contains* mercuric oxide (HgO)  .

Mercuric oxide is soluble in dilute acid.  Because of the

extreme toxicity of Mercury and the solubility of this

mercury compound this waste stream is to be considered

hazardous.
*Versar,Inc.Assessment of Industrial  Hazardous
waste Practices, Inorganic Chemicals Industry"
"Contract #68-01-2246
                       MM

-------
816      Chromium bearing wastewater treatment sludges
         from the production of Ti02 pigment by the chloride
         process  (T)
         The National Interim Primary Drinking Water Regulations
    (NIPDWR) set limits for chemical contamination of Drinking Water,
    The substances listed represent hazards to human health.  In
    arriving at these specific limits, the total environmental
    exposure of man to a stated specific toxicant has been con-
    sidered.   (For a complete treatment of the data and reasoning
    used in choosing the substances and specified limits please
    refer to the NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 -
    003).

         A primary exposure route to the public for toxic con-
    taminants  is through drinking water.  A large percentage of
    drinking water finds its source in groundwater.  EPA has
    evidence to indicate that industrial wastes as presently
    managed and disposed often leaches into and contaminants the
    groundwater.  The Geraghty and Miller reportl indicated that
    in 98% of  50 randomly selected on-site industrial waste
    disposal sites, toxic heavy metals were found to be present,
    and that these heavy metals had migrated from the disposal
    sites in 80% of the instances.  Selenium, arsenic and/or
    cyanides were found to be present at 74% of the sites and
    confirmed  to have migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (such as  arsenic,

cadmium etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream  (beyond the site)  groundwater

concentrations).



     These wastes contain* titanium hydroxide and small
                                         •
amounts of vanadium, copper, chromium, zarconcium and

niobium.



     Chromium is one of the toxicants listed in the NIPDWR

at a concentration of .05mg/l because of its toxicity.  As

explained in the RCRA toxicity background document this

converts to a .5mg/l level in the  EP extract.
 *Versar,  Inc. Asie"ssment of Industrial  Hazardous
 waste Practices,  Inorganic Chemicals  Industry
 "Contract #68-01-2246
                        114

-------
     According to the "Handbook of Industrial Waste Compositions



in California - 1978" - D.L. Storm, California Department of



Health Services Hazardous Materials Management Section, November



1978, the components of a quantity (4800 gal) of waste acid



solution from the chloride process in the production of titanium



dioxide had the following ranges:





     0 - 15%  hydrochloric acid



     0 - 30%  iron



     0 - 1.5% chromium



     0 - .16% magnesium



     0 - .6%  vanadium



     0 - .25% niobium





     with a pH of 1.5





     Because of the toxicity of these contaminents this waste



Stream is considered hazardous.

-------
2816      Chromium bearing wastewater treatment sludges from the
          production ot Ti02 pigment by sulfate process (T)
          The National Interim Primary Drinking Water Regulations

     (NIPDWR) set limits for chemical contamination of Drinking Water,

     The substances listed represent hazards to human health.   in

     arriving at these specific limits,  the total environmental

     exposure of man to a stated specific toxicant has been con-

     sidered.  (For a complete treatment of the data and reasoning

     used in choosing the substances and specified limits please

     refer to the NIPDWR Appendix A-C Chemical Quality,  EPA-6570/9 -

     003).



          A primary exposure route to the public for toxic con-

     taminants is through drinking water.  A large percentage of

     drinking water finds its source in groundwater.  EPA has

     evidence to indicate that industrial wastes as presently

     managed and disposed often leaches into and contaminants the

     groundwater.  The Geraghty and Miller reportl indicated that

     in 98% of 50 randomly selected on-site industrial waste

     disposal sites, toxic heavy metals were found to be present

     and that these heavy metals had migrated from the disposal

     sites in 80% of the instances.  Selenium, arsenic and/or

     cyanides were found to be present at 74% of the sites and

     confirmed to have migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics  (such as  arsenic,


cadmium etc.) in the groundwater from one or more monitoring


wells exceeded EPA drinking water limits  (even after taking


into account the upstream  (beyond the site) groundwater


concentrations).





     Chromium is one of the toxicants listed by the NIPDWR


at a concentration of  .05mg/l because of its toxicity.  As


explained in the RCRA  toxicity background document this converts
     s

to a .mg/1 level in the  EP extract.
      *




     This waste has been shown* to contain chromium hydroxide


at concentrations of between 0 to 185 ppm in the sludge solids.


This waste stream will also contain a large amount of Calcium


sulfate.  The calcium  sulfate will tend to keep the pH of any


water (or leachate) percolating through this waste at a pH


of approximately 5.5.  At this pH the concentration of trivalent


chromium in the leachate may be as high as 50mg/l.
 *Versar, Inc. Assessment of Industrial  Hazardous
 t^aate Practices, Inorganic Chemicals Industry

 •^Contract f 68-01-2246

-------
2816      Arsenic bearing sludges from purification process
          in the production of antimony oxide (T)
          The National Interim Primary Drinking Water Regulations

     (NIPDWR) set limits for chemical contamination of Drinking Water,

     The substances listed represent hazards to human health.   In

     arriving at these specific limits, the total environmental

     exposure of man to a stated specific toxicant has been con-

     sidered.  (For a complete treatment of the data and reasoning

     used in choosing the substances and specified limits please

     refer to the NIPDWR Appendix A-C Chemical Quality/  EPA-6570/9 -

     003).



          A primary exposure route to the public for toxic con-

     taminants is through drinking water.  A large percentage of

     drinking water finds its source in groundwater.  EPA has

     evidence to indicate that industrial wastes as presently

     managed and disposed often leaches into and contaminants the

     groundwater.  The Geraghty and Miller report1 indicated that

     in 98% of 50 randomly selected on-site industrial waste

     disposal sites, toxic heavy metals were found to be present

     and that these heavy metals had migrated from the disposal

     sites in 80% of the instances.  Selenium, arsenic and/or

     cyanides were found to be present at 74% of the sites and

     confirmed to have migrated at 60% of the sites.
                              I3o

-------
     At 52% of the sites toxic inorganics (such as  arsenic,

cadmium etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream (beyond the site)  groundwater

concentrations).



     Arsenic is one of the toxicants listed by the NIPDWR at

a concentration of ,05mg/l because of its toxicity.  As

explained in the RCRA toxicity background document this

converts to a  .5mg/l level in the  EP extract.



     These wastes has been shown to contain* Arsenic

compounds such as arsenic trisulfide (AS2S3) Arsenic tri-

sulfide is soluble in alkalfne solutions (e.g. carbonates.)

Because of the toxicity of arsenic and the solubility of

this compound>this waste stream is to be considered hazardous
*Versar,Inc. Assessment of Industrial  Hazardous
waste Practices, Inorganic Chemicals Industry
"Contract  #  68-01-2246

-------
2816      Antimony bearing wastewater treatment sludge from
          product of antimony oxide (T)
          This waste stream will cont*. (along with the previously

     mentioned arsenic Compounds)  antimony compounds (e.g.  Antimony

     Trioxide).   Antimony Trioxide is readily soluble in acetic acid

     (a typical light violatile a»d found in leachates).  Antimony

     poisoning closely parrallels arsenic poisoning.  Because of the

     toxicity and solubility of an^mnony this waste is considered

     a hazardous waste.
     *Versar, Inc. Assessment of Industrial  Hazardous
     waste Practices,  Inorganic Chemicals Industry
     "Contract # 68-01-2246

-------
«2816       Chromium  or  lead  bearing wastewater  treatment  sludge
           from production of chrome yellows and oranges  (lead
           chromate)  (T)
           The  National  Interim  Primary  Drinking Water  Regulations
      (NIPDWR)  set limits  for chemical contamination of Drinking  Water.
      The  substances  listed  represent hazards  to human  health.  In
      arriving  at these  specific limits,  the total  environmental
      exposure  of man to a stated specific  toxicant has been  con-
      sidered.   (For  a complete  treatment of the data and  reasoning
      used in choosing the substances and specified limits please
      refer to  the NIPDWR  Appendix A-C Chemical Quality, EPA-6570/9  -
      003).

           A primary  exposure route to the  public  for toxic con-
      taminants is through drinking water.  A  large percentage  of
      drinking  water  finds its  source in groundwater.   EPA has
      evidence  to indicate that  industrial  wastes  as presently
      managed and disposed often leaches into  and  contaminants  the
      groundwater. The  Geraghty and Miller report1 indicated that
      in 98% of 50 randomly  selected on-site industrial waste
      disposal  sites, toxic  heavy metals were  found to  be  present,
      and  that  these  heavy metals had migrated from the disposal
      sites in  80% of the  instances.  Selenium, arsenic and/or
      cyanides  were found  to be  present  at  74% of  the sites and
      confirmed to have  migrated at 60%  of  the sites.

-------
     At 52% of the sites toxic inorganics (such as arsenic,

cadmium etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream (beyond the site)  groundwater

concentrations).


     Chromium and lead are two of the toxicants listed by

the NIPDWR both at concentration of .05mg/l  because of

their toxicity.  As explained in the RCRA toxicity back-

ground document this convers to a .5mg/l level in the

EP extract.


     This waste has been shown to contain* lead salts

 (e.g. lead hydroxide, lead chromate, and chromium hydroxide

 (Cr 01*3) .  Chromium hydroxide is soluble in  acidic media.

At pH 5 a saturated solution will contain 5.2X10"1g/l of

trivalent chromium.  Under saturated conditions (i.e. if

equilibrium were reached) then there would be 100 time the

 .5mg/l concentation limit in solution.  Because of the toxicity

of chromium and the solubility of this salt this waste is con-

 sidered hazardous.  Lead chromate is one of the more insoluble

lead salts, however it will reach a concentration level up to

 .2mg/l.  Lead hydroxide is soluble however,  to concentrations

 several order of magnitude greater then the .5mg/l concentration

limit, unded under, neutral, and acidic condition.  Because  of  the

toxicity of  lead and the solubility of these salts this
 *Versar, Inc.  Assessment of Industrial Hazardous Waste
 Practices,  Inorganic Chemicals Industry"  Contract # 68-01-2246


                          US

-------
stream is to be considered hazardous.

-------
2816      Chromium or lead bearing wastewater treatement sludge
          from production of molybdate orange (lead molybdate
          lead chromate)  (T)


          The National Interim Primary Drinking Water Regulations

     (NIPDWR) set limits for chemical contamination of Drinking Water,

     The substances listed represent hazards to human health.  in

     arriving at these specific limits, the total environmental

     exposure of man to a stated specific toxicant has been con-

     sidered.  (For a complete treatment of the data and reasoning

     used in choosing the substances and specified limits please

     refer to the NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 -

     003).



          A primary exposure route to the public for toxic con-

     taminants is through drinking water.  A large percentage of

     drinking water finds its source in groundwater.  EPA has

     evidence to indicate that industrial wastes as presently

     managed and disposed often leaches into and contaminants the

     groundwater.  The Geraghty and Miller report1 indicated that

     in 98% of 50 randomly  selected on-site industrial waste

     disposal sites, toxic  heavy metals were found to be present,

     and  that these heavy metals had migrated from the disposal

     sites  in 80% of the instances.  Selenium, arsenic and/or

     cyanides were  found to be present at  74% of the  sites and

     confirmed to have migrated at  60% of  the sites.

-------
     At 52% of the sites toxic inorganics (such as arsenic,

cadmium etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream  (beyond the site)  groundwater

concentrations).


     Chromium and lead are two of the toxicants listed by

the NIPDWR both at concentration of .05mg/l because of

their toxicity.  As explained in the RCRA toxicity back-

ground document this convers to a ,5mg/l level in the

EP extract.


     This waste has been shown to contain* lead salts

(e.g. lead hydroxide, lead chromate, and chromium hydroxide

(Cr OH3).  Chromium hydroxide is soluble in acidic media.

At pH 5 a saturated solution will contain S^XlCT^-g/l of

trivalent chromium.  Under saturated conditions  (i.e. if

equilibrium were reached) then there would be 100 time the

. 5mg/l concentation limit in solution.  Because of the toxicity

of chromium and the solubility of this salt, this waste is con-

sidered hazardous.  Lead chromate is one of the more insoluble

lead salts, however it will reach a concentration level up to

. 2mg/l«  Lead hydroxide is soluble however, to concentrations

several order of magnitude greater then the .5mg/l concentration

limit, under, neutral, and acidic condition.  Because of the

toxicity of lead and the solubility of these salts this
*Versar,  Inc.  Assessment of Industrial Hazardous Waste
 practices,  Inorganic Chemicals Industry"  Contract # 68-01-2246

-------
waste stream is to be considered hazardous.

-------
816      Zinc and chromium bearing wastewater treatment sludge
         from production of zinc yellow pigment (hydrated zinc
         potassium chromate) (T)
         The National Interim Primary Drinking Water Regulations
    (NIPDWR) set limits for chemical contamination of Drinking Water,
    The substances listed represent hazards to human health.  In
    arriving at these specific limits, the total environmental
    exposure of man to a stated specific toxicant has been con-
    sidered.   (For a complete treatment of the data and reasoning
    used in choosing the substances and specified limits please
    refer to the NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 -
    003).

         A primary exposure route to the public for toxic con-
    taminants  is through drinking water.  A large percentage of
    drinking water finds its source in groundwater.  EPA has
    evidence to indicate that industrial wastes as presently
    managed and disposed often leaches into and contaminants the
    groundwater.  The Geraghty and Miller report1 indicated that
    in 98% o»  50 randomly selected on-site industrial waste
    disposal sites, toxic heavy metals were found to be present,
    and that these heavy metals had migrated from the disposal
    sites in 80% of the instances.  Selenium, arsenic and/or
    cyanides were found to be present at 74% of the sites and
    confirmed  to have migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (such as  arsenic,
cadmium etc.) in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits (even after taking
into account the upstream (beyond the site)  groundwater
concentrations).

     Chromium is one of the toxicants listed by the NIPDWR
at a concentration of .05mg/l because of its toxicity.   As
explained in the RCRA toxicity background document this
converts to a .5mg/l level in the  EP extract.  This waste
has been shown to contain* Chromium hydroxide.  Chromium
          o
hydroxidg,^ OH3) is soluble in acidic media.  At pH 5
a saturated solution will contain 5.2X10'^^^ of trivalent
               O
chromium.  Undersaturated conditions (i.e. if equilibrium were
               A
reached), then there would be 100 times the .5mg/l concentration
in solutio^» Because of the toxicity of chromium and the
solubility of this salt, this waste is considered hazardous.
 *Versar,Inc.Assessment of Industrial  Hazardous
 waste Practices/ Inorganic Chemicals Industry
 "Contract #68-01-2246

-------
316      Ash from incinerated still bottoms (paint and pigment
         production)(T)
         The National Interim Primary Drinking Water Regulations
    (NIPDWR) set limits for chemical contamination of Drinking Water,
    The substances listed represent hazards to human health.  In
    arriving at these specific limits, the total environmental
    exposure of man to a stated specific toxicant has been con-
    sidered.   (For a complete treatment of the data and reasoning
    used in choosing the substances and specified limits please
    refer to the NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 -
    003).

         A primary exposure route to the public for toxic con-
    taminants  is through drinking water.  A large percentage of
    drinking water finds its source in groundwater.  EPA has
    evidence to indicate that industrial wastes as presently
    managed and disposed often leaches into and contaminants the
    groundwater.  The Geraghty and Miller report1 indicated that
    in 98% of  50 randomly selected on-site industrial waste
    disposal sites, toxic heavy metals were found to be present,
    and that these heavy metals had migrated from the disposal
    sites in 80% of the instances.  Selenium, arsenic and/or
    cyanides were found to be present at 74% of the sites and
    confirmed  to have migrated at 60% of the sites.

-------
                   TABLE #1*

ANALYTICAL CHARACTERISTICS OF STILL BOTTOMS SAMPLES
  COLLECTED FROM SOLVENT RECLAIMING OPERATIONS


Sample
Desig-
nation
AI
A2
B!
B2
D!
D2
Jl
J2
J3
J4
Xl
X2
*1
*2
*2
Z
*Wapora ,
Waste Pra
Contract
Percent
Volatile
Carried Percent
off at Trichloro-
103-105°C ethylene
77
79
89
89 6
99
41
14 3
14
61
28
97 45
97 50
59
58
83
61


Lead
mg/1
1700
500
400

100







1200
1200
100
3700


Chro-
mium,
mg/1
280
60
60

10







360
310
10
730


Zinc
mg/1
190
130
130

10







100
990
10
430


Flash
°C
48
44
51
75
40
46
no
58
53
90
84
86
68
82
74
79


Point,
op
118
111
124
167
104
115
flash
136
127
194
183
187
154
180
165
174
Inc. Assessment of Industrial Hazardous
ictices-Paint and Allied
Products
Solvent Reclaiming Operations and
Industry
Factory




-------
                   TABLE 2*




ANALYSIS OF ASH FROM INCINERATED STILL BOTTOMS








                           Concentration,
Constituent
Ti02
Si022
SrO
A1203
Fe2o3
MgO
BaO
Mo03
PbO
sb2o5
CaO
NiO
Sn02
ZnO
CoO
MnO
CuO
Cr203
Hot Detected in Sample: Cd, As, Te, B,
*ffapnr-a. Inc. Assessment of Industrial
Percent
Major
15.00
2.00
.50
.20
.20
.10
.004
.03
.02
.005
.005
.005
.003
.003
.003
.001
.001
W, Ge, Bi,
Hazardous
Waff*-** Practices-Paint and Allied Products Industry
rnn+ract solvent Reclaiming Operations
and Factory

-------
     At 52% of the sites toxic inorganics (such as arsenic,

cadmium etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream (beyond the site)  groundwater

concentrations).


     Chromium, lead and Barium are three of the toxicants

listed by the NIPDWR at a concentrations of .05, .05, and 1.0

mg/1, respectively, because of their toxicity.  As explained

in the RCRA toxicity background document these converts to

concentrations of 0.5, 0.5 and lO.Omg/1, respetively in the

EP extract.


     This waste has been shown contain* chromic oxide

(Cr203), lead oxide (PbO) and Barium oxide  (BaO) at the

concentration levels indicated in Tables 1 and 2.  The

solubility of Barium oxide is 35g/l in cole water, and 900g/l  in

hot water) in aquos solution, this is several orders of magnitude

greater then the allowable TEP concentration limit, so that

a saturated solution would certainly meet the toxicity criteria

for barium.  Chromic oxide is amphoteric and soluble in acidic

and basic solutions as is lead oxides.  The solubility of both
*Wapora,Inc.  Assessment of Industrial Hazardous
waste Practices-Paint and Allied Products Industry
Contract Solvent Reclamining Operations and Factory
Application of Coating.  1976

-------
as is lead oxides.  The solubility of both of these is



such that a saturated solution of either would surpass



the TEP concentration limit by at least an order of



magnitude.  Because of the toxicity and solubility of these



salts this waste is considered hazardous.
                           135-

-------
2819      Arsenic bearing wastewater treatment sludges from
          production of boric acid.   (T)


          The National Interim Primary Drinking Water Regulations

     (NIPDWR) set limits for chemical contamination of Drinking Water,

     The substances listed represent hazards to human health.  In

     arriving at these specific limits, the total environmental

     exposure of man to a stated specific toxicant has been con-

     sidered.  (For a complete treatment of the data and reasoning

     used in choosing the substances and specified limits please

     refer to the NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 -

     003) .



          A primary exposure route to the public for toxic con-

     taminants is through drinking water.  A large percentage of

     drinking water finds its source in groundwater.  EPA has

     evidence to indicate that industrial wastes as presently

     managed and disposed often leaches into and contaminants the

     groundwater.  The Geraghty and Miller report1 indicated that

     in  98% of 50 randomly selected on-site industrial waste

     disposal sites, toxic heavy metals were found to be present,

     and that these heavy metals had migrated from the disposal

     sites in 80% of the instances.  Selenium, arsenic and/or

     cyanides were found to be present at 74% of the sites and

     confirmed to have migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (such as  arsenic,
cadmium etc.) in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits (even after taking
into account the upstream  (beyond the site)  groundwater
concentrations).

    - Arsenic is one of the toxicants listed by the NIPDWR
at a concentration of .05mg/l because of its toxicity.  As
explained in the RCRA toxicity background document this
converts to a .5mg/l level in the  EP extract.

     This waste has been shown to contain* Arsenic.

     Because of the toxicity of Arsenic this waste is
considered hazardous.
*Versar,Inc. Assessment of Industrial  Hazardous
waste  Practice's,  Inorganic Chemicals Industry"
•"Contract #68-01-2246

-------
2834  Arsenic or Organo-Arsenic Containing Wastewater  Treatment

      Sludges from Production of Veterinary Pharmaceuticals

      (T, M, 0)




     The National Interim Primary Drinking Water  Regulations

(NIPDWR) set limits for chemical contamination of Drinking

Water.  The substances listed represent hazards to human health.

In arriving at these specific limits,  the total environmental-

exposure of man to a stated specific toxicant has been

considered.  (For a complete treatment of the data and reason-

ing used in choosing the substances and specified limits please

refer to the NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 -

76 - 003) .




     A primary exposure route to the public for toxic  contami-

nants is through drinking water.  A large percentage of

drinking water finds its source in groundwater.  EPA has evidence

to indicate that industrial wastes as presently managed and

disposed often leaches into and contaminate; the groundwater.
                              1
The Geraghty and Miller report indicated that in 98% of 50

randomly selected on-site industrial waste disposal sites,

toxic heavy metals were found to be present, and that these

heavy metals had migrated from the disposal sites in 80% of

the instances.  Selenium, arsenic and/or cyanides were found

to be present at 74% of the sites and confirmed to have

migrated at 60% of the sites.

-------
     As  stated  earlier a primary exposure route to the public
 for  toxic  contaminants is  through drinking water.  A large
 percentage of drinking water  finds  its  source  in groundwater.
 EPA  has  evidence  to  indicate  that industrial wastes as presen-
 tly  managed and disposed often  leactyeinto and contaminate
 the  groundwater.
     Geraghty and Miller    found that in a majority of the
 fifty  sites examined, organic contamination of the groundwater
 above  background  levels was observed.   In 28  (56%) of these
 sites  chlorinated organics attributable to waste disposal
 were observed in  the groundwater.   While specific identifica-
 tion of  these organics was not  always undertaken in this work,
 (other incidents  and reports  2  through  8 do qualitatively
 identify leached  organic contaminants in groundwater) it
 certainly  serves  to  demonstrate that organic contamination
 of groundwater  frequently  results from  industrial waste
 disposal.   Since  the Administrator  has  determined "that the
 presence in drinking water of chloroform and other trihalo-
 methanes and synthetic organic  chemicals may have an adverse
 effect on  the health of persons..."* and, as noted above,
 because  much drinking water finds its source as groundwater,
 the  presence of available  toxic organics in waste is a
 critical factor in determining  if a waste presents a hazard
 when managed.   (For  a discussion of how the toxicity and
 concentration of  organic contaminants in waste are considered
 in the hazard determination see Toxicity background document.).
     This  waste has  been shown  to also  contain * 1,1,2-
 trichloroethane,  phenol, nitrobenzene and o-nitro-aniline
 because  of the  toxicity of these compounds this waste is a
hazardous  waste.

-------
     At 52% of the sites toxic inorganics (such as arsenic,

cadmium etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream (beyond the site)  groundwater

concentrations).

     Arsenic is one of the toxicants listed by the NIPDWR at

a concentration of .05mg/l because of its toxicity.  As

explained in the RCRA toxicity background document this converts

to a .5mg/l level in the  . EP extract.

     This waste has been shown to contain Arsenic.  According

to several sources*, this arsenic has leached out inot soil

surrounding its disposal site in concentrations from 4-92mg/kg.

Because of the toxicity of Arsenic and the apparent solubility

of its form in this waste, this waste is considered a hazardous

waste.
 (1) "Recommendations Secondary Sites"  Salsbury Labortories,
     Charles City Iowa Dept.  of Environmental Quality,  Dec. £4  1977

 (2) "Report of Investigation of Salsbury Labs., Charles City   Iowa"
     Region VII, USEPA, Sept. 1977.

 (3) "NPDES Compliance, Monitoring and Waste/Water Character-
     Salsbury Labs., Charles  City, Iowa"  6/19-6/30,   1978 NEIC

-------
 2851   Wastewater  treatment and air pollution control sludges

 from  paint production  (T)

      This  waste stream is classified as hazardous because of

 its toxic  properties.   According to the data EPA has on its

 waste stream it meets  the RCRA §250.13d characteristic

 identifying a toxic  hazardous waste.

      EPA bases this  classification on the following information.

      (1) Wapora Inc. has tested a sample of wastewater treatment

 and air pollution sludges and has found the following.


 contaminent                          cone,  (range of samples)
                                      	mg/1
Hg                                        0.2-0.4

Pb                                       24.0 - 120.0

Cd                                          2 - 120

Cr                                         10 - 217

Zinc                                       28 - 10,840

Ti                                         52 - 1205


     The  data presented above are available from:

     Assessment of  Industrial Hazardous Waste Practices:

Paint  and Allied Products Industry, Contract Solvent Reclaiming

Operations,  and Factory Application of Coating.  OSW, PB - 251 -

669,   1976.
                             14!

-------
     The National Interim Primary Drinking Water  Regulations
(NIPDWR) set limits for chemical contamination of Drinking Water.
The substances listed represent hazards to human  health.   in
arriving at these specific limits,  the total  environmental exposure
of man to a stated specific toxicant has been considered.   (For a
complete treatment of the data and reasoning  used in  choosing the
substances and specified limits please refer  to the NIPDWR Appendix
A-C Chemical Quality, EPA-6570/9 - 76 - 003).
     A primary exposure route to the public for toxic contaminents
is through drinking water.  A large percentage of drinking water
finds it source in groundwater.  EPA has evidence to  indicate
that industrial wastes as presently managed and disposed  often
leaches into and contaminents the groundwater. The Geraghty and
Miller report  indicated that in 98% of 50 randomly selected
on-site industrial waste disposal sites, toxic heavy  metals were
found to be present, and that these heavy metals  had  migrated from
the disposal sites in 80% of the instances.  Selenium,  arsenic
and/or cyanides were found to be present at 74% of the sites and
confirmed to have migrated at 60% of the sites.
     At 52% of the sites toxic inorganics (such as arsenic, cadm'
etc.) in the groundwater from one or more monitoring  wells
exceeded EPA drinking water limits (even after taking into acco
the upstream (beyond the site)  groundwater concentrations) .
     Arsenic, barium, cadmium,  chromium, lead, mercury, selenium
and silver are toxicants listed by the NIPDWR at  concentration
of 0.05, 1.00, 0.010, 0.05, 0.05, 0.002, 0.01, and 0.05,  mg/1
respectively  because of their toxicity.  As  explained in the RCRA
toxicity background documents these concentrations convert to

                             ma

-------
0.05, 10.0, 0.1, 0.5, 0.5, 0.02, 0.1, and 0.5, mg/1 respectively
in the "EP extract.
     This waste has been shown to contain mercury,  lead,  cadmium,
and chromium at concentrations of 0.2, to 0.4, 24.0 to 120.0,
2.0 to 120.0, and 10.0 to 217.0 mg/1 respectively,  according
to PB - 251 669, Assessment of Industrial Hazardous Waste Practices
Paint and Allied Products Industry, Contact Solvent Reclaiming
Operations, and Factory Application of Coating.
     Because of the toxicity of these heavy metals  this waste
is to be considered hazardous.
                          IMS

-------
    VACUUM STILL BOTTOMS FROM MALEK*"ANHYDRIDE PRODUCTION
     The Administrator has determined this waste stream
to be a potential threat to the environment if improperly
managed.  Based on available information,  we have determined
that this waste is likely to contain the following:

          12% Maleic anhydride:

     A primary exposure route to the public for toxic
contaminants is through drinking water.  A large percentage
of drinking water finds its source in groundwater.  EPA has
evidence to indicate that industrial wastes as presently
managed and disposed often leach   into and contaminate  the
groundwater.  The Geraghty and Miller reportl indicated that
in 98% of 50 randomly selected on-site industrial waste disposal
sites, toxic heavy metals were found to be present,  and that
these heavy metals had migrated from the disposal sites in 80%
of the instances.  Selenium, arsenic and/or cyanides were found
to be present at 74% of the sites and confirmed to have
migrated at 60% of the sites.

     At 52% of the sites toxic inorganics  (such as arsenic,
cadmium, etc.) in the groundwater from one or more monitoring

-------
wells exceeded EPA drinking water limits  (even after taking

into account the upstream  (beyond the site) groundwater

concentrations).




     Geraghty and Millerl also found that in a majority of the


fifty sites examined organic contamination of the groundwater

above background levels was observed.  In 28 (56%) of these

sites chlorinated organics attributable to waste disposal

were observed in the groundwater.  While specific identification

of these organics was not always undertaken in this work,

(other incidents and reports  (References 2 through 8) do

qualitatively identify leached organic contaminants in

groundwater)/ it certainly serves to demonstrate that

organic contamination of groundwater frequently results

from industrial waste disposal.  Since the Administrator has

determined "that the presence in drinking water of chloroform
                     Ar»*S
and other trihalometh. and synthetic organic chemicals may have

an adverse effect on the health of persons..."* and, as noted

above, because much drinking water finds its source as

groundwater, the presence of available toxic organics in waste

is a critical factor in determining if a waste presents a hazard

when managed.   (For a discussion of how the toxicity and con-

centration of organic contaminants in waste are considered in

the hazard determination see Toxicity background document.)

-------
     The vacuum still bottoms from maleic anhydride production

contain a significant quanity of maleic anhydride which has
an oral rat LD50 of 481mg/kg.  Th4sj~still bottoms also
contain tars believed to be carcinogenic.
Reference:  1.  TRW. Assessment of Industrial Hazardous
                Waste Practices:   Organic Chemicals,
                Pesticides and Explosives.   USEPA SW-118c
                Jan.  1976 p.5-46

            2.  NIOSH Registry of Toxic Effects of Chemical
                Substances, 1977.
                             me.

-------
     STILL BOTTOMS FROM DISTILLATION OP BENZYL CHLORIDE





     The Administrator has determined this waste stream to



be a potential threat to the environment if improperly



managed.  Based on available information, we have determined



that this waste is likely to contain <3(. - chlorotoluene.





     A primary exposure route to the public for toxic



contaminants  is through drinking water.  A large percentage



of drinking water finds its source in groundwater.  EPA has



evidence to indicate that industrial wastes as presently



managed and disposed often leach   into and contaminate - the



groundwater.  The Geraghty and Miller report! indicated that



in 98% of 50  randomly selected on-site industrial waste disposal



sites, toxic  heavy metals were found to be present, and that



these heavy metals had migrated from the disposal sites in 80%



of the instances.  Selenium, arsenic and/or cyanides were found



to be present at 74% of the sites and confirmed to have



migrated at 60% of the sites.







     At 52% of the sites toxic inorganics  (such as arsenic,



cadmium, etc.) in the groundwater from one or more monitoring



wells exceeded EPA drinking water limits  (even after taking



into account  the upstream  (beyond the site) groundwater



concentrations).

-------
     Geraghty and Miller1 also found that in a majority of the

fifty sites examined organic contamination of the groundwater

above background levels was observed.   In 28 (56%)  of these

sites chlorinated organics attributable to waste disposal

were observed in the groundwater.   While specific identification

of these organics was not always undertaken in this work,

(other incidents and reports (References 2 through 8)  do

qualitatively identify leached organic contaminants in

groundwater), it certainly serves  to demonstrate that

organic contamination of groundwater frequently results

from industrial waste disposal.   Since the Administrator has

determined "that the presence in drinking water of chloroform
                        g
and other trihalomethaneK and synthetic organic chemicals may have

an adverse effect on the health of persons..."* and, as noted

above, because much drinking water finds its source as

groundwater,  the presence of available toxic organics in waste

is a critical factor in determining if a waste presents a hazard

when managed.   (For a discussion of how the toxicity and con-

centration of organic contaminants in waste are considered in

the hazard determination see Toxicity background document.)


     The still bottoms from the distillation of benzyl

chloride are likely to contain alpha-chlorotoluene, a

carcinogenic organic.


References 1.  TRW- Assessment of Industrial Hazardous Waste
               Practices:  Organic Chemicals, Pesticides and
               Explosives. USEPA,SW-llSc,Jan. 1976 p. 5-49.

           2.  NIOSH Registry of the Toxic Effects of
               Chemical Substances, 1977.
                             \Ho

-------
           DISTILLATION RESIDUES  FROM  FRACTIONATING
        TOWER FOR RECOVERY  OF  BENZENE  AND  CHLOROBENZENE



      The Administrator has determined this waste  stream to


be  a potential threat  to the  environment  if  improperly managed.


Based on available  information,  we  have determined that this
                                    •

waste is likely to  contain polychlornated aromatic.


      A primary exposure route to the  public  for toxic


contaminants is through drinking water.   A large  percentage


of  drinking  water finds its source  in groundwater.  EPA has


evidence to  indicate that  industrial  wastes  as presently


managed and  disposed often leach   into and  contaminate,   the


groundwater.   The Geraghty and Miller report^ indicated that


in  98% of 50 randomly  selected on-site industrial waste disposal


sites,  toxic heavy  metals  were found  to be present, and that


these heavy  metals  had migrated  from  the  disposal sites in 80%


of  the instances.   Selenium,  arsenic  and/or  cyanides were found


to  be present at 74% of the sites and confirmed to have


migrated at  60% of  the sites.





      At 52%  of the  sites toxic inorganics (such as arsenic,


cadmium/  etc.)  in the  groundwater from one or more monitoring


wells exceeded EPA  drinking water limits  (even after taking


into account the upstream  (beyond the site)  groundwater


concentrations).





      Geraghty and Millerl  also found  that in a majority of the


fifty sites  examined organic  contamination of the groundwater

-------
above background levels was observed.  In 28 (56%)  of these

sites chlorinated organics attributable to waste disposal

were observed in the groundwater.  While specific identification

of these organics was not always undertaken in  this work,

(other incidents and reports (References 2 through  8)  do

qualitatively identify leached organic contaminants in

groundwater),  it certainly serves to demonstrate that

organic contamination of groundwater frequently results

from industrial waste disposal.   Since the Administrator has

determined "that the presence in drinking water of  chloroform

and other trihalomethane* and synthetic organic  chemicals may have

an adverse effect on the health of persons..."* and,  as noted

above, because much drinking water finds its source as

groundwater,  the presence of available toxic organics in waste

is a critical factor in determining if a waste  presents a hazard

when managed.   (For a discussion of how the toxicity and con-

centration of organic contaminants in waste are considered in

the hazard determination see Toxicity background document.)


     Distillation residues from the fractionating tower

for the recovery of benzene and chlorobenzene contain poly-

chlorinated aromatics which are believed to be  toxic and

bioaccumulative.
Reference:  TRW. Assessment of Industrial Hazardous Waste
            Practices:  Organic Chemicals, Pesticides, and
            Explosives .USEPA SW-118c, Jan. 1976 p. 5-14.
                           ISO

-------
VACUUM DISTILLATION RESIDUES FROM PURIFICATION OF 1-CHLORO- 4

                         NITROBENZENE
      The Administrator has determined this waste stream


 to be a potential threat to the environment if improperly


 managed.  Based on available information, we have determined


 that this waste is likely to contain the following:




                o
                Plyaromatic Tars


                Nitro substituted aromatic polymers



      A primary exposure route to the public for toxic


 contaminants is through drinking water.  A large percentage


 of drinking water finds its source in groundwater.  EPA has


 evidence to indicate that industrial wastes as presently


 managed and disposed often leach -- into and contaminate,  the


 groundwater.  The Geraghty and Miller report1 indicated that


 in 98% of 50 randomly selected on-site industrial waste disposal


 sites, toxic heavy metals were found to be present, and that


 these heavy metals had migrated from the disposal sites in 80%


 of the instances.   Selenium,  arsenic and/or cyanides were found


 to be present at 74% of the sites and confirmed to have


 migrated at 60% of the sites.





      At 52% of the sites toxic inorganics (such as arsenic,


 cadmium, etc.)  in  the groundwater from one or more monitoring


 wells exceeded EPA drinking water limits (even after taking
                           151

-------
into account the upstream (beyond the site) groundwater
concentrations).

     Geraghty and Miller1 also found that in a majority of the
fifty sites examined organic contamination of the groundwater
above background levels was observed.  In 28 (56%)  of these
sites chlorinated organics attributable to waste disposal
were observed in the groundwater.  While specific identification
of these organics was not always undertaken in this work,
(other incidents and reports (References 2 through 8) do
qualitatively identify leached organic contaminants in
groundwater), it certainly serves to demonstrate that
organic contamination of groundwater frequently results
from industrial waste disposal.  Since the Administrator has
determined "that the presence in drinking water of chloroform
and other trihalomethanes, and synthetic organic chemicals may have
an adverse effect on the health of persons..."* and, as noted
above, because much drinking water finds its source as
groundwater, the presence of available toxic organics in waste
is a critical factor in determining if a waste presents a hazard
when managed.  (For a discussion of how the toxicity and con-
centration of organic contaminants in waste are considered in
the hazard determination see Toxicity background document.)

-------
     The vacuum distillation residues contain polyaromatic

     and nitro substituted aromatic polymers which are

believed to be
Deference:  TRWf Assessment of Industrial Hazardous Waste
            Practices:  Organic Chemicals, Pesticides and
            Explosives Industries. USEPA SW-118c Jan. 1976
            p. 5-9.
                        153

-------
HEAVY ENDS OF METHANOL RECOVERY - METHYL METHACRYLATE PRODUCTION








       The Administrator has determined this waste stream to



  be a potential threat to the environment if improperly



  managed.  Based on available information,  we have determined



  that this waste is likely to contain the following Toxic



  organic':



            13% Hydroquinone





       A primary exposure route to the public for toxic



  contaminants is through drinking water.  A large percentage



  of drinking water finds its source in groundwater.  EPA has



  evidence to indicate that industrial wastes as presently



  managed and disposed often leach   into and contaminate, the



  groundwater.  The Geraghty and Miller report1 indicated that




  in 98% of 50 randomly selected on-site industrial waste disposal



  sites, toxic heavy metals were found to be present, and that



  these heavy metals had migrated from the disposal sites in 80%



  of the instances.  Selenium, arsenic and/or cyanides were found



  to be present at 74% of the sites and confirmed to have



  migrated at 60% of the sites.







       At 52% of the sites toxic inorganics  (such as arsenic,



  cadmium, etc.) in the groundwater from one or more monitoring
                                 154

-------
wells exceeded EPA drinking water limits  (even after taking



into account the upstream  (beyond the site) groundwater



concentrations).








     Geraghty and Miller1 also found that in a majority of the




fifty sites examined organic contamination of the groundwater



above background levels was observed.  In 28 (56%) of these



sites chlorinated organics attributable to waste disposal



were observed in the groundwater.  While specific identification



of these organics was not always undertaken in this work/



(other incidents and reports  (References 2 through 8) do



qualitatively identify leached organic contaminants in



groundwater), it certainly serves to demonstrate that



organic contamination of groundwater frequently results



from industrial waste disposal.  Since the Administrator has



determined  "that the presence in drinking water of chloroform



and other trihalomethanes, and synthetic organic chemicals may have



an adverse  effect on the health of persons..."* and, as noted



above, because much drinking water finds its source as



groundwater, the presence of available toxic organics in waste



is a critical factor in determining  if a waste presents a hazard



when managed.   (For a discussion of  how the toxicity and con-



centration  of organic contaminants in waste are considered in



the hazard  determination see Toxicity background document.)
                           1SS*

-------
     The heavy ends from methanol recovery during methyl

methacrylate production contain a large amount of hydro-

quinone.  This organic has an oral rat LD 50 of 320mg/kg.
References 1.  TRW.Assessment of Industrial Hazardous  Waste
               Practices:  Organic Chemicals,  Pesticides and
               Explosive .USEPA^W-llSc, Jan. 1976 p.  5-41.

           2.  NIOSH Registry of Toxic Effects of Chemical
               Substances, 1977.
                             ISC

-------
STILL BOTTOMS FROM FRACTIONATION IN EPICHLOROHYDRIN PRODUCTION








      The Administrator has determined this waste stream to



 be a potential threat to the environment if improperly managed,



 Based on available information, we have determined that this



 waste is likely to contain the following:







      10%  Dichloropropanol:



           Epichlorohydrin:
                              is?-

-------
     A primary exposure route to the public for toxic
contaminants is through drinking water.   A large percentage
of drinking water finds its source in groundwater.   EPA has
evidence to indicate that industrial wastes as presently
managed and disposed often leach   into  and contaminate  the
groundwater.  The Geraghty and Miller report1 indicated that
in 98% of 50 randomly selected on-site industrial waste disposal
sites, toxic heavy metals were found to  be present,  and that
these heavy metals had migrated from the disposal sites in 80%
of the instances.  Selenium, arsenic and/or cyanides were found
to be present at 74% of the sites and confirmed to  have
migrated at 60% of the sites.

     At 52% of the sites toxic inorganics (such as  arsenic,
cadmium, etc.) in the groundwater from one or more  monitoring
wells exceeded EPA drinking water limits (even after taking
into account the upstream  (beyond the site) groundwater
concentrations).

     Geraghty and Miller1 also found that in a majority of the
fifty sites examined organic contamination of the groundwater
above background levels was observed.  In 28  (56%)  of  these
sites chlorinated organics attributable to waste disposal
were observed in the groundwater.  While specific identification
of these organics was not always undertaken in this work,
                           IS*

-------
 (other incidents and reports  (References 2 through 8) do

qualitatively identify leached organic contaminants in

groundwater) , it certainly serves to demonstrate that

organic contamination of groundwater frequently results

from industrial waste disposal.  Since the Administrator has

determined  "that the presence in drinking water of chloroform
and other trihalometh. and synthetic organic chemicals may have
                     A
an adverse effect on the health of persons..."* and, as noted

above, because much drinking water finds its source as

groundwater, the presence of available toxic organics in waste

is a critical factor in determining if a waste presents a hazard

when managed.   (For a discussion of how the toxicity and con-

centration of organic contaminants in waste are considered in

the hazard determination see Toxicity background document.)



     The still bottoms from the fractionation process in

epichlorohydrin production contain a significant amount of

dichloropropanol, a toxic organic.  They also contain

epichlorohydrin which is a suspected carcinogen.
References  1.  TRW. Assessment of Industrial Hazardous waste
                Practices:  Organic Chemicals, Pesticides and
                Explosives USEPA SW-118c January, 1976 p. 5-20

            2.  NIOSH Registry of Toxic Effects of Chemical
                Substances, 1977.

-------
HEAVY CHLORINATED ORGANICS PORTION OF FPACTIONATION WASTE FROM
               ETHYL CHLORIDE PRODUCTION
     The Administrator has determined this waste stream to be
a potential threat to the environment if improperly managed.
Based on available information,  we have determined that this
waste is likely to contain the following:
          77% Ilexachlorobutadiene
           7% Chlorobenzenes
           7% Tars and residues
     A primary exposure route to the public for toxic contaminants
is through drinking water.  A large percentage of drinking water
finds its source in groundwater.  EPA has evidence to indicate
that industrial wastes as presently managed and disposed often
leach   into and contaminate  the groundwater.  The Geraghty and
Miller report1 indicated that in 98% of 50 randomly selected cn-
site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated
from the disposal sites in 80% of the instances.  Selenium, arsenic
and/or cyanides were found to be present at 74% of the sites and
confirmed to have migrated at 60% of the sites.
     At 52% of the sites toxic inorganics  (such as arsenic,
cadmium, etc.) in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits  (even after taking into
account the upstream  (beyond the site) groundwater concentrations) .
     Geraghty and Miller1 also found that in a majority of the
fifty sites examined organic contamination of the groundwater
above background levels was observed.  In 28  (56%) of these
                          ICC

-------
sites chlorinated organics attributable to waste disposal

were observed in the grcundwater.  While specific identifi-

cation of these organics was not always undertaken in this

work,  (other incidents and reports  (References 2 through 8) do

qualitatively identify leached organic contaminants in ground-

water) , it certainly serves to demonstrate that organic contami-

nation of groundwater frequently results from industrial waste

disposal.  Since the Administrator has determined "that the

presence in drinking water of chloroform and other trihalomethan«-s

and synthetic organic chemicals may have an adverse effect on the

health of persons..."* and, as noted above, because much drinking

water finds its source as groundwater, the presence of available

toxic organics in waste is a critical factor in determining if

a waste presents a hazard when managed.  (For a discussion of

how the toxicity and concentration of organic contaminants in

waste are considered in the hazard determination see Toxicity

background document.)

     This portion of the fractionation waste from ethyl chloride

production contains chlorobenzenes which are carcinogenic and

bioaccumulative, and tars and residues which are believed to be

carcinogenic.  The major constituent is hexachlorobutadiene which

is bioaccumulative and toxic (oral rat LD50 of 90 mg/kg).

     References:  1.  TRW Assessment of Industrial Hazardous
                      Waste Practices:  Organic Chemicals,
                      Pesticides and Explosives.  USEPA SW-118c.
                      Jan. 1976 p.     .T-Jfr.

                  2.  NIOSH Registry of Toxic Effects of Chemical
                      Substances, 1977.

-------
    COLUMN BOTTOMS FROM PRODUCTION OF TRICHLOROETHYLENE
                        AND PERCHLOROETHYLENE
     A primary exposure route to the public for toxic

contaminants is through drinking water.   A large percentage

of drinking water finds its source in groundwater.   EPA has

evidence to indicate that industrial wastes as presently

managed and disposed often leach   into  and contaminate  the

groundwater.  The Geraghty and Miller report1 indicated that

in 98% of 50 randomly selected on-site industrial waste disposal

sites, toxic heavy metals were found to  be present,  and that

these heavy metals had migrated from the disposal sites in 80%

of the instances.  Selenium,  arsenic and/or cyanides were found

to be present at 74% of the sites and confirmed to have

migrated at 60% of the sites.


     At 52% of the sites toxic inorganics (such as arsenic,

cadmium, etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking

into account the upstream (beyond the site)  groundwater

concentrations).



     Geraghty and Millerl also found that in a majority of the

fifty sites examined organic contamination of the groundwater

above background levels was observed.  In 28 (56%)  of these

sites chlorinated organics attributable  to waste disposal

were observed in the groundwater.  While specific identificatio

of these organics was not always undertaken in this work,

-------
 (other  incidents  and reports  (References  2  through  8) do


qualitatively  identify  leached organic contaminants in


groundwater) ,  it  certainly  serves to demonstrate  that


organic contamination of groundwater frequently results


from  industrial waste disposal.  Since the  Administrator has


determined  "that  the presence in drinking water of  chloroform

                     on4*
and other trihalometh^ and synthetic organic chemicals may have


an adverse  effect on the health of persons..."* and, as noted


above, because much drinking water finds  its  source as


groundwater, the  presence of available toxic  organics in waste


is a  critical  factor in determining if a  waste presents a hazard


when  managed.   (For a discussion of how the toxicity and con-


centration  of  organic contaminants in waste are considered in


the hazard  determination see Toxicity background  document.)
     77% Hexachlorobutadiene :  Toxic and bioaccumulative


     organic  (oral rat LD50 = 90mg/d»^r





     7% Chlorobenzenes:  carcinogenic and bioaccumulative


     7% Tars  and residues:  carcinogenic -poHwVv».l

                            ©F  Hese.  COM poo <*U  "Kis. it
Deferences  1. TRW«Assessment of  Industrial Hazardous Waste

               Practice Organic Chemicals, Pesticides and

               Explosives USEPA SW-118c Jan.  1976 p. 5-6


            2. NIOSH Registry of  Toxic Effects of Chemical
               Substances,  1977

-------
         DIOXIN - BEARING RESIDUES FROM PRODUCTION
                 HEXACHLOROrilDNB AND 2, -,5-T
     The Administrator has determined this waste stream to
be a potential threat to the environment if improperly managed.
Based on available information, we have determined that this
waste is likely to contain the following:

               Dioxin -

     A primary exposure route to the public for toxic
contaminants is through drinking water.  A large percentage
of drinking water finds its source in groundwater.  EPA has
evidence to indicate that industrial wastes as presently
managed and disposed often leach   into and contaminate  the
groundwater.  The Geraghty and Miller report1 indicated that
in 98% of 50 randomly selected on-site industrial waste disposal
sites, toxic heavy metals were found to be present, and that
these heavy metals had migrated from the disposal sites in  80%
of the instances.  Selenium, arsenic and/or cyanides were found
to be present at 74% of the sites and confirmed to have
migrated at 60% of the sites.

     At 52% of the sites toxic inorganics  (such as arsenic,
cadmium, etc.) in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits  (even after taking
into account the upstream  (beyond the  site) groundwater
                           /CH

-------
concentrations).








     Geraghty and Miller1 also found that in a majority of the



fifty sites examined organic contamination of the groundwater



above background levels was observed.  In 28 (56%) of these



sites chlorinated organics attributable to waste disposal



were observed in the groundwater.  While specific identification



of these organics was not always undertaken in this work,



(other incidents and reports (References 2 through 8) do



qualitatively identify leached organic contaminants in



groundwater), it certainly serves to demonstrate that



organic contamination of groundwater frequently results



from industrial waste disposal.  Since the Administrator has



determined "that the presence in drinking water of chloroform



and other trihalomethanes, and synthetic organic chemicals may have



an adverse effect on the health of persons..."* and, as noted



above, because much drinking water finds its source as



groundwater, the presence of available toxic organics in waste



is a critical factor in determining if a waste presents a hazard



when managed.   (For a discussion of how the toxicity and con-



centration of organic contaminants in waste are considered in



the hazard determination see Toxicity background document.)

-------
     These residues contain significant amounts of tetrachlorodi-

benz«lodioxin, an extremely toxic organic.  Its known toxic

effects include anorexia, severe weight loss, hepatototficity,

hepatop«ir'.phyria, vascular -fissions, chloracne, gastric ulcers,

terotogenicity and delayed death.
References:  1.  Carter et al_. Tetrachlorodibenzodioxin:   An
                 Accidental Poisoning Episode in Horse Arenas
                 Science, 188  (4189):  738-740, May 16, 1975

             2.  Processes Research, Inc.  A Study of
                 Hazard Emergency Alarm Control System  EPA
                 Contract #68-01-4658 July, 1978,
                         ](*(,

-------
   HEAVY  ENDS FROM DISTILLATION PROCESS IN VINYL CHLORIDE PRODUCTION
     The Administrator has determined this waste stream to be



a potential  threat to the environment if improperly managed.  Based



on available infomation, we have determined that this waste is



likely  to contain the following:







          97% higher halogenated hydrocarbons



           2% e  thylene dichloride



           1% tars







     A  primary exposure route to the public for toxic



contaminants is  through drinking water.  A large percentage



of drinking  water finds its source in groundwater.  EPA has



evidence to  indicate that industrial wastes as presently



managed and  disposed often leach   into and contaminate  the



groundwater.  The Geraghty and Miller report1 indicated that



in 98%  of 50 randomly selected on-site industrial waste disposal



sites,  toxic heavy metals were found to be present, and that



these heavy  metals had migrated from the disposal sites in 80%



of the  instances.  Selenium, arsenic and/or cyanides were found



to be present at 74% of the sites and confirmed to have



migrated at  60%  of the sites.







     At 52%  of the sites toxic inorganics  (such as arsenic,



cadmium, etc.) in the groundwater from one or more monitoring

-------
wells exceeded EPA drinking water limits (even after taking
into account the upstream (beyond the site)  groundwater
concentrations).

     Geraghty and Miller-*- also found that in a majority of the
fifty sites examined organic contamination of the groundwater
above background levels was observed.  In 28 (56%)  of these
sites chlorinated organics attributable to waste disposal
were observed in the groundwater.  While specific identification
of these organics was not always undertaken in this work,
(other incidents and reports  (References 2 through 8) do
qualitatively identify leached organic contaminants in
groundwater), it certainly serves to demonstrate that
organic contamination of groundwater frequently results
from industrial waste disposal.  Since the Administrator has
determined  "that the presence in drinking water of chloroform
and other trihalomethane^ and  synthetic organic chemicals may have
an adverse  effect on the health of persons..."* and, as noted
above, because much drinking  water finds its source as
groundwater, the presence of  available toxic organics in waste
is a critical  factor in  determining  if a waste presents a  hazard
when managed.   (For a discussion of  how the toxicity and con-
centration  of  organic contaminants in waste are considered in
the hazard  determination see  Toxicity background document.)

-------
                                     •fc
     The heavy ends from the distillaion process in vinyl
                                     A

chloride production contain higher halogenated hydrocarbons

which are toxic, tars which are carcinogenic and a significant

amount of ethylene dichloride a compound which has an

oral rat LD50 of 600mg/kg and is also bioaccumulative.
References  1.  TRW.Assessment of Industrial Hazardous
                Waste Practices: Organic Chemicals, Pesticides
                and Explosives.USEPA>SW-118c,Jan. 1976 p. 5-37,

            2.  NIOSH Registry of Toxic Effects of Chemical
                Substances, 1977.

-------
2869   Heavy Ends or Distillation Residues from Carbon           -^f^e-s?  s'J-J'
,— — -"""*                                                             / ** •
-------
•disposal.  Since the Administrator has determined "that the

 presence in drinking water of chloroform and other trihaloiae

 and synthetic organic chemicals nay have an. adverse effect on

 the health of persons...11* and, as noted above, because much.

 drinking water finds its source as groundwater, the presence

 of available toxic organics in waste as a critical factor in

 determining if a waste presents a hazard ween managed.   (For

 a discussion of how the toxicity and concentration of organic

 contaminants in waste are considered in the hazard determina-

 tion see Toxicity background document.)
tace*oMorob0t*di**O. Because of
                                                         c?
            to
    TRW. Assessment of Industrial Hazardous
    Waste Practices:   Organic Chemicals,
    Pesticides c.nd Explosives. USRPA
    SW-llRc Jan.  .1976* p. 5-;11
* .
     and Welfare.  1977 9

-------
          HEAVY ENDS FROM DISTILLATION OF ETHYLENE DICHLORIDE
                        t>vc.vJiur>e.ve>E
     The Administrator has determined  this waste stream to

be a potential threat to the  environment if improperly managed,

Based on available information,  we  have  determined that this

waste is likely to contain the  following:


          23% ethylene dichloride

          38% 1, 1,  2 - trichloroethan^

          38% tetrachloroethane

-------
     A primary exposure route to the public for toxic

contaminants is through drinking water.  A large percentage

of drinking water finds its source in groundwater.  EPA has

evidence to indicate that industrial wastes as presently

managed and disposed often leach   into and contaminate  the
                                            1
groundwater.  The Geraghty and Miller report! indicated that

in 98% of 50 randomly selected on-site industrial waste disposal

sites, toxic heavy metals were found to be present, and that

these heavy metals had migrated from the disposal sites in 80%

of the instances.  Selenium, arsenic and/or cyanides were found

to be present at 74% of the sites and confirmed to have

migrated at 60% of the^sites.




     At 52% of the sites toxic inorganics  (such as arsenic,

cadmium, etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits  (even after taking

into account the upstream  (beyond the site) groundwater

concentrations).




     Geraghty and Miller1 also found that  in a majority of the

fifty sites examined organic contamination of the groundwater

above background levels was observed.  In  28  (56%) of these

sites chlorinated organics attributable to waste disposal

were observed in the groundwater.  While  specific identification

of these organics was not always undertaken  in this work,

-------
(other incidents and reports  (References 2 through 8) do

qualitatively identify leached organic contaminants in

groundwater) , it certainly serves to demonstrate that

organic contamination of groundwater frequently results

from industrial waste disposal.  Since the Administrator has

determined  "that the presence in drinking water of chloroform

                     ejn*&
and other trihalometh and synthetic organic chemicals may have

an adverse  effect on the health of persons..."* and, as noted

above, because much drinking water finds its source as

groundwater, the presence of available toxic organics in waste

is a critical factor in determining if a waste presents a hazard

when managed.   (For a discussion of how the toxicity and con-

centration  of organic contaminants in waste are considered  in

the hazard  determination see Toxicity background document.)



     The heavy ends from the distillation of ethylene
dichloride. trichloraethane and tetrachloroethans. .  These

compounds are bioaccurriulatirfe".  Ethylene dischloride has

an oral rat LD50 of 6SOmg/kg, and tetrachloroethane has an

oral rat LD50 of 20Cmg/kg.
References   1.   TRW. Assessment of  Industrial Hazardous
                 Waste  Practices:   Organic Chemicals,
                 Pesticides and Explosives. USEPA
                 SW-118c Jan.  1976"p.5-34

             2.   NIOSH  Registry of  the Toxic Effects of
                 Chemical  Substances, 1977.

-------
       PURIFICATION COLUMN WASTES  (STILL BOTTOMS)  FROM
                    NITROBENZENE PRODUCTION


      The Administrator  has determined  this waste  stream

 to  be a potential threat to the environment if  improperly

 managed.   Based on available information,  we have

 determined that this  waste is likely to contain the

 following:

                Nitrobenzene

                Nitrophenol

                Dinitrophenol


      A primary  exposure route to  the public for toxic

 contaminants  is through drinking  water.  A large  percentage

 of  drinking water finds its source  in  groundwater.   EPA has

 evidence to indicate  that industrial wastes as  presently

managed and disposed  often leach    into and contaminate the

groundwater.  The Geraghty and  Miller  report! indicated that

 in  98% of 50  randomly selected  on-site  industrial waste disposal

 sites,  toxic  heavy metals were  found to be  present,  and that

these  heavy metals had  migrated from the disposal sites  in 80%

of  the instances.   Selenium,  arsenic and/or cyanides were found

to  be  present at  74%  of the sites and  confirmed to have

migrated at 60% of the  sites.



     At 52% of  the sites  toxic  inorganics  (such as arsenic,

cadmium,  etc.)  in the groundwater from one  or more monitoring

-------
  wells exceeded EPA drinking water limits (even after taking



into account the upstream (beyond the site)  groundwater



concentrations).








     Geraghty and Miller1 also found that in a majority of the



fifty sites examined organic contamination of the groundwater



above background levels was observed.  In 28 (56%)  of these



sites chlorinated organics attributable to waste disposal



were observed in the groundwater.  While specific identification



of these organics was not always undertaken in this work,



(other incidents and reports  (References 2 through 8) do



qualitatively identify leached organic contaminants in



groundwater), it certainly serves to demonstrate that



organic contamination of groundwater frequently results



from industrial waste disposal.  Since the Administrator has



determined  "that the presence in drinking water of chloroform



and other trihalomethanes, and synthetic organic chemicals may  have



an adverse  effect on the health of persons..."* and, as noted



above, because much drinking water finds its source as



groundwater, the presence of available toxic organics in waste



is a critical  factor in determining  if a waste presents a hazard



when managed.   (For a discussion of  how the toxicity and con-



centration  of  organic contaminants in waste are considered in



the hazard  determination  see'Toxicity background document.)

-------
     The purification column wastes have been found to

contain the toxic organics, nitrophenol and dinitrophenol and

nitrobenzene which has an oral rat LD50 of 640mg/kg.
Reference 1.  Mitre Corporation, Nitrobenzene/Amiline
              Manufacture:  Pollutant Prediction and
              Abatement,EPA Contract #68-01-3188,May, 1978'

          2.  NIOSH Registry of Toxic Effects of Chemical
              Substances, 1977.

-------
          STILL BOTTOMS FROM PRODUCTION OF FURFURAL
     The Administrator has determined this waste stream to
be a potential threat to the environment if improperly
managed.  Based on available information, we have determined
that this waste is likely to contain the following:

     Furfural - containing tars and polymers:

     A primary exposure route to the public for toxic
contaminants is through drinking water.  A large percentage
of drinking water finds its source in groundwater.  EPA has
evidence to indicate that industrial wastes as presently
managed and disposed often leach   into and contaminate-- 'the
groundwater.  The Geraghty and Miller report1 indicated that
in 98% of 50 randomly selected on-site industrial waste disposal
sites, toxic heavy metals were found to be present,  and that
these heavy metals had migrated from the disposal sites in 80%
of the  instances.  Selenium, arsenic and/or cyanides were found
to be present at  74% of the sites and confirmed to have
migrated at  60% of the sites.

     At 52%  of  the sites  toxic inorganics  (such as arsenic,
cadmium, etc.)  in the groundwater from one or more monitoring

-------
wells exceeded EPA drinking water limits  (even after taking



into account the upstream  (beyond the site) groundwater



concentrations).








     Geraghty and Miller1 aiso found that in a majority of the



fifty sites examined organic contamination of the groundwater



above background levels was observed.  In 28 (56%) of these



sites chlorinated organics attributable to waste disposal



were observed in the groundwater.  While specific identification



of these organics was not always undertaken in this work,



(other incidents and report  (References 2 through 8)



gualitatively identify leached organic contaminants in



groundwater), it certainly serves to demonstrate that



organic contamination of groundwater frequently results



from industrial waste disposal.  Since the Administrator has



determined  "that the presence in drinking water of chloroform



and other trihalomethane^ and synthetic organic chemicals may have



an adverse  effect on the health of persons..."* and, as noted



above, because much drinking water finds its source as



groundwater, the presence of available toxic organics in waste



is a critical  factor in  determining  if a waste presents a hazard



when managed.   (For a discussion of  how the toxicity and con-



centration  of  organic contaminants in waste are considered in



the hazard  determination see Toxicity background document.)

-------
     The still bottoms from furfural production consist of

furfural - containing tars and organics.   Furfural is toxic

organic with an oral rat LD50 of 127mg/kg.  Furfural also

has a flash point of 140°F and may create a hazard due to

ignitability.
Reference 1.  TRW.Assessment of Industrial Hazardous Waste
              Practices:  Organic Chemicals, Pesticides and
              Explosives. USEPA SW-118c Jan. 1976 p. 5-22.

          2.  NIOSH Registry of the Toxic Effects of Chemical
              Substances, 1977 .

-------
              SPENT CATALYST FROM FLUOROCARBON PRODUCTION



     The Administrator has determined this waste stream



to be a potential threat to the environment if improperly



managed.  Based on available information, we have determined



that this waste is likely to contain antimony pentachloride.
     Antimony pentachloride fumes in air and may cause
                                                       •


antimony poisoning in humans.  Effects include dermatit

                                                       /


keratitis, conjuctiviti s and  nasafe, septal uiceration.
References  1. TRW,Assessment of Industrial Hazardous Waste



               Practices:  Organic Chemicals, Pesticides and



               Explosives.  USEPA. SW-118c Jan. 1976 p. 5-31



                 &

            2. M$rrck Index, Eighth Edition, p. 90
                         131

-------
   CENTRIFUGE RESIDUE FROM TOLUENE DinbSOCYANATE PRODUCTION








     The Administrator has determined this waste stream



to be a potential threat to the environment if improperly



managed.  Based on available information, we have determined



that this waste is likely to contain 3% Isocyanates.

-------
     A primary exposure route to the public for toxic
contaminants  is through drinking water.  A large percentage
of drinking water finds its source in groundwater.  EPA has
evidence to indicate that industrial wastes as presently
managed and disposed often leach   into and contaminate  the
groundwater.  The Geraghty and Miller report1 indicated that
in 98% of 50  randomly selected on-site industrial waste dis-
posal sites,  toxic heavy metals were found to be present, and
that these heavy metals had migrated from the disposal sites
in 80% of the instances.  Selenium, arsenic and/or cyanides
were found to be present at 74% of the sites and confirmed to
have migrated at 60% of the sites.

     At 52% of the sites toxic inorganics (such as arsenic,
cadmium, etc.) in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits (even after taking
into account the upstream (beyond the site)  groundwater
concentrations).

     Geraghty and Miller1 also found that in a majority of the
fifty sites examined organic contamination of the groundwater
above background levels was observed.  In 28 (56%) of these
sites chlorinated organics attributable to waste disposal
were observed in the groundwater.  While specific identifi-
cation of these organics was not always undertaken in this
work, (other incidents and reports (References 2 through 8)
                            183

-------
do qualitatively identify leached organic contaminants in

groundwater), it certainly serves to demonstrate that organic

contamination of groundwater frequently results from

industrial waste disposal.  Since the Administrator has

determined "that the presence in drinking water of chloroform

and other trihalomethanes, and synthetic organic chemicals

may have an adverse effect on the health of the persons..."*

and,  as noted above, because much drinking water finds its source

as groundwater,  the presence of available toxic organics in waste

is a critical factor in determining if a waste presents a

hazard when managed.  (For a discussion of how the toxicity

and concentration of organic contaminants in waste are con-

sidered in the hazard determination see Toxicity background

document.)



     Our information indicates that toluene diisoc'jf|"anate is a

pressure generating compound which reacts with water to

release carbon dioxide.   Also, when contact by concentrated

alkaline compounds, run-away polymerisation may occur.

Furthermore toluene diisocyanate is listed as a DOT Poison B.
                      39
References   I. TRW. Assement of Industrial Hazardous Waste
               Practices:  Organic, Chemicals, Pesticides
               and Explosives. USEPA SW-118c Jan.  1976
               p. 5-34

             2.- Merck Index, Eighth Edition p. 1058


             3. NIOSH Registry of Toxic Effects of Chemical
               Substances, 1977

-------
       '- LEAD PRECIPITATE FROM LEAD ALKYLS PRODUCTION
     This waste stream is hazardous because of its toxic

properties.  According to data EPA has on this waste stream,

it meets the RCRA 250.13 a (4) characteristic identifying a

toxic hazardous waste.



     Our information indicates that the waste contains the

following toxic substance:
     Lead
Reference:  TRW,  Assessment of Industrial Hazardous
            Waste Practices:  Organic Chemicals, Pesticides,
            Explosives.  USEPA SW-118c Jan. 1976 p. 5-47
                         i8S

-------
     The National Interim Primary Drinking Water Regulations



(NIPDWR) set limits for chemical contamination of Drinking Water,



The substances listed represent hazards to human health.   In



arriving at these specific limits, the total environmental



exposure of man to a stated specific toxicant has been con-



sidered.  (For a complete treatment of the data and reasoning



used in choosing the substances and specified limits please



refer to the NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 -



003) .






     A primary exposure route to the public for toxic con-



taminants is through drinking water.  A large percentage of



drinking water finds its source in groundwater.  EPA has



evidence to indicate that industrial wastes as presently


                                                     ~VL>
managed and disposed often leach   into and contaminantsMihe



groundwater.  The Geraghty and Miller report1 indicated that



in  98% of 50 randomly selected on-site industrial waste



disposal sites, toxic heavy metals were found to be present,



and that these heavy metals had migrated from the disposal



sites in 80% of the instances.  Selenium, arsenic and/or



cyanides were found to be present at 74% of the sites and



confirmed to have migrated at 60% of the sites.

-------
     At  52% of the sites toxic inorganics  (such as  arsenic,



cadmium  etc.) in the groundwater from one  or more monitoring



wells exceeded EPA drinking water limits  (even after  taking



into account the upstream  (beyond the site) groundwater



concentrations).  Because of the toxicity  of lead,  this



waste is considered hazardous.

-------
       SLUDGE FROM WASTEWATER TREATMENT OF STRIPPING
        STILL TAILS - METYLETHYL PYRIDINE PRODUCTION


     The Administrator has determined this waste  stream to

be a potential threat to the environment if improperly managed.

Based on available information,  we have determined that this

waste is likely to contain the following toxic organics:



          Paraldehyde

          Pyridines

          Picolines


     A primary exposure route to the public for toxic

contaminants is through drinking water.  A large  percentage

of drinking water finds its source in groundwater.  EPA has

evidence to indicate that industrial wastes as presently

managed and disposed often leach ' into and contaminate  the

groundwater.  The Geraghty and Miller report1 indicated that

in 98% of 50 randomly selected on-site industrial waste disposal

sites, toxic heavy metals were found to be present, and that

these heavy metals had migrated from the disposal sites in  80%

of the instances.  Selenium, arsenic and/or cyanides were found

to be present at  74% of the sites and confirmed to have

migrated at  60% of the sites.



     At 52%  of the sites  toxic inorganics  (such as arsenic,

cadmium, etc.) in the groundwater from one or more monitoring

-------
wells exceeded EPA drinking water limits  (even after taking



into account the upstream (beyond the site) groundwater



concentrations).








     Geraghty and Miller1 also found that in a majority of the



fifty sites examined organic contamination of the groundwater



above background levels was observed.  In 28 (56%) of these



sites chlorinated organics attributable to waste disposal



were observed in the groundwater.  While  specific identification



of these organics was not always undertaken in this work,



(other incidents and reports  (References  2 through 8) do



qualitatively identify leached organic contaminants in



groundwater), it certainly serves to demonstrate that



organic contamination of groundwater frequently results



from industrial waste disposal.  Since the Administrator has



determined  "that the presence in drinking water of chloroform



and other trihalomethanes, and synthetic  organic chemicals may have



an adverse  effect on the health of persons..."* and, as noted



above, because much drinking water finds  its source as



groundwater, the presence of available toxic organics in waste



is a critical factor in determining  if a  waste presents a hazard



when managed.   (For a discussion of  how the toxicity and con-



centration  of organic contaminants in waste are considered in



the hazard  determination see Toxicity background document.)

-------
     The sludge from wastewater treatment of stripping still
                             t
tails contains paraldehyde,  ptcolines and pyriraidines which

are toxic organics.
 References:  TRW, Assessment of Industrial Hazardous Waste
             Practices:  Organic Chemical, Pesticides and
             Explosives  Industries.  USEPA, SW-118c, Jan.  1976
             p.  5-28.

-------
            STILL BOTTOMS FROM ANILINE DISTILLATION
     The Administrator has determined this waste stream to



be a potential threat to the environment if improperly



managed.  Based on available information, we have determined



that this waste is likely to contain nitrobenzene:





     A primary exposure route to the public for toxic



contaminants is through drinking water.  A large percentage



of drinking water finds its source in groundwater.  EPA has



evidence to indicate that industrial wastes as presently



managed and disposed often leach   into and contaminate  the



groundwater.  The Geraghty and Miller report1 indicated that




in 98% of 50 randomly selected on-site industrial waste disposal



sites, toxic heavy metals were found to be present, and that



these heavy metals had migrated from the disposal sites in 80%



of the instances.  Selenium, arsenic and/or cyanides were found



to be present at 74% of the sites and confirmed to have



migrated at 60% of the sites.








     At 52% of the sites toxic inorganics  (such as arsenic,



cadmium, etc.) in the groundwater from one or more monitoring



wells exceeded EPA drinking water limits  (even after taking

-------
into account the upstream (beyond the site)  groundwater



concentrations).








     Geraghty and Millerl also found that in a majority of the



fifty sites examined organic contamination of the groundwater



above background levels was observed.  In 28 (56%)  of these



sites chlorinated organics attributable to waste disposal



were observed in the groundwater.  While specific identification



of these organics was not always undertaken in this work,



(other incidents and reports (References 2 through 8)  do



qualitatively identify leached organic contaminants in



groundwater), it certainly serves to demonstrate that



organic contamination of groundwater frequently results



from industrial waste disposal.  Since the Administrator has



determined "that the presence in drinking water of chloroform



and other trihalomethanes, and synthetic organic chemicals may  have



an adverse effect on the health of persons..."* and, as noted



above, because much drinking water finds its source as



groundwater, the presence of available toxic organics in waste



is a critical factor in determining if a waste presents a hazard



when managed.  (For a discussion of how the toxicity and con-



centration of organic contaminants in waste are considered in



the hazard determination see Toxicity background document.)

-------
     The still bottoms  from  aniline  distillation contain

nitrobenzene, a toxic organic  with an  oral rat LD50 of

640mg/kg.
References  1.  Mitre  Corp.   Nitrobenzene /Aniline
               Manufacture:   Pollution Prediction and
               Abatement. EPA Contract #68-01-3188,  May 1978 .

            a.   M£>SH   'R/zqisTPii  o$ Toxic.

-------
                .
          AQUEOUS EFFLUENT FROM SCRUBBING OF SPENT

               ACID IN NITROBENZENE PRODUCTION
     The Administrator has determined this waste stream to



be a potential threat to the environment if improperly



managed.  Based on available information,  we have determined



that this waste is likely to contain the following:







          Nitrobenzene



          Nitrophanol



          Benzene



          Dinitrobenzene





     A primary exposure route to the public for toxic



contaminants is through drinking water.  A large percentage



of drinking water finds its source in groundwater.  EPA has



evidence to indicate that industrial wastes as presently



managed and disposed often leach   into and contaminate  the



groundwater.  The Geraghty and Miller reportl indicated that



in 98% of 50 randomly selected on-site industrial waste disposal



sites, toxic heavy metals were found to be present,  and that



these heavy metals had migrated from the disposal sites in 80%



of the instances.  Selenium, arsenic and/or cyanides were found



to be present at 74% of the sites and confirmed to have



migrated at 60% of the sites.







     At 52% of the sites toxic inorganics  (such as arsenic



cadmium, etc.) in the groundwater from one or more monitoring

-------
wells exceeded EPA drinking water limits  (even after taking



into account the upstream  (beyond the site) groundwater



concentrations) .








     Geraghty and Miller1 also found that in a majority of the



fifty sites examined organic contamination of the groundwater



above background levels was observed.  In 28  (56%) of these



sites chlorinated organics attributable to waste disposal



were observed in the groundwater.  Wh'ile  specific identification



of these organics was not always undertaken in this work,



(other  incidents and reports  (References  2 through 8) do



qualitatively identify leached organic contaminants in



groundwater), it certainly serves to demonstrate that



organic contamination of groundwater frequently results



from industrial waste disposal.  Since the Administrator has



determined  "that the presence in drinking water of chloroform



and other trihalomethanes, and synthetic organic chemicals may have



an adverse  effect on the health of persons..."* and, as noted



above,  because much drinking water finds  its source as



groundwater, the presence of available toxic organics in waste



is a critical factor in determining  if a waste presents a hazard



when managed.   (For a discussion of  how the toxicity and con-



centration  of organic contaminants in waste are considered in
                            IIS

-------
the hazard determination see Toxicity background document.)
     The aqueous effluent grom scrubbing spent acid in

nitrobenzene production contains

           (1) nitrobenzene:  toxic organic with an
              oral rat LD50 of 640mg/kg

           (2) nitrophenol:  toxic organic

           (3) dinitrobenzene: toxic organic

           (4) benzene: suspected carciongen
                                            *
References  1.  Mttre Corp. Nitrobenzene /Aniline Manufacture!
                Pollutant Prediction and Abatement.EPA
                Contract #  68-01-3188. May, 1978.

            2.  NIOSH Registry of Toxic Effects of  Chemical
                Substances, 1977.

-------
                               M
  BOTTOM STREAM FROM QUENCH COLUN - ACRYLONITRILE PRODUCTION
      The Administrator has determined this waste stream to


be a  potential  threat to the environment  if  improperly managed.


Based on available  information, we have determined that this


waste is likely to  contain the following:





           7%  Hydrogen cyanide
                                                          *

        0.1%  Acrylamide



      A primary  exposure route to the public  for toxic


contaminants  is through drinking water.   A large percentage


of drinking water finds its source in groundwater.  EPA has


evidence to indicate that industrial wastes  as presently


managed and disposed often leach   into and  contaminate  the


groundwater.  The Geraghty and Miller report-*- indicated that


in 98% of  50  randomly selected on-site industrial waste disposal


sites, toxic  heavy  metals were found to be present, and that


these heavy metals  had migrated from the  disposal sites in 80%


of the instances.   Selenium, arsenic and/or  cyanides were found


to be present at 74% of the sites and confirmed to have


migrated at 60% of  the sites.





      At 52% of  the  sites toxic inorganics (such as arsenic,


cadmium, etc.)  in the groundwater from one or more monitoring

-------
wells exceeded EPA drinking water limits (even after taking



into account the upstream (beyond the site) groundwater



concentrations).








     Geraghty and Miller1 also found that in a majority of the



fifty sites examined organic contamination of the groundwater



above background levels was observed.  In 28 (56%)  of these



sites chlorinated organics attributable to waste disposal



were observed in the groundwater.  While specific identification



of these organics was not always undertaken in this work,



 (other incidents and reports  (References 2 through 8) do



qualitatively identify leached organic contaminants in



groundwater), it certainly serves to demonstrate that



organic contamination of groundwater frequently results



from industrial waste disposal.  Since the Administrator has



determined  "that the presence in drinking water of chloroform



and other trihalomethanes, and synthetic organic chemicals may  have



an adverse  effect on the health of persons..."* and, as noted



above, because much drinking water finds its source as



groundwater, the presence of available toxic organics in waste



is a critical  factor in determining  if a waste presents a hazard



when managed.   (For a discussion of  how the toxicity and con-



centration  of  organic contaminants in waste are considered  in



the hazard  determination  see  Toxicity background document.)

-------
      The bottom stream from the quench column in acrylonitrile

 production contains a significant amount of HCN,  an intensely

 poisonous gas which can cause tachypnea followed by dyspnea,
                                v
 paralysis, unconsciousness,  convulsions and respiratory arrest.

 Death may result in a few minutes from exposure to  300ppm.

 This waste stream also contains acrylamide, a toxic organ^

 which has an oral rat LD50 170mg/kg.
References 1.   Mitre Corp.  Acrylonitrile Manufacture:
                Pollutant Prediction  and Abatement,
                USEPA Contract  #68-01-3188  p.  133, February,  1978

            2.   Merck Index,  Eighth Edition p.  5-44 ,

            3.   NIOSH Registry  of  Toxic Effects  of Chemical
                Substances,  1977

-------
          BOTTOM STREAM FROM WASTEWATER STRIPPER -

                  ACRYLONITRILE PRODUCTION
             n
     The Administrator has determined this waste stream to


be a potential threat to the environment if improperly


managed.  Based on available information/ we have determined


that this waste is likely to contain the following:




               225ppm HCN


               SOOppm Nicotinitrile


               540ppm Succinonitrile
     A primary exposure route to the public for toxic


contaminants is through drinking water.  A large percentage


of drinking water finds its source in groundwater.  EPA has


evidence to indicate that industrial wastes as presently


managed and disposed often leach   into and contaminate,  the


groundwater.  The Geraghty and Miller report1 indicated that


in 98% of  50 randomly selected on-site industrial waste disposal


sites, toxic heavy metals were found to be present, and that


these heavy metals had migrated from the disposal sites in  80%


of the instances.  Selenium, arsenic and/or cyanides were found


to be present at 74% of the sites and confirmed to have


migrated at 60% of the sites.

-------
     At 52% of the sites toxic inorganics (such as arsenic,
cadmium, etc.) in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits  (even after taking
into account the upstream  (beyond the site)  groundwater
concentrations).

     Geraghty and Miller1 also found that in a majority of the
fifty sites examined organic contamination of the groundwater
above background levels was observed.  In 28  (56%) of these
sites chlorinated organics attributable to waste disposal
were observed in the groundwater.  While  specific identification
of these organics was not always undertaken in this work,
(other incidents and reports  (References  2 through 8) do
qualitatively identify leached organic, contaminants in
groundwater), it certainly serves to demonstrate that
organic contamination of groundwater frequently results
from industrial waste disposal.  Since the Administrator has
determined  "that the presence in drinking water of chloroform
and other trihalomethanes, and synthetic  organic chemicals may have
an adverse  effect on the health of persons..."* and, as noted
above, because much drinking water finds  its source as
groundwater, the presence of available toxic organics in waste
is a critical factor in determining if a  waste presents a hazard

-------
when managed.  (For a discussion of how the toxicity and con-

centration of organic contaminants in waste are considered in


the hazard determination see Toxicity background document.)




     The bottom stream from the wastewater stripper contains

HCN, an intensely poisonous gas which can cause tachypnea followed
                                           ^
by dyspnea, paralysis, unconsciousness, convulsions and      '"•


respiratory failure.  Exposure to ISOppm for 1/2 -' 1 hour may,

endanger life.  This stream also contains the toxic organics,

nicotinitrile and succinonitrile.
References  1.  Mitre Corp. Acrylonitrile Manufacture Pollutant
                Prediction and Abatement  USEPA Contract
                #68-01-3188 p. 137 February, 1978


            2.  Merck Index, Eighth Edition


            3.  NIOSH Registry of Toxic Effects of Chemical
                Substances, 1977.

-------
    STILL BOTTOMS FROM FINAL PURIFICATION  OF ACRYLONITRILE

      The Administrator has  determined  this waste  stream  to
 be a potential threat to  the environment  if improperly managed.
 Based on available  information,  we  have determined  that  this
 waste is likely to  contain  the  following:

           Methacrylonitrile
           Acrylamide
           Acrylic acid

      A primary exposure route to the public for toxic
 contaminants is through drinking water.   A large  percentage
 of drinking water finds its source  in  groundwater.  EPA  has
 evidence to indicate  that industrial wastes as presently
 managed and disposed  often  leach .  into and contaminate  the
 groundwater.   The Geraghty  and  Miller  report1 indicated  that
 in 98% of 50 randomly selected  on-site industrial waste  disposal
 sites/ toxic heavy  metals were  found to be present, and  that
 these heavy metals  had migrated from the  disposal sites  in 80%
of the instances.  Selenium,  arsenic and/or cyanides were found
 to be present at 74%  of the sites and  confirmed to  have
migrated at 60% of  the sites.

      At 52% of the  sites  toxic  inorganics (such as  arsenic,
cadmium, etc.) in the groundwater from one or more  monitoring

-------
wells exceeded EPA drinking water limits  (even after taking
into account the upstream  (beyond the site) groundwater
concentrations).

     Geraghty and Miller1 also found that in a majority of the
fifty sites examined organic contamination of the groundwater
above background levels was observed.  In 28 (56%)  of these
sites chlorinated organics attributable to waste disposal
were observed in the groundwater.  While specific identification
of these organics was not always undertaken in this work,
(other incidents and reports (References 2 through 8) do
qualitatively identify leached organic contaminants in
groundwater),  it certainly serves to demonstrate that
organic contamination of groundwater frequently results
from industrial waste disposal.  Since the Administrator has
determined "that the presence in drinking water of chloroform
and other trihalomethanes, and synthetic organic chemicals may have
an adverse effect on the health of persons..."* and, as noted
above, because much drinking water finds its source as
groundwater, the presence of available toxic organics in waste
is a critical factor in determining if a waste presents a hazard
when managed.   (For a discussion of how the toxicity and con-
centration of organic contaminants in waste are considered in
the hazard determination see Toxicity background document.)

-------
      The still bottoms contain methacrylonitrile (toxic
 organic with an oral rat LD50 of 250mg/kg) ,  acrylamide
 (toxic organic with an oral rat LD50 of 170mg/kg) and
 acrylic acid (a corrosive and toxic organic  with an oral
 rat LD50 of 340mg/kg).
References   1.   Mitre  Corp. Acrylonitrile Manufacture:
                 Pollutant Prediction and Abatement. USEPA
                 Contract 168-01-3188 p. 138, Feb.  1978  •
             2.   NIOSH  Registry of  Toxic Effects  of Chemical
                 Substances,  1977.

-------
SOLID WASTE FROM ION EXCHANGE COLUMN - ACRYLONITRILE PRODUCTION





      The Administrator has determined this waste stream to



 be a potential threat to the environment if improperly managed.



 Based on available information, we have determined that this



 waste is likely to contain the following:







           Acrylonitrile -





      A primary exposure route to the public for toxic



 contaminants is through drinking water.  A large percentage



 of drinking water finds its source in groundwater.   EPA has



 evidence to indicate that industrial wastes as presently



 managed and disposed often leach   into and contaminated the



 groundwater.  The Geraghty and Miller report1 indicated that



 in 98% of 50 randomly selected on-site industrial waste disposal



 sites, toxic heavy metals were found to be present, and that



 these heavy metals had migrated from the disposal sites in 80%



 of the instances.  Selenium, arsenic and/or cyanides were found



 to be present at 74% of the sites and confirmed to have



 migrated at 60% of the sites.







      At 52% of the sites toxic inorganics (such as arsenic,



 cadmium, etc.) in the groundwater from one or more monitoring



 wells exceeded EPA drinking water limits (even after taking

-------
into account the upstream  (beyond the site) groundwater
concentrations).

     Geraghty and Miller1 also found that in a majority of the
fifty  sites examined organic contamination of the groundwater
above  background levels was observed.  In 28 (56%) of these
sites  chlorinated organics attributable to waste disposal
were observed in the groundwater.  While specific identification
of these organics was not always undertaken in this work,
(other incidents and reports  (References 2 through 8) do
qualitatively identify leached organic contaminants in
groundwater), it certainly serves to demonstrate that
organic contamination of groundwater frequently results
from industrial waste disposal.  Since the Administrator has
determined  "that the presence in drinking water of chloroform
and other trihalomethanes, and synthetic organic chemicals may have
an adverse  effect on the health of persons..."* and, as noted
above,  because  much drinking water finds its source as
groundwater, the presence of available toxic organics in waste
is a critical factor in determining if a waste presents a hazard
when managed.   (For a discussion of how the toxicity and con-
centration  of organic contaminants in waste are considered in
the hazard  determination see Toxicity background document.)

-------
     The waste from the ion exchange column contains

acrylonitrile, a toxic/ flammable organic with an oral

rat LD50 of 82mg/kg.
References  1.  Mitre Corp. Acrylonitrile Manufacture"Pollutant
                Practices Prediction and Abatement,  USEPA Contract
                #68-01-3188 February, 1978 p. 138.

            2.  NIOSH Registry of Toxic Effects of Chemical
                Substances, 1977.

-------
 WASTE STREAM FROM HCN PURIFICATION - ACRYLONITRILE  PRODUCTION

      The Administrator has determined  this waste  stream to
 be a potential threat to the  environment  if  improperly
 managed.  Based on available  information, we have determined
 that this waste is likely to  contain the  following:
           Propenes,  Butenes and  Pentenes.
           Propenes and butenes are flammable gases.   Pentene
      has a flash point of 0°F.
      As is evident from above this waste  stream has a flash
 point of 140°F or below.   Ignitables with flash points less
 than 140°F can become a problem  while  they are  landfilled.
 During and after the disposal of an ignitable waste,  there
 are many available external and  internal  energy sources
 which can provide an impetus  for combustion,  raising
 temperatures of waste to their flash points.  Disposal of
 ignitable waste may  result in fire that will cause  damage
 directly from heat and smoke  production or may  provide a
vector bywhich other hazardous waste can  be  dispersed.
      Ignitable wastes tend to be highly volatile  and  the
evaporation of these volatiles contributes to poor  air
quality.   (Refer to  ignitability background  document  for
 further detail) .

-------
                          Reference
1.  Mitre Corp. Acrylonitrile Manufacture
    Pollutant Prediction and Abatement
    USEPA contract §68-01-3188 Febu^vbry, 1978 p.  140.
                             3116

-------
  BOTTOMS FROM ACETONITRItfE PURIFICATION - ACRYLONITRILE PRODUCTION
     The Administrator has determined this waste stream to be



a potential threat to the environment if improperly managed.



Based on available information, we have determined that this



waste is likely to contain the following:



     Acetonitrile:



     Benzene:

-------
     A primary exposure route to the public for toxic



contaminants is through drinking water.   A large percentage



of drinking water finds its source in groundwater.   EPA has



evidence to indicate that industrial wastes as presently



managed and disposed often leach * into and contaminate  the



groundwater.  The Geraghty and Miller reportl indicated that



in 98% of 50 randomly selected on-site industrial waste disposal



sites, toxic heavy metals were found to be present,  and that



these heavy metals had migrated from the disposal sites in 80%



of the instances.  Selenium, arsenic and/or cyanides were found



to be present at 74% of the sites and confirmed to have



migrated at 60% of the sites.







     At 52% of the sites toxic inorganics  (such as arsenic,



cadmium, etc.) in the groundwater from one or more monitoring



wells exceeded EPA drinking water limits  (even after taking



into account the upstream  (beyond the site) groundwater



concentrations).







     Geraghty and Miller1 also found that  in a majority of the



fifty sites examined organic contamination of the groundwater



above background levels was observed.  In  28  (56%) of these



sites chlorinated organics attributable to waste disposal



were observed in the groundwater.  While  specific identification



of these organics was not always undertaken in this work,

-------
 (other  incidents and reports  (References  2 through 8) do
qualitatively  identify leached organic contaminants in
groundwater) ,  it certainly serves to demonstrate that
organic contamination of groundwater frequently results
from  industrial waste disposal.  Since the Administrator has
determined  "that the presence in drinking water of chloroform
and other  trihalometh and synthetic organic chemicals may have
                     A
an adverse effect on the health of persons..."* and/ as noted
above/ because much drinking water finds its source as
groundwater/ the presence of available toxic organics in waste
is a critical factor in determining if a waste presents a hazard
when managed.   (For a discussion of how the toxic ity and con-
centration of organic contaminants in waste are considered in
the hazard determination see Toxic ity background document.)

     The column bottoms from acetonitrile purification contain
acetonitrile/ ana organic substance with a flash point of 42°F,
and benzene/ a  suspected carcinogen.
References:    1.  Mitre Griop. Acrylonitrile Manufacture'Pollutant
                   Prediction and Abatement,USEPA Contract
                   #68-01-3188 February/ 1978 p. 139
               2.  NIOSH Registry of the Toxic Effects of
                   Chemical Substances, 1977.
                           •XV3

-------
2890 Sludges, wastes from tub washes (Ink Formulation) (T)

     This waste is classified as hazardous because of its
toxic characteristic.  According to the information EPA has
on this waste stream it meets RCRA §250.13d characteristic
indentifying toxic waste.
     The Administrator has determined this waste stream to be
a potential threat to the environment if improperly managed.
     EPA bases this classification on the following information:
          1)  An EPA contractor has tested a sample of waste
          sludges and has found the following:
               Contaminant              Cone  mg/1
               Cr as total Chromium          150
               Cd                            .29
               Pb                            760
                              pH = 12.5
     The data presented are available from:
     Effluent Guidelines for Paint Formulating and the Ink
     Formulating Industry.  EPA 444/1-75/050.
     The National Interim Primary Drinking Water Regulations
 (NIPDWR) set limits  for chemical contamination of drinking water.
 The  substances listed represent hazards to human health.
 In  arriving at these specific limits/ the total environ-
 mental  exposure of man to a stated specific  toxicant  has
 been considered.   (For a complete treatment  of the data
 and reasoning used  in choosing the substances and specified

-------
 limits please refer to the NIPDWR Appendix  A-C
 Chemical Quality,  EPA-6570/9  -  76 -  003).
      A primary exposure route to the public for  toxic
 contaminants is through drinking water.  A  large percentage
 of drinking water  finds its source in groundwater.  EPA has
 evidence to indicate that industrial wastes as presently
 managed and disposed often leaches into  and contaminate the
 groundwater.  The  Geraghty and  Miller report indicated that
 in 98% of 50 randomly selected  on-site industrial waste
 disposal sites, toxic heavy metals were  found to be present,
 and that these heavy metals had migrated from the disposal
 sites in 80% of the instances.   Selenium, arsenic and/or
 cyanides were found to be present at 74% of the  sites  and
 confirmed to have  migrated at 60% of the sites.
      At 52% of the sites toxic  inorganics  (such  as arsenic,
 cadmium etc.)  in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits (even after taking
 into account the upstream (beyond the site)  groundwater
concentrations.
      Arsenic,  barium,  cadmium,  chromium, lead, mercury,
selenium, and silver are toxicants listed by the NIPDWR
at  concentrations  of 0.05,  1.00,  0.010,  0.05, 0.05, 0.002,
O.Ol/  and 0.05 mg/1 respectively because of  thier toxicity.
As  explained in the RCRA toxicity background documents
these concentrations convert  to  0.5,  10.0,  0.1,  0.5,
0.5,  0.02,  0.1, and 0.5 mg/1  respectively in the  EP extract.
      This waste has been shown to contain chromium,  cadmium,

-------
and lead at concentrations of 150.0, 0.29, 760.0 mg/1

respectively, according to EPA 444/1-75/050, Effluent

Guidelines for Paint Formulation and Ink Formulating

Industry.

          2) California Manifest

          Additional information regarding the composition

     of this waste stream was obtained from sample analyses

     as shown in Handbook of Waste Composition in California,

     1978.  Shown below are typical compositions of ink waste

     water and equipment cleaning wash water as found on the

     California Manifests.


          Ink Waste Water               0.16% Zinc

                                        0.10% lead

                                      236ppm suspended solids

                         1575 gals



          Printing Ink                       Equipment Cleaning
          Production                         Wash water


                    1-2% lead chromate

                    5-7% other pigments

                    4-6% phenolics

                    3-5% NaOH

                    balance Water

                    pH 8

-------
      The following section discusses  the  listed wastes  resulting
 from the manufacture of those  organic chemicals commonly  used  as
 pesticides.   The discussions of  these has been organized  differently
 than for those for the other listed waste streams.   This  has been
 done because of the repetitive nature of,  and similiarities between
 the type of  available information  on  these wastes,  and  because
 of the similiarities between the types of sources of these wastes
 (e.g.  side reactions hydrolyzed  product/  product contamination
 of waste).
      A general section detailing the  hazards posed  by these
 types of waste will be followed  by descriptions of  the  reactions
 undergone in the processes generating these wastes  (including
 identification of toxicity information on potential contaminents).
 PESTICIDES:   GENERAL DISCUSSION
      A primary exposure route  to the  public for toxic contaminants
 is through drinking water.  A  large percentage of drinking water
 finds its source in groundwater.   EPA has evidence  to indicate
 that industrial wastes as  presently managed and disposed  often leaches
 into and contaminates the  groundwater.  The Geraghty and  Miller
 report^- indicated that in  98%  of 50 randomly selected on-site
 industrial waste disposal  sites, toxic heavy metals  were  found to
be  present,  and that these heavy metals had migrated from the  disposal
 sites  in 80% of the instances.   Selenium,  arsenic and/or  cyanides
were found to be present at 74%  of the sites and confirmed to  have
migrated at  60% of the sites.
      At 52%  of the sites toxic inorganics  (such as  arsenic, cadmium,
etc.)  in tne groundwater from  one  or  more  monitoring wells exceeded
EPA drinking water limits  (even  after taking into account the
upstream (beyond the site)  groundwater concentrations)..

-------
     Geraghty and Miller1 also found that in a majority of the

fifty sites examined organic contamination of the groundwater

above background levels was observed.   In 28 (56%)  of these sites

chlorinated orgaincs attributable to waste disposal were observed

in the groundwater.  While specific identification of these organics

was not always undertaken in this work,  (other incidents and

references 2 through 8 do qualitatively  identify leached organic

contaminants in groundwater) it certainly serves to demonstrate

that organic contamination of groundwater frequently results from

industrial waste disposal.  Since the Administrator has determined

"that the presence in drinking water of  chloroform and other

trihalomethanes and synthetic organic chemicals may have an adverse

effect on the health of persons..."* and, as noted above, because

much drinking water finds its source as  groundwater, the presence

of available toxic organics in waste is  a critical factor in

determining if a waste presents a hazard when improperly managed.

(For a discussion of how the toxicity and concentration of organic

contaminants in waste are considered in  the hazard determination

see Toxicity background document).
*"Interim Primary Drinking Water Regulations,"
  p. 5756, Federal Register, 2/9/78

-------
The following waste streams:
          Wastewater treatment sludges from the production of
          dieldrin, chlordane, toxaphen, disulfoton, mala-
          thion, phorate, carbarftyj, trifluraline, alachlor,
          methyl parathion, parathion, vernolate, methomly,
          carbofuran, captan, creosote, dithio carbamates,
          pentachlorophenol, bromacil, diuron,  dichlorobenzene
          and cloroxuron.   (O,M,B,)

          Wastewater from oxidation of aldrin solution in
          production of dieldrin.   (O,M,B,)

          Wastewater from extraction of dieldrin solution in
          production of dieldrin.   (0,M,B)

          Wastewater and scrub water from chlorination of
          cyclopentadiene in production of chlordane.
           (0,M,B)

          Filter solids from filtration of hexachlorocylopenta-
          diene in production of chlordane.   (O,M,B)

          Filter cake from  filtration of toxaphene  solution
          in production of  toxaphene.   (O,M,B)

          Unrecovered triester from production of disulfoton.   (0,M)

          Still bottoms from toluene reclamation distillation in
          production of disulfoton.   (O,M)

          Filter cakes from filtration of dimethylphosphoro-
          thion and DMTA in production of malathion.   (O,M)

          Liquid wastes from washing and stripping  in production
          of malathion.  (O,M,)

          Liquid and solid  wastes  from the washing, stripping
          and filtration of phorate in phorate production.   (0,M)

          Filter cake from  the filtration of diethylphosphorodi-
          thoric acid in the production of phorate.   (0,M)

          Heavy ends and distillation residues from production
          of carbaryl.   (0,M)

          2, 6-D waste by-product  from production of 2,4-D.   (O,M,B)

          Heavy ends or distillation residues from  distillation
          of tetrachlorobenzene  in production of 2f4,5-T.
           (0,M,B)

          Scubber and filter wastes from production of
          atrazine.   (0,M)

-------
           Filter cake from production of diazinon.   (O,M)

           By-product salts in production of  MSMA.   (0,M)

           By-product salts in production of  cacodylic  acid.   (T)

           Tars from manufacture of bicycloheptadiene and
           cyclopentadiene.  (0,M,B)

potentially contain the organic contaminants listed in the  following

section under the respective waste stream.   The  toxicity of these

contaminents is also indicated.  Because of  the  toxicity of these

contaminents and because of the persistance  and  bioaccumulation

characteristics of many of them,these waste  streams are to  be

considered hazardous, as noted in the specific listing.

-------
                             Alachlor
         Aiachlor is produced according to the following  reaction.
     scheme  :
C2H5
Diethylauiline
H2CO     C2H
                 Solvent
            CICH^   C-CH£C1


C1CH2COC1    C2H^^iv.^C2H5
                                       NH4C1
                                                          CH3OH
                                     !?   8-CH2CI
                                     or%
                                                   Alachlor-
                                    m^
    Alachlor, its hydrolyzed derivaties, solvent, and reaction

    tars may be present in the wastestream.
    alachlor
        -  Oral  Rat      - LD50: 1200 mg/kg
    3^:  Ref  1, p. 153-156
    2.  Ref  2

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                    References
1.  Lawless, E.W., Pesticide Study Series -5-
    The Pollution Potential in Pesticide Manufacturing.
    Technical Studies Report:  TS -00- 72 - 04.
    Washington, U.S. GPO, 1972.  250p.

2.  NIOSH Registry of Toxic Effects of Chemical Substances,
    VOL I and II.  U.S. Department of Health, Education,
    and Welfare.  1977.

3.  Parsons, T., Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77 - 023h,
    Technology Series, Environmental Protection Agency,
    Washington, 1977.  232p.

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                                                             I. *
                  Aldrin,  Dieldrin





      Due  to  the  lack  of quantitative information on the



contents  of  the  wastestrearas,  this  report is more detailed



than  is customary.  Aldrin and Dieldrin will be considered



together  since Dieldrin is produced from the epoxidation



of Aldrin.   In the  first  step  of the reaction,  the freshly



cracked cyclopentadiene is condensed with acetylene to form



bicycloheptadiene.
              C5Hg. + C2H2
                                Bicycloheptadiene






     The reaction  is  either  carried out in an organic



solvent or else  the acetylene  is  diluted with a nitrogen



stream.  The  reaction goes in  about 30-60% yield in toluene
     •


with the major by-products being  tricycline and other



multiple ring compounds  .  The C-^Hg produced is removed



and the "bottoms"  are introduced  back  into the cracker.






1. ref. 1 pg. 5-88,89

-------
     Bicycloheptadiene undergoes a Diels-Alder

condensation with hexachlorocyclopentadiene to form Aldrin.
     Hexachlorocyclopentadiene may contain as impuritiesr

trichlorocyclopentene isomers, octachlorocyclopentene,

and pentachlorocyclopentadiene2 formed from incomplete

chlorination.  CsHg and C2^2 may also be present in the

diene reactor.  Therefore many other chlorinated condensation

products are possible, some of high molecular weights.

     Technical grade Aldrin contains about 12-13% analogs

and 5% various other compounds3.  A possible source of

hazardous wastes would be in the cleaning of the diene

reactor  (for reaction(2)) where chlorinated tars and Aldrin

might be present.
2. ref. 2 pg. 7
3. ref 1  5-88,89

-------
     Liquid wastes  from  spill  cleanup  or washing go to
an asphalt-lined  evaporation basin.  During shut down,
the Aldrin unit is  washed  with toluene and these wastes
                            4
go into  Dieldrin  manufacture  .
     Dieldrin  is  produced  from the  epoxidation of Aldrin
with a peracid.
                     HOAc
           Aldrin             Dieldrin
In the first  stage of  the process,  a  solution of  Aldrin
in toluene is filtered and  the  filter solids  are  incinerated  .
The filter solids contain chlorinated tars  and higher molecular
weight condensation products produced from  the diene
reaction  (2).
4 ref. 3 pg.  80-83
5 ref. 3 pg.  84-87

-------
     The filtered Aldrin is oxidized with the peracid

with H2S04 as a catalyst.  The aqueous phase is removed,

the Dieldrin solution is extracted with water, and both

these wastewater streams are sent to an evaporation basin .

     The waste water is likely to contain sulfuric acid,

acetic acid, toluene, Aldrin, Dieldrin, and Aldrin and

Dieldrin analogs.  The waste may also contain side products

from the epoxidation such as glycols, glycol esters and

ketone derivatives of Dieldrin6.

     Aldrin is chemically stable but is oxidized by chlorination,

potassium permanganate, ozone and aeration.  Incomplete

oxidation leads to Aldrin rather than a nontoxic product

while Dieldrin is chemically stable towards alkali and

mineral acids.  Both undergo catalytic decomposition in the

presence of an active metal  .

     The last stage of the process involves solvent stripping

and recycling.  Tars are removed from the equipment by toluene.


5 ref. 3 pg. 80-83                                    *~
6 ref. 4 pg. 618-619
7 ref. 5 pg. 42

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                       Toxicity Data8
     Dieldrin:
          oral human - LDLo:  28mg/kg
          oral rat   - LD50:  46mg/kg
          carcinogenic determination:  animal positive
     Aldrin:
          oral human - TCLo:  14mg/kg
          oral child - TDLo:  1250/«.g/kg
          oral rat - LD50:   67mg/kg

          Toxic effects - central nervous  system
          Carcinogenic detn. - indefinite
     Toluene;


          oral human - LDLo: 50mg/kg
          oral rat - LD50: 5000mg/kg

          Aquatic toxicity TLm 96: 100-lOppm
          DOT - flammable

     Cyclopentadienef Hexachloro;

          oral rat - LD50:  113mg/kg

                  Miscellaneous Information


     Aldrin9:

          water solubility: 27ppb
          persistance in soil: more than 12 months

             9
     Dieldrin :

          .water solubility: 185ppb
          persistance in soil: more than 12 months
8 ref. 6
9 ref. 5 pg. 164

-------
                    References
1.  Office of Solid Waste Management Programs.
     Assessment of Industrial Hazardous Waste Practices:
     Organic Chemicals, Pesticides and Explosives.
     Environmental Protection Publication SW-118C.
     Washington, D.C., U.S. GPO, 1976.

2.  Parsons, T., Editor. Industrial Process
     Profiles for Environmental Use:  Chapter 8.
     Pesticide Industry.  EPA - 600/2- 77 - 023h,
     Technology Series, Environmental Protection Agency,
     Washington, 1977. 232p.

3.  Lawless, E.W. Pesticide Study Series -5--
     Th e Pollution Potential in Pesticide Manufacturing.
     Technical Studies Report:  TS -00- 72 - 04.
     Washington, U.S. GPO , 1972. 250p.

4.  March, J.  Advanced Organic Chemistry:
     Reactions, Mechanisms, and Structure.
     New York, McGraw-Hill Book Company, 1968. 1098p.

5.  Atkins, P. The Pesticide Manufacturing Industry-
     Current Waste Treatment and Disposal Practices.
     Office of Research and Monitoring, Project 12020FYE.
     Washington, U.S. GPO, 1972. 185p.

6.  NIOSH Registry of Toxic Effects of Chemical Substances,
     VOL I and II.  U.S. Department of Health, Education,
     and Welfare.  1977.

-------
                         Atrazine
   process
        Atrazine is produced by the following four-step
          1/2.
  Cl2(g)  + HCN(g)
  CNC1. .  + HC1, .
      (g)       (g)
                                                  (i)
           300-410°
  CNCL
                                             Cl
                                       ci
                                         Cyanuric
                                         chloride
                             (2)
                Cl
Cl
             Cyanuric
             chloride
                       Solvent
        Cl

      JOL
      ^-^^
                                                   HC1
                             (3)
Cl
H
H
                                      Cl
                                                 )-
                                                3 2
                                                      HC1    (4)
                                   Atrazine
  TIRef  1,  p.  14,15,17-20
  2.   Ref  2,  p.  143-147

-------
     According to the report by Lowenbach and Schlesinger ,
the following pollutants may be present in the waste streams
generated from Atrazine production:
                                                    4*
Cyanuric chloride
Ethyl amine
       «
Isopropylamine

Methylethyl Ketone

Diethylamine

Diisopropylamine

Atrazine
2-chloro-4,6-bis-ethyl amino-s-triazine
2-chloro-4,6-bis-isopropyl amino-s-
  triazine
   LD5Qrat
     mg/kg
      **
 LDLo:400
 820 (DOT flammable
       liquid)
  3400 (DOT flammable
        liquid)
 540 (DOT flammable
       liquid)
 700 (DOT flammable
       liquid)
1750
5000
5000
Cyanuric acid                             LDLo:500
2,6-dichloro-4-ethyl amino-s-triazine          **
2,6-dichloro-4-isopropyla amino-s-triazine
2-hydroxy-4,6-bis-ethyl amino-s-triazine
     **
     **
2-hydroxy-4,6-bis-isopropyl amino-s-
  triazine
2-hydroxy-4-ethyl araino-6-isopropy1
  amino-s-triazine
Other related s-triazines (hydrolyzed and
  unhydrolyzed)
3. Ref 1
4. Ref 3  *  Except where otherwise stated
          ** Not available
     **
     **
     **
                        230

-------
                                                    4*
                                             LD5Qrat
                                               mg/kg
Cyanogen polymers                               **
Cyamelic chloride                               **
Cyanuric chloride polymers                      **
Oxalyl chloride                                 **
Cyanogen                                   inn-rat LC50:350 ppm/lH
Cyanides                                     (DOT-Poison B)
Cyanic acid                                     **
Hydrocyanic acid                           LDLotlO  (DOT-Poison A)
          l»
     N-nitosoamines may also be formed from the reaction of
          <*
secondary amines  (atrazine and its side products) with
nitrogen oxide .
     The calcium chloride and calcium sulfate used to dry
cyanogen before the cyanuric chloride reaction may contain
cyanogen, cyanogen chloride, cyanuric acid, cyanic acid,
                                    6
chlorine, hydrocyanic acid and water .
     The spent carbon catalyst used to catalyze the cyanuric
chloride reaction may contain cyanogen chloride, dimers of
cyanogen chloride, cyanuric acid, and cyanuric chloride .
5. Ref l, p.J
6. Ref 1, p. 15,30
7. Ref 1, p. 15,31

-------
                      References


1.  Lowenbach,  W.,  Schlesinger, J.,  and King,  J.
    Toxic Pollutant Identification:   Atrazine Manufacturing.
    Office of Energy, Minerals, and Industry,  Washington, D.C.,
    1978.  54p.

2.  Lawless, E.W.,  Pesticide Study Series -5-
    The Pollution Potential in Pesticide Manufacturing.
    Technical Studies Report:  TS -00- 72 - 04.
    Washington, U.S. GPO, 1972.  250p.

3.  NIOSH Registry of Toxic Effects of Chemical Substances.
    VOL I and II.  U.S. Department of Health,  Education,
    and Welfare.  1977

-------
          Bicycloheptadiene and Cyclopentadiene

     Bicycloheptadiene and cyclopentadiene are used as starting
materials for a variety of diene-based chlorinated pesticides.
Cyclopentadiene is produced from the cracking of the
cyclopentadiene dimer.  Bicycloheptadiene is produced from the
condensation of cyclopentadiene and acetylene.  Numerous higher
molecular weight condensation products and tars  are formed by
this process.

                                        Rat !
Chemical                                LD50  mg/kg
Bicycloheptadiene                       890 (intraperitoneal)
Bicyclopentadiene                       353 (oral)
1.   NIOSH  Registry of Toxic Effects of Chemical Substances.
     VOL  I  and  II.  U.S. Department of Health/ Education,
     and  Welfare.  1977 .

-------
                          Bromacil
     Bromacil is produced according to the following

process-*-;


                         CH3COCH2CO2C2H3   ..
The first step of the process is the formation of sec-butyl urea.

Possible side products are urea and bis- (sec-butyl) urea.

The alkyl urea is next condensed with ethyl-acetoacetate  to

produce 3-sec-butyl-6-methyl uracil.  Other possible side

products are l-sec-buty-6-methyl-uracil, 6-methyl-uracil,

and 1,3-di (sec-butyl)- 6-methyl-uracil.  The uracil is purified

neutralized with I^SC^, and then brominated to yield

Bromacil .
1. Ref 1, p. 77,81
2. Ref 2, p. 52,55,56

-------
     Other possible brominated products of the uracils



may also be present.  All the above mentioned by-products,



reaction intermediates/ tars, and residues in addition



to Bromacil may be found in the wastewater sludge.



     Bromacil  oral rat  LD50:  5200mg/kg
3. Ref 3

-------
                         References
1.  Parsons,?.,  Editor.   Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.   EPA-600/2-77-023h,
    Technology Series,  Environmental Protection  Agency,
    Washington,  1977.   232p.

2.  Effluent Guidelines Division,  Office of Water  and
    Hazardous Materials.  Development Document for Interim
    Final Effluent Guidelines for  the Pesticide  Chemicals
    Manufacturing Point Source Category.  EPA 440/1-75/
    060d Group II.  Washington, 1976

3.  NIOSH Registry of  Toxic Effects of Chemical  Substances,
    VOL I and II.  U.S.  Department of Health,  Education,
    and Welfare.  1977 .

-------
                Cacodylic  Acid/  MSMA
     Cacodylic acid  and  MSMA will be treated together since
they are manufactured  from the same intermediate.  The pro-
duction scheme is  shown  below :
         3NaOH
1/2 As203 — • -
                 -f 3/2
            CH3A$O(ONa)2
               DSMA
                 O
                CH3AsO
                 K>
                                     CH3AiO(ONo)OH + NaSO4
                                        MSMA
                                            HC1
                                                            NoCt
                                                CoeodylTe
                                                Acid
Discharge  at one MSMA plant contains  0.7 to 0.8 ppm arsenic
as well  as NaCl and Na2604.  The solid waste from the
Cacodylic  acid process contains a mixture of NaCl, Na2S04
                                     2
and  1-1  1/2% cacodylate contaminants •
      Cacodylic acid and its salts are undergoing pre-RPAR
review due to "oncogenicity; mutagenicity; teratogenicity;
fetotoxicity; male reproductive effects"

TT Ret 1,  p. 97-104
2. ibid                        ;
3. Special Pesticides Review Dvision Status Report, ITov  2,  1978

-------
                     Reference
1.  Parsons, T.,  Editor.  Industrial Process Profiles for
    Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA-600/2-77-023h,
    Technology Series, Environmental Protection Agency/
    Washington, 1977.  232p.

-------
                        Captan

                                                 1
     Captan is produced by the following process  •
CH-CH2
j • •
CH=CH2
Butadiene
•• •
,,


CH-CO
| ^>Q + NH:
CH-CO
Haleic
" anhydride



HC
j — > !j
HC
CH-CO
j >
CH-CO
1
NH 2

,NaOH
,CC13SC1
•-
XrfJ.*^
Tetrahydrophthalimide









HC
||
HC


v^
NCH-CO
| > NSCC1
CH-CO
                                                            NaCl
                                         Captan
                              I,
                    CS2 + 3C12 - ^ CC13SC1 + SC12


                       Perchloromethyl raercaptaa
The wastewater treatment sludge may contain captan/ starting

materials,  reaction intermediates, by-products,  and tars.

1200  pounds of chemical wastes are generated each year

by +Hi& process.

i" Rei  1,  p. 157-162
2. Ref  2,  p. 93-94

-------
A few  possible side reactions  are listed  below

               o            o
RX + ©N
                        R-N;
  il
  ,c
    /
        NH   +
                           c
                           I
                           c
O
U
c
                                           \
                                                NE
          CH,
          r
          c
          I
          c >
              CH,
                         H
                             CH,
                                         to
3. Ref 3, p. 340

-------
   Possible ;
   Found in Wastewater
   Treatment Sludges

   Captan

   Butadiene

   Maleic an .hydride

   Tetrahydrophthalic acid anydride

   Tetrahydrophthalimide
                     r
   Perchloromethyl melpeaptan

   CC13SNH2

   4-Vinyl-1-cyclohexene
   Tetrahydrophthalate

   Misq-condensation products

   Tars

   Carbon disulfide

   Iodides

   Misc. sulfides

   Solvent
                                           Oral Rat
                                          LD50 mg/kg*

                                            9000

                                            5480

                                             4816

                                          (DOT: corrosive)

                                                **

                                              83

                                              **

                                            3080
(carcinogenic
 determination:
 indefinite     )
                                              **
                                              **
                                              **
                                          (DOT: flammable)
                                              **

                                              **

                                              **
G
i<  Unless otherwise indicated
** Data unavailable
. . Ref 4
 . (Federal Register - 10/28/77-Maleic Anhydride
    Dncogenic in mice, mutagenic in plants,
    •flies, rats; reproductive effects in rats])

-------
                     References
1.  Lawless, E.W., Pesticide Study Series -5-
    The Pollution Potential in Pesticide Manufacturing.
C                       Environmental Protection Agency
    Washington, 1977.., 232p.
    T.chMuoJ Stud***  Report
2.  Parsons, T., Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77 - 023h,
    Technology Series, Environmental Protection Agency,
    Washington, 1977.  232p.

3.  March, J.  Advanced Organic Chemistry:
    Reactions, Mechanisms, and Structure.
    New York, McGraw-Hill Book Company, 1968.  1098p.

4.  NIOSH Registry of Toxic Effects of Chemical Substances,
    VOL I and II.  U.S. Department of Health, Education,
    and Welfare.  1977.

-------
                        Carbaryl


      Carbaryl is manufactured according  to the following

production scheme:
 Naphthalene
Tetrahydro-
naphthalene
         . 0-C(0)NHCH3
                      ,CH3NH2
                        NaOH
1-Tetralol
1-Tetralone
                0-C(0)C1
                           COCl?
                           KaOH
      Carbarvl
          l-Nut;I-thyl-
          chloroforraate
                1-Iiaphthol
The  by-products that may be present  from the production of
                                  L,
1—naphthol are:  unreacted naphtalene/  tetrahydronaphthalene
                                  A
1-tetralone, 2-tetralone, and 2-naphthol.
T.  Ret 1 pg. 118-122
                             543

-------
     The 1-naphthol and its by-products are next reacted
with phosgene (COC1 )  and sodium hydroxide to form 1-naphthyl-
chloroformate and sodium chloride.  By-products formed in this
step are: 2-naphthyl chloroformate and 1-1 (or either 1,2 or 2,2)
                   2
dinaphthylcarbonate .   All of these may be present in the
wastewater in small quantities.
     The 1-naphthyl-chloroformate is next reacted with
methylamine and sodium hydroxide to produce carbaryl.  Unreacted
tetralone  (if present) may react with the amine to form an
imine or an enamine '   which could aromatize to form N-methyl—
napthylamine.  These would also be present in the wastewater.
     Carbaryl is susceptible to basic hydrolysis to yield
1-naphthol' and N-methyl-carbonate.
 2.  Ref 2,  p.  319
 3.  Ref 3,  p.  858
 4.  Ref 2,  p.  667
 5.  Ref 4,  p.  41

-------
                     Toxicity Data
Carbaryl
     Oral rat
     Oral man
     Oral human
1-naphthol
     Oral rat
2-naphthol
     Oral rat
                         -  LD50:   400 mg/kg
                                       -ft,
                         -  TDLo:  2800 -»g/kg
                         -  LDLo:    50 mg/kg

                         -  LD50:  2590 mg/kg
                         -  LD50:  2420 mg/kg
1,2,3,4-tetrahydro-naphthalene
     Oral rat            -  LD50:  2860 mg/kg
     Oral human          -  LDLo:    500 mg/kg
     Aquatic toxicity rating  - TLm  96:100-10 ppm
1-tetralone
     Oral rat            -  LD50:    810 mg/kg
Naphthalene
     Oral rat
     Oral human
N-methyl-1-naphthylamine
     Oral rat
Miscellaneous  Information'
     Carbaryl  solubility in water -  
-------
                   References
Lawless, E.W.  Pesticide Study Series -5-
 The Pollution Potential in Pesticide Manufacturing.
 Technical Studies Report:  TS -00- 72 - 04.
 Washington, U.S. GPO, 1972.  250p.

March, J.  Advanced Organic Chemistry:
 Reactions, Mechanisms, and Structure.
 New York, McGraw-Hill Book Company, 1968.  1098p.

Morrison, R.T. and Boyd, R.N.  Organic Chemistry.
 Boston, Allyn and Bacon, Inc., 1973.  1258p.

Atkins, P.  The Pesticide Manufacturing Industry-
 Current Waste Treatment and Disposal Practices.
 Office of Research and Monitoring, Project 12020FYE.
 Washington, U.S. GPO, 1972.  185p.

NIOSH Registry of Toxic Effects of Chemical Substances,
 VOL I and II.  U.S. Department of Health, Education,
 and Welfare.  1977.

Parsons, T., Editor.  Industrial Process
 Profiles for Environmental use:  Chapter 8.
 Pesticide Industry.  EPA - 600/2- 77 -023h,
 Technology Series, Environmental Protection Agency,
 Washington, 1977.  232p.

-------
                       Carbofuran


     Very little information is available on this manufactur-

ing process.  Carbofuran is produced by the reaction of

2/3-dihydro-2,2-dimethyl-7-benzofuranol and methyl isocyanate

in the presence of ether and trimethylamine.  The carbofuran is
        *-.

recovered from the products, and the waste stream goes
      i
through  neutralization, concentration equalization/ and

settling before discharge1.  Normally, wastes from aryl and
                       2
and some heavy residues .
alkyl carbanate production include liquid streams, vents,

          e

Carbofuran

Oral rat       LD50: 5300 fg/kg
1. Rei i, p. 65
2. Ref 2, p. 50-51
3. Ref 3

-------
                                                      -7-


                    References
1.   Parsons, T., Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77 - 023h,
    Technology Series/ Environmental Protection Agency,
    Washington, 1977.  232p.

2.   Effluent Guidelines Division, Office of Water and
    Hazardous Materials.  Development Document for Interim
    Final Effluent Guidelines for the Pesticide Chemicals
    Manufacturing Point Source Category.  EPA 440/1-75/
    06Od Group II.  Washington, 1976

3.   NIOSH Registry of Toxic Effects of Chemical Substances,
    VOL I and II.  U.S. Department of Health, Education,
    and Welfare.  1977

-------
                        Chlordane


      Chlordane is manufactured, according to  the  following

production scheme:


     Ka^tha 	•	-> Cyclopentadiene
     C12 + NaOH (aq.)	••	*. NaCIO .(aq.)
     NaCIO (aq.) + C5H6	^ C5C16 + NaCI Calk-
     C^Cl^ + C5H6	'	—& Chlordene CCioH6C16
     Cnlordene -f- C12	—> Tech. chlordane  CC1OH6C18 *
                              '  • related epds.)
      Cyclopentadiene is produced from the cracking  of naphtha.

Tars  are a by-product of this process and need  to be disposed

of.

      The second phase of the process is the free radical

chlorination of Cyclopentadiene with NaCIO to produce

hexachlorocyclopentadiene.   Trichlorcyclopentene isouters,

octachlorocyclopentene, and pentachlorocyclopentadiene
                         2
are possible by-products .   The wastewater has  about 2%
                       3,4.
NaOH  and 400 ppm C5ci6      The above mentioned by-products

should  also be present as should Nad, NaCIO, and NaClOgr

formed  from the disproportionation of CIO .

      The C_ci- solution is  next filtered to remove  the tars
           ->  6
formed  in the reaction.
1. Ref  1,  p.  88-93
2. Ref  2f  p.  7
3. Ref  1,  p.  88-93
4. Ref  2,  p.  39-40

-------
     CgClg and C,.H  are condensed to form chlordene.
Other types of condensation products are possible such as the
condensation of C H  with some of the by-products of  the
                 o 6
C5cig production step.
     Chlorination of chlordene to produce chlordane yields a
variety of chlorinated epimers, one of which is the pesti-
cide Heptachlor that results from the substitution chlorina-
tion rather than the addition chlorination .   Technical
                                              6
grade chlordane contains about 7-8% Heptachlor .   Chlordane,
Heptachlor, and related compounds may be present in the
wastewater from periodic equipment cleaning and production
area cleanup.
STRef 3, p. 39
6. Ref 1, p. 88-93

-------
                     Toxicity Data
Chlordane
Oral rat     LD50: 283 rag/kg
Heptachlor
Oral rat LD50: 40 rag/kg
Cyclopentadiene, Hexachloro
Oral rat LD50: 113 mg/kg
Sodium Chlorate
Oral rat     LD50: 1200 mg/kg
7. Ref  4

-------
                       References
1.  Lawless, E.W., Pesticide Study Series -5-
    The Pollution Potential in Pesticide Manufacturing.
    Technical Studies Report:  TS -00- 72 - 04.
    Washington, U.S. GPO, 1972.  25Op.

2.  Parsons, T., Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77 - 023H,
    Technology Series, Environmental Protection Agency,
    Washington, 1977.  232p.

3.  Atkins,  P., The Pesticide Manufacturing Industry-
    Current Waste Treatment and Disposal Practices.
    Office of Research and Monitoring, Project 12020FYE.
    Washington, U.S. GPO, 1972.  185p.

4.  NIOSH Registry of Toxic Effects of Chemical Substances,
    VOL I and II.  U.S. Department of Health, Education,
    and Welfare.  1977.

-------
                                                       *"/"  —
                        Chloroxuron
     Chloroxuron is manufactured according to the following
reaction  scheme :
   cocta
                   ixj«y) onilin
                  Heal
-N - C - O
       
-------
                       References
1.  Parsons, T., Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77 - 023h.
    Technology Series, Environmental Protection Agency.
2.  NIOSH Registry of Toxic Effects of Chemical Substances,
    VOL I and II.  U.S. Department of Health, Education,'
    and Welfare.  1977

-------
                                                         .-, <•_
                                                         >  -1
                                                         *->
                        Creosote
Creosote, a distillate of coal tar  is used primarily  for
wood preservation.  Creosote is presently under  RPAR  review
 (FR 10/18/78) due to oncogenic and  mutagenic  effects.   The
RPAR working group determined that  the oncogenic criteria
                               '0M'XiMDWY<1ws''.
had been exceeded by considering    occupationally exposed
                                \
workers who developed tumors, reports of animal  experiments
in which mice, rats, or rabbits developed tumors from either
dermal or inhalation studies, and the Carcinogenic Assessment
Group  (CAG) conclusions that creosote and coal tars are
                                                       o
oncogenic.  Creosote and coal tar contain a number of plycyclic
                                                        IN
and heterocyclic aromatic hydrocarbons which  have been well
established as carcinogens.  Some of these are:
     benz[a]anthracene, benzo[b]fluoranthene, benzo[j]fluor-
     anthene, benzo[a]pyrene, etc.
Studies indicate that creosote and  coal tar migrate to some
extent from treated wood into the surrounding environment.
For additional information, see Federal Register,  "Wood
Preservative Pesticides," October 18, 1978

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                                  2,4 - D

            2,4  -  D is  produced according to the following reaction
      scheme^:
                                 0-CH2-COONa       OCH2COOH   "    '  *
            C1CH2COOH
                       NaOH
Dichloro-    Chloroacetic
phenol       acid
    Cl
2,4-D Sodium
salt •
                                                                Salt:
      The waste  stream from 2,4-D contains "large amounts  of sodium
      chloride,  hydrochloric acid, some caustic, and organics including
      phenols, chlorophenols and chlorophenoxy acids.  These
      arise  from acidification, washing steps, phase seperation
      steps,  incomplete yields and chlorination of the phenolic
      compounds
                ,,2
      17 Ref  1,  p.  128-135
      2. Ref  2,  p.  24-25

-------
      According  to  Parsons,  a  typical waste  stream may  be
 characterized by:
                Total  solids - 104,000 mg/1
                Suspended  Solids  -  2,500 mg/1
                Chlorides  -  52,000  mg/1
                Chlorophenols  - 112 mg/1
                Chlorophenoxy  Acids - 235 mg/1
 The waste streams  vary  considerably from plant  to plant.   A
 primary drinking water  standard  exists for  2,4  -  D.
Chemicals Possibly Present
     in Waste Stream
2,4 - D
2,4 - Dichlorophenol
2,6 - Dichlorophenol
Chloroacetic acid
2,6 - Dichlorophenoxyacetic acid
o - Chlorophenol
m - Chlorophenol
p - Chlorophenol
                                              Oral  Rat
                                              LD50  mg/kg
                                              375
                                              580 suspected  carcinogen
                                              2940
                                              76
                                              **
                                              670
                                              570
                                              **
   data  not available
3 Ref  3

-------
                         References
1.  Lawless, E.W. Pesticide Study Series -5-
    The Pollution Potential in Pesticide Manufacturing
    Technical Studies Report:  TS -00- 72 - 04.
    Washington, U.S. GPO ,  1972. 250p.

2.  Parsons, T.,  Editor.  Industrial Process
    Profiles for environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77 - 023h,
    Technology Series, Environmental Protection Agency,
    Washington, 1977. 232p.

3.  NIOSH Registry of Toxic Effects of Chemical Substances.
    VOL I and II.  U.S. Department of Health, Education,
    and Welfare.   1977.

4.  Atkings, P. The Pesticide Manufacturing Industry-
    Current Waste Treatment and Disposal Practices.
    Office of Research and Monitoring, Project 12020PYE.
    Washington, U.S.  GPO,  1972.  185p.
                         OSS

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                      Diazinon

     Diazinon is produced by the reaction of diethylphosphoro-
chloridothionate and 2-isopropyl-4-methyl-6-hydroxypyrimidine
with sodium carbonate in a solvent such as toluene, benzene,
          1
or dioxane .  The manufacturing process is probably very
similar to that for malathion and methyl parathion and the
                                                       2
waste stream should contain the same types of compounds
Some of the organophosphates that may be present in the
waste stream are:  triethyldithiophosphate, triethylthio-
phosphate, triethyl trithiophosphate, diethyl thiophosphoric
                   oric
acid, diethylphosph    acid, 2-isopropyl-4-methyl-6-hydro-
xypyrimidine (IMHP) and its ester, diazinon, and other organo
phosphate derivatives of IMHP and ethanol.

piazinon
Oral rat  LD50 : 76 mg/kg
       1, p.  bt>
2. See Methyl Parathion and Malathion Background Document
3. Ref 2, p. 291-299
4. Ref 3
                             OS"?

-------
                   References
1.  Parsons/ T./  Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 11 - 023h,
    Technology Series, Environmental Protection Agency,
    Washington, 1977.  232p.

2.  Warner, J. S., etal.  Identification of Toxic Impurities
    in Technical Grades of Pesticides Designated as Substitute
    Chemicals.
    Office of Research and Development.
    EPA-600/-1-78-031, May, 1978.  387p.

3.  NIOSH Registry of Toxic Effects of Chemical Substances.
    VOL I and II.  U.S. Department of Health, Education,
    and Welfare.   1977

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                     Dichlorobenzene
     Dichlorobenzene is produced by the chlorination of

benzene over iron turnings in a lead or glass-lined reactor .
                                                        2
The wastewater sludge contains mostly polychlorobenzenes •

Iron and lead may also be present in the sludge.  Dichloroben-

zene is presently undergoing a pre-RPAR review due to possible
                   3
oncogenic activity.
Possible Chemicals in
Wastewater Sludge

Benzene


Ortho-dichlorobenzene

Para-dichlorobenzene

Chlorobenzene

Trichloro~benzene
         w
Tetrachloro"lbenzene

Lead
  Oral Rat*
LD50 mg/kg •

3800 - suspected human
         carcinogen

 500 - suspected carcinogen

 500       "          "

2910

 756

1500
1. Rexi, p. iy
2. Ibid
3. Special Pesticide Reviews Division Status Report.  Nov 2, 1978
4. Ref 2

-------
                       References
1.  Parsons, T.,  Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77 - 023h,
    Technology Series/ Environmental Protection Agency,
    Washington, 1977.  232p.

2.  NIOSH Registry of Toxic Effects of Chemical Substances,
    VOL I and II.  U.S. Department of Health,  Education,
    and Welfare.   1977.

-------
                         Disulfoton



     Due to the lack of quantitive information on the composition


of the waste streams, the following document described ai^cci-


pated by-products of the Disulfoton Process-


Disulfoton is produced according to the following production


scheme:



     P2S5+4C2H5OH  +2NaOH Toluene^  2(C2H50)2P(S)Na+H2S        (1)


                                                  +2H20


                                    "Diethyl Salt"   (DES)



PCt3+3HOC2H4-S- C2H5	 3 C« C2H4-S-C2H5 +HP(0)(OH)2       (2)


     thio alcohol           "Choloro Thio Alcohol"  (CTA)
         P         JL
(C2H50)2) (S)SNa + C*C2H4-S-C2H5	(C2  «• 50)2 S-C2H4-S-C2H5
         *                                     A
                                    Disulfoton + NaCl        (3)


            t
     The  reation between P2S5 and ethanel in toluene  occurs under


anhydrous conditions to produce-the dialKyl phospho^dithioic


acid.  The major side product of this reaction is the triester.

                          a r
The dithio acid is next coye^ted to the dithio salt with caustic


soda •
1. ref.  I-  pg  99  -  103         2. ref.  2. pg 46 - 49

-------
     Triester, organic residues, and unreacted ethanol are
contained in the organic phase which goes to burial.
     PCl3 and the thio alcohol are combined to form the
chloroethyl thioethyl  e ther and phosphorous acid,  a white
crystalline solid of melting point 73.6°C.   By-products of the
                                   3 *f ?
reaction are   fe.o)aT»MO  
-------
     The third step of the  production process involves the

reaction between the dieth^ salt  (DES) and the chloroCthio

alcohol (CTA)  to form disulfoton and sodium chloride.   A

possible side reaction can  be represented by the following

general equations:
        .i_i-
         i  s*?on-
This reaction can lead  to  the following types of products
6. ref. 6 pg.  329,  764.

-------
     The process wastewater next goes is a toluene extractor
                                             7,6
and skimmer with a final NaOH/NaOCL treatment.   THe wastewater

                                                            q
has a high salt content high pH, and contains toxic organics,


  and phosphates.  Intermediate products, residues, and ta£s


are recovered from the still bottom and reactors and are buried,
               7 ref. 7. pg. 51

               8 ref. 1 pg. 99-103


               9 ref. 2. pg. 84-85

-------
                        Toxicity Datafi
Disulfoton

     oral human LD Lo:5 mg/kg

     oral rate: LDLo: 2 mg/kg

     unreported rat: LD5O: 2500^ft(g/kg


Phosphorothioic acid, 070,0, - triethyl ester
    inhalation rat   LCLo: 41~~ppm/4 hours

Sulfide, Chloroethyl ethyl
    oral rat  LD 50: 252 rag/kg

Ethanol, 2-(ethylthto)-
    oral rat  LD50: 2320 mg/kg

Phosphorous acid, diethyl ester
    oral ratLD50: 5190 mg/kg

-------
                    References
 1.   Lawless, E.W.  Pesticide  Study Series -5-
      The Pollution Potential  in Pesticide Manufacturing.
      Technical  Studies Report:  TS -00- 72-04.
      Washington, U.S. GPO  ,  1972,  250p.

 2.   Office Water and Hazardous Materials, Effluent Guidelines
      Division.  Development  Document for Interim Final Effluent
      Limifctions Guidelines for the Pesticide Chemicals
      Manufacturing Point Source Category.  Washington,
      1976.  331pg.

 3.   Cotton, F.A. and Wilkinson, G. Advanced Inorganic Chemistry.
      New York,  Interscience  Publishers, 1972.  1145p.

 4.   Bailer, J.C. Comprehensive INorganic Chemistry, Vol 2.
     New York, Pergamon Press, 1973.

 5.  Fezt, C. and Schmidt, K.  -J.  The Chemistry of
     Organophosphorous Pesticides.  New York,
     Springer-Verlay, 1973.   339p.


 5.   March, J. Advanced Organic Chemistry:
      Reactions, Mechanisms,  and Structure.
      New york, McGraw-Hill Book Company, 1968.  1098p.


 7.   Parsons, T., Editor. Industrial Process
      Profiles for  Environmental use:  Chapter 8.
      Pesticide Industry.  EPA - 600/2 77 - 123h,
      Technology Series, Enviromental Protection Agency,


g.   NIOSH Registry of Toxic Effects of Chemical Substances
      VOL I and II.  U.  S. Department of Health, Education  "
      and Welfare.   1977                            <-*tion,

-------
                      Dithiocarbamates

     Very little information is available on the manufacturing
process and waste streams of the dithiocarbamate pesticides.
These pesticides are normally produced by the reaction of
carbon disulfide, an amine, and either a hydroxide or ammonia1.
The major pesticides of this class plus other possible components
in the waste stream are listed below along with available
information.
1. Ref 1, p. 60,62

-------
Pesticide

CDCE
     Chemical2
        Name
   2-chlorMltyl dl«tbyi thlocarb-
    •Mian
                                                Chemical2
                                                Structure
                           Oral  Rat3
                             LD50
                              850
                                             Comments
                                         sol  in water2
                                         lOOppm
Nabam
   dlsodlum ethylenebiuiithlo-
    carbamate
       «
CW2-NH-C-S-;
CH2-NH-C-S-]
Na
Na
                                                                           395
                                                      sold as  aqueous4
                                                      solution (22%)
Ferbam
Maneb
Zineb
  ferric dimethyldlthiocarbamaif
  tiLs(dlmethyl'
   Iron.       .
 manganoia ethylcne-1.2-bi»-
   dithlocarbamate;
 [ethylenebls(dithlocarbaniato)j
   manganese
fcthylcnebls (ditbiocarbamatoi)
I  zinc;
zinc cthylene-1.2-bi$dithlo-
  carbamate
                                                   -CS-N(CH3)2
                                                 S-CS-N(CH3)2
                                       Approx. formula: (is a polymer)
                                         CH2-NH-CS-S,
Approx. formula: (is a polymer)

   En2-NH-CS-S'Zn
                  ethylene  diamine

                  ethylene  thiourea

                  2,3-dicholoro-propene
 2.  Ref  2,
 3.  Ref  3
 4.  Breakdown product of Maneb -  see Ref 2
                                                                         4000
                                                                         6750
                             5200


                              760

                              200

                              320
                                                  sol  in water2
                                                  ISOppm
                                                  carcinogen detn:J
                                                  indefinite
                                                  carcinogen det:3
                                                  animal suspected
                                         carcinogen de t:
                                         animal  suspected
                                                                                                                   r*-
                                                                                                                   rt
                                                                                  carcinogen detn:3
                                                                                  animal positive

-------
                         References
1.  Parsons, T., Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2-77 - 023h,
    Technology Series,  Environmental Protection Agency,
    Washington, 1977. 232p.

2.  Nonogon Index.  A Dictionary of Pesticides,  1975*

3.  NIOSH Registry of Toxic Effects of Chemical Substances,
    Vol I and II.  U.S. Department of Health,  Education,
    and Welfare.  1977.

-------
                            Diuron




      Diuren is  produced according to  the  following  reaction


 scheme1:
                                                           \
 3,4-dichlorophenyl  iscyanede  is  reacted  with  dimethyl amine


 in a  solvent  such as  dioxane  to  produce  Diuron.  The urea is


 insoluble  and precipitates.   The solvent can  then  be
t

 flash-distilled  and recycled.  The  crude product is washed


 with  aqueous  HCL to remove insolubles  and finally  water washed

               2
 a precipitator.
 1. Ref  1 p.  11,  82
 2. Ref  2 p.  52,  55,  56

-------
The wastewater treatment sludge may contain Diuron, starting

materials, solvent, still bottom and reactor tars and residues,

and other reaction by-products.
     Possible Pollutants           Oral
     Present in Wastestream        LD50 mg/ffg*

     Diuron                        437

     3,4 - dichloroaniline         648

     N-3,4 - dichlorophenyl-
             carbamic acid         **

N/N- dimethyl carbamic acid        **

     Solvent                       **

     Tars                          **
* unless otherwise noted
** data unavailable
3. ref 3

-------
                         References
1.  Parsons, T., Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77 - 023h,
    Technology Series, Environmental Protection Agency,
    Washington,  1977.  232p.

2.  Effluent Guidelines Division, Office of Water an
    Hazardous Materials.  Development Document for
    Final Effluent Guidelines for the Pesticide Chemicals
    Manufacturing Point Source Category.  EPA 440/l-75/060d
    Group II.  Washington, 1976.

3.  NIOSH Registry of Toxic Effects of Chemical Substances.
    VOL I and II.  U.S. Department of Health, Education,
    and Welfare.  1977.

-------
                        Malathion

     Due  to  the lack of quantitative information on  the
contents  of  the waste streams, this document  indicates the
probable  nature of the wastes generated in the manufacturing
process.   The first step in the production of Malathion is
the  formation of dimethyl dithiophosphoric acid  from ?2S5
and  methanol in toluene:
                         4MeOH	MeOP  + H2S
                                                      2 3.
The major  by-product of the reaction  is  the  triester '
                2PSH + H(|-COOEt 	> (HeO)2PSCHCOOEt
                   HC-COOEt
         Dimethyl-   Diethylmaleate
         phosphoro-  or futnarate
         dithioic   (DEM or DEF)
         acid (DMTA)
IT	Ref 1,  p.  104-108
2.   Ref 2,  p.  (5-98)-(5-101)
3.   Ref 3,  p.  46-48
4.   Ref 2,  p.  (5-98)-(5-101)
5.   Ref 1,  p.  104-103

-------
     After volatile components are stripped off, the stream
is then washed with a basic solution.  During the wash pro-
cedure, the following reaction can occur:
       j
            I -CH-COOCjHj
     The dithiophosphate anion can undergo reactions with
triestars and dithio phosphates to yield compounds of the
               7
following form:
     The waste stream should contain diethyl maleate,
malathion, dimethyl dithiophosphoric acid, dimethyl thiophoa-
phoric acid, dimethyl phosphoric, trimethyl dithiophosphate
other organophosphate derivatives and toluene.  Malathion is
                                                   p
hydrolyzed and catalytically oxidized by iron salts .
6. Ref 4, p. 28
7. Ref 4, p. 36
8. Ref 5, p. 41

-------
                                 Q
                    Toxicity Data


Malathion


     Oral human        - LDLo:   50 mg/kg


     Oral human        - LDLo:  857 mg/kg


     Oral rat          - LDLo: 1401 mg/kg


     Aquatic toxicity testing  - TLm96:  10-under 1 ppm


Maleic Acid, Diethyl Ester


     Oral rat              - LD50:3200 mg/kg


Maleic Acid/ Sodium Salt


     Intraperitoneal rat   - LD50:600 mg/kg


Phosphorodithioic Acid, 0,0-Dimethyl Ester


     Oral rat  - LDLo: 1000 mg/kg


Toluene


     Oral human       -  LDLo: 50 mg/kg


     Oral rat         -  LD50:  4000 mg/kg


     Aquatic toxicity rating - TLm96: 166-10 ppm


     DOT flammable liquid


Phosphoric Acid


     Oral rat   - LD5 0:1530 mg/kg


     Aquatic toxicity - TLm 96:1000-10 ppm


     DOT - corrosive


Phosphoric Acid, Trimethyl Ester


     Oral rat  - LD50: 840 mg/kg


Phosphor othioic Acid,0, 0,0 -Trimethyl Ester


     Inhalation rat - LCLo:  220ppm/4 hours
 . Ret  b

-------
                     References
1.  Lawless/  E.W.   Pesticide Study Series -5-
     The Pollution Potential in Pesticide Manufacturing.
     Technical Studies Report:   TS -00- 72 - 04.
     Washington,  U.S. GPO,  1972.  250p.

2.  Office of Solid Waste Management Programs.
     Assessment of Industrial Hazardous Waste Practices:
     Organic  Chemicals, Pesticides and Explosives.
     Environmental Protection Publication SW-118C.
     Washington,  D.C./ U.S. GPO, 1976

3.  Effluent  Guidelines Division,  Office of Water and
     Hazardous Materials.  Development Document for Interim
     Final Effluent Guidelines for the Pesticide Chemicals
     Manufacturing Point Source Category.  EPA 440/1-75/
     060d Group II.  Washington, 1976

4.  Fest, C.  and Schmidt, K.-J.  The Chemi^stry of Organo-
     phosphorus Pesticides.  New York, Springer-Verlag, 1973,
     339p.

5.  Atkins, P.  The Pesticide Manufacturing Industry-Current
     Waste Treatment and Disposal Practices.  Office of
     Research and Monitoring, Project 12020FYE.

6.  NIOSH Registry of Toxic Effects of Chemical Substances.
     VOL I and II.  U.S. Department of Health,  Education,
     and Welfare.   1977

-------
                                  Methomy1
           Methomyl may  be manufactured by  the following chemical

      reaction  scheme  :
   CH3CHO

acetaldehyde
                                NH2OH

                            hydroxylaaine
                           acetaldehyda
 CH3CH-NOH

acetaldehyde
   oxime
                   C12

                 chlorine
                                BMF
dinethyl-
formaaide
    CH3C(C1)-NOH     +    HC1

N-hydroxyethaninldoyl    Bydrogen.
      chloride           chloride
  CH3C(C1)-NOH

K-hydroxyethan-
'         chloride
                         CH3SH

                        nethyl
                       jaercaptan
                                          NaOH
           sodium
          hydroxide
              methyl H—hydroscy—
cthaninidothioat
                       CH3NCO

                       nethyl
                      isocyanate
      (C2H5)3N

      triethyl
        anine
                                                   CH3C(SCH3)-NOCOSHCH3
       nethyl N-
         carbonyl]oxy] etLhau—
             imidothioate
             (nethonyl)
   l7~Ref 1 P-  348-352

-------
     The following list contains chemicals that may be formed

     during the production and storage of diazinon and may
                                              2
     therefore be present in the waste streams :

                                             ui.o.j. &.a.\.
          Chemicals
          Methomyl
                                             Oral Raf
                                             LD50 mg/Kg
                                                   17
CH
      -  N
         \
         C
            O
            \\
            N
           CH-
N  -
(
C
CH3
     CH3C(C1)=NOCONHCH3

     CH3NHCOSCH3

     CH3CH=NOCONHCH3

     CH3NHCONHCH3

     CH3CONHOH

     CH3C(SCH3)=NOH
                                                   **

                                                   **

                                                   **
                                                   (teratogen)

                                                   (teratogen)
                                                   **
** data unavailable
2. Ref 1 p. 348-352
3. Ref 2

-------
                         References
1.  Warner et al.
    Identification of Toxic Impurities in Technical
    Grades of Pesticides Designated as Substitute
    Chemicals.  EPA - 600/1-78-031.  May 1978.  387p.

2.  NIOSH Registry of Toxic Effects of Chemical Substances,
    VOL I and II.  U.S. Department of Health, Education,
    and Welfare.  1977.

-------
               Methyl Parathion and Parathion

     The synthesis of Parathion is essentially the same as
for Methyl Parathion except that methanol is used as a
starting material instead of ethanol.  The two will be
treated together.  Methyl Parathion is produced according
to the following production scheme':
                                      S
                              U)
              S
              II
      S
                             (C2H50)2PC1 -!• HC1 + S
                              (2)
   S
        NaO
       S
       II
(C2H50)2P-0
Nad   <3)
     Residues and tank bottoms contain large amounts of
                               2
intermediates and some products .  The waste streams may
       3 4
contain '  sulfur, NaCl, sodium carbonate, trialkyl thio-
phosphate, dialkydithiophosphoric acid, dialkyl-chlorothio-
phosphate, paranitrophenol, o-alkyl o,o-bis(4-nitrophenyl)
thiophosphate, and other organophosphate derivatives.
1. Ref 1, p.  (5-96)-(5-9S)
2. Ref 2, p. 34-35
3. Ref 3, p. 53-55
4. Ref 1, p.  (5-96)-(5-99)

-------
                                 5,6
                    Toxicity Data
                                        Oral Rat
     Chemical    ,                      LD50 mg/kg*
     ————    D                       	 -	 •  *
                A
Methyl parathion                            9

         B
Parathion                                   2
                 AB
para-nitro phenol                         350


triethyl thiophosphate                 inhalation LCLO: 41 ppm/4H
                       j^
trimethyl thiophosphate                inhalation LCLo: 220 ppm/4H
                            B
diethyldithiophosphoric acid              4510
                             A
dimethyldithiophosphoric acid          LDLo: 1000

                            B
diethyl-chloro-thiophosphate           LDLo: 1000

                             A
dimethyl-chloro-thiophosphate          LDLo: 1000

                                           B
o-ethyl-o,o-bis(4-nitrophenyl)thiophosphate    67

                                            A
o-methyl-ofo-bis(4-nitrophenyl)thiophosphate  312

       AB
Sulphur                                        **
funless otherwise indicated
** Data not available
5. Ref 4
6.  Chemical followed by A formed in Methyl Parathion Process
    Chemical followed by B formed in Parathion Process

-------
                       References
1.  Office of Solid Waste Management Programs.
    Assessment of Industrial Hazardous Waste Practices:
    Organic Chemicals/ Pesticides and Explosives.
    Environmental Protection Publication SW-118C.
    Washington, D.C., U.S. GPO, 1976.

2.  Atkins, P.  The Pesticide Manufacturing Industry-
    Current Waste Treatment and Disposal Practices.
    Office of Research and Monitoring, Project 12020FYE.
    Washington, U.S. GPO, 1972.  185p.

3.  Parsons, T., Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77 - 023h,
    Technology Series, Environmental Protection Agency,
    Washington, 1977.  232p.

4.  NIOSH Registry of Toxic Effects of Chemical Substances,
    VOL I and II.  U.S. Department of Health, Education,
    and Welfare.  1977.

5.  Lawless, E.W.  Pesticide Study Series -5-
    The Pollution Potential in Pesticide Manufacturing.
    Technical Studies Report:  TS -00- 72 - 04.
    Washington, U.S. GPO, 1972.  250p.

-------
                   Pentachlorophenol
     Pentachlorophenol is produced by the simple chlorination
of phenol over anhydrous aluminum chloride.
     -The wastewater from this process contains lower chlorinated
phenols  and possibly pentachlorophenol.  Pentachlorophenol and
its
derivatives are under RPAR review due to "fetotoxicity
and teratogenicy."

Chemical
Pentachlorophenol
Trichlorophenol
Tetrachlorophenol
2,4-dichlorophenol
2,6-dichlorophenol
O-chlorophenol
Oft-chlorophenol
p-chlorophenol
                                Oral Rat
                               LD50 mg/kg
                                   50
                                  820
                                  140
                                  580
                                 2940
                                  670
                                  570
                                  **
** Data not available
3. Ref 2


-------
                       References
1.  Parsons, T.,  Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77 - 023h,
    Technology Series, Environmental Protection Agency,
    Washington, 1977.  232p.

2.  NIOSH Registry of Toxic Effects of Chemical Substances.
    VOL I and II.  U.S. Department of Health,  Education,
    and Welfare.   1977.

-------
                            Phorate

      Phorate is produced according to the following production

 scheme :                                   S
                 P2S5 + AEtOH	:	>2(EtO)2PSH + H2S
                     S                       S
               (EtO)2PSH + H2C=0	>(EtO)2PS-CH2OH
                 S                          S
             (EtO)2P-SCH2SEt

One  of the major byproducts of this reaction is the
          234
triester.  ' '    The o-o-o-triethyl-thiophosphate can isomerize

to produce o-o-s-triethylphosphate.  The filter cake may

contain diethyldithiophosphoric  acid, triethylthiophosphate/

unreacted P2S5,  and other insoluble reaction products.

      The dithiophosphate is condensed with formaldehyde and

ethyl mercaptan  to produce Phorate.  This is washed, steam

stripped,  and filtered.   The solid and liquid wastes may

contain Phorate, ethyl mercaptan, formaldehyde, diethyldithio-•

phosphoric acid, and triethylthiophosphate.  Additionally,

by-products may  be formed by the following reactions:
i.  Ret i p. 109-113
2.  Ref 1 P. 99-108
3.  Malathion Background Document
4]  Disulfoton Background Document
5!  Ref 2 p. 36

-------
          tl
                                              CO

                                              CO
     These above mentioned chemicals may also be present

in the wastewater from equipment cleanup.
                       Toxicity Data?
     Chemical
Phorate

Phosphorodithioic Acid,
0,0,-Diethyl Ester

Phosphorothioic Acid,
o,o,o-Triethyl Ester

Formaldehyde

Ethanethiol

Phosphorodithioic Acid,
s,s'-methylene o,o,o',o'-
Tetraethyl Ester

CH3CH2S CH2(OH)

(CH3CH2S)2 CH2
LD50 mg/kg*
Oral Rat

     1.1
     4510
     inhalation 41ppm/4H

     800

     1960



     13

     **

     **

     389
6. Ref 3 p. 665
* unless where otherwise noted
** not available
7. Ref 4

-------
                     References
Lawless, E.W. Pesticide Study Series -5-
The Pollution Potential in Pesticide Manufacturing •
Technical Studies Report:  TS -00- 72 - 04.
Washington, U.S. GPO , 1972.  250p.

Pest, C. and Schmidt, K.-J.
The Chemistry of Organophosphorus Pesticides.
New York, Springer-Verlay, 1973.  339p.

March, J.  Advanced Organic Chemistry:
Reactions,  Mechanisms, and Structure.
New York, McGraw-Hill Book Company, 1968.  1098p.

NIOSH Registry of Toxic Effects of Chemical Substances,
VOL I and II.  U.S. Department of Health, Education,
and Welfare.  1977.

-------
                             2,4,5  -  T

       2,4,5 - T is manufactured according to the following

  reaction scheme :

     OH
                             0-CH2COONa
   OCH2COOH
TrichLoro-    Chloroacetic   2,4,5-T, sodium
  phenol      acid        salt
   ci

2,4,5-T
  The waste stream from  2,4,5  -  T contains "large amounts of

  sodium chloride, hydrochloric  acid,  some caustic, and

  organics including  solvents, phenols,  chlorophenols, and

  chlorophenoxy acids.   These  wastes arise from acidification

  washing steps, phase separation steps, incomplete yields

  and chlorination of the  phenolic compounds"2.  2,4,5-tri-

  chlorophenol may be contaminated with 2,3,7,8-tetrachloro-

  dibenzo-p-dioxin.
  1. Re£ 1 p.  136-142
  2t Ref 2 p.  35-37
  3. Ref 3 p.  37-39

-------
Atkins reports that a typical waste stream may be

characterized by:

          Total solids

          Suspended solids

          Chlorides

          Chlorophenols

          Chlorophenoxy acids
104,000 mg/1

  2,500

 52,000

    112

    235
The waste streams vary considerably from plant to plant.
     Chemicals Possibly
     Present in Waste Stream

     2,4,5 - T

     chloroacetic acid

     o-chlorophenol

     m-chlorophenol

     p-chlorophenol

     2,4-Dichlorophenol

     2,6-Dichlorophenol

     2,3,6-Trichlorophenol

     2,4,5-Trichlorophenol

     2,4,6-Trichlorophenol

     3,4,5-Trichlorophenol

     Tetrachlorophenol
     Oral Rat*
     LD50 mg/kg

     300 +

      76

     670

     570

     **

     580-suspected carcinogen

    2940

     **

     820

     820

     **

     140
+ - teratogenic due to 2,3,7-8 TCDD contaminant
** data not available
4 Ref 4

-------
                         References
1.   Lawless, E.W. Pesticide Study Series -5-
    The Pollution Potential in Pesticide Manufacturing.
    Technical Studies Report:  TS -00- 72 - 04.
    Washington, U.S. GPO ,  1972.  250p.

2.   Atkins, P.  The Pesticide Manufacturing Industry-
    Current Waste Treatment and Disposal Practices.
    Office of Research and Monitoring, Project 12012FYE.
    Washington, U.S. GPO, 1972.  185p.

3.   Effluent Guidelines Division, Office of Water and
    Hazardous Materials.  Development Document for Interim
    Final Effluent Guidelines for the Pesticide Chemicals
    Manufacturing Point Source Category.  EPA 440/1-75/
    060d Group II.  Washington, 1976.

4.   NIOSH Registry of Toxic Effects of Chemical Substances,
    VOL I and II.  U.S. Department of Health, Education,
    and Welfare.  1977.

-------
                         Toxaphene
     Toxaphene  is  produced by the following process
                                       ,, C10H10C18 + 6 HC1
                                        Toxaphene (mixed isoaers
                                          and relate
                                          67-697. Cl)
      Camphene is chlorinated with chlorine over a catalyst
or by UV radiation and is then filtered and washed with
solvent.   The filter cake probably contains tars produced
in the chlorination and possibly suspended a-pinene, camphene,
toxaphene,  solvent,  and catalyst.  Wastewater used in equip-
ment  cleanup may also contain the above mentioned chemicals.
                         Toxicity Data
Toxaphene
      Oral rat       LD50:  60 mg/kg
1. Rei:  1,  p.  94-98
2. Kef  2

-------
                       References
1.  Lawless, E.W., Pesticide Study Series -5-
    The Pollution Potential in Pesticide Manufacturing.
    Technical Studies Report:  TS -00- 72 - 04.
    Washington, U.S. GPO, 1972.  250p.

2.  NIOSH Registry of Toxic Effects of Chemical Substances,
    VOL I and II.  U.S. Department of Health, Education,
    and Welfare.  1977.

3.  Parsons, T., Editor.  Industrial Process
    Profiles for Environmental Use:  ckpter 8.
    Pesticide Industry.  EPA - 600/2- *77 - 023h,
    Technology Series, Environmental Protection Agency,
    Washington, 1977.  232p.

-------
                          Trifluralin
     Trifluralin is  produced according to the following
scheme  :
            CF3-C6H4-C1    3H2S04>    CF3-Q>-C1



                                             N02
                                _N(C3H7)2 +  NaCl
     According  to  the report by Lowenbach, Schlesinger,

         2
and King  the following chemicals may be present in the


waste  streams:
1. Ref  1,  p.  148-152

2. Ref  2

-------
          Chemical
p-Chlorobenzotrifluoride
o-,m-Chlorobenzotrifluorides
Dichlorobenzotrifluorides
p-Chlorobenzoic acid
p-Chloronitrobenzoic acids
p-Chlorodinitrobenzoic acids
2,6-dinitro-4-a'a'a-trifluororaethyl phenol
Dipropylamine
Hydrogen fluoride (and other fluorides)
Naptha  (aromatic)
N-Nitroso di-n-propylamine

Nitrogen oxides
Nitrates
Nitrites
Nitrous acid
Propylamine
Substituted 2,6-dinitroanilines
Substituted nitrochlorobenzotrifluorides
Substituted nitrophenols
Substituted sulfonates
Sulfates
Sulfones
Trifluralin
Xylene
3. Ref  3
                    ORAL RAT3
                  LD50 mg/kg*
                    **
                    **
                    **
                    838flg/kg  (sodium salt)
                    3150
                    **
                    **
                    930
                    180  (sodium salt)
                    **
                    480(carcinogenic &
                        neoplastic effects
                    **
                    **
                    85  (sodium salt)
                    **
                    570
                    418  (for  dinitro)
                    **
                    **
                    **
                    **
                    **
                    500
                    4300
 * except where otherwise noted
** data unavailable

-------
                         References
1.   Lawless,  E.W.  Pesticide Study Series -5-
    The Pollution Potential in Pesticide Manufacturing.
    Technical Studies Report:  TS-00-72 - 04.
    Washington, U.S.  GPO ,  1972.  250p.

2.   Lowenbach W.,  Schlesinger J., and King J.
    Toxic Pollutant Identification:  Trifluralin
    Manufacturing.  EPA, Office of Energy,
    Minerals, and Industry,  1978. 53p.

3.   NIOSH Registry of Toxic Effects of Chemical Substances,
    Vol I and II.   U.S. Department of Health, Education,
    and Welfare.  1977.

4.   Office of Solid Waste Management Programs.
    Assessment of Industrial Hazardous Waste Practices:
    Organic Chemicals, Pesticides and Explosives.
    Environmental Protection Publication SW-118C.
    Washington, D.C., U.S.   GPO,  1976.

5.   Parsons,  T., Editor.  Industrial Process
    Profiles for Enivronmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77- 023h,
    Technology Series, Environmental Protection Agency,
    Washington,  1977. 232p.

-------
                      Vernolate


     Very little information is available on the production

process for this pesticide.  Vernolate is probably produced
                                           r
from the reaction of phosgene and di-n-prop .yl amine to give
                                           v^
the intermediate, N,N-di-n-propyl carbamyl chloride.  This

can then be combined with n-propyl mer^captan, to give

vernolate •  The wastewater treatment sludge may contain:

vernolate, the intermediate carbamyl chloride, n-propyl

mercaptan, N,N-di-n-propylcarbamic acids, tars and residues
          O<"5
from react-'    and spills, and solvent .
                                             2
                                     Oral Rat
Chemical                             LD50 mg/kg

Vernolate                                320
Propanethiol                            1790
 1.  Ref  1,  p.  61
 2.  Ref  2

-------
                     References
1.  Parsons,  T.,  Editor.  Industrial Process
    Profiles for Environmental Use:  Chapter 8.
    Pesticide Industry.  EPA - 600/2- 77 - 023h,
    Technology Series, Environmental Protection Agency,
    Washington,  1977.  232P.

2.  NIOSH Registry of Toxic Effects of Chemical Substances.
    VOL I and II.  U.S. Department of Health, Education/
    and Welfare.   1977.

3.  Effluent Guidelines Division, Office of Water and
    Hazardous Materials.  Development Document for Interim
    Final Effluent Guidelines for the Pesticide Chemicals
    Manufacturing Point Source Category.  EPA 440/1-75/
    060d Group II.  Washington, 1976.

-------
2892 Waste water treatment sludges from explosives,
propellants, and initiating compounds manufacture (C,T,R,I).

     This waste is classified as hazardous because of its
corrosive, toxic, reactive, and ignitable character-
istics.  According to the information EPA has on this
waste stream its meets RCRA Section 250.13 (a), (b), (c),
& (d) characteristics identifying corrosive,  toxic,
reactive, and ignitable waste.

     EPA bases this classification on the following
information:

     TRW has tested a sample of wastewater treatment
sludges from explosives, propellants, and initiating
compounds manufacture and found the following:

                    Explosive Manufacture

              Contaminant             Concentration mg/1

              Nitroglycerin              1800
                   TNT                   70 to  350
                   pH=l

                         Propellants

              Contaminant             Concentration mg/1

              Nitrocellulose fines       1,000  to 10,000

                    Initiating Compounds

              Contaminants            Concentration mg/1

              Pb (lead azide             200
              & lead styphnate)

The data presented are available from:

     TRW. Assessment of Industrial Hazardous  Waste Practices:
Organic Chemicals, Pesticides and Explosives  Industries.
EPA publication PB-251-307.  National Technical Information
Service.  1976.  and

-------
     Development Document for Interim Final Effluent
Limitations Guidelines and Proposed New Source Perform-
ance Standards for the Explosives Manufacturing.  EPA
440/1-76/060-j.  March 1976.

     As is evident from the above the waste acid sludge
has a pH of 3 or below.  Liquid waste streams with such
acidic character present an environmental risk for
several reasons.  Very low pH liquid waste if disposed in
a sanitary landfill would leach high concentrations of
toxic heavy m«.tals (such as lead) from ordinary municipal
trash.  These heavy metals would otherwise remain bound
in the waste matrix.  Highly acidic liquid wastes also
present a handling risk because of their corrosive
properties.  Highly acidic waste streams are also danger-
ous because they have been known to initiate potentially
dangerous reactions when combined with otherwise innocuus
waste.

     OSW has in its files many damage incidents resulting
from the mismanagement of highly acidic or caustic
wastes.  These include:  several deaths and many serious
illnesses resulting from the inhalation of toxic gases
formed by the reaction of acidic wastes with wastes
containing sulfide or cyanide salts, contamination and
degradation of groundwater and wells from improper
disposal of acidic and caustic wastes, severe burns from
handling and contact with acidic and caustic wastes and
several incidents of fish kills from discharge of acidic
and caustic wastes.  (Refer to corrosivity and reactivity
bacground documents for further information).

     The National Interim Primary Drinking Water Regula-
tions (NIPDWR) set limits for chemical contamination of
Drinking Water. 'The substances listed represent hazards
Co human health.  In arriving at these specific limits,
the total environmental exposure of man to a stated
specific toxicant has been considered.  (For a complete
treatment of the data and reasoning used in choosing the
substances and specified limits please refer to the
Appendix A-C Chemical Quality, EPA-6570/9 - 76 -003).

     A primary exposure route to the public for toxic
contaminants is through drinking water.  A large percentage
of drinking water finds its source in ground water.  EPA
has evidence to indicate that industrial wastes as presently
                         3<»t

-------
managed and disposed often leaches into contaminates the
groundwater.  The Geraghty and Miller^l)report   indicated
that in 98% of 50 randomly selected onsite industrial
waste disposal sites, toxic heavy metals were found to be
present, and that these heavy metals had migrated from
the disposal sites in 80% of the instances.  Selenium,
aresenic and/or cyanides were found to be present at 74%
of the sites and confirmed to have migrated at 60% of the
sites.

     At 52% of the sites toxic inorganics (such as arsenic,
cadmium etc.) in the groundwater from one or more monitoring
wells exceed EPA drinking water limits (even after taking
into account the upstream (beyound the site) groundwater
concentrations).

     Arsenic, barium, cadmium, chromium, lead, mercury,
selenium, and silver are toxicants listed by the NIPDWR
at concentrations of 0.05, 1.00, 0.010, 0.05, 0.05,
0.002, 0.01, and 0.05 mg/1 respectively because of their
toxicity.  As explained in the RCRA toxicity background
documents these concentrations convert to 0.5, 10.0, 0.1,
0.5, 0.5, 0.02, 0.1, and 0.5 mg/1 respectively in the  EP
extract.

     This waste has been shown to contain Pb at 200 mg/1
according to EPA 440/1-76/060-j, Development Document for
Interim Final Effluent Guidelines and Proposed New Source
Performance Standards for Explosives Manufacturing; and
PB-251-307, Assessment of Hazardous Waste Practices:
Organic Chemicals, Pesticides, and Explosives Industries.

     Reactice wastes as defined by Section 250.14 of RCRA
pose a threat to human health and the environment, either
through the physical consequences of their reaction
(i.e., high pressure and/or heat generation) or through
the chemical consequences of their reaction  (i.e.,
generation of toxic  fumes),

     According to Assessment of Industrial Hazardous
Waste Practices:  Organic Chemicals, Pesticides and
Explosives Industry, EPA PB-251-307, 5-109 to 5-130, this
waste has been shown to contain nitroglycerin (1800 mg/1)
and TNT  (70  to 350 mg/1).  These contaminants are extremely
unstable to  thermal  stress.  For a more detailed discussion
of  the hazard presented by reactive waste see 3001
background document  on reactivity.

-------
     As is evident from the above information on the make
up of this waste, this waste stream has a flash point of
140*  F or below.  Ignitables with flash points less than
140*  F can become a problem while they are landfilled.
During and after the disposal of an ignitable waste,
there are many available external and internal energy
sources which can provide an Impetus for combustion,
raising temperatures of waste to their flash points.
Disposal of ignitable wastes may result in fire that will
cause damage directly from hea.: and smoke production or
may provide a vector by which other hazardous waste can
be dispersed.  Ignitable wastes tend to be highly volatile
and the evaporation of these volatiles contribute to poor
air quality.  (Refer to ignitability background document
for further detail).

-------
     Red v.ater and pink water from TNT product:* or  (O)       '*-'"7 • &*'
     *                                       '         .  ' "//-'•
          A primary exposure route to the public for toxic
contaminants is  through drinking water.  A large percentage*
of drinking water finds its source in groundwater.   EPA has
evidence to indicate that  industrial wastes as presently-
managed and disposed often, leaches into and contaminates, the
groundwater.  The Gerhity  and Miller report  indicated that
in 98% of 50 randomly selected on-site industrial waster clis— '
posal sites, toxic heavy metals were found to be pre:3«=:i>-fc> -and
that these heavy metals had migrated from the disposal sites
in 80% of the instances.  Selenium, arsenic and/or  cyanides,
were found to be present at 74% of the sites and confirmed-
to have migrated at 60% of the sites.
     At 52% of the sites toxic inorganics (such as  arsenio,
cadmium, etc.) in the groundwater from, one or more  monitoring-
walls "exceeded EPA drinking water limits (even after taking •
into account the upstream  (beyond the site) groundwa-ter
concentrations)..
     Gerhity and Miller also found that in a majority b£ the
fifty sites examined organic contamination of the- graioadiwater:
above background levels was observed.  In 28 (56%)  of! these>
sites chlorinated organics attributable to waste* disposal
were observed in the groundwater.  While specific identifi-
cation of these  organics was not always undertaken  in this.
work,  (other incidents and reports 2 through 8 do qualitatively
identify leached organic contaminants in groundwater) it
certainly serves to demonstrate that organic contamination
of groundwater frequently  results from industrial waste-

-------
disposal.   Since the  Administrator  has  determined "that the       j

presence  in drinking  water  of  chloroform and other tarihalorae
-------
2892 Catch basin materials in RDX/HMX production (C).

     This waste is classified as hazardous because of  its
corrosive characteristic.  According to the information
EPA has on this waste stream it meets RCRA Section 250.13
(b) characteristic identifying corrosive waste.

     The Administrator has determined this waste to be a
potential threat to the environment if improperly managed.

     EPA bases this classification on the following
information.

     1.   An  EPA contractor has tested a sample  of waste
sludges and has found the following:

          60% acetic acid
          2-3% nitric acid
          RDX/HMX

     The data presented are available from:

          Assessment of Industrial Hazardous Waste Practices
Organic Chemicals, Pesticides and Explosives Industries.
EPA PB-251-307.  National Technical Information  Service.
1976.

     As is evident from the above the waste acid sludge
has a pH of 3 or below.  Liquid waste streams with such
acidic character present an environmental risk for several
reasons.  Very      low pH liquid waste if disposed in a
sanitary landfill would leach high concentrations of
toxic heavy metals (such as lead) from ordinary  municipal
trash.  These heavy metals would otherwise remain bound
in the waste matrix.  Highly acidic liquid wastes also
present a handling risk because of their corrosive
properties.  Highly acidic waste streams are also dangerous
because they have been known to initiate potentially
dangerous reactions when combined with otherwise innocuous
waste.

     OSW has in its files many damage incidents  resulting
from the mismanagement of highly acidic or caustic wastes.
These include:  several deaths and many serious  illnesses
resulting from the inhalation of toxic gases formed by
the reaction of acidic wastes with wastes containing
sulfide or cyanide salts, contamination and degradation
of groundwater and wells from improper disposal  of acidic
and caustic wastes, severe burns from handling and contact
with acidic and caustic wastes and several incidents of
fish kills from discharge of acidic and caustic  wastes.
(Refer to corrosivity and reactivity background  documents
for further information).

-------
2892 Spent carbon columns used in treatment of wastewater
-LAP operations (R) .
          waste is classified as hazardous because of its
      characteristic.  According to the information EPA
has on this waste stream it meets RCRA Section 250.13 (c)
characteristic identifying reactive waste.

     The Administrator has determined this waste stream
to be potential threat to the environment if improperly
managed .

     EPA bases this classification on the following
information.

     1.   An EPA contractor has tested a sample of waste
sludges and has found the following:

     Contaminant                   Concentration

     Nitrobodies                   0.0132 to 0.0416 Kg
                                   per Kg of explosives
                                   loaded .

     The data presented are available from:

          Assessment of Industrial Hazardous Waste Practices
Organic Chemicals, Pesticides and Explosives Industries.
EPA publication PB-251-307.  National Technical Information
Service .

     Reactive wastes as defined by Section 250.14 of RCRA
pose a threat to human health and the environment, either
through the physical consequences of their reaction
(i.e., high pressure and/or heat generation) or through
the chemical consequences of their reaction  (i.e.,
generation of toxic  fumes).  For further information
refer  to reactivity background document.

-------
"2892  Wastewater treatment sludges from production of
       initiating compounds (T)

                           See

"2892  Wastewater treatment sludges from explosives,
       propellants and initiating compounds manufacture
       This document

-------
 2911  Petroleum refining, high octane production neutralization
 HP  alkylation sludge  (T)
      This waste is classified as hazardous because of its toxic
 characteristic.  According to the information EPA has on this
 waste stream it meets the RCRA §250.13d characteristic
 identifying toxic wastes.
      EPA bases this classification on the following information.
      (1) Jacobs Engineering has tested a sample of HF alkylation
 sludge and found the following:
 contaminant                        cone, mg/kg sludge  (dry)

 CN                                          23.10
 Se                                           7.10
 As                                           2.30
 Hg  sol                                      0.07
 Ni  sol                                     55.20
 Cu  sol                                     14.30
 Pb  sol                                      7.10

 oil                                         6.9%
      The data presented are available from:
      Jacobs Engineering Company.  Assessment of Hazardous Waste
 Practices in the Petroleum Refining Industry.  Environmental
 Protection Publication PB - 259 097.  National Technical Infor-
mation Service.  June 1976.
      and
      Jacobs Engineering Company.  Alternative For Hazardous
Waste Management in the Petroleum Refining Industry.  OSW Contract
 #68-01-4167.  unpublished data.  July 1977.

-------
     The National Interim Primary Drinking Water Regulations


 (NIPDWR) set limits for chemical contamination of drinking flfeter.


The substances listed represent hazards to human health.  In


arriving at these specific limits, the total environmental


exposure of man to stated specific toxicant has been considered.


 (For a complete treatment of the data and reasoning used in


choosing the substances and specified limits please refer to the


NIPDWR Appendix A-C Chemical Quality/ EPA-6570/9 - 76 - 003) .


     A primary exposure route to the public for toxic contaminants


is through drinking water.  A large percentage of drinking water


finds its source in groundwater.  EPA has evidence to indicate that


industrial wastes as presently managed and disposed often Icachoo"^

                 oTi'
into and contamine****-the groundwater.  The Geraghty and Miller


report1 indicated that in 98% of 50 randomly selected on-site


industrial waste disposal sites, toxic heavy metals were found to


be present, and that these heavy metals had migrated from the


disposal sites in 80% of the instances.  Selenium, arsenic and/or


cyanides were found to be present at 74% of the sites and confirmed


to have migrated at 60% of the sites.


     At 52% of the sites toxic inorganics (such as arsenic, cadmium


etc.) in the groundwater from one or more monitoring wells exceeded


EPA drinking water limits (even after taking into account the


upstream (beyond the site) groundwater concentrations).


     Arsenic, barium, cadmium, chromium, lead;mercury, selenium,


and silver are toxicants listed by the NIPDWR at concentrations

                                    y
of 0.05, 1.00, 0.010, 0.05,  0.05, O.J0T002, 0.01, and 0.05, mg/1


respectively because of their toxicity.  As explained in the
                            3lo

-------
RCRA toxicity background documents these concentrations convert



to 0.5, 10.0, 0.1, 0.5, 0.5, 0.02, 0.1, and 0.5, mg/1 respectively



in the  EP extract.



     This waste has been shown to contain selenium, arsenic,



mercury, and lead at concentrations of 7.10, 2.30, 0.07 and 7.1



sludge  (dry) respectively, according to PB-259 097, Assessment of



Hazardous Waste Practices in the Petroleum Refining Industry,  p.  103



to 104.
                          311

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2911 Petroleum refining DAF sludge  (T)



     This waste stream is classified as hazardous because of its



toxic properties.  According to the data EPA has on this waste



stream it meets the RCRA §250.13d characteristic identifying a



toxic hazardous waste.



     Our information indicates that this waste has the following



properties:



     (1) Jacobs Engineering has tested a sample of DAF sludge and



found the following.





contaminant                             cone, mg/kg sludge  (dry)





As as Arsenic                                  2.00



Hg (aqueous state)                             0.27



Cr (OH)3                                     140.00



Pb (in the oil)                                7.50





oil  (light & heavy)                           12.5%





     The data presented are available from:



     Jacobs Engineering Company.  Assessment of Hazardous Waste



Practices in the Petroleum Refining Industry.  Environmental



Protection Publication PB-259 097.  National Technical Information



Service.  June 1976.



     and



     Jacobs Engineering Company.  Alternatives For Hazardous



Waste Management in the Petroleum Refining Industry.  OSW Contract



# 68 - 01 - 4167.  unpublished data.  July 1977.

-------
      The National Interim Primary Drinking Water Regulations
 (NIPDWR) set  limits for chemical contamination of Drinking Water.
The  substances  listed represent hazards to human health.  In
arriving at these specific limits, the total environmental exposure
of man to  a stated specific toxicant has been considered.  (For a
complete treatment of the data and reasoning used in choosing the
substances and  specified limits please refer to the NIPDWR Apendix
A-C  Chemical  Quality, EPA-6570/9 - 76 - 003).
       A primary exposure route to the public for toxic contami-
nants is through drinking water.  A large percentage of drinking
water finds its source  in groundwater.  EPA has evidence to indicate
that industrial Wastes  as presently managed and disposed often
           o  and contamineaferthe groundwater.  The Geraghty and
        report^-  indicated that in 98% of 50 randomly selected on-
site industrial waste disposal sites, toxic heavy metals were found
to be present,  and  that these heavy metals had migrated from the
disposal  sites  in  80% of the instances.  Selenium, arsenic and/or
cyanides were found to  be present at 74% of the sites and confirmed
to have migrated at 60% of the sites.
      At 52% of  the  sites toxic organics  (such as arsenic, cadmium
etc.) in  the  groundwater from one or more monitoring wells exceeded
EPA  drinking  water  limits  (even after taking into account the
upstream  (beyond the  site) groundwater concentrations).
      Arsenic, barium, cadmium, chromium, lead, mercury, selenium,
and  silver are  toxicants listed by  the NIPDWR at concentrations
0£  0.05,  1.00,  0.010,  0.05,  0.05,  0.002, 0.01, and 0.05 mg/1
respectively  because  of their toxicity.  As explained in the RCRA
          background documents these concentrations convert to 0.5,

                           513

-------
10.0, 0.5, 0.5, 0.02, 0.1, and 0.5 mg/1 respectively in the  EP
extract.
     This waste has been shown to contain arsenic, mercury, chromium,
and lead at concentrations of 2,00, 0.27, 140.0, and 7.50, mg/kg
sludge  (dry)  respectively according to PB - 259 097, Assessment
of Hazardous Waste Practices in the Petroleum Refining Industry,
P103-104.
                          31 M

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2911  Petroleum refining kerosene filter cakes  (T)



      This  waste  is  classified as hazardous because of its toxic



characteristic.  According to the information EPA has on this



waste stream it  meets the RCRA §250.13d characteristic



identifying  toxic waste.



      EPA bases this classification on the following information.



      (1) Jacobs  Engineering has tested a sample of kerosene filter



cake  and found the  following:





contaminant                             cone, mg/kg sludge  (dry)





As  as Arsenic                                 2.20





oil (light fraction)                           3.5%





      The data presented are available from:



      Jacobs  Engineering Company.  Assessment of Hazardous Waste



practices  in the Petroleum Refining Industry.  Environmental



protection Publication PB - 259 097.  National Technical



Information  Service.  June 1976.



      and



      Jacobs  Engineering Company.  Alternative For Hazardous



Waste Management in the Petroleum Refining Industry.  OSW



Contract*  68- 01 -  4167.  unpublished data.  July 1977.

-------
     The National Interim Primary Drinking Water Regulations

(NIPDWR) set limits for chemical contamination of drinking Water.

The substances listed represent hazards to human health.  In

arriving at these specific limits, the total environmental exposure

of man to a stated specific toxicant has been considered.  (For a

complete treatment of the data and reasoning used in choosing the

substances and specified limits please refer to the NIPDWR

Appendix A-C Chemical Quality, EPA-6570/9 - 76 -003).

     A primary exposure route to the public for toxic contami-

nants is through drinking water.  A large percentage of drinking

water finds its source in groundwater.  EPA has evidence to indicate

that industrial wastes as presently managed and disposed often

leachaa^into and contamine«4?^the groundwater.  The Geraghty and

Miller report1 indicated that in 98% of 50 randomly selected on-

site industrial waste disposal sites, toxic heavy metals had

migrated from the disposal sites in 80% of the instances.  Selenium,

arsenic and/or cyanides were found to be present at 74% of the sites

and confirmed to have migrated at 60% of the sites.

     At 52% of the sites toxic inorganics  (such as arsenic, cadmium

etc.) in the groundwater from one or more monitoring wells exceeded

EPA drinking water limits  (even after taking into account the

upstream  (beyond the site) groundwater concentrations).

     Arsenic, barium, cadmium, chromium, lead, mercury, selenium,
                       s
and silver are toxicant^ listed by the NIPDWR at concentrations of

0.05, 1.00, 0.010, 0.05, 0.05, 0.002, 0.01, and 0.05 mg/1

respectively because of their toxicity.  As explained in the RCRA

toxicity background documents these concentrations convert to

0.5, 10.0, 0.1, 0.5, 0.5,  0.02, 0.1, and 0.5, mg/1 respectively

-------
in the  EP extract.



     This waste has been shown to contain arsenic with a concen-



tration of 2.2 mg/kg sludge (dry), according to PB 259 097.



Assessment of Hazardous Waste Practices in the Petroleum Refining



Industry, p. 103-104.

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2911  Petroleum refining lube oil filtration clays  (T)



     This waste is classified as hazardous because of its toxic



characteristic.  According to the information EPA has on this



waste stream it meets the RCRA §250.13d characteristic



identifying toxic waste.



     EPA bases this classification on the following information.



     (1) Jacobs Engineering has tested a sample of lube oil



filtration clays and found the following:
contaminent





As as Arsenic



Cd (organically bound)



Ni (organically bound)



Pb (organically bound)





oil
cone, mg/kg sludge (dry)





          0.07



          0.76



         11.10



          1.28





         21.9%
     The data presented are available from:



     Jacobs Engineering Company.  Assessment of Hazardous Waste



Practices in the Petroleum Refining Industry.  Environmental



Protection Publication PB-259 097.  National Technical Information



Service.  June 1976.



     and



     Jacobs Engineering Company.  Alternatives For Hazardous



Waste Management in the Petroleum Refining Industry.  OSW



Contract #68-01-4167.  unpublished data.  July 1977.

-------
      The  National  Interim Primary Drinking Water Regulations
 (NIPDWR)  set  limits  for chemical contamination of Drinking Water.
 The substances  listed  represent hazards to human health.  In arriving
 at these  specific  limits, the total environmental exposure of man
 to a stated specific toxicant has been considered.   (For a complete
 treatment of  the data  and reasoning used  in choosing the sustances
 and specified limits please  refer to the  NIPDWR Appendix
 A-C Chemical  Quality,  EPA-6570.9 - 76 - 003).
      A primary exposure route to the public for toxic  contami-
 nants is  through drinking water.  A large percentage of drinking
 water finds its source in groundwater.  EPA has evidence to
 indicate  that industrial wastes as presently managed and disposed
 often leaches into and contaminents the groundwater.   The Geraghty
 and Miller report1 inidicated that in 98% of 50 randomly selected
 on-site industrial waste disposal sites,  toxic heavy metals were
 found to  be present, and that these heavy metals had migrated
 from the  disposal  sites in  80% of the instances.  Selenium,
 arsenic and/or cyanides were found to be  present at 74% of the
 sites and confirmed to have  migrated at 60% of the sites.
      At 52% of the sites toxic inorganics (such as arsenic, cadmium
 etc.) in  the groundwater from one or more monitoring wells exceeded
EPA drinking water limits  (even after taking into account the
 pgtream (beyond the site)  groundwater concentrations).
      Arsenic, barium,  cadmium, chromium,  lead, mercury, selenium,
and silver, toxicants  listed by the NIPDWR at concentrations of
0.05/ 1«0°» 0.010, 0.05, 0.05, Q.jtQQ2, 0.01, and 0.05  mg/1
 eSpectively because of their toxicity.   As explained  in the

-------
RCRA toxicity background documents these concentrations convert



to 0.5, 10.0, 0.1, 0.5, 0.5, 0.02, 0.1, and 0.5 mg/1 respectively



in the  EP extract.



     This waste has been shown to contain arsenic, cadmium, and



lead at concentrations of 0.7, and 1.28 mg/kg sludge (dry)



respectively, according to PB-259 097, Assessment of Hazardous



Waste Practices in the Petroleum Refining Industry, p.  103-104.

-------
 2911 Petroleum refining slop  oil  emulsion  solids  (T)
      This waste is classified as  hazardous because  of  its  toxic
 characteristic.  According to the information  EPA has  on this
 waste stream it meets the RCRA §250.13d  characteristic
 identifying toxic waste.
      EPA bases this classification on  the  following information.
      (1) Jacobs Engineering has tested a sample of  slop oil  emulsion
 solids and found the following.
 contaminant                        cone, mg/kg sludge  (dry)

 As as Arsenic                              7.40
 Hg (grim crude)                            0.59
 Cr as Cr(OH)3                           525.00
 Ni (in oil)                               50.00
 Cu (in oil)                               48.00
 Zn as carbonate                      .  250.00
 Cd (in oil)                                0.19
 Pb as TEL                                 28.1

 oil                                         48%
      The data presented are available  from:
      Jacobs Engineering Company.   Assessement  of  Hazardous Waste
 practices in the Petroleum Refining Industry.   Environmental
 protection Publication PB - 259 097.   National Technical
 information Service.  June 1976.
      and
      Jacobs Engineering Company.   Alternatives For  Hazardous
Waste Management in the Petroleum Refining Industry.   OSW
Contract* 68 - 01 - 4167.  unpublished data.   July  1977.

-------
     The National Interim Primary Drinking Water Regulations

(NIPDWR) set limits for chemical contamination of Drinking Water.

The substances listed represent hazards to human health.  In

arriving at these specific limits, the total environmental

exposure of man to a stated specific toxicant has been considered.

(For a complete treatment of the data and reasoning used in

choosing the substances and specified limits please refer to the

NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 - 76 - 003).

     A primary exposure route to the public for toxic contami-

nants is through drinking water.  A large percentage of drinking

water finds its source in groundwater.  EPA has evidence to

indicate that industrial wastes as presently managed and disposed

often leachajB^lnto and contamina&fe-f- the groundwater.  The Geraghty

and Miller report1 indicated that in 98% of 50 randomly selected
                                      <
on-site industrial waste disposal siteT,  toxic heavy metals were

found to be present, and that these heavy metals had migrated from

the disposal sites in 80% of the instances.  Selenium, arsenic

and/or cyanides were found to be present at 74% of the sites and

confirmed to have migrated at 60% of the sites.

     At 52% of the sites toxic inorganics  (such as arsenic, cadmium

etc.) in the groundwater from one or more monitoring wells

exceeded EPA drinking water limits (even after taking into account

the upstream (beyond the site) groundwater concentrations).

     Arsenic, barium, cadmium, chromium, lead, mercury, selenium,

and silver are toxicants listed by the NIPDWR at concentrations

of 0.05, 1.00,  0.010, 0.05, 0.05, 0.002, 0.01, and 0.05, mg/1

respectively because of their toxicity.   As explained in the RCRA

-------
toxicity  background documents these concentrations convert to



0.5,  10.0,  0.1, 0.5, 0.5, 0.02, 0.1, and 0.5, mg/1 respectively



in  the  EP  extract.



      This waste has been shown to contain arsenic, mercury,



chromium, and lead at concentrations of 7.40, 0.59, 525.0,



0.19, and 28.1 mg/kg sludge  (dry)  respectively, according to



PB  -  259  097, Assessment of Hazardous Waste Practices in the



Petroleum Refining Industry; p 103 - 104.
                            323

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2911 Petroleum refining exchange bundle cleaning solvent  (T)



     This waste is classified as hazardous because of its toxic



characteristic.  According to the information EPA has on this



waste stream it meets RCRA §250.13d characteristic identifying



toxic waste.



     EPA bases this classification on the following information,



     (1) Jacobs Engineering has tested a sample of exchange



bundle cleaning solvent and found the following.





contaminent                        cone, mg/kg sludge (dry)





Se as Oxide or Silicate                    27.20



As as Arsenic                              10.60



Cr as Oxide or Silicate                   311.00



Zn as Oxide or Silicate                   194.00



Pb as TEL                                  78.00



Mo as Oxide or Silicate                     6.50





oil  (light & heavy)                        10.7%





     The data presented are available from:



     Jacobs Engineering Company.  Assessment of Hazardous Waste



Practices in the Petroleum Refining Industry.  Environmental



Protection Publication PB - 259 097.  National Technical



Information Service.  June 1976.



     and



     Jacobs Engineering Company.  Alternatives For Hazardous



Waste Management in the Petroleum Refining Industry.  OSW



Contract* 68 - 01 - 4167.  unpublished data.  July 1977.

-------
      The National Interim Primary Drinking Water Regulations



 (NIPDWR) set limits for chemical contamination of Drinking Oteter.



 The substances listed represent hazards to human health.   In



 arriving at these specific limits,  the total  environmental



 exposure of man to a stated specific  toxicant has been  considered.



 (For a complete treatment of the data and  reasoning used  in



 choosing the substances and specified limits  please refer to the



 NIPDWR Appendix A-C Chemical Quality,  EPA-6570/9 -  76 - 003).



      A primary exposure route to the  public for toxic contaminants



 is through drinking water.  A large percentage of drinking water



 finds its source in groundwater.  EPA has  evidence  to indicated



 that industrial wastes as presently managed and disposed  often



 leacha^into and contaminents the groundwater.  The Geraghty and



 Miller report1 indicated that in 98%  of 50 randomly selected on-



 site industrial waste disposal sites,  toxic heavy metals  were



 found to be present, and that these heavy  metals had migrated



 from the disposal sites in 80% of the instances. Selenium, arsenic



 and/or cyanides were found to be present at 74% of  the  sites and



 confirmed to have migrated at 60% of  the sites.



      At 52% of the sites toxic inorganics  (such as  arsenic, cadmium



    -) in tne groundwater from one or  more  monitoring wells exceeded



     drinking water limits (even after taking  into account



     upstream  (beyond the site) groundwater concentration).



      Arsenic, barium, cadmium, chromium, lead, mercury, selenium,



     silver are toxicants listed be the NIPDWR at concentrations



    0.05, 1.00, 0.01, 0.05, 0.05, 0.002, 0.01, and 0.05, mg/1



respectively because of their toxicity. As explained in  the RCRA



to3cicity background documents these concentrations  convert to

-------
0.05, 10.0, 0.1, 0.5, 0.5,  0.02,  0.1,  and 0.5  mg/1  respectively



in the  EP extract.



     This waste has been shown to contain selenium,  arsenic,



chromium, and lead at concentrations of 27.2,  10.6,  311.0,  and



78.0 mg/kg sludge (dry)  respectively,  according to  PB  -  259 097,



Assessment of Hazardous  Waste Practices in the Petroleum Refining



Industry, p. 103 - 104.
                           334

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 2911   Petroleum refining API separator sludge(T)



      This waste is classified as hazardous  because  of  its  toxic



 characteristic.  According to the information EPA has  on this



 waste stream it meets RCRA §250.13d characteristic  identify-



 ing toxic waste.



      EPA bases this classification on the following information.



      (1) Jacobs Engineering has tested a sample of  API separator



 sludge and found the following:            ,





 contaminent                        cone, mg/kg  sludge  (dry)





 As as Arsenic                                  6.20



 Hg as Carbonate or Hydroxide                   0.40



 Cr as Carbonate or Hydroxide                 253.00



 Cd as Carbonate or Hydroxide                   0.42



 Zn as Carbonate or Hydroxide                 298.00



 pb as TEL                                    26.00



 oil as tar                                   22.6%





      The data presented are available from:



      Jacobs Engineering Company.  Assessment  of Hazardous  Waste



 practices in the Petroleum Refining Industry.   Environmental



 protection Publication PB-259 097.  National  Technical Information



 Service.  June 1976.



      and



      Jacobs Engineering Company.  Alternatives  For  Hazardous



Waste Management in the Petroleum Refining  Industry.   OSW



 Contract # 68-01-4167.  unpublished data.   July 1977.

-------
     The National  Interim Primary Drinking Water Regulations
 (NIPDWR) set limits for chemical contamination of rfrinking <
-------
explained  in  the RCRA toxicity background documents this converts
to  0.5,  0.02,  0.5, 0.1, and 0.5 mg/1 level respectively in the
 EP extract.
      This  waste has been shown to contain arsenic, mercury,
chromium,  cadmium and lead at 6.20, 0.40, 253.0, 0.42, and 26.0
mg/kg sludge  (dry) respectively, according to PB - 259 097,
Assessment of Hazardous Waste Practices in the Petroleum Refininj
Industry,  p.  103-104.
                            32?

-------
     3111
                 LEATHER TANNING & FINISHING
    Wastewater Treatment Sludge from Chrome Tannery and
                     Beamhouse/Tanhouse

     This waste stream is classified as hazardous because of
its toxic properties.  According to data EPA has on these waste
stream, they meet the RCRA §250.13a(4)  characteristic identifying
a toxic hazardous waste.
     The National Interim Primary Drinking Water Regulations
(NIPDWR) set limits for chemical contamination of drinking water.
The substances listed represent hazards to human health.  In
arriving at these specific limits, the total environmental ex-
posure of man to a stated specific toxicant has been considered.
(For a complete treatment of the data and reasoning used in choos-
ing the substances and specified limits please refer to the
NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 - 76 - 003) .
     A primary exposure route to the public for toxic contaminants
is through drinking water.  A large percentage of drinking water
finds its source in groundwater.  EPA has evidence to indicate
that industrial wastes as presently managed and disposed often
leaches into and contaminants the groundwater.  The Geraghty and
Miller report  indicated that in 98% of 50 randomly selected on-
site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated
from the disposal sites in 80% of the instances.  Selenium,
arsenic and/or'cyanides were found to be present at 74% of the
sites and confirmed to have migrated at 60% of the sites.
                                 330

-------
      At 52% of the sites  toxic  inorganics  (s.a. arsenic,


cadmium etc.)  in the  groundwater from one or more monitoring


wells exceeded EPA drinking water limits (even after taking


into account the upstream (beyond the site) groundwater con-


centrations) .


      Our information  indicates  that the waste contains the follow-


ing  toxic substances  in excess  of Drinking Water Standards:


          • Chromium       24000  - 38800 ppm


           Lead            140  - 310   ppm




      Reference:   SCS  Engineering.  Assessment of Industrial

                  Hazardous Waste Practices in Leather Tanning

                  and  Finishing  Industry^Nov. 76 PB # 261-0i8
                 p.  67, 68
hing I
rife
      This waste  presents an environmental problem because it may


pose  a chronic hazard to human health and the environment.
                             331

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                LEATHER TANNING & FINISHING
   3111

   Wastewater Treatment Screenings from Sheepskin Tannery,

      Split Tannery/ Retan/Finishers and Chrome Tannery




     This waste stream is classified as hazardous because of
                                                      *

its toxic properties.  According to data EPA has on th'*   waste

          Vfr                s
stream: , '.t  j meet* the RCRA s250.13a(4) characteristic identifying


a toxic hazardous waste.


     The National Interim Primary Drinking Water Regulations


(NIPDWR) set limits for chemical contamination of drinking water.


The substances listed represent hazards to human health.   In


arriving at these specific limits, the total environmental ex-


posure of man to a stated specific toxicant has been considered.


(For a complete treatment of the data and reasoning used in choos-


ing the substances and specified limits please refer to the


NIPDWR Appendix A-C Chemical Quality, EPA-6570/9 - 76 - 003) .


     A primary exposure route to the public for toxic contaminants


is through drinking water.  A large percentage of drinking water


finds its source in groundwater.  EPA has evidence to indicate


that industrial wastes as presently managed and disposed often


leach into and contaminate the groundwater.  The Geraghty and


Miller report1 indicated that in 98% of 50 randomly selected on-


site industrial waste disposal sites/ toxic heavy metals were


found to be present, and that these heavy metals had migrated


from the disposal  sites in 80% of the instances.  Selenium,


arsenic and/or cyanides were found to be present at 74% of the


sites and confirmed to have migrated at 60% of the sites.
                            331

-------
      At 52%  of  the  sites  toxic  inorganics  (s.a. arsenic,

cadmium etc.)  in  the groundwater  from one  or more monitoring

wells exceeded  EPA  drinking water limits  (even after taking

into  account the  upstream (beyond the site) groundwater con-

centrations) .

      Our information indicates  that the waste contains the

following toxic substances in excess of Drinking Water Standards;


           Chromium:    4200  -   33,000 ppm

           Lead:         175  -      280 ppm


      Reference:   SCS Engineering  Assessment of Industrial
                  Hazardous Waste  Practices in the Leather
                  Tanning  and Finishing IndustryTPB # 261-018
                  Nov.  1§76. pp. 67, 88, 97, 120.


      We believe the waste presents a hazard to human health and

the environment.
                             333

-------
         .        LEATHER TANNING & FINISHING
     31/1
   Trimmings and Shavings from Chrome and Split Tanneries
            Beamhouse/Tanhouse and Retan/Finishers
     These waste streams are classified as hazardous because of
their toxic properties.  According to data EPA has on these waste
streams, they meet the RCRA §250.13a(4) characteristic identifying
a toxic hazardous waste.
     The National Interim Primary Drinking Water Regulations
(NIPDWR) set limits for chemical contamination of drinking water.
The substances listed represent hazards to human health.   In
arriving at these specific limits, the total environmental ex-
posure of man to a stated specific toxicant has been considered.
(For a complete treatment of the data and reasoning used in choos-
ing the substances and specified limits please refer to the NIPDWR
Appendix A-C Chemical Quality, EPA-6570/9 - 76 - 003).
     A primary exposure route to the public for toxic contaminants
is through drinking water.  A large percentage of drinking water
finds its source in groundwater.  EPA has evidence to indicate
that industrial wastes as presently managed and disposed often
leach into and contaminate the groundwater.  The Geraghty and
Miller report1 indicated that in 98% of 50 randomly selected on-
site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated
from the disposal sites in 80% of the instances.  Selenium,
arsenic and/or cyanides were found to be present at 74% of the
sites and confirmed to have migrated at 60% of the sites.

-------
     At 5.2%  of  the  sites  toxic  inorganics  (s.a. arsenic,

cadmium etc.) in  the groundwater from one  or more monitoring

wells  exceeded  EPA  drinking water  limits  (even after taking

into account the  upstream (beyond  the site) groundwater con-

centrations) .

     Our information indicates  that this waste stream contains

the following toxic heavy metals in excess of Drinking Water

Standards.

          Chromium:       10,000  - 44000  ppm

          Lead:             130  -   330  ppm

     Reference:   SCS Engineering,  Assessment of Industrial
                  Hazardous Waste Practices in the Leather
                  Tanning  and Finishing Industry.  PB ft 261-018.
                  Nov.  1976 pp.  64-66, 88,  96, 117,  119

     We feel this waste stream  poses a hazard to human health

and the environment.

-------
  •5/ .           LEATHER TANNING & FINISHING



   Wastewater Treatment Sludge From Dehairing and Tanning





     This waste stream is classified as hazardous because of



its toxic properties.  According to available data, this waste



stream meets the RCRA fJ250.13a(4) characteristic identifying a



toxic hazardous waste.



     The National Interim Primary Drinking Water Regulations



(NIPDWR) set limits represent hazards to human health.  In



arriving at these specific limits, the total environmental ex-



posure of man to a stated specific toxicant has been considered.



(For a complete treatment of the data and reasoning used in choos-



ing the substances and specified limits please refer to the NIPDWR



Appendix A-C Chemical Quality, EPA-6570/9 - 76 - 003).



     A primary exposure route to the public for toxic contaminants



is through drinking water.  A large percentage of drinking water



finds its source in groundwater.  EPA has evidence to indicate



that industrial wastes as presently managed and disposed often



leach into and contaminate the groundwater.  The Geraghty and



Miller report1 indicated that in 98% of 50 randomly selected on-



site industrial waste disposal sites, toxic heavy metals were



found to be present, and that these heavy metals had migrated



from the disposal sites in 80% of the instances.  Selenium, arsenic



and/or cyanides were found to be present at 74% of the sites and



confirmed to have migrated at 60% of the sites.

-------
     At  52% of the sites toxic inorganics (s.a. arsenic,
cadmium  etc.) in the groundwater from one or more monitoring
wells exceeded EPA drinking water limits (even after taking
into account the upstream  (beyond the site)  groundwater con-
centrations) .
     This waste stream has been shown to contain chromium.  On
that basis we feel it poses a threat to human health and the
environment.
     Reference:  Storm, Handbook of Industrial Waste Compositions
                 in California - 1978 California Department of
                 Health Services, Nov. 1978, p. 66.

-------
3312  Coking; Decanter Tank Pitch/Sludge/Tar  (0)

     This waste is classified as hazardous because of its toxic
characteristics.  According to the information EPA has about
this waste stream, it contains phenol in concentrations large
enough to classify the waste stream as a hazardous waste.

     EPA bases this classification on the following information;
(1) Calspan Corp. has tested a sample of Decanter Tank Pitch/Sludge
and found the following:
     pH = 8.9 (Dist H20 leachate)

                          Dist. H20              Waste
                          Leachate               Sample
Contaminant               Cone.  ppm             Analysis  ppm
     Cr                     0.01                      4
     Cu                     0.03                      1
     Mn                     0.01                      44
     Ni                     0.05                      10
     Pb                     0.2                       30
     Zn                     0.01                      20
     CN                     0.59                     1.3 - 9.8
     oil and grease         198                   144,000 - 297,000
     phenol                 500                    1,711 - 3,127
     conductivity           350

-------
 (2)   Tar Composition                         %, Weight







      Liquor                                 1.6 - 5.8



      Benzol                                 0.1 - 0.3



      Toluol                                 0.1 - 0.4



      Xylol                                  0.1 - 0.5



      Total Tar Acids  (phenols,  cresols,



        xylenols)                             2.0 - 3.9



      Total Tar Bases  (pyridine, picolines,



        quinolines)                           1.4 - 2.0



      Naphtha (coumarone,  indene)             0.4 - 2.0



      Crude Napthalene                       7.7 - 11.7



      Methylnaphthalene Oil                   2.1-2.9



      Biphenyl Oil                           0.9 - 1.5



      Acenaphthene Oil                       1.4 - 2.8



      Fluorene Oil (fluorene,  diphenyl



        oxide)                                1.9 - 3.6



      Anthracene-Heavy Oil (anthracene,



        phenanthrene,  carbazole)              9.6 - 12.3



      Pitch                                  60.2 - 64.2



      Distillation Losses                     0.9 - 2.8
Source:  "The Coal Tar Data Book."  The Coal Tar Research



AgSociation, 2nd ed.,  Section AL,  2-4, 1965.



        of composition of five typical tars.
                             35"?

-------
     A primary exposure route to the public for toxic contaminants

is through drinking water.  A large percentage of drinking water

finds its source in groundwater.  EPA has evidence to indicate

that industrial wastes as presently managed and disposed often

leach   into and contaminate  the groundwater.  The Geraghty and
             1
Miller report indicated that in 98% of 50 randomly selected on-

site industrial waste disposal sites, toxic heavy metals were

found to be present, and that these heavy metals had migrated

from the disposal sites in 80% of the instances.  Selenium,

arsenic and/or cyanides were found to be present at 74% of the

sites and confirmed to have migrated at 60% of the sites.




     At 52% of the sites toxic inorganics (such as arsenic,

cadmium, etc.) in the groundwater from one or more monitoring

wells exceeded EPA drinking water limits (even after taking in-

to account the upstream (beyond the site) groundwater concen-

trations) .


                        1
     Geraghty and Miller also found that in a majority of the

fifty sites examined organic contamination of the groundwater

above background levels was observed.  In 28 (56%) of these

sites chlorinated organics attributable to waste disposal were

observed in the groundwater.  While specific identification of

these organics was not always undertaken in this work, (other

incidents and reports (References 2 through 8) do qualitatively

identify leached organic contaminants in groundwater), it

certainly serves to demonstrate that organic contamination of

-------
groundwater  frequently results from industrial waste disposal.
Since  the  Administrator has determined "that the presence in
drinking water of chloroform and other trihalomethanes and
synthetic  organic chemicals may have an adverse effect on the
health of  persons..."* and, as noted above, because much drinking
water  finds  its  source as groundwater, the presence of available
toxic  organics in waste is a critical factor in determining if a
waste  presents a hazard when managed.  (For a discussion of how
the  toxicity and concentration of organic contaminants in waste
are  considered in the hazard determination see Toxicity background
document).

     Coking  Decanter Tank Sludge has been found to contain
phenol according to Calspan Corp, Vol III, p. 6-69.  App. page
121  37. Since the water extract of the waste has been shown to
contain phenol at a 500 ppm concentration, the phenol is not
fixed  in the solid matrix.  It is therefore available to migrate
down through a disposal site to groundwater.  Thus, we feel that
this waste stream poses a threat to human health and the
environment.
*«Interim Primary Drinking Water  Regulations,"
  p.  5756, Federal Register,  2/9/78.

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste  Practices



in the Metal Smelting and Refining Industry  Appendices.



April 1977.  Contract # 68-01-2604.   Vol III,  6-69.  App.  page



12, 37.







Enviro Control Inc.   Hazardous Waste Listings  Fully  Integrated



Steel Mills.  May 1978.  Contract #  68-01-3937.  Pages 4.1-4.4,



App. table A-l.







NUS Corp.  Development Document for  Effluent Limitations.   (etc,)



Iron and Steel Industries-Hot Forming and Cold Finishing Segment.



July 1974.  Contract # 68-01-1507.







Dravo Corp.  Managing and Disposing  of Residues  from Environmental



Control Facilities in the Steel Industry.  June  1976.  Contract  #



R-803C19.  Page 26-35.

-------
 3312  Coking:  Oleum Wash Waste   (C)

      This waste  is  classified as hazardous because of its
 corrosive characteristics.  According to the information EPA
 has about this waste stream it meets the RCRA S250.13b
 characteristic identifying corrosive wastes.

      EPA bases this classification on the following information.
 Oleum wash waste is fuming H2S04.  The resulting sludge from
 the Oleum wash contains up to 50% free acid  (Bethlehem Steel
 Corp./ 1978)  there  by  causing a highly corrosive waste.  Sludge
 is  expected to contain heterocyclic hydrocarbons and sulfur
 containing organics.

      Liquid waste streams with such acidic character present
 an  environmental risk  for several reasons.  Very low pH liquid
waste if disposed in a sanitary landfill would leach high con-
 centrations of toxic heavy metals (such as lead) from or iinary
municipal trash.  These heavy metals would otherwise remain
bound in the waste  matrix.  Highly acidic liquid wastes also
present a handling  risk because of their corrosive properties.
Highly acidic waste streams are also dangerous because they have
been known to initiate potentially dangerous reactions when
combined with otherwise innocuous waste.
                            3M3

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste



Practices in the Metaj^ Smelting and Refining Industry



Appendices.  April 1977.  Contract # 68-01-2604.   Vol III,



pages 6-69.  App. pages 12, 37.







Enviro Control Inc.  Hazardous Waste Listings Fully Integrated



Steel Mills.  May 1978.  Contract # 68-01-3937.   page 4,5.







NUS Corp.  Development Document for Effluent Limitations.



etc,) Iron and Steel Industries-Hot Forming and  Cold Finishing



Segment.  July 1974.  Contract # 68-01-1507.







Dravo Corp.  Managing and Disposing of Residues  from



Environmental Control Facilities in the Steel Industry.



June 1976.  Contract # R-803619.  pages 26-35.

-------
     OSW has in its files many damage incidents resulting



from the mismanagement of highly acidic or caustic wastes.



These  include:  several deaths and many serious illnesses



resulting from the inhalation of toxic gases formed by the



reaction of acidic wastes with wastes containing sulfide or



cyanide salts, contamination and degradation of groundwater



and wells from improper disposal of acidic and caustic wastes,



severe burns from handling and contact with acidic and caustic



wastes and several incidents of fish kills from discharge of



acidic and caustic wastes.   (Refer to corrosivity and reac-



tivity background documents for further information).

-------
3312  Coking; Caustic Neutralization Waste  (C)







     This waste is classified as hazardous because of its



corrosive characteristics.  According to the information EPA has



about this waste stream it meets the RCRA S250.13b characteris-



tic identifying corrosive wastes.







     Crude light oil is recovered from the coke oven off-gas.



This light oil is scrubbed with Oleum (fuming H2S04).  The



scrubbed light oil stream is next neutralized with a caustic



wash.  This caustic wash generates the sludge that is discussed



here.







     Liquid waste streams with such Caustic character present



an environmental risk for several reasons.  Very high pH liquid



waste if disposed in a sanitary landfill would leach high con-



centrations of toxic heavy metals from ordinary municipal trash.



These heavy metals would otherwise remain bound in the waste



matrix.  Highly caustic liquid wastes also present a handling



risk because of their corrosive properties.  Highly caustic



waste streams are also dangerous because they have been known



to initiate potentially dangerous reactions when combined with



otherwise innocuous waste.

-------
     OSW has in its files many damage incidents resulting



from the mismanagement of highly acidic or caustic wastes.



These include:  several deaths and many serious illnesses



resulting from the inhalation of toxic gases formed by the



reaction of acidic wastes with wastes containing sulfide or



cyanide salts, contamination and degradation of groundwater



and wells from improper disposal of acidic and caustic wastes,



severe burns from handling and contact with acidic and caustic



wastes and several incidents of fish kills from discharge of



acidic and caustic wastes.  (Refer to corrosivity and reactivity



background documents for further information).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste



Practices in the Metal Smelting and Refining Industry



Appendices.  April 1977.  Contract # 68-01-2604.   Vol III



6-69, App. page 12, 37.







Enviro. Control Inc.  Hazardous Waste Listings  Fully Integrated



Steel Mills.  May 1978.  Contract # 68-01-3937, page 4,5.







NUS Corp.  Development Document for Effluent Limitations.



(etc,)  Iron and Steel Industries-Hot Forming and  Cold Finishing



Segment.  July 1974.  Contract # 68-01-1507.








Dravo Corp.  Managing and Disposing of Residues from Environmental



Control Facilities in the Steel Industy.   July  1976.  Contract #



R-803619.  pages 26-35.

-------
3312  Coking; Ammonia Still Lime Sludge  (R)



     This waste is classified as hazardous because of its

toxic characteristics.  According to the information EPA has

about this waste stream it meets the RCRA §250.13c characteris-

tic identifying reactive waste.



     EPA bases this classification on the following information

;  ;  Calspan Corp. has tested a sample of Ammonia Still Lime

Sludge and found the following:
     pH = 11.5
                          Dist. H20
                          Leachate
Contaminant
Cr
Cu
Mn
Ni
Pb
Zn
CN
P
oil & grease
phenol
conductivity
Cone, ppm
0.02
0.09
0.05
< 0.05
0.5
< 0.01
198
-
-
20
> 10,000
Waste
Sample
Analysis  ppm

  43-80

 22.5 - 35

  500 - 550

    5-15

 < 10 - 67

  550 - 710

 0.25 - 1,940



 12,100 - 104,000

  3.4 - 1,910

-------
     Reactive wastes as defined by Section 250.14 of RCRA
pose a threat to human health and the environment, either
through the physical consequences of their reaction  (i.e.,
high pressure and/or heat generation) or through the chemical
consequences of their reaction  (i.e., generation of toxic
fumes).

     According to Calspari Corp, Vol III, pages 6-69, this
waste stream has been shown to contain up to 1940 ppm cyanides,
and to  leach 198 ppm cyanides.  Under mildly acid and/or basic
conditions these may solubilize to generate HCN gas.  HCN gasr
in an intensly poisonous gas even when mixed with air.  High
concentration produces tachypnea (causing increased intake of
cyanide);  then dyspnea, paralysis, unconsciousness, convulsions
and respiratory arrest.  Exposure to 150 ppm for 1/2 to 1 hour
may endanger life.  Death may result from a few minutes exposure
to 300 ppm.  Average fatal dose: 50 to 60 rag.

-------
References







Calspan Corp.  Assessment of Industrial Hazardous  Waste



Practices in the Metal Smelting and Refining Industry



Appendices.  April 1977.  Contract # 68-01-2604 Vol III,



pages 6-69.  App. page 12, 37.







Enviro Control Inc.  Hazardous Waste Listings Fully



Integrated Steel Mills.  May 1978.  Contract # 68-01-3937,



pages 4-5.  App. table A-2.







NUS Corp.  Development Document for Effluent Limitations.



(etc,) Iron and Steel Industries-Hot Forming and Cold



Finishing Segment.  July 1974.  Contract f 68-01-1507.







Dravo Corp.  Managing and Disposing of Residues from



Environmental Control Facilities in the Steel Industry.



June 1976.  Contract ft R-803C19.  Page 26-35.

-------
3312  Iron Making; Ferromanganese Blast Furnace Dust  (T,  R)
     This waste is classified as hazardous because of its

reactive and toxic characteristics.   According to the infor-

mation EPA has about this waste stream it meets both the RCRA

S250.13c and S250.13d characteristics identifying reactive

and toxic wastes.


     EPA bases this classification ori the following information;

(1)  Dravo Corp. and Calspan Corp., have tested samples of

Ferromanganese Blast Furnace Dust and found the following:

     pH = 9.7 Dist H20 Leach Test
Contaminent

     Zn

     Pb

     Al

     K

     Mg

     Ca

     Mn

     Na

     C

     Total fe

     Si 02

     Cr

     Cu

     Ni

     Sn
Dist. H20
Leachate
Cone,  ppm

   110

   560
    7.5
    0.2

    4.5

    0.53
Waste
Sample
Analysis  ppm

1,600 - 45,000

  100 - 6000

50,500

18,700 - 28,700

2,800

16,800 - 19,100

155,000 - 212,200

500 - 700

71,000 - 95,000

48,000 - 53,000

61,700 - 68,000

      32

     200



     400

-------
     Primary treatment dusts have been reported as pyrophoric



(Dravo Corp., 1976).  Ferromanganese dust collected in a bag-



house and analyzed by the Calspan solubility test leached



exceedingly high concentrations of lead and zinc.







     The lead concentrations is several orders of magnitude



greater than drinking water standards.







     Lead is one of the toxicants listed by the N I ? £> W R



at a concentration of .05mg/l because of its toxicity.  As



explained in the RCRA toxicity background document this



converts to a .5mg/l level in the  EP extract.







     Since the water extract of the waste has been shown to



contain lead at a 560 ppm concentration, the heavy metals are



not fixed in the Solid rtiatrix.  They are therefore available



to migrate down through a disposal site to groundwater.  Thus,



ferromanganese blast furnace dust has been classified as toxic,



and the dust is also classified as reactive due  to its



pyrophoric nature.







     Reactive wastes as defined by Section 250.14 of RCRA pose



a threat to human health and the environment, either through



the physical consequences of their reaction (i.e., high



pressure and/or heat generation) or through the chemical



consequences of their reaction  (i.e., generation of toxic



ftimes) .
                          1S3

-------
     The National Interim Primary Drinking Water Regulations (NIPDWR)

set limits for chemical contamination of Drinking Water.  The sub-

stances listed represent hazards to human health.  In arriving at

these specific limits, the total environmental exposure of man to a

stated specific toxicant has been considered.  (For a complete


treatment of the data and reasoning used in choosing the substances
                                                             «^ /
and specified limits please refer to the NIPDWR Appendix A-C

Chemical Quality, EPA-6570/9 - 76 - 003).                   '




     A primary exposure route to the public for toxic contaminants

is through drinking water.  A large percentage of drinking water

finds its source in groundwater.  EPA has evidence to indicate that

industrial wastes as presently managed and disposed often leache

into and contaminate the groundwater.  The Geraghty and Miller
      1
report indicated that in 98% of 50 randomly selected on-site

industrial waste disposal sites, toxic heavy metals were found to

be present, and that these heavy metals had migrated from the

disposal sites in 80% of the instances.  Selenium, arsenic and/or

cyanides were found to be present at 74% of the sites and confirmed

to have migrated at 60% of the sites.
     At 52% of the sites toxic inorganics (such as arsenic, cadmium

etc.) in the groundwater from one or more monitoring wells exceeded

EPA drinking water limits (even after taking into account the

upstream (beyond the site) groundwater concentrations).
                                354

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste Practices



in  the Metal Smelting and Refining Industry Appendices.  April 1977,



Contract #  68-01-2604.  Vol III, pages 97-144.  App.  pages 29, 35.







Enviro Control Inc.  Hazardous Waste Listings Fully Integrated



Steel Mills.  May  1978.  Contract # 68-01-3937.  Pages 4.9, 4.13-14,







NUS  Corp.   Development Document for Effluent Limitations.  (etc,)



iron and Steel Industries-Hot Forming and Cold Finishing Segment.



July 1974.  Contract ft 68-01-1507.







Dravo Corp.  Managing and Disposing of Residues from Environmental



Control Facilities in the Steel Industry.  June 1976.  Contract #



R-803C19.   Page  63-66.

-------
3312  Iron Making Ferromanganese Blast Furnace Sludge  (R)
     This waste is classified as hazardous  because of its

toxic characteristics.  According to the information EPA has

about this waste stream it meets the RCRA S250.13c charac-

teristic identifying reactive waste.


     EPA bases this classification on the following informa-
              (
tion? (".',  Dravo Corp and Bethlehem Steel have tested a sample

of ferromanganese blast furnace sludge and  found the following:
     pH = 11 Dist.  H20 leach test
Contaminent

     Zn

     Pb

     Sn

     Al

     k

     Mg

     Ca

     Mn

     Na

     C

     Total Fe

     Si 02

     Cr

     Cu

     Ni

     Cd
 Dist.  H20
 Leachate
 Cone,   ppm

  0.061
  0.2
  45.8



< 0.07

* 0.05

< 0.08
Waste
Sample
Analysis  ppm

1.7  4,100

  2  400

400 - 600

35,500 - 36,100

74,900 - 87,400

17,000 - 19,300

63,800 - 69,500

57,500 - 68,600

 4,800 - 5,100

74,000 - 76,000

 1400 - 24,000

      54,200

   0.05 -18

   0.05
                      < 0.05

-------
     Although the data do not present any alarming concentra-



tions of heavy metals, sources indicate that high levels of



cyanide in the off-gas from these blast furnaces would be



absorbed in scrubber solutions and render the sludge toxic to



human health and the environment.







     Reactive wastes as defined by Section 250.14 of RCRA pose



a threat to human health and the environment, either through



the physical consequences of their reaction  (i.e., high



pressure and/or heat generation)  or through the chemical con-



sequences of their reaction (i.e., generation of toxic fumes).







     According to Enviro Control, page 4.9, 4.13-14, this



waste stream has been shown to contain cyanides.  Under



mildly acid and/or basic conditions these may solubilize to



generate HCN gas.  High concentration produces tachypnea



(causing increased intake of cyanide); then dyspnea, paralysis,



unconsciousness, convulsions and respiratory arrest.  Exposure



to 150 ppm for 1/2 to 1 hour may endanger life.  Death may



result from a few minutes exposure to 300 ppm.  Average fatal



dose: 50 to 60 mg.
*Merck  Index, Eighth Edition, p.  544

-------
References








Calspan Corp.  Assessment of Industrial Hazardous Waste



Practices in the Metal Smelting and Refining Industry



Appendices.  April 1977.  Contract # 68-01-2604,  Vol III,



pages 97-144.  App. pages 29, 35.







Enviro Control Inc.  Hazardous Waste Listings Fully



Integrated Steel Mills.   May 1978.   Contract # 68-01-3937,



Pages 4.9, 4.13-14.







NUS Corp.   Development Document for Effluent Limitations.



(etc,)  Iron and Steel Industries-Hot Forming and  Cold



Finishing Segment.   July 1974.   Contract #  68-01-1507.







Dravo Corp.  Managing and Disposing of  Residues from



Environmental Control Facilities in the Steel Industry.



June 1976.  Contract # R-803C19, pages  63-66.
                      3S3

-------
3312  Iron Making, Electric Arc Furnace Dust  (T)

     This waste is classified as hazardous because of its
toxic characteristics.  According to the information EPA has
about this waste stream it meets the RCRA S250.13d characteris-
tics identifying toxic wastes.

     EPA bases this classification on the following information
     Calspan Corp. has tested a sample of Electric Arc Furnace
Dust and found the following:
Contaminent
     Mn
     Cr
     Cu
     Pb
     Ni
     Zn
     F
     PH
Dist. H20
Leachate
Cone.  ppm
   0.26
   0.34
   0.1
    150
 < 0.05
   0.7
   7.6
   12.6
Waste
Sample
Analysis  ppm
38,000 - 45,000
770 - 1,500
1,800 - 3,400
20,000 - 46,000
170 - 500
54,000 - 240,000
1,700 - 2,940
                         SSI

-------
     According to the Solubility test performed by Calspan



Corp. the leachate derived from Electric Arc Furnace Dust



contains Pb in concentrations which are several orders of



magnitude greater than drinking water standards.







     Lead is one of the toxicants listed by the N I p D W R



at a concentration of .05mg/l because of its toxicity.  As



explained in the RCRA toxicity background document this con-



verts to a .5mg/l level in the  EP extract.







     Since the water extract of the waste has been shown to



contain lead at a ISOppm concentration, the heavy metal  is



not fixed in the Solid Matrix.  It is therefore available to



migrate down through a disposal site to groundwater.  Thus,



we feel that this waste stream poses a threat to human health



and the environment.
                           340

-------
      The National Interim  Primary Drinking Water Regulations  (NIPDWR)

set limits for chemical  contamination of Drinking Water.  The sub-

stances listed represent hazards to human health.  In arriving at

these specific limits, the total environmental exposure of man to a

stated specific toxicant has been considered.  (For a complete

treatment of the data and  reasoning used in choosing the substances

and specified limits  please refer to the NIPDWR Appendix A-C

Chemical Quality, EPA-6570/9 -  76 - 003).



      A primary exposure  route to the public for toxic contaminents

is  through drinking water.  A large percentage of drinking water

finds its source in groundwater.  EPA has evidence to indicate that

industrial wastes as  presently  managed  and disposed often leache

into and contaminate  the groundwater.   The Geraghty and Miller
       1
report indicated that in 98% of 50 randomly selected on-site

industrial waste disposal  sites, toxic  heavy metals were found to

be  present, and that  these heavy metals had migrated from the

Disposal sites in 80% of the instances.  Selenium, arsenic and/or

cyanides were found to be  present at 74% of the sites and confirmed

to  have migrated at 60%  of the  sites.



      At 52% of the sites toxic  inorganics  (such as arsenic, cadmium

ete.)  in the groundwater from one or more monitoring wells exceeded

EPA drinking water limits  (even after taking into account the

upstream (beyond the  site)  groundwater  concentrations).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste Practices



in the Metal Smelting and Refining Industry Appendices.   April 1977,



Contract # 68-01-2604 Vol III,  pages 6-69,  App.  pages  12,  37.







Enviro Control Inc.   Hazardous  Waste Listings  Fully  Integrated



Steel Mills.  May 1978.   Contract # 68-01-3937,  pages  4.16,  4.23-



25, App. Table A-14.







NUS Corp.  Development Document for Effluent Limitations.   (etc,)



Iron and Steel Industries-Hot Forming and Cold Finishing Segment.



July 1974.  Contract # 68-01-1507.







Dravo Corp.  Managing and Disposing of Residues  from Environmental



Control Facilities in the Steel Industry.   June  1976.   Contract #



R-803619, page 91-99.

-------
3312  Iron Making, Electric Arc Furnace Sludge  (T)



     This waste is classified as hazardous because of its toxic

characteristics.  According to the information EPA has about

•this waste stream it meets the RCRA S250.13d characteristic

identifying toxic wastes.



     EPA bases this classification on the following information;

•;".)  Calspan Corp. has tested a sample of Electric Arc Furnace

Sludge and found the following:
Contaminent

     Mn

     Cr

     Pb

     Cu

     Ni

     Zn
Dist. H2O
Leachate
Cone.  ppm

   0.03

    94

   2.0

   0.17

 < 0.05

   0.06
Waste
Sample
Analysis  ppm

48,000 - 55,000

 1,800 - 2700

 2,000

 520 - 550

 3,000 - 3,750

 2,500 - 3,800
     pH
   11.5
                            313

-------
     According to the solubility test performed by Calspan



Corp. the leachate derived from Electric Arc Furnace Sludge



contains Cr, and Pb in concentrations which are several orders



of magnitude greater than drinking water standards.







     Chromium and Lead are toxicants listed by the N I p.D W R



at a concentration of .05mg/l because of their toxicity.  As



explained in the RCRA toxicity background document this converts



to a ,5mg/l level in the  EP extract.







     Since the water extract of the waste has been shown to



contain chromium and lead at a 94 and 2.0ppm concentration, the



heavy metals are not fixed in the solid matrix.  They are



therefore available to migrate down through a disposal site to



groundwater.  Thus we feel that this waste stream poses a threat



to human health and the environment.

-------
      The National  Interim Primary Drinking Water Regulations  (NIPDWR)


 set limits for chemical  contamination of Drinking Water.  The sub-


 stances listed represent hazards to human health.  In arriving at


 these specific limits, the  total environmental exposure of man to a


 stated specific toxicant has been considered.  (For a complete


 treatment of the data  and reasoning used in choosing the substances

 and specified limits please refer to the NIPDWR Appendix A-C


 Chemical Quality,  EPA-6570/9 -  76 - 003).




      A primary exposure  route to the public for toxic contaminents

 is through drinking water.  A large percentage of drinking water


 finds its source in groundwater.  EPA has evidence to indicate that


 industrial wastes  as presently  managed  and disposed often leache


 into and contaminate the groundwater.   The Geraghty and Miller
       1
 report indicated that  in 98% of 50 randomly selected on-site


 industrial waste disposal sites, toxic  heavy metals were found to


 be present,  and that these  heavy metals had migrated from the


 disposal sites in  80%  of the instances.  Selenium, arsenic and/or

 cyanides were found to be present at 74% of the sites and confirmed


 to have migrated at 60%  of  the  sites.




      At 52%  of the sites toxic  inorganics (such as arsenic, cadmium


etc-)  in the groundwater from one or more monitoring wells exceeded

gpA drinking water limits (even after taking into account the


upstream (beyond the site)  groundwater  concentrations).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste



Practices in the Metal Smelting and Refining Industry



Appendices.  April 1977.  Contract ft 68-01-2604 Vol III,



pages 6-69, App. pages 12, 37.







Enviro. Control Inc.  Hazardous Waste Listings Fully



Integrated Steel Mills.  May 1978.  Contract f 68-01-3937,



page 4.16, 4.23-25, App. table A-15.







NUS Corp.  Development Document for Effluent Limitations.



(etc,)  Iron and Steel Industries-Hot Forming and Cold



Finishing Segment.  July 1974.  Contract # 68-01-1507.







Dravo Corp.  Managing and Disposing of Residues from



Environmental Control Facilities in the Steel Industry.



June 1976.  Contract R-803619.  pages 91-99.

-------
 3312  Steel Finishing:  Alkaline Cleaning Waste   (C)
      This waste  is  classified as hazardous because of its
 corrosive characteristics.  According to the information EPA
 has about this waste  stream it meets the RCRA S250.13a.2 charac-
 teristic identifying  corrosive wastes.

      Prior to electrolytic or hot-dip plating procedures, cold-
 reduced steel must  be cleaned of oils and lubricants so that no
 residue is formed during  annealing.  This is commonly done by
 application of aqueous  alkaline detergent solutions containing
 such chemicals as sodium  hydroxide, sodium orthosilicate, and
 trisodium phosphate.

      These solutions  are  routinely wasted and may constitute
 corrosive hazards.  Since the pH of these solutions is generally
 above 12, it is  classified as a hazardous waste.
      Liquid waste streams with such caustic character present
 an  environmental risk for several reasons.  Very high pH liquid
waste if disposed in  a  sanitary landfill would leach high con-
 centrations of toxic  heavy metals from ordinary municipal trash.
 These heavy metals  would  otherwise remain bound in the waste
matrix.  Highly  caustic liquid wastes also present a handling
 risk because of  their corrosive properties.  Highly caustic waste
 streams are also dangerous because they have been known to
 initiate potentially  dangerous reactions when combined with
 otherwise innocuous waste.

-------
     OSW has in its files many damage incidents resulting from
the mismanagement of highly acidic or caustic wastes.  These
include:  several deaths and many serious illnesses resulting
from the inhalation of toxic gases formed by the reaction of
acidic wastes with wastes containing sulfide or cyanide salts,
contamination and degradation of groundwater and wells from
improper disposal of acidic and caustic wastes, severe burns
from handling and contact with acidic and caustic wastes and
several incidents of fish kills from discharge of acidic and
caustic wastes.   (Refer to corrosivity and reactivity background
documents for further information).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous  Waste Pnactices



in the Metal SmeltAng and Refining Industry Appendices.



April 1977.  Contract t 68-01-2604.   Vol III,  6-69,  App.  page



12, 37.







Enviro Control Inc.  Hazardous Waste Listings  Fully  Integrated



Steel Mills.  May 1978.  Contract #  68-01-3937.  Pages  4.25-27,



4.37.







NUS Corp.  Development Document for Effluent Limitations.  (etc,)-



Iron and Steel Industries-Hot Forming and Cold Finishing Segment.



July 1974.  Contract # 68-01-1507.







Dravo Corp.  Managing and Disposing of Residues from Environmental



Control Facilities in the Steel Industry.  June 1976.  Contract #



R-803619.  Page 133-135.

-------
3312  Steel Finishing:  Waste Pickle Liquor  (C, T)

     This waste is classified as hazardous because of its
corrosive and toxic characteristics.  According to the
information EPA has about this waste stream it meets both
the RCRA §250.13b and §250.13d characteristics identifying
corrosive and toxic wastes.

     EPA bases this classification on the following information:
(1)  Waste Management Inc. has tested a sample of spent pickle
liquor and found the following:

     pH = .6
contaminent         cone, mg/1
Cd                      461
Cr (total)             11460
Cr VI                   .2
Cu                     4867
Pb                      578
Zn                    12680
                California Manifest Listings
     The following waste discriptions were taken from "Handbook
of Industrial Waste Compositions'/  These waste discriptions are
typical of wastes entering the California waste control system.
These listings are included to demonstrate that these waste
streams can contain the hazardous component indicated.
(2)  Pickling liquor - 7% sulfuric acid
     (this would give a pH slightly greater that 0,  and
     less then 1)
(3)  Metal pickling acid soln.

-------
                                    5-15% Hydrochloric Acid
                                   20-30% Sulfuric Acid
 C4)   Steelpickling Acid  solution
                                    4% Sulfuric Acid
                                   96% H20
                                   ph 1
 (51   Acid solution,  Ironworks
                                    5% Inhibited Hydrochloric Acid
                                    Balance H20
 £6}   Pickling Liquor               4-6% HNO3
      Acid Solution                10-12% H3PO4
                                   .5-12% HCI
                                   .5-1% H2 S04    pH = 1
      As is evident from  the  above,  the waste pickling liquor has
a  pH of 2 or below.   Liquid  waste  streams with such acidic
character Present an environmental risk for several reasons.
Very low pH liquid waste if  disposed in a sanitary landfill would
leach high concentrations of toxic heavy metals (such as lead)
from ordinary municipal  trash.  These heavy metals would other-
wise remain bound in the waste matrix.  Highly acidic liquid
wastes also present a handling risk because of their corrosive
properties.  Highly acidic waste streams are also dangerous
because they have been known to initiate potentially dangerous
reactions when combined  with otherwise innocuou waste.

-------
     OSW has in its files many damage incidents resulting from
the mismanagement of highly acidic or caustic wastes.  These
include:  several deaths and many serious illness resulting from
the inhalation of toxic gases formed by the reaction of acidic
wastes with wastes containing sulfide or cyanide salts, con-
tamination and degradation of groundwater and wells from improper
disposal of acidic and caustic wastes, severe burns from handling
and contact with acidic and caustic wastes and several incidents
of fish kills from discharge of acidic and caustic wastes.  (Refer
to corrosivity and reactivity background documents for further
information).
     According to the Analysis performed by Waste Management
Inc.  Spent pickle liquor, contains Cd, Cr, and Pb, in concen-
trations which are several orders of magnitude greater than
drinking water standards.  Since the pH of this waste is very
low (0.6, analogous to a 1 to 0.1 molar solution HN03 or other
strong acid) these heavy metals are mostly in solution and
therefore are available to migrate down through a disposal site
to groundwater.  Chromium and Lead are toxicants listed by
the NIPDWR at a concentration of ,05mg/l because of their
toxicity.  As explained in the RCRA toxicity background document
this converts to a ,5mg/l level in the  EP extract.  Cadmium
is one of the toxicants listed by the NIPDWR at a concentration
of .Olmg/1 because of its toxicity.  As explained in the
RCRA toxicity background document this converts to a .lmg/1
level in the  EP extract.  Since this waste has been shown

-------
to contain Cadmium, Chromium and Lead at a 461, 11460, and
578ppm concentration according to Waste Management Inc., we
feel that this waste stream poses a threat to human health and
the environment.

-------
     The National Interim Primary Drinking Water Regulations (NIPDW



set limits for chemical contamination of Drinking Water.   The sub-



stances listed represent hazards to human health.  In arriving at



these specific limits,  the total environmental exposure of man to a



stated specific toxicant has been considered.   (For a complete



treatment of the data and reasoning used in choosing the substances



and specified limits please refer to the NIPDWR Appendix A-C



Chemical Quality, EPA-6570/9 - 76 - 003) .



     A primary exposure route to the public for toxic contaminents



is through drinking water.  A large percentage of drinking water



finds its source in groundwater.  EPA has evidence to indicate that



industrial wastes as presently managed and disposed often leache



into and contaminate the groundwater.  The Geraghty and Miller



report1 indicated that in 98% of 50 randomly selected on-site



industrial waste disposal sites, toxic heavy metals were found to



be present, and that these heavy metals had migrated from the



disposal sites in 80% of the instances.  Selenium, arsenic and/or



cyanides were found to be present at 74% of the sites and confirmed



to have migrated at 60% of the sites.



     At 52% of the sites toxic inorganics  (such as arsenic, cadmium



etc.) in the groundwater from one or more monitoring wells exceeded



EPA drinking water limits  (even after taking into account the



upstream  (beyond the site) groundwater concentrations).

-------
References





Calspan  Corp.  Assessment of Industrial Hazardous Waste Practices



in  the Metal Smelting & Refining Industry Appendices.  April 1977.



Contract ff  68-01-2604, Vol III pages 6-69, App. page 12, 37.





Enviro Control Inc.  Hazardous Waste Listings Fully Integrated



Steel Mills.  May 1978.  Contract I 68-01-3937, pages 4.25-27,



4.38-40,  App. table A-20, 21.





NUS Corp.   Development Document for Effluent Limitations.



(etc.) Iron and Steel Industries-Hot forming and Cold Finishing



Segment.  July 1974.  Contract # 68-01-1507.





Dravo Corp.  Managing and Disposing of Residues front Environmental.



Control  Facilities in the Steel Industry.  June 1976.  Contract



R-803C19, page 127-133.



     Handbook of Industrial Waste Compositions in California 1978



Storm, D, Dept. of Health Calif, pages 72, 74, 84, 85.

-------
3312  Steel Finishing;  Cyanide-bearing Wastes from Electrolytic
      Coating  (R)
     This waste is classified as hazardous because of its reactive
characteristics.   According to the information EPA has about this
waste stream it meets the RCRA S250.13c characteristic identifying
reactive waste.
     EPA bases this classification on the following,  information:
(1)  The following table summarizes the composition of electro-
plating baths.  Of particular concern in the waste streams are  '
(1) cyanide-bearing wastes which may result from electroplating
of cadmium, copper, brass, and zinc, and (2)  heavy metal content
of wastes, particularly cadmium and mercury.   Certain wastes and
plating solutions would be corrosive as well.  Corrosivity would
be expected to be a problem from the chromium,  copper, and zinc
plating wastes.
                  Composition of Electroplating Baths
                        as Used in Steel Mills
     Electrolytic Coatings               Bath Composition (per
                                          gallon H20)
     Cadmium                             3 oz.  Cadmium Oxide
                                         14.5 oz. Sodium Cyanide
     Copper  (cyanide)                    3 oz.  Copper Cyanide
                                         4.5 oz. Sodium Cyanide
                                         2 oz.  Sodium Carbonate
     Brass                               3.6 oz. Copper Cyanide
                                         1.2 oz. Zinc Cyanide
                                         4 oz.  Sodium Carbonate
     Zinc  (cyanide)                      8 oz.  Zinc Cyanide
                                         3 oz.  Sodium Cyanide
                                         7 oz.  Sodium Hydroxide
                                         1-1/16 oz. Mercuric Salts

-------
                California Manifest Listings



      The  following waste discriptions were taken from  "Handbook

                                a '
of  Industrial Waste Compositions.  These waste discriptions are


typical of  wastes entering the California waste control  system.


These listings  are included  to demonstrate that these  waste streams


can contain the hazardous component indicated.


(2)   Cadmium plating Alkaline solution


          1000  - 2500 ppm cadmium


          1000  - 3000 ppm cyanide


          99% water


          ph 11.5


(3)   Metal  plating, Alkaline tank bottom sediment


          2% sodium cyanide


          1% zinc


          3% copper


          4% sodium bicarbonate


          1% nickel


          89% water


          ph 12


(4)   Zinc Automatic plating, Alkaline solution


          2  oz/gal. zinc


          5  oz/gal. sodium cyanide


          11 oz/gal caustic


          ph 12


     Alkaline solution - Metal refining


          10% Sodium Cyanide


          90% water


          ph 12

-------
     Reactive wastes as defined by Section 250.14 of RCRA pose
a threat to human health and the environment, either through the
physical consequences of their reaction  (i.e., high pressure and/
or heat generation) or through the chemical consequences of their
reaction (i.e., generation of toxic fumes).
     According to Enviro Control, pages 4.25-27, 4.40-44, this
waste stream has been shown to contain cyanides.  Under mildly
acid and/or basic conditions these may solubilize to generate
HCN gas.  HCN gas* is an intensly poisonous gas even when mixed
with air.  High concentration produces tachypnea (causing
increased intake of cyanide); then dyspnea, paralysis, unconscious-
ness, convulsions and respiratory arrest.  Exposure to 150 ppra for
1/2 to 1 hour may endanger life.  Death may result from a few
minutes exposure to 300 ppm.  Average fatal dose: 50 to 60 ing.

-------
References

Calspan Corp.  Assessment of Industrial Hazardous Waste Practices
in  the Metal Smelting and Refining Industry Appendices.  April 1977
Contract  #  68-01-2604.  App. page 12,  37.   Vol  III,  6-69.

Enviro Control Inc.  Hazardous Waste Listings Fully  Integrated
Steel Mills.  May 1978.  Contract f 68-01-3937.  Pages 4.25-27,
4.40-44.

NUS  Corp.   Development Document for Effluent Limitations.   (etc,)
iron and  Steel Industries-Hot Forming and  Cold  Finishing Segment.
July 1974.  Contract # 68-01-1507.

Dravo Corp.  Managing and Disposing of Residues from Environmental,
control Facilities in the Steel Industry.   June 1976.  Contract #
K-803C19.   Page 133-135.

Handbook  of Industrial Waste Compositions  in California  1978
Storm, D, Dept. of Health Calif, pages 77, 85,  86.
                               3V?

-------
3312  Steel Finishing:  Chromates and Bichromates from Chemical
      Treatment, Spent Chromating Solution, Chroma^ Rinse,  (T,C)

     This waste is classified as hazardous because of its toxic
characteristics.  According to the information EPA has about this
waste stream it meets both the RCRA §250.13b and §250.13d charac-
teristics identifying corrosive and toxic wastes.
     EPA bases this classification on the following information:
(1)  Chromating
     Chromating is done to develop a protective amorphous chromic
oxide layer directly on steel.  Chromating solutions are reported
to contain 2 to 35mg/l of hexavalent chromium as chromic acid,
potassium chromate, or potassium dichromate.  Steel is dipped in
or sprayed with this solution.
Spent Chromating Solution
     Wastes from the Chromating process include spent solution
which is classified as hazardous.  If chromic acid is used in
the solution, the waste may be corrosive as well as toxic.
Chromate Rinse
     In order to prevent formation of white rust on galvanized
steel and corrosion of tin-plated or other types of finished
steel, use of a chromate rinse is commonly employed.   There is
both continuous discharge of chromium and occasional total
discharge of the bath.  The untreated wastes contain high con-
centrations of hexavalent chromium as chromic acid, dichromate,
or chromate and would thus be considered toxic.  Depending on
acid concentration, the waste may be corrosive as well.

-------
                 California Manifest Listings

      The following waste descriptions were  taken  from  "Handbook
of  Industrial  Waste  Compositions".  These waste descriptions
are typical of wastes  entering  the California waste  control
system.   These listings are  included to  demonstrate  that these
waste streams  can contain the hazardous  component indicated.
 (1)   Metal Plating Acid Solution ,
           0-5% Sulfuric Acid and Chromic Acid
           Balance:   Water
           pH 1.3
 (2)   Metal Plating Acid Solution
           5% Chromic Acid
           95% Water
           pM 2
(3)   Metal Plating
      Chromium Sludges
           1-5% Chromium  (131) hydroxide
           balance water and  calcium sulfate
           pH 7

      As is indicated by the  above  information  this waste stream
can contain chromium.  Chromium is one of  the  toxicants listed
    the NIPDWR at a  concentration of  .05mg/l because of its toxicity.
    explained in the  RCPA  toxicity  background document  this converts
to  a .5mg/l level in the  EP  extract.

-------
     The National Interim Primary Drinking Water Regulations (NIPDW1



set limits for chemical contamination of drinking Water.   The sub-



stances listed represent hazards to human health.  In arriving at



these specific limits, the total environmental exposure of man to a



stated specific toxicant has been considered.   (For a complete



treatment of the data and reasoning used in choosing the substances



and specified limits please refer to the NIPDWR Appendix A-C



Chemical Quality, EPA-6570/9 - 76 - 003).







     A primary exposure route to the public for toxic contaminants



is through drinking water.  A large percentage of drinking water



finds its source in groundwater.  EPA has evidence to indicate that



industrial wastes as presently managed and disposed often leach



into and contaminate the groundwater.  The Geraghty and Miller



report indicated that in 98% of 50 randomly selected on-site



industrial waste disposal sites, toxic heavy metals were found to



be present, and that these heavy metals had migrated from the



disposal sites in 80% of the instances.  Selenium, arsenic and/or



cyanides were found to be present at 74% of the sites and confirmed



to have migrated at 60% of the sites.







     At 52% of the sites toxic inorganics (such as arsenic, cadmium



etc.) in the groundwater from one or more monitoring wells exceeded



EPA drinking water limits (even after taking into account the



upstream  (beyond the site) groundwater  concentrations).
                         58-2-

-------
      Chromating  solutions using Chromic Acid may make the waste

hazardous  due  to it corrosive properties.  Also, if the pH of

•the solution is  below or equal to 3 the waste is classified as

corrosive.  Liquid waste streams with such acidic character

present an environmental risk for several reasons.  Very low pH


liquid waste if  disposed in a sanitary landfill would leach high
                                                    »•,
concentrations of toxic heavy metals  (such as lead) from ordinary

municipal  trash.  These heavy metals would otherwise remain

bound in the waste maxtrix.  Highly acidic liquid wastes also

present a  handling risk because of their corrosive properties.

Highly acidic  waste streams are also dangerous because they

have been  known  to initiate potentially dangerous reactions when

combined with  otherwise innocuous waste.




      OSW has in  its files many damage incidents resulting from

the mismanagement of highly acidic or caustic wastes.  These

include:  several deaths and many serious illnesses resulting


from the inhalation of toxic gases formed by the reaction of

acidic wastes  with wastes containing sulfide or cyanide salts,

contamination  and degradation of groundwater and wells from

         disposal of acidic and caustic wastes, severe burns


      handling  and contact with acidic and caustic wastes and

several incidents of fish kills from discharge of acidic and

caustic wastes.   (Refer to corrosivity and reactivity background

Documents  for  further  information).

-------
References

(1)  Calspan Corp.  Assessment of Industrial Hazardous Waste
     Practices in the Metal Smelting S Refining Industry
     Appendices.  April 1977.  Contract # 68-01-26.04 Vol III
     6-69, App. page 12, 37.

(2)  Enviro Control Inc.  Hazardous Waste Listings Fully
     Integrated Steel Mills.  May 1978.  Contract # 68-01-3937.
     Page 4.25-27, 4.44-45.

(3)  NUS Corp.  Development Document for Effluent Limitations
     (etc.) Iron and Steel Industries-Hot Forming and Cold
     Finishing Segment.  July 1974.  Contract # 68-01-1507.

(4)  Handbook of Industrial Waste Compositions in California
     1978.  Storm, D, Dept. of Health California.  Pages 72, 85,

-------
33J1    Pr i mary Copper,  £/«c^Wc -furnace S let j
      This  waste  is  classified  as hazardous  because of  its toxic
characteristics.  According  to the  information EPA has about the
waste stream it  meets  the  RCRA S250.13d  characteristic identifying
toxic wastes.

      EPA bases this classification  on  the following  information.
Calspan Corp.  has tested a sample of  6/actvTc FMr*ci*e  S/*»*
and  found  the following:
                             Dist. H20                  Waste
                             Leachate                   Sample
contaminant                 Cone,   ppm                Analysis  ppm
      Zn                        3.0
      cd                       0. /5"                     ^ S
      Cr                       0.03-
      Cu                       <
      Mn                       (
      Pb                       fe                       3.50
      Sb                     ^>tf.X                   */<*0
      s*                       O-I3                      10
      Ni                      <
      ph
      A*                     °

-------
     According  to the solubility test performed by Calspan Corp.


the leachate  derived from E/-*
-------
      The National  Interim Primary Drinking Water Regulations  (NIPDWR)



set limits for chemical  contamination of Drinking Water.  The  sub-



stances listed represent hazards to human health.  In arriving at



these specific limits, the  total environmental exposure of man to a



stated specific toxicant has been considered.  (For a complete



treatment of the data and reasoning used in choosing the  substances



and specified limits  please refer to the NIPDWR Appendix  A-C



Chemical Quality,  EPA-6570/9 -  76 - 003) .







      A primary exposure  route  to the public for toxic contaminants



.is  through drinking water.  A  large percentage of drinking water



finds its source in groundwater.  EPA has evidence to indicate that



industrial wastes  as  presently managed  and disposed often leach



into and contaminate  the groundwater.   The Geraghty and Miller



report, indicated that in 98% of 50 randomly selected on-site



industrial waste disposal sites, toxic  heavy metals were  found to



    present, and that  these  heavy metals had migrated from the



          sites in  80% of the instances.  Selenium, arsenic and/or



cyanides were found to be present at 74% of the sites and confirmed



to  have migrated at 60%  of  the sites.







      At 52% of the sites toxic inorganics  (such as arsenic, cadmium



etc.) in the groundwater from  one or more monitoring wells exceeded



EPA drinking water limits  (even after taking into account the



  stream (beyond the  site)  groundwater  concentrations) .

-------
References

Calspan Corp.  Assessment of Industrial Hazardous Waste Practices
in the Metal Smelting & Refining Industry Appendices.  April 1977.
Contract # 68-01-2604, Vol II'  page  H - V3y   App. page 2, 32.

Battelle.  Cross Media Impact of the Disposal of Hazardous Waste
from Metals.  Inorganic Chemicals and Related Industries.
Vol I, page 20-45, Vol III, page   3-/£   Contract f 68-01-2552.

-------
33*1    Primary Copper,  C«Mt/-e*^«^ OiSf/                  (T)
      This waste is classified as hazardous because  of  its  toxic
characteristics.  According to the information EPA  has about  the
waste stream it meets the RCRA S250.13d characteristic identifying
toxic wastes.

      EPA bases this classification on  the  following information.
Calspan Corp. has tested a sample of  C O*. \str+-*r O*A*?'
and found the following:
                            Dist. H20                  Waste
                            Leachate                   Sample
Contaminant                 Cone.  ppm                Analysis  ppn*
      Zn                       *ljooQ
      Cd                       I"7O
      Cr                       0.1                     *<>
      Cu                       11,000
      Mn                        33
      Pb                        S.3
      sb       .                 a. o
      s<                     < 0*oS                    30
      Ni                        fs                      no
      ph                        3.1
      Hy                    O.
       $                    3«

-------
       According to the solubility tost performed by  Calspan Corp.
 the  leachate derived from Con */« r~f-fft, fosf contains Cd

 in concentration^ which are orders of magnitude greater than
                                              J /Jrs^M'c AK^
 drinking water standards.  Lead ck r«Mn/*f  /* "  toxicants listed

 by  the  NIPDWR at a concentration of . Q5mg/l because of its

 toxicity.  As explained in the RCRA toxicity background docu
 this converts  to a .5mg/l level in the EP extract.  Cadmium is

• one of the toxicants listed by the NIPDWR at a concentration of

 .Olmg/1 because  of its toxicity.   As explained in the RCRA

 toxicity background document this converts to a .lmg/1 level £tt

 the EP extract.!                             ^CKCt/ry      is
                                                      r-
• one of the toxicants listed by the NIPDWR at  a concentration of

,OOZmg/l because  of its toxicity.   As  explained in the RCRa.

 toxicity background document this converts to a.Ojmg/l level in,

 the EP extract.



      Since the water extract of the waste has been shown to
  /H-e *e«/ry, ^' *•»*«• C,  Ck
-------
      The National Interim Primary Drinking Water Regulations  (NIPDWR)



 set limits for chemical contamination of Drinking Water.   The sub-



 stances listed represent hazards to human health.  In arriving at



 these specific limits,  the total environmental exposure of man to a



 stated specific toxicant has been considered.  (For a complete



 treatment of the data and reasoning used in choosing the  substances



 and specified limits please refer to the NIPDWR Appendix  A-C



 Chemical Quality, EPA-6570/9 -  76 - 003).







      A primary exposure route to the public for toxic contaminetnts



.is through drinking water. A large percentage of drinking water



 finds its source in groundwater.  EPA has evidence to indicate that



 industrial wastes as presently  managed  and disposed often leach



J.nto and contaminate the groundwater.   The Geraghty and Miller
        indicated that in 98%  of  50  randomly selected  on-site



industrial waste disposal sites,  toxic heavy metals were found to



be present, and that these heavy metals had migrated  from the



Disposal sites in 80% of the  instances.  Selenium, arsenic and/or



cyanides were found to be present at  74% of the sites and confirmed



to have migrated at 60% of the sites.







      At 52% of the sites toxic inorganics  (such as arsenic,  cadmium



     ) in the groundwater from one or  more  monitoring  wells exceeded



     drinking water limits (even  after taking into account the



rrostream (beyond the site)  groundwater concentrations) .

-------
References

Calspan Corp.  Assessment of  Industrial Hazardous Waste Practices
in the Metal Smelting & Refining  Industry Appendices.  April 1977.
Contract f 68-01-2604, Vol II' page  «/ - *3,   App. page 2,
Battelle.  Cross Media Impact of the Disposal of Hazardous Waste
from Metals.  Inorganic Chemicals and Related Industries.
Vol 1, page 20-45 , Vol III, page   3-/£   Contract I 68-01-2552.

-------
33^1    Primary  Copper,  A"Ct'e/  Pt^^'f  $ I v*rp •*.                (T)

      This  waste  is  classified as  hazardous  because of its toxic
characteristics.  According  to  the  information  EPA has about the
waste stream it  meets  the  RCRA  S250.13d characteristic identifying
toxic wastes.

      EPA bases this classification  on the following information.
Calspan Corp. has tested a sample of ^c.*W  fl^vCf S/v*/f~*.
and found  the following:

                             Dist. H20                 Waste
                             Leachate                  Sample
Contaminant                 Cone.  ppm                 Analysis  ppm
      Zn
      Cd
      Cr
      Cu
      Mn                      hO"
      Pb                     7,$
      sb                    < 0.03.                  <2o° — ' *-*"*
      S«                      -                     V^  -
      Ni                    C
      ph

     •"3
      /V5                  0

-------
     According  to  the solubility test performed by Calspan Corp.

the leachate derived from Aci«  rJ«*vf S/c«£«  contains Cd^'J*  Pb>,

in concentration* which are orders of magnitude greater than
                                 £hf»wl'*">1 >*••»•' **•$«* ifc  «fr««.
drinking water  standards.   Lead c              toxicants listed

by the NIPDWR at a concentration of ,05mg/l because of its

toxicity.  As explained in the RCRA toxicity background document

this converts to a . 5mg/l  level in the EP extract. . Cadaium is

one of the toxicants listed by the NIPDWR at a concentration of

.Olmg/1 because of its toxicity.  As explained in the RCRA.

toxicity background document this converts to a .lmg/1 level in

the EP extract.



     Since the water extract of the waste has been shown to
       *r/*i»«y, Clir»*i«/«••,    O.fyfj O'5
contain-cadmiutn and lead at a/i  J.y and£9ppm concentration, the

heavy metals are not fixed in the solid matrix.  They are there-

fore available to  migrate  down through a disposal site to

groundwater.  Thus,  we feel that this waste stream poses a threat

to human health and the environment.

-------
      The National Interim Primary  Drinking Water  Regulations  (NIPDWR)

 set limits for chemical contamination of  Drinking Water.  The sub-

 stances listed represent hazards  to human health.   In arriving at

 these specific limits,  the total  environmental  exposure of man to a

 stated specific toxicant has  been  considered.   (For a complete

 treatment of the data and reasoning used  in  choosing the substances
           »',
 and specified limits please refer  to the  NIPDWR Appendix A-C

 Chemical'Quality, EPA-6570/9  -  76  - 003).



      A primary exposure route to  the public  for toxic contaminants

 is  through drinking water.  A large percentage  of drinking water

 finds its source in groundwater.   EPA has evidence  to indicate that

 industrial wastes as presently  managed and disposed often leach

 into and contaminate the groundwater.   The Geraghty and Miller

 report indicated that in 98%  of 50 randomly  selected on-site

 industrial waste disposal sites,  toxic heavy metals were found to

 be  present, and that these heavy  metals had  migrated from the

 disposal sites .in 80% of the  instances.  Selenium,  arsenic and/or

 cyanides were found to be present  at 74%  of  the sites and confirmed

 to  have migrated at 60% of the  sites.



      At 52% of the sites toxic  inorganics (such as  arsenic, cadmium

 etc-)  in *-^e groundwater from one  or more monitoring wells exceeded

EPA drinking water limits (even after taking into account the

upstream (beyond the site)  groundwater concentrations).

-------
References

Calspan Corp.  Assessment of Industrial Hazardous Waste Practices
in the Metal Smelting & Refining Industry Appendices.  April 1577.
Contract f 68-01-2604, Vol IT  page «/ - f/3,   App. page 2, 32.

Battelle.  Cross Media Impact of the Disposal of Hazardous Waste
from Metals.  Inorganic Chemicals and Related Industries.
Vol I, page 20-45, Vol III, page   3-/£   Contract f 68-01-2552.

-------
33$1    Primary Copper,  R« Mr bit or*  O^sT                   (T)
      This  waste  is classified as hazardous because of its toxic
characteristics.   According to the information EPA has about the
waste stream it  meets the RCRA S250.13d characteristic identifying
•toxic wastes.

      EPA bases this classification on the following information.
Calspan Corp.  has tested a sample of H•««/•• r b«*w*/ O^^'f
and  found  the following:
                             Dist.' H20                 Waste
                             Leachate                  Sample
Contaminant                 Cone.  ppm                Analysis  ppm
      Zn                         -
      cd                        no                       3to
      Cr                        0.1                        yj-
      Cu                      lljOOO                   -mOjOOO
      Mn                        IS"                       IOO
      Pb-                        7. 3                      \L OOO
      Sb       .               < *'2-                      *75*0
      Se                      <*-.*?                        f0
      Ni                        OL .5"                        35-
      .                        Al •»
      ph                        " • i.
     As                        o.i                           -
                             0.00$                        -> r-

-------
     According to the solubility test performed by Calspan Corp.


the leachate derived from r • v«r b«ett>/^ dusfr  contains Cd and Pb-

                3
in concentration, which are orders of magnitude greater than
                A •

drinking water standards.  Lead is one of the toxicants listed


by the NIPDWR at a concentration of .05mg/l because of its


toxicity.  As explained in the RCRA toxicity background document


this converts to a .5mg/l level in the EP extract.  Cadmium is


one of the toxicants listed by the NIPDWR at a concentration of


.Olmg/1 because of its toxicity.   As explained in the RCRA


toxicity background document this converts to a .lrag/1 level in


the EP extract.




     Since the water extract of the waste has been shown to


contain cadmium and lead at a a.30 and?.3ppra concentration,., the.


heavy metals are not fixed in the solid matrix.  They are there-


fore available to migrate down through a disposal site to


groundwater.  Thus, we feel that this waste stream poses a threat


to human health and the environment.

-------
      The National Interim Primary Drinking Water  Regulations  (NIPDWR)



 set limits for chemical contamination of Drinking Water.  The sub-



 stances listed represent hazards to human health.   In arriving at



 these specific limits,  the total environmental  exposure of man to a



 stated specific toxicant has been considered.   (For a complete



 treatment of the data and reasoning used in  choosing the  substances



 and specified limits please refer to the NIPDWR Appendix  A-C



 Chemical Quality, EPA-6570/9 - 76 - 003).







      A primary exposure route to the public  for toxic contaminonts



 is through drinking water.  A large percentage  of drinking water



 finds its source in groundwater.  EPA has evidence  to indicate that



 industrial wastes as presently managed and disposed often leach



 into and contaminate the groundwater.   The Geraghty and Miller



 report indicated that in 98% of 50 randomly  selected on-site



 industrial waste disposal sites, toxic heavy metals were  found to



 be present, and that these heavy metals had  migrated from the



 disposal sites in 80% of the instances.   Selenium,  arsenic and/or



 cyanides were found to be present at 74% of  the sites and confirmed



    have migrated at 60% of the sites.
      At 52% of the sites toxic inorganics  (such as arsenic, cadmium



etc.) in the groundwater from one or  more  monitoring wells exceeded



EPA drinking water limits (even after taking into account the



upstream (beyond the site)  groundwater concentrations) .

-------
References

Ca1span Corp.  Assessment of  Industrial Hazardous Waste Practices
in the Metal Smelting & Refining  Industry Appendices.  April  1977,
Contract § 68-01-2604, Vol II' page  «/ - 

-------
3332  Primary Lead, Blast Furnace Dust  (T)



     This waste is classified as hazardous because of its toxic

characteristics.  According to the information EPA has about

this waste stream it meets the RCRA S250.13d characteristic

identifying toxic wastes.



     EPA bases this classification on the following information-

 ;".' Calspan Corp. has tested a sample of Blast Furnace Dust and

found the following:
Contaminent

     As

     Cd

     Cr

     Cu

     Hg

     Mn

     Ni

     Pb

     Sb.

     Zn

     Se

     ph
Dist. H20
Leachate
Cone,  ppm

  0.177

  8.0

 <0.01

   130

 <0.02

  0.25

  0.09

  7.3

 <0.2

    45

 <0.05

  8.8
Waste
Sample
Analysis  ppm
  14,000

     10

   5,350
  148,000
   82,000

-------
     According to the Solubility test performed by Calspan Corp.
the leachate derived from Blast Furnace Dust contains Cd and Pb
in concentrations which are orders of magnitude greater than
drinking water standards.

     Lead is one of the toxicants listed by the N I.P-.D :v :R  at
a concentration of ,05mg/l because of its toxicity.   As explained
in the RCRA toxicity background document this converts to a
.5mg/l level in the  SP extract.

     Cadmium is one of the toxicants listed by the N I p D W R
at a concentration of .Olmg/1 because of its toxicity.  As
explained in the RCRA toxicity background document this converts
to a .lmg/1 level in the  EP extract.

     Since the water extract of the waste has been shown to
contain Cadmium and Lead at a 8 and 7.3 ppm concentration, the
heavy metals are not fixed in the Solid iriatrix.  They are there-
fore available to migrate down through a disposal site to ground-
water.  Thus we feel that this waste stream poses a threat to
human health and the environment.

-------
      The National Interim Primary  Drinking Water  Regulations  (NIPDWR)

 set limits for chemical  contamination  of  Drinking Water.   The sub-

 stances listed represent hazards  to human health.   In  arriving at

 these specific limits, the total  environmental  exposure of man to a

 stated specific toxicant has  been considered.   (For a  complete

 treatment of the data and reasoning used  in  choosing the substances
                                *•.
 and specified limits please refer to the  NIPDWR Appendix A-C

 Chemical Quality, EPA-6570/9  -' 76  - 003) .




      A primary exposure  route to  the public  for toxic  contaminants

 is through drinking water.  A large percentage  of drinking water

 finds its source in groundwater.   EPA  has evidence to  indicate that

 industrial wastes as presently managed and disposed often leache

 into and contaminate the groundwater.   The Geraghty and Miller
       1
 report indicated that in 98%  of 50  randomly  selected on-site

 industrial waste disposal sites,  toxic heavy metals  were  found to

be present,  and that these heavy metals had  migrated from the

 disposal sites in 80% of the  instances.   Selenium,  arsenic and/or

 cyanides were found to be present  at 74%  of  the sites  and confirmed

 to have migrated at 60%  of the sites.




      At 52% of the sites.toxic inorganics (such as  arsenic, cadmium

 etc.)  in the groundwater from one  or more monitoring wells exceeded

EPA drinking water limits (even after  taking into account the

upstream (beyond the site)  groundwater concentrations).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste Practices



in the Metal Smelting and Refining Industry Appendices.  April 1977,



Contract # 68-01-2604 V  . :.  ..::.  .      Vol II pages 44-64.



App. page 3, 32.







Battelle.  Cross Media Impact of the Disposal of Hazardous



Waste from Metals.  Inorganic Chemicals and Related Industries.



Vol. I pages 20-45, Vol III pages 12-17.  Contract # 68-03-2552.

-------
3332   Primary Lead, Lagoon Dredgings (Smelter)  (T)

      This  waste  is classified as hazardous because of its toxic
characteristics.  According to the information EPA has about
this  waste stream it meets the RCRA S250.13d  characteristic
identifying toxic wastes.

      EPA bases this classification on the following information»
    Calspan Corp. has tested a sample of Lagoon Dredging (Smelter)
and found  the following:
Contaminent
     As
     Cd
     Cr
     Cu
     Mg
     Mn
     Ni
     Pb
     Sb
     Zn
     Se
     ph
Dist. H20
Leachate
Cone,  ppm
  0.231
    11
< 0.01
  0.53
< 0.02
    27
  0.08
  4.5
< 0.2
  9.5
< 0.05
  6.7
Waste
Sample
Analysis  ppm
  640 - 700
   28 - 60
  1490 - 6200
  115,000 - 140,000
  80,00 - 132,000

-------
     According to the Solubility test performed by Calspan Corp.

the leachate derived from Lagoon Dredging (Smelter)  contains Cd

and Pb in concentrations which are orders of magnitude greater

than drinking water standards.



     Lead is one of the toxicants listed by the N I'P.D W R  at

a concentration of .05mg/l because of its toxicity.   As explained

in the RCRA toxicity background document this converts to a

.5mg/l level in the  :EP extract.



     Cadmium is one of the toxicants listed by the N I p D W R

at a concentration of .01 mg/1 because of its toxicity.  As

explained in the RCRA toxicity background document this converts

to a .lmg/1 level in the  EP extract.



     Since the water extract of the waste has been shown to

contain cadmium and lead at a 11 and 4.5ppm concentration, the
                                        r
heavy metals are not fixed in the Solid matrix.  They are there-

fore available to migrate down through a disposal site to ground-

water.  Thus we feel that this waste stream poses a threat to

human health and the environment.

-------
     The National Interim Primary Drinking Water Regulations (NIPDWR)


set  limits  for chemical contamination of Drinking Water.  The sub-


stances listed represent hazards to human health.  In arriving at


these  specific limits, the total environmental exposure of man to a


stated specific  toxicant has been considered.  (For a complete


treatment of  the data and reasoning used in choosing the substances


and  specified limits please refer to the NIPDWR Appendix A-C


Chemical Quality, EPA-6570/9 - 76 - 003).




     A primary exposure route to the public for toxic contaminents


is through  drinking water.  A large percentage of drinking water


finds  its source in groundwater.  EPA has evidence to indicate that


industrial  wastes as presently managed  and disposed often leache


into and contaminate the groundwater.   The Geraghty and Miller
       1
report indicated that in 98% of 50 randomly selected on-site


industrial  waste disposal sites, toxic  heavy metals were found to


be present, and  that these heavy metals had migrated from the


disposal  sites in 80% of the instances. Selenium, arsenic and/or

cyanides were found  to be present at 74% of the sites and confirmed


to have migrated at  60% of the sites.




     At  52% of the sites toxic inorganics  (such as arsenic, cadmium


     )  in  tne groundwater from one or more monitoring wells exceeded


     drinking water  limits  (even after taking into account the


 pStream  (beyond the site) groundwater  concentrations).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste Practices



in the Metal Smelting and Refining Industry Appendices.  April 1977,



Contract # 68-01-2604, ". :.    ::.:.  ..:;;:. Vol II, pages 44-64.



App. pages 3, 32.







Battelle.  Cross Media Impact of the Disposal of Hazardous Waste



from Metals.  Inorganic Chemicals and Related Industries.



Vol I, pages 20-45.  Vol III, pages 12-17.  Contract # 68-03-2552.

-------
 3333   Primary  Zinc  Smelting and Refining:  Gypsum Cake  (C,T)

      This  waste  is  classified as hazardous because of its corro-
 sive  and toxic characteristics.  According to the information EPA
 has about  this waste stream it meets both the RCRA §250.13(b)
 and §250.13(d) characteristics identifying corrosive and toxic
 wastes.
      According to analyses performed by Calspan, Inc. the
 water extract of gypsum cake  (acid cooling tower) has a pH of
 1.4.   This data  can be found in Calspan Report No. ND-5520-M-1,
 Assessment of  Industrial Hazardous Waste Practices in the Metal
 Smelting and Refining Industry, Appendices, page 32.
      Waste streams  with such acidic character present an environ-
 mental risk for  several reasons.  Very low pH wastes if disposed
 in a  sanitary  landfill when contacted with rainwater, would leach
 high  concentrations of toxic heavy metals  (such as lead) from
 ordinary municipal  trash.  These heavy metals would otherwise
 remain bound in  the waste matrix.  Highly acidic wastes also
present  a  handling  risk because of their corrosive properties.
Highly acidic wastes streams are also dangerous because they have
been  know  to initiate potentially dangerous reactions when
combined with otherwise innocous wastes.

-------
     OSW has in its files many damage incidents resulting from
the mismanagement of highly acidic or caustic wastes.   These
include: several deaths and many serious illnesses resulting
                                                         oF
from the inhalation of toxic gases formed by the reaction^acidic
wastes with wastes containing sulfide el"cyanide salts,  contami-
nation and degradation of groundwater and wells from improper
disposal of acidic and caustic wastes, severe berns from handling
and contact with acidic and caustic wastes,  and several incidents
of fish kills from discharge of acidic and caustic wastes.  (Refer
to corrosivity and reactivity background documents for further
information).

-------
      The National  Interim Primary  Drinking Water  Regulations



 (NIPDWR)  set limits  for  chemical contamination of drinking water.



 The substances  listed  represent hazards to human  health.  In



 arriving at  these  specific  limits, the total environmental



 exposure of  man to a stated specific toxicant has been considered.



 (For a complete treatment of the data and reasoning used  in choosing



 the substances  and specified limits please refer  to the NIPDWR



 Appendix A-C Chemical  Quality/ EPA-6570/9 - 76 -  003).



      A primary  exposure  route to the public for toxic contami-



 nants is through drinking water.   A large percentage of drinking



 water finds  its source in groundwater.  EPA has evidence  to



 indicate that industrial waste as  presently managed and disposed



 often leaches into and contaminates the groundwater.  The Geraghty



 and Miller report  indicated that  in 98% of 50 randomly selected



 on-site industrial waste disposal  sites, toxic heavy metals were



 found to be  present, and that these heavy metals  had migrated



 from the disposal  sites  in  80% of  the instances.  Selenium, arsenic



 and/or cyanides were found  to be present at 74% of the sites and



 confirmed to have  migrated  at 60%  of the sites.



      At 52%  of  the sites toxic inorganics  (such as arsenic, cadmium,



 etc.)  in the groundwater from one  or more monitoring wells



 exceeded EPA drinking water limits  (even after taking into



 account the  upstream (beyond the site) groundwater concentrations).



      Cadmium, chromium,  and lead are three of the toxicants listed



by  the NIPDWR at concentrations of 0.01 mg/1, 0.05 mg/1,  and



 0.05 mg/1, respectively, because of their toxicity.  As explained in



 the RCRA toxicity  background document these concentrations convert

-------
to 0.1 mg/1, 0.5 mg/1, and 0.5 mg/1 levels respectively, in the

EP extract.

     This waste has been shown to contain cadmium, chromium, and

lead at the following concentrations according to Calspan

Report No. ND-5520-M-1, Assessment of Industrial Hazardous

Waste Practices in the Metal Smelting and Refining Industry,

Appendices, page 4:


                              Contaminant Concentration  (ppm)
     Material Analysed	Cd	Cr	Pb	


     Gypsum Cake                <10      10     98
       (Neutral Cooling
     	Tower)	


     Gypsum Cake                <10        9   1,750
       (Acid Cooling
         Tower)	_____


     Gypsum Cake                550       11   18,100
       (Land Dump)	


     Since the water extract of the waste has been shown to

contain cadmium, chromium, and lead at the concentrations  listed

below, according to the same report, page 32, we feel  that

this waste  stream  poses a  threat to human health and  the environ-

ment.


     Gypsum Cake Leachate         24      0.04      2.1
       (Neutral  Cooling
          Tower)	


     Gypsum Cake Leachate          11      0.67     1.0
       (Acid Cooling
        Tower)	

-------
 3333   Primary Zinc  Smelting and Refining:  Acid Plant Sludge  (T)





      This  waste  is  classified as hazardous because of its toxic



 characteristics.  According to the  information EPA has about  this



 waste stream it  meets  the  RCRA §250.13(d) characteristic identi-



 fying toxic waste.



      The National Interim  Primary Drinking Water Regulations



 (NIPDWR) set limits for  chemical contamination of drinking water.



 The substances listed  represent hazards  to human health.  In  arriving



 at  these specific limits,  the total environmental exposure of



 man to a stated  specific toxicant has been considered.   (For  a



 complete treatment  of  the  data and  reasoning  used in choosing



 the substances and  specified limits please refer to the



 NIPDWR Appendix  A-C Chemical Quality, EPA-6570/9 - 76 -  003).



      A primary exposure  route to the public for toxic



 contaminants is  through  drinking water.  A large percentage of



 drinking water finds its source in  groundwater.  EPA has evidence



 to  indicate that industrial waste as presently managed and disposed



 often leaches into  and contaminates the  groundwater.  The Geraghty



 and Miller report1  indicated that in 98% of 50 randomly  selected



 on-site industrial  waste disposal sites, toxic heavy metals were



 found to be present, and that these heavy metals had migrated



 from the disposal sites  in 80% of the instances.  Selenium,



arsenic and/or cyanides  were found  to be present at 74%  of the



 sites and  confirmed to have migrated at  60% of the sites.



      At 52% of the  sites toxic inorganics  (such as arsenic, cadmium,



etc.)  i° the groundwater from one or more monitoring wells



exceeded  EPA drinking water limits (even after taking into

-------
account the upstream  (beyond the site) groundwater concentrations) .



     Lead is one of the toxicants listed by the NIPDWR



at a concentration of 0.05 mg/1 because of its toxicity.  As



explained in the RCRA toxicity background document this converts



to a 0.5 mg/1 level in the EP extract.



     This waste has been shown to contain lead at a 4,350 ppm



concentration according Calspan Report No. ND-5520-M-1, Assessment



of Industrial Hazardous Waste Practices in the Metal Smelting



and Refining Industry,  Appendices, page 4.



     Since the water extract of the waste has been shown to contain



lead at a 1.3 mg/1 concentration/ according to the same report,



page 32, we feel that this waste stream poses a threat to human



health and the environment.

-------
3333  Primary Zinc Smelting and Refining:  Anode Sludge (C,T)

     This waste is classified as hazardous because of its corro-
sive and toxic characteristics.  According to the information
EPA has about this waste stream it meets both the RCRA §250.13(b)
and §250.13(d) characteristics identifying corrosive and toxic
wastes.
     According to analyses performed by Calspan, Inc., the
water extract of anode sludge has a pH of 2.5.  This data can be
found in Calspan Report No. ND-5520-M-1, Assessment of Industrial
Hazardous Waste Practices in the Metal Smelting and Refining
Industry,  Appendices, page 32.
     Waste streams with such acidic character present an environ-
mental risk  for several reasons.  Very low pH wastes if disposed
in a sanitary landfill when contacted with rainwater would  leach
high concentrations of toxic heavy metals  (such as lead) from
ordinary municipal trash.  These heavy metals would otherwise
remain bound in the waste matrix.  Highly acidic wastes also
present  a handling risk because of their corrosive properties.
Highly acidic waste streams are also dangerous because they have
been known to initiate potentially dangerous reactions when
combined with otherwise innocuous wastes.

-------
     OSW has in its files many damage incidents resulting from


the mismanagement of highly acidic or caustic wastes.  These


include: several deaths and many serious illnesses resulting

                                                         of
from the inhalation of toxic gases formed by the reaction.acidic


wastes with wastes containing sulfide Of cyanide salts, contami-


nation and degradation of groundwater and wells from improper


disposal of acidic and caustic wastes, severe bMrns from handling


and contact with acidic and caustic wastes, and several incidents


of fish kills from discharge of acidic and caustic wastes.   (Refer


to corrosivity and reactivity background documents for further


information).

-------
     The National Interim Primary Drinking Water. Regulations



 (NIPDWR) set limits for chemical contamination of drinking water.



The substances listed represent hazards to human health.  In



arriving at these specific limits, the total environmental exposure



of man  to a stated specific toxicant has been considered.  (For a



complete treatment of the data and reasoning used in choosing the



substances and specified limits please refer to the NIPDWR



Appendix A-C Chemical Quality, EPA-6570/9 - 76 - 003).



     A  primary exposure route to the public for toxic contaminants



is through drinking water.  A large percentage of drinking water



finds its source in groundwater.  EPA has evidence to indicate



that industrial waste as presently managed and disposed often



leaches into and contaminates the groundwater.  The Geraghty



and Miller report  indicated that in 98% of 50 randomly selected



on-site industrial waste disposal sites, toxic heavy metals were



found to be present, and that these heavy metals had migrated



from the disposal sites in 80% of the instances.  Selenium,



arsenic and/or cyanides were found to be present at 74% of



the sites and confirmed to have migrated at 60% of the sites.



     At 52% of the sites toxic inorganics  (such as arsenic, cadmium,



etc.) in the groundwater from one or more monitoring wells exceeded



EPA drinking water limits  (even after taking into account



the upstream  (beyond the site) groundwater concentrations).



     Cadmium, chromium, and lead are three of the toxicants listed



by the  NIPDWR at concentrations of 0.01 mg/1, 0.05 mg/1, and



0.05 mg/1, respectively, because of their toxicity.  As explained



in the  RCRA toxicity background document these concentrations



convert to 0.1 mg/1, 0.5 mg/1, and 0.5 mg/1 respectively, in the EP

-------
extract.
     This waste has been shown to contain cadmium, chromium,
and lead at the following concentrations according to Calspan
Report No. ND-5520-M-1, Assessment of Industrial Hazardous Waste
Waste Practices in the Metal Smelting and Refining Industry,
Appendices, page 4:

                             Contaminant Concentration (ppm)
Material Analysed
Fresh Anode Sludge
Old Anode Sludge
Cd
12
1,400
Cr
10
8
Pb
170,000
87,000
 (from dump)

     Since the water extract of the waste has been shown to
 contain cadmium, chromium, and lead, at concentrations of
 12 ppm, 0.05 ppm, and 2.0 ppm respectively, according to the
 same report, page 32, we feel that this waste stream poses a
 threat to human health and the environment.

-------
3339  Primary Tungsten, Digestion Residue  (T)



     This waste is classified as hazardous because of its

toxic characteristics.  According to the information EPA has

about this waste stream it meets the RCRA S250,13d characteristic

identifying toxic wastes.



     EPA bases this classification on the following information;

" ;.  Calspan Corp. has tested a sample of Digestion Residue and

found the following:
Contaminent

     As

     Cd

     Cr

     Cu

     Hg

     Mn

     Ni

     Pb

     Sb

     Zn

     Se

     ph
 Dist. H20
 Leachate
 Cone.  ppm

< 0.003

  0.15

  0.05

    90

< 0.02

    75

    60

  0.7

< 0.2

  1.5

 <0.05

  6.4
Waste
Sample
Analysis  ppm
 38,000
    90

  < 10

   850

-------
     According to the solubility test performed by Calspan



Corp. the leachate derived from Digestion Residue contains



Cd and Pb in concentrations which are orders of magnitude



greater than drinking water standards.







     Lead is one of the toxicants listed by the N I p D W R



at a concentration of .05mg/l because of its toxicity.  As



explained in the RCRA toxicity background document this converts



to a .5mg/l level in the  EP extract.







     Cadmium is one of the toxicants listed by the N I P D W R.



at a concentration of .Otmg/l because of its toxicity.  As



explained in the RCRA toxicity background document this converts



to a .lmg/1 level in the  EP extract.







     Since the water extract of the waste has been shown to



contain Cadmium and lead at a 0.15 and 0.7ppm concentration,



the heavy metals are not fixed in the Solid /Matrix.  They are



therefore available to migrate down through a disposal site to



groundwater.  Thus we feel that this waste stream poses a threat



to human health and the environment.

-------
     The National Interim Primary Drinking Water Regulations  (NIPDWR)


set limits for chemical contamination of Drinking Water.  The sub-


stances listed represent hazards to human health.  In arriving at


these specific limits, the total environmental exposure of man to a


stated specific toxicant has been considered.  (For a complete


treatment of the data and reasoning used in choosing the substances

and specified limits please refer to the NIPDWR Appendix A-C

Chemical Quality, EPA-6570/9 - 76 - 003).




     A primary exposure route to the public for toxic contaminents


is through drinking water.  A large percentage of drinking water

finds its source in groundwater.  EPA has evidence to indicate that


industrial wastes as presently managed and disposed often leache


into and contaminate the groundwater.  The Geraghty and Miller
      1
report indicated that in 98% of 50 randomly selected on-site


industrial waste disposal sites, toxic heavy metals were found to


i>e present, and that these heavy metals had migrated from the


disposal sites in 80% of the instances.  Selenium, arsenic and/or


cyanides were found to be present at 74% of the sites and confirmed


to have migrated at 60% of the sites.




     At  52% of the sites toxic inorganics  (such as arsenic, cadmium


etc.) in the groundwater from one or more monitoring wells exceeded

EPA drinking water limits  (even after taking into account the


upstream  (beyond the  site) groundwater  concentrations).

-------
References



Calspan Corp.  Assessment of Industrial Hazardous Waste Practices

in the Metal Smelting and Refining Industry Appendices.  April 1977

Contract f 68-01-2604 '  "          '::.  Vol II 178-193.   App.  pages

8, 32.
     i-_


Battelle.  Cross Media Impact of the Disposal of Hazardous Waste

from Metals.  Inorganic Chemicals and Related Industries.

Vol I, page 20-45.  Vol III, page 53-58.  Contract # 68-01-2552.

-------
 3332  Primary Lead, S',n+*r
      This waste is classified as hazardous because of its toxic

 characteristics.  According to the information EPA has about

.this waste stream it meets the RCRA S250.13d characteristic

 identifying toxic wastes.
      EPA bases this classification on the following information-

  ' '  Calspan Corp. has tested a sample of S i* *»**€*" •$<"-<•* 4i«

found the following:
Contaminant

      As

      Cd

      Cr

      Cu

      Hg

      Mn

      Mi

      Pb

      Sb

      Zn

      Se

      ph
Dist. H2O
Leachate
Cone.  ppm
 < 0.01

    *. 6

 <0.02

  J..3

 < 0.05

  s.r

 <0.2

    7.5

  CLL7

  b.8
waste
Sample
Analysis
   100

     11
      0-1
   05,600

-------
     According to the solubility test performed by Calspan Corp.



the leachate derived from  SfnTer Sc r nhber S^^contains Cd and Pb


                s
in concentration which are orders of magnitude greater -than
                A


drinking water standards.  Lead is one of the toxicants listed



by the NIPDWR at a concentration of .05mg/l  because of its



toxicity.  As explained in the RCRA toxicity background document



this converts to a .5mg/l level in the EP extract.   Cadmium is



one of the toxicants .listed by the NIPDWR at a concentration of



.Olmg/1 because of its toxicity.  As explained in  the RCRA



toxicity background document this converts to a .lmg/1 level in



the EP extract.







     Since the water extract of the waste has been shown to



contain cadmium and lead at a 9. i andF-Sppm concentration, the



heavy metals are not fixed in the solid matrix. They are there-



fore available to migrate down through a disposal  site to



groundwater.  Thus, we feel that this waste  stream, poses a threat
      •


to human health and the environment.

-------
      The National Interim Primary Drinking Water Regulations (NIPDWR)



 set limits for chemical contamination of Drinking Water.   The sub-



 stances listed represent hazards to human health.  In arriving at



 these specific limits, the total environmental exposure of man to a



 stated specific toxicant has been considered.  (For a complete



 treatment of the data and reasoning used in choosing the substances



 and specified limits please refer to the NIPDWR Appendix A-C



 Chemical Quality, EPA-6570/9 - 76 - 003) .







      A primary exposure route to the public for toxic contaminants



 is through drinking water.  A large percentage of drinking water



 finds its source in groundwater.  EPA has evidence to indicate that



 industrial wastes as presently managed and disposed often leach



 into and contaminate the groundwater.  The Geraghty and Miller



        indicated that in 98% of 50 randomly selected on-site
industrial waste disposal sites, toxic heavy metals were found to



be  present, and that these heavy metals had migrated from the



disposal, sites in 80% of the instances.  Selenium, arsenic and/or



cyanides were found to be present at 74% of the sites and confirmed



to  have migrated at 60% of the sites.








      At 52% of the sites toxic inorganics (such as arsenic,  cadmium



etc
-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste  Practices



in the Metal Smelting and Refining Industry  Appendices.   April 1977.



Contract f 68-01-2604 *       . ::.        Vol II  pages  44-64.




App. page 3, 32.







Battelle.  Cross Media Impact of the Disposal  of Hazardous



Waste from Metals.  Inorganic Chemicals and  Related  Industries.



Vol. I pages 20-45, Vol III pages 12-17.  Contract f 68-03-2552.

-------
3313  Ferrochrome Silicon Furnace Emission Control Dust/Sludge  (T)



     This waste is classified as hazardous because of its toxic

characteristics.  According to the information EPA has about this

waste stream it meets the RCRA S250.13d characteristic identifying

toxic wastes.



     EPA bases this classification on the following information- .

     Calspan Corp. has tested a sample of Ferrochrome Silicon

Emission Control Dust/Sludge and found the following:



                         Dist. H20                Waste
                         Leachate                 Sample
Contaminent              Cone,  ppm               Analysis  ppm

     Cr                     190     •                   41

     Cu                     0.44                       45

     Zn                     0.3                        700

     Mn                     0.1                        700

     Ni                   < 0.05

     Pb                     1.5

     Ph                     8.8

-------
     According to the Solubility test performed by Calspan Corp.


the leachate derived from Cerrochrome silicon emission control


dust/sludge contains Cr and Pb in concentrations which are greater


than drinking water standards.




     Chromium and lead are toxicants listed by the N I P D W R<
                                                           *** '

at a concentration of .05mg/l because of their toxicity.  As


explained in the RCRA toxicity background document this converts


to a .5mg/l level in the  ,EP extract.




     Since the water extract of the waste has been shown to


contain chromium and lead at a 190 and l.Sppm concentration, the


heavy metals are not fixed in the Solid Matrix.  They are there-


fore available to migrate down through a disposal site to


groundwater.   Thus we feel that this waste stream poses a threat


to human health and the environment.

-------
      The  National  Interim Primary  Drinking Water  Regulations  (NIPDWR)
 set limits  for chemical  contamination  of Drinking Water.   The  sub-
 stances  listed represent hazards to  human health.   In  arriving at
 these specific limits, the total environmental  exposure of man to a
 stated specific toxicant has been  considered.   (For a  complete
 treatment of  the data and reasoning  used in  choosing the  substances
 and specified limits please refer  to the NIPDWR Appendix  A-C
 Chemical  Quality,  EPA-6570/9 -  76  -  003) .

      A primary exposure  route to the public  for toxic  contaminents
 is  through  drinking water.  A large  percentage  of drinking water
 finds its source in groundwater.   EPA  has evidence  to  indicate that
 industrial  wastes  as presently  managed and disposed often leache
 into and  contaminate the groundwater.   The Geraghty and Miller
       1
 report indicated that in 98% of 50 randomly  selected on-site
 industrial  waste disposal sites, toxic heavy metals were  found to
 be  present, and that these heavy metals had  migrated from the
 disposal  sites in  80% of the instances.  Selenium,  arsenic and/or
 cyanides  were found to be present  at 74% of  the sites  and confirmed
 to  have migrated at 60%  of the  sites.
     At  52%  of  the  sites  toxic  inorganics  (such as arsenic, cadmium
etc.)  in the groundwater  from one or more  monitoring wells exceeded
EpA  drinking water  limits  (even after taking into account the
upstream (beyond  the  site) groundwater concentrations).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste  Practices



in the Metal Smelting and Refining Industry  Appendices.



April 1977.  Contract # 68-01-2604 Vol III,  page 97-144.



App. pages 29, 35.

-------
3313  Ferrochrome Furnace Emission Control Dust/Sludge  (T)



     This waste is classified as hazardous because of its

toxic characteristics.  According to the information EPA has

about this waste stream it meets the RCRA S250.13d characteristic

identifying toxic wastes.



     EPA bases this classification on the following information:

(".' Calspan Corp. has tested a sample of Ferrochrome Emission

Control Dust/Sludge and found the following:



                           Dist. H20            Waste
                           Leachate             Sample
Contaminent                Cone,  ppm           Analysis  ppm

     Cr                       710                 3,390

     Cu                       0.2                   54

     Pb                       0.7                   300

     Zn                       0.09                14,000

     Mn                       0.07                 7,200

     pH                       12.3

-------
     According to the Solubility  test performed by Calspan Corp.

the  leachate derived from Ferrochrome Emission Control Dust/

Sludge contains Cr and Pb in concentrations which are orders  of

crvagnitude greater than drinking water standards.




     Chromium and Lead are toxicants listed by the N I P D W  R

at a concentration of .05mg/l because of their toxicity.  As

explained in the RCRA toxicity background document this converts

to a .5mg/l level in the  EP extract.




     Since the water extract of the waste has been shown to
                                                        re*ft«.T
contain  chromium and lead at a 710 and  . V7ppm concentration^  the

heavy metals are not fixed in the Solid matrix.  They are there-

fore available to migrate down through a disposal site to

groundwater.  Thus we feel that this waste stream poses a threat

to human health and the environment.

-------
     The National Interim Primary Drinking Water Regulations (NIPDWR)

set limits for chemical contamination of Drinking Water.  The sub-

stances listed represent hazards to human health.  In arriving at

these specific limits, the total environmental exposure of man to a

stated specific toxicant has been considered.  (For a complete

treatment of the data and reasoning used in choosing the substances

and specified limits please refer to the NIPDWR Appendix A-C

Chemical Quality, EPA-6570/9 - 76 - 003).



     A primary exposure route to the public for toxic contaminents

is through drinking water.  A large percentage of drinking water

finds its source in groundwater.  EPA has evidence to indicate that

industrial wastes as presently managed and disposed often leache

into and contaminate the groundwater.  The Geraghty and Miller
      1
report indicated that in 98% of 50 randomly selected on-site

industrial waste disposal sites, toxic heavy metals were found to

be present, and that these heavy metals had migrated from the

disposal sites in 80% of the instances.  Selenium, arsenic and/or

cyanides were found to be present at 74% of the sites and confirmed

to have migrated at 60% of the sites.



     At 52% of the sites toxic inorganics (such as arsenic, cadmium

etc.) in the groundwater from one or more monitoring wells exceeded

EPA drinking water limits (even after taking into account the

upstream (beyond the site) groundwater concentrations).

-------
References
Calspan Corp.  Assessment of Industrial Hazardous Waste  Practices



in the Metal Smelting and Refining Industry  Appendices.



April 1977.  Contract # 68-01-2604 Vol III,  pages 97-144.



App. pages 29, 35.

-------
3339  Primary Antimony,  Pyrometallurgical Blast Furnace Slag   (T)



     This waste is classified as hazardous because of its toxic

characteristics.  According to the information EPA has about  this

waste stream it meets the RCRA S250.13d characteristic identifying

toxic wastes.



     EPA bases this classification on the following information;-

    Calspan Corp. has tested a sample of Blast Furnace Slag and

found the following:
Contaminant

     Sb

     Pb

     Cu

     Zn

     Ni

     Mn

     Cr

     As

     Cd

     Se

     ph
Dist. H20
Leachate
Cone.  ppm

    100

   < 0.2

      5

    1.7

   < 0.05

    0.01

   < 0.01

    3.00

    0.09

   < 0.05

    9.2
Waste
Sample
Analysis  ppm

 18,000

    66

    50

   500

-------
     According to the Solubility test performed by Calspan Corp.
the leachate derived from Blast Furnace Slag contains As in
concentration which is orders of magnitude greater than the
drinking water standard.

     Arsenic is one of the toxicants listed by the N I p D W R
at a concentration of ,05mg/l because of its toxicity.  As
explained in the RCRA toxicity background document this 'converts
to a .5mg/l level in the  EP extract.

     Since the water extract of the waste has been shown to
contain Arsenic at a 3ppm concentration, the heavy metal is
not fixed in the solid Matrix.  It is therefore available to
migrate down through a disposal site to groundwater.  Thus we
feel that this waste stream poses a threat to human health and
the environment.

-------
      The National Interim Primary Drinking Water  Regulations  (NIPDWR)

 set limits for chemical contamination of  Drinking Water.   The sub-

 stances listed represent hazards  to human health.   In arriving at

 these specific limits,  the total  environmental exposure  of man to a

 stated specific toxicant has been considered.   (For a complete

 treatment of the data and reasoning used  in  choosing the substances

 and specified limits please refer to the  NIPDWR Appendix A-C

 Chemical Quality, EPA-6570/9 - 76 - 003).




      A primary exposure route to  the public  for toxic contaminents

 is through drinking water.   A large percentage of drinking water

 finds its source in groundwater.   EPA has evidence  to indicate that

 industrial wastes as presently managed and disposed often leache

 into and contaminate the groundwater.   The Geraghty and  Miller
       1
 report indicated that in 98% of 50 randomly  selected on-site

 industrial waste disposal sites,  toxic heavy metals were found to

be present, and that these heavy  metals had  migrated from the

disposal sites in 80% of the instances.   Selenium,  arsenic and/or

cyanides were found to be present at 74%  of  the sites and confirmed

to have migrated at 60% of the sites.




      At 52% of the sites toxic inorganics  (such as  arsenic, cadmium

etc.)  in the groundwater from one or more monitoring wells exceeded

EpA drinking water limits (even after taking into account the

upstream (beyond the site)  groundwater concentrations).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste  Practices



in the Metal Smelting and Refining Industry Appendices.   April 1977,



Contract # 68-01-2604.  -        :    . .   Vol II  page  132-153.



App. page 6, 32.







Battelle.  Cross Media Impact of the Disposal of Hazardous Waste



from Metals.  Inorganic Chemicals  and Related Industries.



Vol I, page 20-45.  Vol III, page  34-39.  Contract #  68-03-2552.

-------
3341  Secondary Lead, Scrubber Sludge from S02 Emission Control,

      Soft Lead Production  (T)



     This waste is classified as hazardous because of its toxic

characteristics.  According to the information EPA has about this

waste stream it meets the RCRA S250.13d characteristic identifying

toxic wastes.



     EPA bases this classification on the following information-  •

     Calspan Corp. has tested a sample of S02 Scrubber Sludge and

found the following:



                             Dist. H20              Waste
                             Leachate               Sample
Contaminent                  Cone.   ppm            Analysis  ppm

     Zn                        1.3                       25

     Cd                          5                      340

     Cr                        0.05                      30

     Cu                        0.5                       20

     Mn                        0.21                     120

     Pb                        2.5                    53,000

     Sb                      < 0.2                     1,100

     Sn                        1.6

     Ni                                                  5

     pM                        8.4

-------
     According to the solubility test performed by Calspan Corp.

the leachate derived from SO2 Scrubber Sludge contains Cd and Pb

in concentrations which are orders of magnitude greater than

drinking water standards.



     Lead is one of the toxicants listed by the NIPDWR at a con-

centration of .05mg/l because of its toxicity.  As explained in

the RCRA toxicity background document this converts to a .5mg/l

level in the "EP extract.



     Cadmium is one of the toxicants listed by the NIPDWR at a

concentration of .Olmg/1 because of its toxicity.   As explained

in the RCRA toxicity background document this converts to a .lmg/1

level in the  'EP extract.



     Since the water extract of the waste has been shown to

contain cadmium and lead at a 5 and 2.5ppm concentration, the
                                         ^i
heavy metals are not fixed in the solid matrix.  They are there-

fore available to migrate down through a disposal site to ground-

water.  Thus, we feel that this waste stream poses a threat to

human health and the environment.

-------
     The National Interim Primary Drinking Water Regulations  (NIPDWR)


set limits  for  chemical contamination of Drinking Water.  The sub-


stances listed  represent hazards to human health.  In arriving at


•these  specific  limits, the total environmental exposure of man to a


stated specific toxicant has been considered.  (For a complete


treatment of  the data  and reasoning used in choosing the substances


and specified limits please refer to the NIPDWR Appendix A-C


Chemical Quality, EPA-6570/9 -  76 - 003).





     A primary  exposure route to the public for toxic contaminents


is  through  drinking water.  A large percentage of drinking water


finds  its source in groundwater.  EPA has evidence to indicate that


industrial  wastes as presently  managed  and disposed often leache


into and contaminate the groundwater.   The Geraghty and Miller

       1
report indicated that  in 98% of 50 randomly selected on-site


industrial  waste disposal sites, toxic  heavy metals were found to


be  present, and that these heavy metals had migrated from the


disposal sites  in 80%  of the instances. Selenium, arsenic and/or


cyanides were found to be present at 74% of the sites and confirmed


to  have migrated at 60% of the  sites.




     At  52% of  the sites toxic  inorganics  (such as arsenic, cadmium


etc.)  in  the groundwater from one or more monitoring wells exceeded


EPA drinking water limits  (even after taking into account the


upstream  (beyond the site) groundwater  concentrations).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste Practices



in the Metal Smelting & Refining Industry Appendices.   April 1977,



Contract # 68-01-2604, Vol II page 262-282,  App.  page  10,34.







Battelle.  Cross Media Impact of the Disposal of  Hazardous Waste



from Metals.  Inorganic Chemicals and Related Industries.



Vol I page 20-45, Vol III page 12-J-126, Contract # 68-01-2552.

-------
 3341  Secondary Lead, White Metal Production, Furnance Dust  (T)



     This waste is classified as hazardous because of its toxic

 characteristics.  According to the information EPA has about

 this waste  stream it meets the RCRA S250.13d characteristic

 identifying toxic wastes.



     EPA basis this classification on the following information- .

 ;."'  Calspan Corp. has tested a sample of Furnance Dust and found

 the following:



                              Dist. H20              Waste
                              Leachate               Sample
Contaminent                  Cone,  ppm             Analysis  ppm

     Zn                       4,000                    120,000

     Cd                         230                        900

     Cr.                         12                        150

     Cu                          45                        400

     Mn                           4                          5

     Pb                          24                    120,000

     Sb                      < 0.02                       1800

     Sn                         860                    117,000

     Ni                                                      5

                                3.9

-------
     According to the solubility test performed by Calspan Corp.



the leachate derived from Furnance Dust contains Cd, Cr and Pb



in concentrations which are several orders of magnitude greater



than drinking water standards.







     Chromium and Lead are toxicants listed by the NIPDWR at a



concentration of ,05mg/l because of their toxiciiy.  As explained



in the RCRA toxicity background document this converts to a .5mg/l



level in the  "EP extract.







     Cadmium is one of the toxicants listed by the NIPDWR at a



concentration of .Olmg/1 because of its toxicity.  As explained



in the RCRA toxicity background document this converts to a .lmg/1



level in the  EP extract.







     Since the water extract of the waste has been shown to



contain Cdf Cr, and Pb at a 230, 12, and 24ppm concentration,  the



heavy metals are not fixed in the .Solid irjatrix.  They are there-



fore available to migrate down through a disposal site to ground-



water.  Thus, we feel that this waste stream poses a threat to



human health and the environment.
                           fff

-------
      The National  Interim Primary  Drinking Water Regulations  (NIPDWR)
 set limits for chemical  contamination  of Drinking Water.  The  sub-
 stances listed represent hazards to human health.   In arriving at
 these specific limits, the total environmental  exposure of man to a
 stated specific toxicant has  been  considered.   (For a complete
 treatment of the data  and reasoning used in  choosing the  substances
 and specified limits please refer  to the NIPDWR Appendix  A-C
 Chemical Quality,  EPA-6570/9  -  76  - 003).

      A primary exposure  route to the public  for toxic contaminents
 is  through drinking water.  A large percentage  of drinking water
 finds its source in groundwater.   EPA  has evidence  to indicate that
 industrial wastes  as presently  managed and disposed often leache
 into and contaminate the groundwater.   The Geraghty and Miller
       1
 report indicated that  in 98%  of 50 randomly  selected on-site
 industrial waste disposal sites, toxic heavy metals were  found to
be  present,  and that these heavy metals had  migrated from the
disposal sites in  80%  of the  instances.  Selenium,  arsenic and/or
cyanides were found to be present  at 74% of  the sites and confirmed
to  have migrated at 60%  of the  sites.

      At 52% of the sites toxic  inorganics  (such as  arsenic, cadmium
etc.)  in the groundwater from one  or more monitoring wells exceeded
EPA drinking water limits (even after  taking into account the
upstream (beyond the site)  groundwater concentrations).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste Practices



in the Metal Smelting and Refining Industry  Appendices.  April 1977



Contract # 68-01-2604, Vol II page 262-282 App.  page  10,34.







Battelle.  Cross Media Impact of the Disposal of Hazardous Waste



from Metals.  Inorganic Chemicals and Related Industries.



Vol I page 20-45, Vol III page 120-126, Contract #  68-03-2552.

-------
3341  Secondary Copper, Pyrometallurgical Blast Furnance  Slag   (T)



     This waste is classified as hazardous because of  its toxic

characteristics.  According to the information EPA has about the

waste stream it meets the RCRA S250.13d characteristic identifying

toxic wastes.



     EPA bases this classification on the following  information.

Calspan Corp. has tested a sample of Blast Furnance  Slag

and found the following:


                            Dist. H20                  Waste
                            Leachate                   Sample
Contaminant                 Cone.  ppm                 Analysis  PP"L

     Zn                         55                     75,000

     Cd                        1.0                     45

     Cr                        0.03                    20

     Cu                        170                     12,000

     Mn                        0.3                      7,000

     Pb                         6                       2,600

     Sb                      4^0.2                       <100

     Sn                      < 0.2

     Ni                                                    260

     ph                        9.4

-------
     According to the solubility test performed by Calspan Corp.
the leachate derived from Blast Furnance slag contains Cd and Pb
in concentration, which are orders of magnitude greater than
drinking water standards.  Lead is one of the toxicants listed
by the NIPDWR at a concentration of .05mg/l because of its
toxicity.  As explained in the RCRA toxicity background document
this converts to a ,5mg/l level in the EP extract.  Cadmium is
one of the toxicants listed by the NIPDWR at a concentration of
.Olmg/1 because of its toxicity.  As explained in the RCRA
toxicity background document this converts to a .lmg/1 level in
the EP extract.
     Since the water extract of the waste has been shown to
contain cadmium and lead at a 1.0 and 6ppm concentration, the
heavy metals are not fixed in the solid matrix.  They are there-
fore available to migrate down through a disposal site to
groundwater.  Thus/ we feel that this waste stream poses a threat
to human health and the environment.

-------
      The National Interim Primary  Drinking Water  Regulations  (NIPDWR)
 set limits for chemical contamination of  Drinking Water.   The sub-
 stances listed represent hazards  to human health.  In arriving at
 these specific limits,  the total  environmental exposure of man to a
 stated specific toxicant has been considered.   (For a complete
 •treatment of the data and reasoning used  in  choosing the substances
 and specified limits please refer to the  NIPDWR Appendix A-C
 Chemical Quality, EPA-6570/9 - 76  - 003).

      A primary exposure route to  the public  for toxic contaminants
 is through drinking water.  A large percentage of drinking water
 finds its source in groundwater.   EPA has evidence to indicate that
 industrial wastes as presently managed and disposed often leach
 into and contaminate the groundwater.  The Geraghty and Miller
 report indicated that in 98% of 50 randomly  selected on-site
 industrial waste disposal sites,  toxic heavy metals were found to
 be present, and that these heavy  metals had  migrated from the
 disposal sites in 80% of the instances.  Selenium, arsenic and/or
 cyanides were found to be present at 74%  of  the sites and confirmed
 to have migrated at 60% of the sites.

      At 52% of the sites toxic inorganics (such as arsenic, cadmium
etc.)  in the groundwater from one or more monitoring wells exceeded
EpA drinking water limits (even after taking into account the
upstream (beyond the site) groundwater concentrations).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste Practices



in the Metal Smelting & Refining Industry Appendices.   April 1977.



Contract # 68-01-2604, Vol II"  page 239-261,  App. page 9, 34.







Battelle.  Cross Media Impact of the Disposal of Hazardous Waste



from Metals.  Inorganic Chemicals and Related Industries.



Vol I, page 20-45, Vol III, page 110-119, Contract # 68-01-2552.  .

-------
 3341  Secondary Copper, Electrolytic Refining Waste Water Sludge
       (T)

     This waste is classified as hazardous because of its toxic
 characteristics.  According to the information EPA has about
 this waste stream it meets the RCRA S250.13d characteristic
 identifying toxic wastes.

     EPA bases this classification on the following information-
 ;:,'•  Calspan Corp. has tested a sample of Electrolytic Refining
waste  water sludge and found the following:

                            Dist. H_0               Waste
                            Leachatl                Sample
Contaminent                 cone.  ppm              Analysis  ppm
     Zn                      <0.01                   1,850
     Cd                        0.05                   10
     Cr                        7.1                   94,000
     Cu                        0.63                 170,000
     Mn                        0.06
     pb                        0.5                    900
     Sb                      < 0.2
     Sn                      <0.2                    20,000
     Ni                         -                     16,600
     Ph                        8.6

-------
     According to the solubility test performed by Calspan Corp.



the leachate derived from Electrolytic Refining waste water



sludge contains Cr and Pb in concentrations which are orders of



magnitude greater than drinking water standards.







     Chromium and Lead are toxicants listed by the NIPDWR at a



concentration of .05mg/l because of their toxicity.  As explained



in the RCRA toxicity background document this converts to a



.5mg/l level in the  EP extract.







     Since the water extract of the waste has been shown to



contain chromium and lead at a 7.1 and O.Sppm concentration, the



heavy metals are not fixed in the Solid matrix.  They are there-



fore available to migrate down through a disposal site to ground-



water.  Thus, we feel that this waste stream poses a threat to



human health and the environment.

-------
      The National  Interim Primary Drinking Water Regulations  (NIPDWR)


 set limits  for  chemical  contamination of Drinking Water.  The sub-


 stances listed  represent hazards to human health.   In  arriving at


 these specific  limits, the  total environmental  exposure  of man to a


 stated specific toxicant has been considered.   (For a  complete


 treatment of  the data and reasoning used in choosing the substances


 and specified limits please refer to the NIPDWR Appendix A-C


 Chemical Quality,  EPA-6570/9 - 76 - 003).




      A primary  exposure  route to the public for toxic  contaminents


 is  through  drinking water.  A large percentage  of drinking water


 finds its source in groundwater.  EPA has evidence  to  indicate that


 industrial  wastes  as presently managed  and disposed often leache


 into and contaminate the groundwater.   The Geraghty and  Miller

       1
 report indicated that in 98% of 50 randomly selected on-site


 industrial  waste disposal sites, toxic  heavy metals were found to


t>e  present,  and that these  heavy metals had migrated from the


 Disposal sites  in  80% of the instances. Selenium,  arsenic and/or


 cyanides were found to be present at 74% of the sites  and confirmed


 to  have migrated at 60%  of  the sites.




      At 52% of  the sites toxic inorganics  (such as  arsenic, cadmium


@-tc.) in the groundwater from one or more monitoring wells exceeded


EPA drinking water limits  (even after taking into account the


upstream (beyond the site)  groundwater  concentrations).

-------
References







Calspan Corp.  Assessment of Industrial Hazardous Waste Practices



in the Metal Smelting & Refining Industry Appendices.   April 1977,



Contract * 68-01-2604,   ".         '.:::.. Vol II, pages 239-261,



App. page 9, 34.







Battelle.  Cross Media Impact of the Disposal of Hazardous Waste



from Metals.  Inorganic Chemicals and Related Industries.



Vol I, page 20-45, Vol III, page 110-119.  Contract f  68-03-2552.

-------
 333417  Secondary Aluminum Smelting and Refining:  Secondary
         Aluminum Dross Smelting High Salt Slag (T)


      This waste is classified as hazardous because  of  its  toxic

 characteristics.   According to information EPA has  about this

 waste stream it meets the RCRA §250.13(d)  characteristic identi-

 fying toxic wastes.

      The National Interim Primary Drinking Water Regulations

 (NIPDWR) set limits  for chemical contamination of  drinking water.

 The substances listed represent hazards to human health.   In

 arriving at these specific limits,  the  total  environmental

 exposure of man to a stated specific toxicant has  been considered.

 (For a complete treatment of the data and reasoning used in
                                           \
 choosing the substances and specified limits  please refer  to

 the NIPDWR Appendix  A-C Chemical Quality,  EPA-6570/9

 -  76 - 003).

      A primary exposure route to the public for toxic  contami-

 nants is through drinking water.   A large percentage of drinking

 water finds its source in groundwater.   EPA has evidence to

 indicate that industrial waste as presently managed and

 disposed often leaches into and contaminates  the groundwater.

 The Geraghty and Miller Report  indicated that in  98%  of 50

randomly selected on-site industrial waste disposal sites,  toxic

heavy metals had migrated from the disposal sites  in 80% of the

instances.  Selenium, arsenic and/or cyanides were  found to be

present at 74% of the sites and confirmed to  have migrated at 60%

0£  the sites.

      At 52% of the sites toxic inorganics (such as  arsenic, cadmium

etc-)  in the groundwater from one or more monitoring wells

-------
exceeded EPA drinking water limits (even after taking into



account the upstream (beyond the site) groundwater concentrations) .



     Chromium and lead are two of the toxicants listed by the



NIPDWR at concentrations of 0.05mg/l because of their



toxicity.  As explained in the RCRA toxicity background document



this converts to a 0.5mg/l level in the EP extract.



     This waste has been shown to contain chromium and lead



concentrations 60 ppm and 300 ppm respectively, according to



Calspan Report No. ND-5520-M-1, Assessment of Industrial Hazardous



Waste Practices in the Metal Smelting and Refining Industry,



Appendices, page 11.



     Since the water extract of the waste has been shown to



contain chromium and lead concentrations of 1.5 ppm and 0.24 ppm



respectively, according to the same report, page 36, we feel



that this waste stream poses a threat to human health and the



environment.

-------
  3333 Primary Zinc Smelting and Refining:   Cadmium Plan  Residue  (T)
                                                       A
       This waste is classified as hazardous because of its  toxic
  characteristics.  According to the information  EPA has  about  this
  waste stream it meets the RCRA §250.13(d)  characteristic identi-
  fying toxic wastes.
       The National Interim Primary Drinking Water Regulations
  (NIPDWR) set limits for chemical contamination  of drinking water.
  The substances listed represent hazards  to human health.   In
  arriving at these specific limits, the total environmental
  exposure of man to a stated specific  toxicant has been  considered.
  (For a complete treatment of the data and  reasoning used in
  choosing the substances and specified limits please refer  to
  the NIPDWR Appendix A-C Chemical Quality,  EPA-6570/9
f  -  76 - 003).
       A primary exposure route to the  public for toxic
  contaminants is through drinking water. A  large percentage of
  drinking water finds its source in groundwater.   EPA has evidence
  to  indicate that industrial waste as  presently  managed  and
 disposed often leaches  into and contaminates the groundwater.
 The Geraghty and Miller report1 indicated  that  in 98% of 50
 randomly selected on-site waste disposal sites  toxic heavy metals
 had migrated from the disposal  sites  in 80%  of  the  instances.
 Selenium,  arsenic and/or cyanides  were found to  be  present at 74%
 Of  the  sites  and confirmed to have migrated  at  60%  of the  sites.
       At 52%  of the sites toxic  inorganics  (such  as  arsenic, cadmium,
 etc-)  in tne  groundwater from one  or more monitoring wells
           EPA  drinking water  limits  (even after taking into account

-------
the upstream (beyond the site) groundwater concentrations) .
     Cadmium, chromium, and lead are three toxicants listed by
the NIPDWR at concentrations 0.01 mg/1, 0.05 mg/1,  and 0.5 mg/1
respectively, because of their toxicity.  As explained in the
RCRA toxicity background document these concentrations convert to
0.1 mg/1, 0.5 mg/1, and 0.5 mg/1 levels, respectively,  in the
EP extract.
     This waste has been shown to contain cadmium,  chromium, and
lead at concentrations of 280 ppm, and 24 ppm, and 215,000 ppm,
respectively, according Calspan Report No. ND-5520-M-1, Assessment
of Industrial Hazardous Waste Practices in the Metal Smelting
and Refining Industry,  Appendices, page 4.
     Since the water extract of the waste has been shown to
contain cadmium, chromium, and lead at concentrations of <0.01
ppm, 0.02 ppm, and 9.0 ppm, respectively, according to the same
report, page 32, we feel that this waste stream poses a threat to
human health and the environment.

-------
 3691   Lead  acid battery production wastewater
 treatment sludge  (T)
      This waste is classified as hazardous because of its toxic
 characteristic.   According to the information EPA has on this
 waste stream  it meets RCRA §250.13d characteristic identifying
 toxic waste.
      EPA bases this classification on the following information.
      (1)  Booz-Allen has tested a sample of lead acid battery
 production  wastewater treatment sludge and found the following.

 contaminant                          cone, kg/kkg product

   Pb  as PbS04 & Pb(OH)2                 150.00

      The data presented are available from:
      Booz-Allen.  A Study of Hazardous Waste Materials, Hazardous
 Effects and Disposal Methods.  Vol. 1-14.  PB - 221 - 466.
 Contract #68  - 03 - 0032.
      and
      Versar,  Inc.  Assessment of Industrial Hazardous Practices,
 Storage and Primary Batteries.  PB - 241 - 204/7WP.  1975.
      The "Handbook of Industrial Waste Compositions in
California" - 1978, indicates that a load of this waste had the
following composition  (Reference 9, p. 10).
      Storage battery wastewater treatment sludge - lead hydroxide
                  load size - 8 yards

-------
     The National Interim Primary Drinking Water Regulations
 (NIPDWR) set limits for chemical contamination of Drinking Water.
The substances listed represent hazards to human health.  In
arriving at these specific limits, the total environmental exposure
of man to a stated specific toxicant has been considered.  (For a
complete treatment of the data and reasoning used in choosing the
substances and specified limits please refer to the NIPDWR Appendix
A-C Chemical Quality, EPA-6570/9 - 76 - 003).
     A primary exposure route to the public for toxic contaminents
is through drinking water.  A large percentage of drinking water
finds it source in groundwater.  EPA has evidence to indicate
that industrial wastes as presently managed and disposed often
leaches into and contaminents the groundwater.  The Geraghty and
Miller report1 indicated that in 98% of 50 randomly selected
on-site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated from
the disposal sites in 80% of the instances.  Selenium, arsenic
and/or cyanides were found to be present at 74% of the sites and
confirmed to have migrated at 60% of the sites.
     At 52% of the sites toxic inorganics  (such as arsenic, cadmium
etc.) in the groundwater from one or more monitoring wells
exceeded EPA drinking water limits (even after taking into account
the upstream (beyond the site) groundwater concentrations) .
     Arsenic, barium, cadmium, chromium, lead, mercury, selenium,
and silver are toxicants listed by the NIPDWR at concentrations
of 0.05, 1.00, 0.010, 0.05, 0.05, 0.002, 0.01, and 0.05, mg/1
respectively  because of their toxicity.  As explained in the RCRA
toxicity background documents these concentrations convert to

-------
0.5, 10.0, 0.1, 0.5, 0.5, 0.02, 0.1, and 0.5, mg/1 respectively



in the  'EP extract.



     This waste has been shown to contain lead at 150kg/1000 kg



product according to PB - 221 - 466,  A Study of Hazardous Waste



Materials, Hazardous Effects and Disposal Methods; and PB - 241 -



204/7WP, Assessment of Industrial Hazardous Practices, Storage



and Primary Batteries.



     Because of the toxicity of lead and the solubility of the



hydroxide salt  (slightly soluble in aquous solution, soluble in



audio solution) this waste stream is to be considered hazardous.

-------
3691  Lead acid storage battery production & clean-up wastes



from cathode and anode paste production (T)



     This waste is classifed as hazardous because of its toxic



characteristic.  According to the information EPA has on this



waste stream it meets RCRA §250.13d characteristic identifying



toxic waste.



     EPA bases this classification on the following information.



     (1)  Booz-Allen has tested a sample of lead acid storage



battery production clean-up waste from cathode and anode paste



production and found the following.





contaminents                        cone,  kg/1000 kg product





Pb as PbO, Pb, PbO2             .           67.00





     The data presented are available from:



     Booz-Allen.  A Study of Hazardou Waste Materials, Hazardous



Effects and Disposal Methods.  Vol. 1-14.  PB - 221 - 466.



Contaract #68 - 03 - 0032.



     and



     Versar, Inc.  Assessment of Industrial Hazardous Practices,



Storage and Primary Batteries.  PB - 241 - 204/7WP.  1975.

-------
      The National Interim Primary Drinking Water Regulations
 (NIPDWR) set  limits for chemical contamination of Drinking Water.
The  substances listed represent hazards to human health.  In
arriving at these specific limits/ the total environmental exposure
of man  to  a stated specific toxicant has been considered.   (For a
complete treatment of the data and reasoning used in choosing the
substances and specified limits please refer to the NIPDWR Appendix
A-C  Chemical  Quality, EPA-6570/9 - 76 - 003).
      A  primary exposure route to the public for toxic contaminents
is through drinking water.  A large percentage of drinking water
finds it source  in groundwater.  EPA has evidence to indicate
that industrial  wastes as presently managed and disposed often
leaches into  and contaminents the groundwater.  The Geraghty and
Miller  report indicated that in 98% of 50 randomly selected
on-site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated from
the  disposal  sites in 80% of the instances.  Selenium,  arsenic
and/or  cyanides  were found to be present at  74% of the  sites and
confirmed  to  have migrated at 60% of the sites.
      At 52% of the sites toxic inorganics (such as arsenic, cadmium
etc.) in the  groundwater from one or more monitoring wells
exceeded EPA  drinking water limits (even after taking into account
the  upstream  (beyond the site) groundwater concentrations).
      Arsenic, barium, cadmium, chromium, lead, mercury, selenium,
and  silver are toxicants listed by the NIPDWR at concentrations
Of 0.05, 1.00, 0.010, 0.05, 0,05, 0.002, 0.01, and 0.05, mg/1
respectively  because of their toxicity.  As explained  in the RCRA
toxicity background documents these concentrations convert to
                            ft*

-------
0.5, 10.0, 0.1, 0.5,-0.5, 0.02, 0.1, and 0.5,  mg/1 respectively



in the TEP extract.



     This waste has been shown to contain lead at 67.0 kg/1000 kg



product according to Pb - 221 - 466, A study of Hazardous Waste



Materials, Hazardous Effects and Disposal Methods; and PB - 241



- 204/7WP, Assessment of Industrial Hazardous Practices,  Storage



and Primary Batteries.



     Because of the toxicity of lead this waste is to be  considered



hazardous.

-------
 3691  Nickel cadmium battery production wastewater treatment


 sludges (T)
                           I


      This waste is classif^pd as hazardous  because of its  toxic



 characteristic.  According to the information EPA has on  this



 waste stream it meets RCRA §250.13d characteristic identifying



 toxic waste.



      EPA bases this classification on  the  following information.



      (1)   Booz-Allen has  tested a sample of nickel cadmium battery



 production wastewater treatment sludges  and found the following.




 contaminent                              cone,  kg/1000 kg  product




 Cd  as Cd(OH)2                                  5.34



 Ni  as Ni(OH)2                                  1.66




      The data  presented are  available  from:



      Booz-Allen.   A Study of Hazardous Waste  Materials, Hazardous


Effects and  Disposal Methods.   Vol  1-14.   PB  - 221 -  466.  Contract


 f68  - 03 - 0032.



      and



      Versar, Inc.   Assessment of  Industrial Hazardous Practices;



Storage and  Primary Batteries.  PB  - 241 - 204/7WP.   1975.

-------
     The National Interim Primary Drinking Water Regulations
(NIPDWR) set limits for chemical contamination of Drinking Water.
The substances listed represent hazards to human health.  In
arriving at these specific limits, the total environmental exposure
of man to a stated specific toxicant has been considered.  (For a
complete treatment of the data and reasoning used in choosing the
substances and specified limits please refer to the NIPDWR Appendix
A-C Chemical Quality, EPA-6570/9 - 76 - 003) .
     A primary exposure route to the public for toxic contaminants
is through drinking water.  A large percentage of drinking water
finds it source in groundwater.  EPA has evidence to indicate
that industrial wastes as presently managed and disposed often
leaches into and contaminents the groundwater.  The Geraghty and
Miller report1 indicated that in 98% of 50 randomly selected
on-site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated from
the disposal sites in 80% of the instances.  Selenium, arsenic
and/or cyanides were found to be present at 74% of the sites and
confirmed to have migrated at 60% of the sites.
     At 52% of the sites toxic inorganics (s. a. arsenic, cadmium
etc.) in the groundwater from one or more monitoring wells
exceeded EPA drinking water limits (even after taking into account
the upstream (beyond the site) groundwater concentrations) .
     Arsenic, barium, cadmium/ chromium, lead, mercury, selenium
and silver are toxicants listed by the NIPDWR at concentrations
of 0.05, 1.00, 0.010, 0.05, 0.05, 0.002, 0.01, and 0.05, mg/1
respectively  because of their toxicity.  As explained in the RCRA
toxicity background documents these concentrations convert to

-------
 0.5,  10.0,  0.1, 0.5, 0.5, 0.02, 0.1, and 0.5, mg/1 respectively
 in  the  EP  extract.
      This waste has been shown to contain cadmium at 5.34 kg/1000
 kg  product, according to PB - 241 - 204, Assessment of Industrial
 Hazardous Practices, Storage and Primary Batteries.
      Because of the toxicity of Cadmium and the solubility
 (soluble in acid solution)  of cadmium hydroxide this waste is
considered hazardous.

-------
3691  Cadmium silver oxide battery production wastewater



treatment sludge (T)



     This waste is classified as hazardous beq/i^gfse of its toxic



characteristic.  According to the information EPA has on this



waste stream it meets RCRA §250.13d characteristic identifying



toxic waste.



     EPA bases this classification on the following information.



     (1)  Booz-Allen has tested a sample of cadmium silver oxide



battery production wastewater treatment sludge and found the



following.





contaminent                               cone, kg/1000 kg product





Cd as Cd(OH)2                                   5.34



Ag as Silver Oxide                              2.24





     The data presented are available from:



     Booz-Allen.  A Study of Hazardous Waste Materials, Hazardous



Effects and Disposal Methods.  Vol 1-14.  PB - 221 - 446.  Contract



#68 - 03 - 0032.



     and



     Versar, Inc.   Assessment of Industrial Hazardous Practices,



Storage and Primary Batteries.  PB - 241 - 204/7WP.  1975.

-------
      The  National  Interim Primary Drinking Water Regulations



 (NIPDWR)  set  limits for chemical contamination of Drinking Water.



The  substances  listed represent hazards to human health.  In



arriving  at these  specific limits, the total environmental exposure



of man  to a stated specific toxicant has been considered.   (For a



complete  treatment of the data and reasoning used in choosing the



substances and  specified limits please refer to the NIPDWR Appendix



A-C  Chemical  Quality, EPA-6570/9 - 76 - 003) .



      A  primary  exposure route to the public for toxic contaminents



is through drinking water.  A large percentage of drinking water



finds it  source in groundwater.  EPA has evidence to indicate



that industrial wastes as presently managed and disposed often



leaches into  and contaminents the groundwater.  The Geraghty and



Miller  report^  indicated that in 98% of 50 randomly selected



on-site industrial waste disposal sites, toxic heavy metals were



found to  be present, and that these heavy metals had migrated from



the  disposal  sites in 80% of the instances.  Selenium, arsenic



and/or  cyanides were found to be present at 74% of the sites and



confirmed to  have  migrated at 60% of the sites.



      At 52% of  the sites toxic inorganics  (ST. a. arsenic, cadmium



etc.) in  the  groundwater from one or more monitoring wells



exceeded  EPA  drinking water limits  (even after taking into account



the  upstream  (beyond the site) groundwater concentrations).



      Arsenic, barium, cadmium, chromium, lead, mercury, selenium,



and  silver are  toxicants listed by the NIPDWR at concentrations



Of 0.05,  1.00,  0.010, 0.05, 0.05, 0.002, 0.01, and 0.05, mg/1



respectively  because of their toxicity.  As explained in the RCRA



toxicity  background documents these concentrations convert to

-------
0.5, 10.0, 0.1, 0.5, 0.5, 0.02, 0.1, and 0.5 mg/1 respectively



in the  EP extract.



     This waste has been shown to contain cadmium and silver at



5.34 and 2.24 kg/1000 kg product respectfully, according to



PB 241-204/7WP,  Assessment of Industrial Hazardous Practices,



Storage and Primary Batteries.



     Because of the toxicity of cadmium and silver and the



solubility of these salts (soluble in acid solution), this waste



is to be considered hazardous.

-------
 3691  Mercury cadmium battery production wastewater treatment



 sludges (T)



      This waste is classified as  hazardous  because  of  its  toxic



 characteristic.  According to the information  EPA has  on this



 waste steam it meets RCRA §250.13d characteristic identifying



 toxic waste.



      EPA bases this classification on  the following information.



      (1)   Booz-Allen has  tested a sample of mercury cadmium



 battery production wastewater treatment  sludge and  found



 it to contain silver,  cadmium and mercury.





         (1,022 kg/yr of this  waste are landfilled)





  Note:   This  listing will include other  storage batteries



         that  are not otherwise listed, that is,  Zinc-Silver



         Oxide & Silver lead as an example





      The data presented are available  from:



      Booz-Allen.   A Study of  Hazardous Waste Materials,  Hazardous



Disposal Methods.   Vol 1-14.   PB   221  -  466.   Contract #68  -  03 -



0032.



      and



      Versar,  Inc.   Assessment of  Industrial Hazardous  Practices;



Storage and Primary Batteries.  PB - 241  -  204/7WP.  1975.

-------
     The National Interim Primary Drinking Water Regulations
 (NIPDWR) set limits for chemical contamination of Drinking Water.
The substances listed represent hazards to human health.  In
arriving at these specific limits, the total environmental exposure
of man to a stated specific toxicant has been considered.  (For a
complete treatment of the data and reasoning used in choosing the
substances and specified limits please refer to the NIPDWR Appendix
A-C Chemical Quality, EPA-6570/9 - 76 - 003).
     A primary exposure route to the public for toxic contaminants
is through drinking water.  A large percentage of drinking water
finds it source in groundwater.  EPA has evidence to indicate
that industrial wastes as presently managed and disposed often
leaches into and contaminents the groundwater.  The Geraghty and
Miller report^- indicated that in 98% of 50 randomly selected
on-site industrial waste disposal sites, toxic heavy metals were
found to be present, and that these heavy metals had migrated from
the disposal sites in 80% of the instances.  Selenium, arsenic
and/or cyanides were found to be present at 74% of the sites and
confirmed to have migrated at 60% of the sites.
     At 52% of the sites toxic inorganics  (such as arsenic, cadmium
etc.)  in the groundwater from one or more monitoring wells
exceeded EPA drinking water limits (even after taking into account
the upstream (beyond the site) groundwater concentrations).
     Arsenic, barium, cadmium, chromium, lead, mercury, selenium,
and silver are toxicants listed by the NIPDWR at concentrations
of 0.05, 1.00,  0.010, 0.05, 0.05, 0.002, 0.01, and 0.05, mg/1
respectively  because of their toxicity.  As explained in the RCRA
toxicity background documents these concentrations convert to

-------
o.5,  10.0,  0.1, 0.5, 0.5, 0.02, 0.1, and 0.5 mg/1 respectively
in  the TEP  extract.
      This waste has been shown to contain cadmium, silver, and
mercury  at  a total concentration of 1,022.3 kg/1000 kg product,
according to PB - 241 - 204/7WP,  Assessment of Industifa^l Hazardous
Practices,  Storage and Primary Batteries.
      Because of the toxicity of cadmium, mercury and silver, this
waste is to be considered hazardous.

-------
3692  Magnesium carbon battery production chromic acid



wastewater treatment sludges  (T)



     This waste is classified as hazardous because of its toxic



characteristic.  According to the information EPA has on this



waste stream it meets RCRA §250.13d characteristic identifying



toxic waste.



     EPA bases this classification on the following information.



     (1)  Booz-Allen has tested a sample of magnesium carbon



battery production chromic acid wastewater treatment sludges



and found the following.





contaminent                          cone, kg/1000 kg product





Cr as chromium hydroxide                    11.07



  and chromium carbonate





     The data presented are available from:



     Booz-Allen.  A Study of Hazardous Waste Materials, Hazardous



Effects and Disposal Methods.  Vol 1-14.  PB 221-446.  Contract



#68 - 03 - 0032.



     and



     Versar, Inc.  Assessment of Industrial Hazardous Practices,



Storage and Primary Batteries.  PB 241-204/7WP.   1975,

-------
      The National Interim Primary Drinking Water Regulations
 (NIPDWR) set limits for chemical contamination of Drinking Water.
 The substances listed represent hazards to human health.   In
 arriving at these specific limits, the total environmental exposure
 of man to a stated specific toxicant has been considered.   (For a
 complete treatment of the data and reasoning used in choosing the
 substances and specified limits please refer to the NIPDWR Appendix
 A-C Chemical Quality, EPA-6570/9 - 76 - 003).
      A primary exposure route to the public for toxic contaminents
 is through drinking water.   A large percentage of drinking water
 finds it source in groundwater.  EPA has evidence to indicate
 that industrial wastes as presently managed and disposed often
 leaches into and contaminents the groundwater.  The Geraghty and
 Miller report1 indicated that in 98% of 50 randomly selected
 on-site industrial waste disposal sites, toxic heavy metals were
 found to be present,  and that these heavy metals had migrated from
 the disposal sites in 80% of the instances.   Selenium,  arsenic
 and/or cyanides were found to be present at 74% of the  sites  and
 confirmed to have migrated at 60% of the sites.
      At 52% of the sites toxic inorganics (such as arsenic,  cadmium
 etc.)  in the groundwater from one or more monitoring wells
 exceeded EPA drinking water limits (even after taking into  account
 the upstream (beyond the site)  groundwater concentrations).
      Arsenic,  barium, cadmium,  chromium,  lead,  mercury, selenium,
 and silver are toxicants listed by the  NIPDWR at concentrations
Of  0.05, 1.00, 0.010, 0.05,  0.05, 0.002,  0.01,  and 0.05, mg/1
 respectively  because of their toxicity.   As explained  in  the RCRA
toxicity background documents these concentrations  convert  to

-------
0.5, 10.0, 0.1, 0.5, 0.5, 0.02, 0.1, and 0.5, mg/1 respect ively


in the  EP extract.


     This waste has been shown to contain chromium levels of 11.07


kg/kkg product, according to PB 241-204,  Assessment of Industrial


Hazardous Practices, Storage and Primary Batteries.


     Because of the toxicity of chromium and the solubility of
the    .1  hydroxide (in the presence of chloride ion) this waste
                  A

is to be considered hazardous.

-------
BD-6

-------
BD-6
                           DRAFT
                    BACKGROUND DOCUMENT
          RESOURCE CONSERVATION AND RECOVERY ACT
          SUBTITLE C -  HAZARDOUS WASTE MANAGEMENT
       SECTION 3001  -  IDENTIFICATION AND LISTING OF
                      HAZARDOUS  WASTE
          SECTION  250.14  -  HAZARDOUS  WASTE LISTS
                    RADIOACTIVE WASTE
                                       DECEMBER IS,  1978
        U.S. ENVIRONMENTAL PROTECTION AGENCY
               OFFICE OF SOLID WASTE

-------
     This document provides background information and
support for regulations which have been designed to identify
and list hazardous waste pursuant to Section 3001 of the
Resource Conservation and Recovery Act of 1976.  It is being
made available as a draft to support the proposed regulations.
As new information is obtained, changes may be made in the
background information and used as support for the regulations
when promulgated.
     This document was first drafted many months ago and has
been revised to reflect information received and Agency
decisions made since then.  EPA made some changes in the
proposed regulations shortly before their publication in the
Federal Register.  We have tried to ensure that all of those
decisions are reflected in this document.  If there are any
inconsistencies between the proposal (the preamble and the
regulation) and this background document, however, the
proposal is controlling.
     Comments~'ih~wrltlhg"may be made to:
          Alan S. Corson
          Hazardous Waste Management Division  (WH-565)
          Office of Solid Waste
          U. S. Environmental Protection Agency
          Washington, D.C.  20460

-------
          IDENTIFICATION AND LISTING OF HAZARDOUS RADIOACTIVE
            WASTE PURSUANT TO THE RESOURCES CONSERVATION AND
                      RECOVERY ACT (RCRA) OF 1976
               Application of Generic Numerical Criteria
 I.  INTRODUCTION

     Numerical criteria were considered for use as uniform measures of

hazard for radioactive waste in the initial development of Section

3001.  This approach was viewed as the optimal one at the time because

it provides relative ease of implementation by both regulator and the

industry being regulated, and insures consistency of regulation with

respect to criteria being proposed for other hazard characteristics

under RCRA.  Uniform criteria, for example, could be applied to all

waste streams, regardless of origin (except where restricted by the

Act), where elevated concentrations of natural radionuclides are

present.  These criteria would be used both to determine compliance

with RCRA permit requirements and eligibility for relief from Section

3001 listing.

     The development and application of this regulatory approach,

however, is predicated on the availability-of-supporting data.  The

extent to which data is available to characterize various wastes and

the extent to which this data substantiates the correlation of hazard

level (radiological impact) with waste concentration (i.e.,

radionuclide content), will determine whether uniform criteria can be

practically implemented.  For diffuse radium-containing waste,

supporting information is largely available for only the phosphate and

-------
                                   2



uranium industries, where the radiological  impact of major  waste



streams has already been evaluated to a  large degree.  This  particular



body of data is supportive of a uniform  hazard  criterion  for



radium-226, the critical radionuclide involved,  between 5 and  10



pCi/g, based on known radon emanation and diffusion rates,  with the



radium-radon exposure pathway being the  prime one of concern.



     The following discussion serves a two-fold purpose:  1)  to provide



rationale and general background  for the 'proposed classification  of



certain wastes containing radiura-226 as  hazardous under RCRA,  and 2)



to  propose  a framework  for development and  implementation of numerical



concentration criteria  for these  and other  wastes in Section 3001.



The Agency  will pursue  the development of such  criteria on  a timely



schedule and requests that interested parties submit any  information



or  comments they  feel relevant  to this development.  A determination



will be made by the Agency shortly following the closing  of the ANPR



comment period concerning the  feasibility of this latter  approach for



regulating  radioactive  wastes  under Subtitle C  of RCRA.








II.   BACKGROUND



      Under  Section  1004(5) of  the "Resource Conservation  and Recovery



Act of 1976" (RCRA  or "the Act")  solid waste materials which may  cause



an  increase in mortality are  termed hazardous waste, and  therefore



must be considered  under the  hazardous waste management provisions of



Subtitle C  of the Act.   Since  all radioactive materials satisfy  this

-------
                                   3
criterion in the absolute sense, it is necessary to consider all
wastes which contain significant concentrations of radioactivity.
Excluding those activities or substances subject under the Atomic
Energy Act of 1951 (as required by RCRA Section 1006(a)), the
radionuclides of concern can be categorized as either naturally-
occurring or accelerator-produced.
     Naturally-occurring radioactive materials are those containing
radionuclides which are present in the earth's crust or atmosphere as
the result of natural processes.  Among these, uranium-238,
uranium-235, and thorium-232, and their respective decay products, as
well as potassium-HO, carbon-14, and tritium, are the principal
radionuclides of interest.  The latter three are isotopes of elements
which are significant constituents of human tissues.  Prom the
standpoint of avoidable human radiation exposure, though, only members
of the uranium and thorium decay series are usually significant.
     Nuclides of the uranium and thorium decay series are present in
elevated concentrations in certain minerals, and are typically
redistributed by extraction processes, especially in the mining and
milling of uranium, thorium, and phosphates.  These large volume
sources can be characterized as low-level diffuse wastes by virtue of
their relatively low specific activity.  Radiun-226 concentrations in
uranium mill tailings, for example, on the average range from 600 to
700 picocuries per gram of tailings (Swift,  1976), with maximum
concentrations in excess of  1500 pCi/g (Hendricks, 1978).  This

-------
compares with the average terrestrial concentration of  about  one

picocurie per gram for igneous or  sedimentary  rocks,  and  about  half a

picocurie per gram for soil  (NCRP  45, 1975,  UNSCEAR,  1977).   For

phosphate mining and milling wastes, average radium concentrations of

30 to 60 picocuries per gram for slimes,  byproduct gypsum,  and

byproduct slag have been observed  (Guimond,  1975).

     Discrete radium sources, which are widely used in  medical  and
                                                                    »
commercial applications, are potentially  hazardous if not handled

properly.  Overall use is now decreasing,  due  in  large  measure  to

technological advances and radiological health considerations.

However, according to the most recent survey available, over  1300

curies  of radium (1.3 kg) have been distributed by various

manufacturers through 1971 (Pettigrew, et al.,  1971).   Of this  amount,

State licensure and registration data accounted for usage of  480

curies  of radium at 4200 facilities.  Approximately 330 curies  of this

total are contained in about 50,000 medical  sources at  2300 medically

related facilities.

     Excluding  those sources known to be  in  disposal  or storage,  the

remaining ones  are generally either unaccounted for or  have been

incorporated as low activity sources into various consumer products

(e.g.,  timepieces, smoke detectors, gauges,  etc.).  Such  products may

contain up to one millicurie of  radium-226 (UNSCEAR,  1977).

     A  wide variety of accelerator-produced  radioisotopes are in  use

today,  particularly in the area  of medical and biological applications

-------
                                   5

(NEC, 1977).  Cobalt-57 sources, for example, have widespread use  in  a

number of items, such as anatomical markers which are designed  to

enhance the ability of the physician to outline areas of  the body

during radiography.  Other sources such as cesium-131, mercury-197 and

bismuth-206 are used in various organ scanning procedures.
                                                   *
     Due to physical-and chemical requirements for their  application

in medicine, the majority of the material used is small in  quantity

and short-lived, with half-lives of minutes to days.  Cobalt-57, with

a half-life of 0.25 year, for the most part represents the  upper bound

in longevity for those materials in widespread use.  Their  disposal as

radioactive waste is therefore unlikely to pose a significant problem,

since they can easily be retained for a sufficient amount of time  to

insure sufficient decay before disposal.  Wastes from industrial and

research applications of accelerator-produced radionuclides likewise

do not represent a hazard for the same reasons.



III. IDENTIFICATION OF HAZARDOUS RADIOACTIVE WASTE

     Radium-226, a radlonuclide in the uranium-238 series (Figure  1),

is the only radlonuclide proposed to be identified as hazardous in

waste materials under the Act at this time.  The potential  health

impact of this  radionuclide is associated primarily  with  its emissions

of gamma rays and alpha particles from it and its decay products.

Listing of  radium-226 is based on its persistence and relative

abundance in the environment, radiotoxlcity, and presence in waste

-------
                                                                           I ••• M>lf*«4
                                                                                    ttttmt »ti*
-------
                                   7



materials as a result of man's activity  , which  together  result  in a



relatively higher degree of potential hazard for it  than  for  other



radioactive materials discussed above.  On a more pragmatic basis,



radium-226 requires regulatory consideration under the  Act because of



the potential health hazard to the public from existing uranium  mining



and wastes in the Western plateau, phosphate mining  and milling  wastes



in Florida and Idaho, and other mineral extraction wastes for which



uniform Federal or State regulations do not exist.



     The following radioactive materials, among  others, will  be



reviewed for possible future identification:



           Thorium-228



           Thorium-230



           Lead-210



           Polonium-210



           Radium-224



           Radium-228



           Blsmuth-207







IV.  RATIONALE FOR REGULATION OF RADIQM-226 UNDER RCRA







     A.  Persistence and Relative Abundance in Environment



     Radium-226 is an alpha emitter with a half-life of 1620  years



which decays to the radioactive noble gas, radon-222.   Radon  itself,



decays with a half-life of 3.8 days, leading to  a series  of

-------
                                   8



short-lived, alpha emitting radionuclides which  decay  in  succession  to



the longer lived lead-210  (half-life of  22 years),  poloniura-210



(half-life of 138 days) and eventually,  lead-206, which is  stable.



Being largely an alpha emitter  (96J),  the gamma  component usually



associated with radium-containing  materials  is  primarily  due to



daughter  decay.



     Radium-226 is naturally  present  in  soils  throughout  the United



States in reported average concentrations ranging from about 0.2 to  3



picocuries per gram.  Certain types of rock, such as igneous,  have



been found to contain a slightly higher  average  content of  radium than



other  types, such as sandstone  and shale.  Likewise,  for  specific



mineral  ores, such as coal and  phosphate, increased radium



concentrations as much as  an  order of  magnitude  above  "background"



levels  have  been noted.  Increased concentrations such as these  are



primarily the result of geochemical action over  time.







     B.   Radiotoxicity



     The  ubiquitousness of radium  in  the environment and  its



usefulness in various commercial applications  has led  to  extensive



epidemiological and health effects data  on human exposure to radium



and its  decay products.  The  reported  instances  of



occupationally-related bone cancer and aplastic  anemia in radium dial



painters  is  a classic example.   During the years 1917  to  1924,



approximately 2,000 individuals were  employed  in the luminous dial

-------
                                   9
industry in this country, where radium containing  phosphorescent  zinc
sulfide paint was used.  The "tipping" of paint  brushes  by  the
painters with their lips led to the continuous ingestion of radium  and
eventually to clinical manifestations.  Since the  initial radium  dial
painter studies of the 1920's, over 700 cases of radium  ingestion have
been surveyed.  Fifty deaths in the United States  have been attributed
directly to radium exposure and more are likely  to have  been
unreported.
     As a general rule, radium is  transported in the  environment  and
absorbed by plants in a manner similar to calcium,  which is necessary
for plant metabolism.  Since it has chemical characteristics similar
to calcium, radium is likewise absorbed and enters the food chain.
The degree of impact on humans through this pathway is dependent  upon
the characteristics of the soil, the concentration of radium available
for uptake, and whether the plant  is directly eaten (i.e.,  the  degree
of concentration by animal intermediaries).  The ingestion  of radium
through drinking water has also been of concern  where elevated
concentrations exist by virtue of  either natural or technically
enhanced sources.  After ingestion, radium concentrates  in  bone where
the tabecular and surface tissue received the highest exposure.
     Depending on whether an absolute or relative  risk estimate for
bone cancer, leukemia, and all other cancers is  assumed  as  calculated
in the National Academy of Sciences-BEIR  report (1972), an
    *Biological Effects of Ionizing Radiation

-------
                                    10



annual rate of total cancers  from  radium  ingeation of 5 or 20 per



million person-rem/year  is  estimated,  respectively.   Therefore,



applying the International  Commission  on  Radiological Protection



(ICRP) estimated dose  to  bone of 0.15  rem per year from an ingestion



rate of 10 pCi of  radium-226  per day,  the annual  rate of induced



cancer is between  0.7  to  3  cancers per year per million exposed



persons (EPA,  1976b).



     With regard to  external  exposure, the penetrating gamma radiation



of the radium  decay  products  is of primary concern.   For such "whole



body" exposure, proximity to  the source,  the size and geometry of the



source, and  its activity are  factors affecting the degree of exposure.



Assuming an  exposed  population, total  body irradiation would be



expected  to  result in  200 lethal and  200  non-lethal cancers per  year



per  10 annual  person-rem, as  well  as  200  serious  genetic abnormalities



per  rem per  10 live  births (NAS/BEIR,  1972).




      The major public  health  hazard of radium, however, is not due to



ingestion  or external  exposure,  but more  often is due to inhalation of



its  decay  products.  Radon-222,  the first generation decay product of



radium-226,  is a  radioactive  noble gas which has  a relatively short



half-life  (3.8 days).   The decay products of radon-222, several  of



which decay  by alpha particle emission, through inhalation can deposit



in and irradiate  the lung.  The  observed  result of exposure to radon



decay products at  relatively  higher levels of cumulative exposure has



been the induction of  lung cancer.  This  response has been



demonstrated by extensive epidemiological surveys of underground

-------
                                   11

uranium miners in this country and miners in a variety of mining

operations in other countries.  This data indicates an increase in

lung cancer over normal incidence of approximately 2  to  5 percent per

working level month  cumulative exposure  (Ellett,  1977).  The  basis

of this estimate and the qualifying factors  related to its  derivation

are given  in Ellett, 1977.

     Data  are not available  to demonstrate  unequivocally a linear,

non-threshold dose-effect  relationship  at doses  as low as those

usually found in the environment.  However,  the  data  from the miner

studies are consistent with  a  linear non-threshold hypothesis down to

the higher levels measured in  some structures  in Grand Junction,

Colorado,  and in Central Florida.  It  is  therefore prudent to assume

that  on  the basis of this  aa well as more general experience with

radiation exposure, that individuals occupying structures with

elevated  levels  of  radon are subject  to a potential hazard for

induction of  lung  cancer in  proportion  to the  total accumulation of

exposure  they experience.



      C.   Ubiquitiousness of  Radium-226  in Waste  Materials

      Due  to its  presence in  byproducts  and  wastes of  a number of
     *Working level month (WLM):  exposure to 1 working level (WL) for
170 hours (a working month).   Continuous exposure to radon daughters
at  1 WL for one year is  equivalent  to 36 WLM.  A working level is
defined as any combination of short-lived radon daughter products in
one liter of air that can result in the ultimate emission of 1.3 x
     MeV of alpha energy.

-------
                                    12



mineral extraction industries, as well as  its continued application  in



many medical sources and commercial products, the  total quantity of



radium in distribution has increased steadily.  The  following  is a



partial list of sources and processes in which radium may be found in



significant quantities:



           Ore mining and milling



             (including tailings, slag, waste rock,



             etc., from the uranium, thorium, zirconium, heavy metals,



             and phosphate industries)



           Fossil fuel use (ash and scrubber sludge)



           Water Treatment (sludge)



           Commercial products, including:



              Smoke detectors



              Lightning rods



              Static eliminators



              Radioluminous sources



              Industrial gauges



              Vacuum tubes



              Vacuum gages



              Ion generators



              Well logging devices



              Calibration and  check sources



              Educational materials



           Medical diagnostic  and therapeutic sources including:



              Needles, capsules and tubes

-------
                                   13



              Plaques



              Nasopharangeal applicators



              Radon seeds



     Of these sources, wastes from mineral extraction and discarded



radium sources represent the major ones of public health concern.



Their production and distribution into the general environment may



result in contamination with a potential for long-term, or chronic,



public health impact and, in the case of discrete sources, more acute



hazards.  Continuing efforts to assess and control potential hazards



due to radium have been ongoing at the State and Federal level, as



evidenced by the EPA and the State of Florida phosphate program, the



Joint Federal/State mill tailings project, and reports of the



Conference of Radiation Control Program Directors (1977) and NRC's



Task Force on Naturally Occurring and Accelerator Produced Radioactive



Materials (NARM) (1977).







           a.  Diffuse Radium-containing Wastes



     This category consists of waste which contains  radium dispersed



throughout a non-radioactive medium at a relatively  low concentration,



which would make chronic exposure to the waste and the decay products



of radium of principle concern.  The elevated radium content of  these



wastes results primarily from the extraction and processing of mineral



ores, which due to geochemical factors are enriched  in radium.  These



process sources, examples of which are listed in Table 1, are large in

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             TABLE 1

DIFFUSE RADIUM-CONTAINING WASTES
       (PARTIAL LISTING)*
Process Source
Uranium ore milling
Phosphate mining


Phosphoric Acid
production
Elemental phosphorus
production

Zirconium extraction
Water Treatment
Coal Combustion
Waste Material
tailings
slimes
sand tailings
raining debris
gypsum
slag
Fluid bed p-ills
chlorinator res.
clarif ier sludge
sludge (lime)
ash
Average
Primary Re*-226
Locality pf Cpncentration
Production (pCi/g)
Western Plateau
Florida


Florida
Idaho
North Carolina
Florida
Idaho
Florida/Tennessee**
Florida
Idaho
Oregon
National
National
600-700 (a)
45 (b)
8 (b)
13 (c)
33 (b)
23 (d)
56 (b)
35 (c)
18 (b)
13 (e)
150-1300(f)
6-9 (g)
1-8
Annual Tota.1 Average
Quantity Annual
Produced Activity
(million MT) (Ci)
9 (i) 6000
32 (b) 1500
49 (b) 400
-
23 (b) 800
4.5 (b) 200

0.3
-
_ _
        (Tat   cont'd)

-------
 * Others for which substantive data is unavailable include  some  heavy metal, copper, rare earth, and coal
   extraction and processing wastes.

** One plant using a blend of Tennessee and Florida Ores.
(a) Swift, et al., 1976                   (g)  Brink,  et al.,  1976
(b) Guimond and Windham, 1975             (h)  Martin, 1970
(c) Eadie, et aj.., 1977a                  (i)  Hendricks,  1978
(d) Eadie, et al., 1977b
(e) University of Florida,  1977
(f) Oregon State Health Division,  1977

-------
                                    16



volume and therefore disposal is less practicable than  for  discrete



radium sources.  One non-mineral extraction waste listed, water



treatment sludge, results from the  removal of  various contaminants,



including radium, from drinking water in order to satisfy Safe



Drinking Water regulations  (1976b).



     Because of  the relatively low  activity and diffuse configuration



of these wastes, the exposure pathways of major concern are inhalation



from radon emanation and, to a lesser degree,  direct gamma



irradiation.  Both pathways of exposure have been found in  structures



constructed with uranium  tailings material in  Grand Junction,



Colorado, and on phosphate  reclaimed land in Central Florida.



Concerns resulting from the use of  radium-containing raw materials,



such as  by-product gypsum and coal  ash, in construction materials have



also been raised (O'Riordan, «st al  ,  1972; Hamilton, E.I.,  1972;



Moeller  and Underhill,  1976).  However, while  uranium,  phosphate, and



zirconium ores characteristically contain elevated  radium



concentrations,  the  radium  content  of coal, heavy metal source  ores,



and water treatment  sludge, among others, vary considerably by  virtue



of geochemical and hydrogeological  factors.  Some waste materials,



such as  coal ash, may  also  have physical properties  related to  their



formation which  would  decrease radon emanation and  diffusion.   The



public health hazard posed  by  these wastes, therefore,  would vary



considerably as  a result  of these factors.

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                                   17

           b.  Discrete Radium Sources

     The radiological characteristics of radium have encouraged its

use in numerous medical, industrial, and military applications, as

well as in consumer products, as shown in Table 2.  It is extremely

difficult, though, to quantify the potential waste source resulting

from this broad use over the past several decades.  At present, no

reporting is required on a national scale of the amount of  radium

disposed or recycled.  To give some indication, since 1964, over 2,300

disposed sources have been sent voluntarily to the Federal  radium

repository now operated by EPA at Montgomery, Alabama.

     In a recent FDA report  (1975), roughly twice as much radium was

reportedly used in medical as in non-medical applications,  with 330

curies contained in 50,000-55,000 medical sources at 2300 facilities,

and 150 curies for non-medical applications at 1900 facilities.

Radium users constitute about ^8% of users of radioactive materials

who are subject to licensing by State programs having that
          «
authority.   The HRC Task Force on the Regulation of Naturally

Occurring and Accelerator-Produced Radioactive Materials  (NRC, 1977)
     This percentage, therefore, excludes  the  use of radium sources
in Federal facilities.  Of the total  50 States,  which individually
have the regulatory authority to establish programs  for licensing or
registering users of HARM, 30 States  have  licensing  programs  and  16
have registration programs.  The remainder have  liminted programs or
in one case, no program.

-------
                                TABLE  2.

                   DISCRETE RADIUM-CONTAINING SOURCES*
Source Type
CONSUMER PRODUCTS
1. Radioluminous
Products
-
2. Electronic and
electrical
devices

3. Antistatic
devices

4. Gas and aerosol
detectors
MEDICAL SOURCES
1. Sealed sources
	 	 	 _. _ „ _ .. .


INDUSTRIAL
1. Sealed sources
Product
Timepieces
Aircraft Instruments
Electronic tubes
Fluorescent lamp
starters
Lightening Rod
Antistatic devices
contained in instru-
ments
Smoke and fire
detectors

Needles, tubes, cells
and capsules
Plaques
Nasopharyngeal
Radon seeds

Well logging
Radiography
Uncontrolled
Activity Distribution
per Source to public
0.1-3uCi
,< 20jiCi
O.luCi
luCi
0.2-lmCi
IQuCi
0. 01-15 uCi

l-50nCi
5-25mCi
SOmCi
•v ImCi

10-50mCi (gamma)
300-600mCi
(neutron)
10-lSOmCi
Wide
Limited**
Hide
Wide
Wide
Wide
Wide
Wide

Limited**
Limited**

Limited***

Limited**
Limited *»
 * Data extracted from UNSCEAR, 1977 and Pettigrew, et al.. 1971
** Limited is used here to denote that no planned distribution to the general
   public is forseen.

-------
                                   19
noted that the health and safety control by these users has been a
continuing problem to State authorities.
     The principal hazard from medical and industrial uses of radium
is the possibility of an acute exposure.  By far the most common
medical source has been the radium needle, whose primary use is
internal implantation for irradiation treatment of malignancies.
Other medical sources, such as plaques and nasopharyngeal applicators,
also contain similar concentrations of radium which  can result  in  an
acute exposure.  Accounting of the many sources in existance and those
lost or disposed of has been inadequate.  Many State regulatory
authorities involved in the control of such hazards  have  reported
instances where sources have reached the general environment,  and  in
some cases the general public, via accessible trash  and garbage from
medical and industrial facilities.  There is a clear need for  uniform
regulation of discarded radium sources and radium-containing products
to insure proper accountability  and disposal practices.
     For the most part, consumer products containing radium are likely
to be disposed of as household refuse.  However,  the disposal  of such
discarded sources is not  likely  to be  significant  because of more
restrictive national and  international  controls  which limit the
quantities and types of  consumer product application.   An annual
average gonadal dose of  less  than  1 mrad has  been  calculated for all
disposed  consumer products  containing  radioactive  material of  any kind
(UNSCEAR,  1977).  -

-------
                                    20

     In summary, wastes containing  elevated  concentrations  of

radium-226 are proposed to  be  listed as  hazardous  under  this  Act

because:

     a.  Radium poses a recognized  potential hazard  to health.

Factors which contribute  to the  significance of  this hazard include

its long half-life and relatively high radiotoxiclty;

     b.  Radium-226  is found concentrated  in both  diffuse and discrete

waste  to levels significantly  in excess  of its average natural

physical abundance;  and

     c.  There is currently uncontrolled widescale distribution of

products,  byproducts  and  wastes  containing radium  in the environment

resulting  from man's  activities.



V.   PROPOSED NUMERICAL HAZARD CRITERIA  FOR  RADIUM

     A radium-containing  waste is proposed to be designated as a

hazardous  waste for  the purposes of this Act if  a  representative

sample of  the waste  has either of the  following  properties:

      (1) The average  radium concentration  equals or  exceeds 5

picocuries per gram  for solid  wastes,  or 50  picocuries per  liter for

liquid wastes (for the latter, radium-226  and radium-228 combined)

      (2) The total activity of any  single  discrete source equals or

exceeds  10 microcuries.
    *The radium  criterion  for  liquids  is  based  in part on the EPA
Drinking Water regulation  which  requires  measurement of combined
radium-226 and radium-228  as part of its  analytical regimen.

-------
                                   21

Perspective

     In proposing these numerical hazard criteria for radium-226,  it

should be recognized that they do not constitute "de minimus" levels,

i.e., radiation levels below which exposure is considered negligible.

Rather, they specify which wastes are sufficiently high in radium

content to involve a high expectation of hazard should the wastes  be

mismanaged under circumstances reasonably expected to occur.  Under
                                   I
these criteria, diffuse wastes which because of their small quantity

and configuration, or their radon emanation characteristics, are not

hazardous via the pathways described may also be included.  This

likelihood represents the most important hindrance to the use of these

radioactive waste criteria in a uniform manner and will be addressed

in Section VI.  For radium-containing wastes with concentrations less

than those established by these criteria, the well established  federal

radiation protection requirement that any radiation exposures be

maintained as far below limiting radiation protection standards "as

practicable" or "reasonably achievable" remains in effect.

Rationale

     Solid Waste Concentration Criterion

     The radium source-term criterion of 5 pCi/g is based primarily on

consideration of the radium-radon exposure pathway and on levels

experienced for observed concentrations in waste materials.  This

pathway is given prime consideration because of the hazard of lung

cancer induction associated with the chronic inhalation of radon decay

-------
                                   22

products originating from radon diffusion into structures  from

underlying radium-containing material.  This pathway, which may  be of

significance at radium concentrations equal to or in excess of the

proposed criterion, is the major radiological health concern  for

radium-bearing waste materials of this type.  Data  for  this situation
                                            »
is available from ongoing studies in Florida  and from  studies

conducted of housing built over uranium tailings in Grand  Junction,

Colorado (Culot, ejt al,  1973).

     Indoor radon decay  product concentrations in structures  built on

normal  soils throughout  the U.S. are usually between  .001  and .007 WL,

with the average around  .003 WL.  Preliminary EPA data  for twenty-two

structures in Florida  showed that in general the radon  progeny

concentration of structures increases  as  a  function of  soil  radium

 ~~ .tent.  This  data was  derived from the  average radium concentration

    core samples  taken  (to  a maximum  depth of  three  feet) at  the  site,

    well as average TLD air sampling measurements for radon decay

 ;.'oducts.  These average measurements  are plotted  in Figure 2.
     "being performed, respectively, by the Environmental Protection
 Agency (Office of Radiation Programs), the State  of Florida
 (Department of Health and Rehabilitative Services) and the University
 of Florida (the latter under contract to the Florida Phosphate
 Council).   An EPA technical report providing detailed information on
 health effects associated with radon decay product exposure on
 phosphate  land in Florida and available control options will be
 published  in January-February 1979.

-------
V*!?.
                                   -&gid&j^y&~jyr&isvs<>
                              *V&

                         p:cocuries  per

-------
                                   21

     It is recognized that measurement error  ( + 25% for  TLD air

sampling) and the relatively small sample size are qualifying  factors

in drawing firm conclusions on a defined correlation between soil

radium and radon progeny concentrations in structures.   However, the

relationship is sufficiently defined to permit broad projections for

radium concentrations in excess of 5 pCi/g.   As Figure 2 shows, for

structure sites with such soil concentrations, it is likely that

indoor radon progeny concentrations considerably in excess of  normal

background levels can be observed in many structures.  From health

effects information analyzed to date (Ellett, 1977), exposure  to

indoor radon decay product levels in excess of .01 WL (including

background), a level which can be associated  with land containing

greater than 5 pCi/g of radium-226, is estimated to result in  an

increased lung cancer risk of greater than 1  percent over the  normal

risk.  This is based upon occupancy of the structure 75  percent of

the time.

     The University of Florida, as part of its study of  the

radiological impact of radon in structures on Florida phosphate land,

has also collected data for the relationship  between soil radium

concentration and indoor radon progeny levels as a function of land

type for a relatively small sample of structures.  Their data  show
    *With a normal incidence of lung cancer  in  the United States  of
about 40 per 100,000 per year, this represents  an increase of  .U  per
100,000 per year at  .01 WL above background  (about 30  cancers  per
100,000 over a lifetime assumed to be 70 years).

-------
                                   25



significantly elevated indoor radon decay product concentrations in



structures located on soil containing moderate radium concentrations



(2 to 7 pCi/g) (University of Florida, 1977).



     These latter observations are consistent with the EPA findings,



although it is recognized that the values observed in both studies may



not be representative of radium-indoor radon progeny relationships in



a more extensive sample obtained in a wide geographical area.



     Healy and Rodgers (1978) in their review of exposure pathways to



the population from radium contaminated soils concluded that  the most



limiting pathway is the emanation of radon into residences.   As shown



in Table 3, they indicate that given an assumed exposure limit of 0.01



WL, a soil concentration of 3 pCi/g would be the corresponding limit



for soil radium contamination.  This soil level is comparable to



average natural concentrations found in many parts of the country.



Their correlation is based on derived emanation rates of radon through



various soil  types and a "barrier factor" of 0.2 for transport of



radon through a structure's foundation.  The correlation provided by



this theoretical model compares favorably with the field data graphed



in Figure  2.



     Using the Federal Radiation Council (FRC) guidance of  170 mrem



whole body exposure per year to a member of the general public  (Fe60),



a corresponding soil concentration limit of 11 jjR/h  is calculated by



Healy and  Rodgers.  With the 3 pCi/g estimated limit, this criterion



defines a  narrow range of consideration (5-10 pCi/g, with appropriate

-------
                                   26
                                TABLE 3

             SUMMARY OF RADIUM LIMITS FOR INFINITE DEPTH OF
                 CONTAMINATION AND A SANDY SOIL (He 78)
                                                        Derived Level
Condition                      Dose Used                (pCi/g Radium)
Radium Resuspension         0.01 uCi - bone             7 000 pCi/g

                            0.5 rem/y - lung            2 000 pCi/g

Radium in Foods             0.01 uCi - bone

  Home Gardner                                            300 - 700

  All foods                                                80

External Dose               0.17 rem/y                     11

Rn Downwind                 0.01 WL

  Small area (35 000 m2)                                  U90

  Large area (6.6 x 107m2)                                  5

Rn in Home                  0.01 WL                         3



consideration of practicality and implementation) for wastes whose

hazard is due principally to radon decay products or gamma exposure,

or a combination of both.

     Indoor concentrations greater than  .005 WL have been measured  for

structures located on sites with soil radium concentrations at or near

natural background levels (e.g., 1-3 pCi/g for Florida).  Notwith-

standing the possibility of some structures having undesirable indoor

radon decay product levels at soil radium concentrations less than  5

-------
                                   27



pCi/gram (due, in part, to uncontrollable factors such as indoor



ventilation), it is impractical to provide and implement effective



control measures at such levels.  Likewise, for radium concentrations



at or near background, a degree of hazard in excess of that



attributable  to normal background levels cannot practicably  be



delineated on a generic, national basis.



     Given these considerations, the criteria should prudently  achieve



a balance between minimizing public health risk, and the practical



considerations of measurement and regulatory implementation.  The 5



pCi/g criterion level achieves this balance through reflection  of



available information concerning hazardous radium concentrations in



diffuse wastes, with the inclusion of only those wastes whose radium



content and proximity to the population necessitates their



consideration under the Act.



     Liquid Source Term Criterion;



     The 50 pCi/1 criterion for liquid waste is based on the EPA



Drinking Water Regulation of 5 pCi/1 for radium (226 and 228) (EPA,



1976), with a 10-fold dilution factor.  This dilution factor, which  is



uniformly applied in the RCRA Section 3001 toxicity characteristic to



substances for which a corresponding Drinking Water regulation  exists,



is based on the assumption of a 500 feet minimum distance from  a



landfill or similar disposal site to the nearest potable water  well.



Radium-228 is included in the characteristic solely for measurement



purposes in order to provide consistency with the Drinking Water

-------
                                   28



standard, which stipulates an analysis of combined radium-226 and



radium-228.



     Total Activity Criterion;



     The basis for this criterion is the Suggested State Regulations



for Control of Radiation (SSRCR), Part D, Section 304(a), and 10 CFR



20.30Ma) which specify for disposal by burial in soil:



     No licensee shall dispose of radioactive material by burial in



soil unless the total quantity of radioactive material buried at any



one location and time does not exceed, at the time of burial, 1000



times the amount specified (0.01 yCi for radium-226).



     A total activity criterion is required to delineate a hazard



level for discrete sources, where direct exposure is of primary



concern.  Both alpha and gamma radiation contribute to this exposure



with the latter resulting in an estimated exposure rate of 10 UR/h at



one meter from a 10 uCi discrete radium source.  On the basis of past



experience and practice with the distribution and disposal of sources



with less radium concentration (watches, clocks, gauges, smoke



detectors, etc), it is reasonable to apply the 10 uCi criterion for



the purposes of RCRA.  This "screening level" would exclude most



consumer sources from regulatory consideration while insuring such



consideration for the majority of medical and industrial sources whose



typical millicurie activities have resulted in documented hazardous



situations (DHEW, 1975; NRC, 1977).



     Extent of Applicability of Criteria to Waste Materials;



     As Table 4 shows, the respective criteria levels proposed for

-------
                        TABLE H

PROJECTED APPLICABILITY OF PROPOSED RADIUM.-226 CRITERIA
            FOR SELECTED APPLICABLE HASTES
                                                                  Relative
Process Source
Product Use Before
Deposition
DIFFUSE
Uranium Ore
milling
Phosphate


Phosphoric acid
production
Elemental phos-
phorus production

Zirconium
extraction
Water Treatment
Coal combustion
DISCRETE
Consumer Products

Haste Material
tailings
debris
slimes
sand tailings
gypsum
slag
fluid bed |rills

chlorinator res.
clarifier sludge
lime sludge
ash
Aircraft
instruments
Potential Public
Average Health Impact
Activity Identified
600-700pCi/g
10-15pCi/g
t5 pCi/g
8 pCi/g
20-30 pCi/g
20-60 pCi/g
10-15 pCi/g


6-9 pCi/g
1-8 pCi/g

20 uCi
Yes
Yes
Possible
None identified
Yes
Yes
None identified

None identified
None identified
None identified

None identified
Degree of RCRA 6
Section 3001
Applicability
None(NRC regulated)
Complete
Complete
Partial
Complete
Complete
Complete

Complete
Partial
Partial

Partial
Magnitude of
Applicable Haste
(estimated)
Large
30 million tons
(800 acres)
Large*
IxlO11 gallons
Large*
1
Large,
300 Billion tons
I^rgf0
SxlO-1" gallons
Small*

moderate (4-5 thousands)
Moderate**
Moderate**

Small*

-------
TABLE 4 (continued)
Medical Sources

Industrial
   Lightning rod      0.2-1 m Ci

   Antistatic
   devices (con-      10 m Ci
tained in instruments)

   Smoke and
   Fire Detectors     0,01-15uCi

   Sealed sources     1-50 m Ci

   Sealed sources     10-600 M Ci
None identified   Complete


None identified   Partial



None identified   Partial

Yes               Complete

Yes               Complete
Small*


Small*



Small*

Moderate**

Moderate**
 * not definied
** not defined; however, is primarily a function of the number of waste generators exceeding these criteria
                                                                                                                          OJ
                                                                                                                          o

-------
                                   31


diffuse and discrete radium-containing wastes would encompass most


medical and industrial discrete sources, and a large proportion  (by


volume) of the wastes generated by the uranium and phosphate


extraction industries.  Potential hazards have been identified for all


of these wastes except those of marginal concentration or  activity,


such as phosphate sand tailings and consumer products containing very


small amounts of radium.


     The extent to which each waste category is  applicable to  the Act


with regard to its respective criteria depends on the variability of


radium concentration or quantity, with only a small fraction of  some


waste categories being in excess of the proposed criteria.  Wastes


which only marginally or non-uniformly fall within the criteria


consist largely of diffuse wastes such as water  treatment  sludge and


coal ash whose radium concentrations are a function of the


radium-content of their source material.  For discrete sources,  most


medical and industrial sources would qualify, while consumer

        »
products  whose activities for readily accessible sources  rarely


exceed 5 uCi, generally do not.
VI.   CONSIDERATIONS FOR GENERIC APPLICATION OF NUMERICAL  HAZARD
      CRITERIA FOR RADIUM-226  CONTAMINATED WASTE UNDER  RCRA
     With 5 and  10 pCi/g proposed aa  soil  radium  contamination


criteria based,  respectively,  on radon  decay product  and  gamma
    *Wastes produced  by  residential  generators  are  exempted  under
RCHA Section  3001.

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                                    32



exposure hazard, the key to implementation in Section  3001  of  RCRA  is



the proper application of these numerical criteria  to  wastes which  may



or may not be characteristically hazardous by one or the  other route.



While self-shielding may result in  lower gamma  levels  than  expected,



this would be a relatively minor factor except  where material



densities are extremely high  (e.g., lead or zinc extraction waste,  for



example).  The more important consideration is  the  radon  emanation  "



fraction.  The emanation fraction,  the measure  of radon release from



the surface of a radium-containing  material, varies by the  physical



characteristics of the waste  material.  This fraction  or  ratio varies



considerably from one type of waste to another, which  clearly  poses a



problem to the development of a uniform definition  of  hazard based



solely on concentration.  One option would be to incorporate an



emanation fraction criterion  into  the regulations as given  in  the



following example:



     Waste would be listed under Section 3001 for either:



     1) gamma exposure hazard, if  the average concentration of the



     waste is equal to or in  excess of  10 pCi/g (about 20 yR/h



     continuous exposure), or 2) radon decay product exposure  hazard,



     if the emanation fraction is  equal to or in excess of  0.1



     (typical soil including  waste  materials, such  as  uranium  and



     phosphate mining waste have fractions of approximately 0.2), and



     the average concentration of  waste is equal to or in excess of 5



     PCi/g;

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                                   33



     The 0.1 emanation fraction value is a factor of  two  less  than  the



0.2 fraction for phosphate overburden waste on which  the  5  pCi/g



criterion is based, and is assumed to reduce the radon  diffusion  by a



like factor which would preclude hazard designation.



     Another available option would be to implement a single criterion



6f 5 pCi/g with provision for relief if the emanation fraction is less



than 0.1 and radium content equal to or less than  10  pCi/g.  This



alternative is effectively identical to the preceding one although it



places the burden on the regulated industry to seek relief from RCRA



regulation (the other option makes it a condition  for inclusion).



     Implementation of this hazard definition for  Ra-226  in diffuse



waste would require representative sampling and analysis  to determine



average radium concentrations and emanation fractions.

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                               REFERENCES
Brink, W.L., R.H. Schliekelman, D.L. Bennett, C.R. Bell and I.M.
Markwood, Determination of Radium Removal Efficiencies in Water
Treatment Processes, U.S. Environmental Protection Agency, Office of
Radiation Programs, Technical Note ORP/TAD-76-5 (December 1976).

Conference of Radiation Control Program Directors, Inc., U.S.
Environmental Protection Agency, U.S. Nuclear Regulatory Commission,
U.S. Department of Health Education and Welfare, Guides for Naturally
Occurring and Accelerator Produced Radioactive Materials (NARM), HEW
(FDA)77-8025, Prepared in support of PHS 223-76-6018 (July 1977)

Culot, M.V.J., and K.J. Schiager, Radon Progeny Control in
Buildings, Final Report under EPA R01 EC00153 and AEC AT(11-1)-2273,
Colorado State University, Ft. Collins Colorado (May 1973).

Eadie, G.G., J.A. Cochren and G.A. Boysen, Radiological Surveys of
Idaho Phosphate Ore Processing—The Wet Process Plant, U.S.
Environmental Protection Agency, Office of Radiation Programs (DRAFT).

Eadie, G.G., D.E. Bernhardt and J.A. Cochran, Radiological Surveys
of Idaho Phosphate Ore Processing—The Thermal Process Plant, U.S.
Environmental Protection Agency, Office of Radiation Programs,
ORP/LV-77-3 (1978).

Ellett, W.H., "Exposure to Radon Daughters and the Incidence of
Lung Cancer," Presented at American Nuclear Society Meeting,
December 1, 1977, San Francisco, California, U.S. Environmental
Protection Agency, Office of Radiation Programs.

Guimond, R. J., and S. T. Windham, "Radioactivity Distribution in
Phosphate Products, By-products, Effluents, and Waste," U.S.
Environmental Protection Agency, Technical Note ORP/CSD-75-3 (August
1975).

Hamilton, E.I. (1972), D.J. Beninson, A. Bouville, B.J. O'Brien and
J.O. Snies (1975), "Dosinetric Implications of the Exposure to the
Natural Sources of Irradiation," Presentation to the International
Symposium on Areas of High Radioactivity, Pocos de Caldas, Brazil.

Healy, J.W. and J.C. Rodgers, A Preliminary Study of
Radium-Contaminated Soils, Los Alamos Scientific Laboratory,
LA-7391-MS, October 1978.

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                                  H-2

Hendricks, D.W., Director, EPA/ORP Las Vegas Facility,  Memorandum
of February 23,1978, to Dr. William A. Mills, Director, Criteria &
Standards Division, EPA/ORP.

Martin, J. E., E. D. Harvard, and D. T. Oakley, "Radiation Doses from
Fossil-Fuel and Nuclear Power Plants," Power Generation and
Environmental Change, Chapter 9, MIT Press,  Cambridge~7 Mass.,  (1971),
paper presented at the Symposium of the Committee on Environmental
Alteration, American Association for the Advancement of Science, pp
107-125 (1970).

Moeller, D.W. and D.W. Underbill (1976), Final Report on Study of the
Effects of Building Materials on Population Dose Equivalents,  Harvard
University, School of Public Health, Boston, Massachusetts,
EPA/68-01-3292.

National Council on Radiation Protection and Measurements, Report No.
45, Natural Background Radiation in the United States, Washington,
D.C.  (1975)

National Academy of Sciences, The Effects on Populations of Exposure
to Low Levels of Ionizing  Radaitiaon, Report of the Advisory Committee
on the Biological Effects  of Ionizing Radiation, Washington,  D.C.

O'Riordan, M.C., M.J. Duggan, W.B. Rose and G.F. Bradford  (1972), the
Radiological Implications  of Using By-Product Gypsum as a Building
Material, National Radiological Protection Board, NRPB-R7, Harwell,
Didcot, Berks,  London.

Pettigrew, G. L., E. W. Robinson, and G. D. Schmidt, "State and
Federal Control of Health  Hazards from  Radioactive Materials Other
Than  Materials  Regulated Under  the Atomic Energy Act of 1954," Bureau
of Radiological Health, Department of Health, Education and Welfare,
Report 72-8001,  (June  1971).

Surgeon General's Guidelines for Remedial Action in Grand  Junction,
Colorado.   (Code of Federal Regulations, Title  10, Part 12, 1970).

Swift, J. J., J. M. Hardin, and H. W. Galley,  Potential Radiological
Impact of Airborne  Releases and Direct  Gamma Radiation to  Individuals
Living Near  Inactive Uranium Mill Tailings Piles," U.S. Environmental
protection Agency,  EPA-520/1-76-001  (January 1976).

University  of Florida, College  of Engineering,  Radioactivity of Lands
and Associated  Structures, A Semiannual Technical Report Submitted  to
Florida Phosphate  Council, Lakeland,  Florida,  Gainesville, Florida,
(1977).

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                                  R-3

U.S. Department of Heailth, Education and Welfare (DHEW), Food and Drug
Administration, Bureau of Radiological Health, Radioactive Materials
Reference Manual for Regulatory Agencies, (1975)

U.S. Environmental Protection Agency, Office of Water Supply, Drinking
Water Regulations, EPA-570/9/76 (1976)

U.S. Environmental Protection Agency, Final Environmental Impact
Statement, Vol. 1, Environmental Radiation Protection Requirements for
Normal Operations of Activities in the Uranium Fuel Cycle,
EPA-520/4-74-016, Appendix B (Policy Statement-Relationship between
Radiation Dose and Effect), 1976

U.S. Nuclear Regulatory Commission, Regulation of Naturally Occurring
and Accelerator-Produced Radioactive Materials, A Task Force Review,
NUREG-0301, July  1977.

U.S. Environmental Protection Agency, Office of Radiation Programs,
Radiation Protection Activities 1976, EPA-520/4-77-005 (August 1977).

United Nations Scientific Committee on the Effects of Atomic
Radiation, 32 Session, Supplement No. 40 (A/32/40), United Nations,
New York  (1977).

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                              DEFINITIONS

background  (material); A general term describing the level of normal
radioactivity  and/or  external radiation intensity in a given area or
environment; background radiation is that produced by sources other
than  those  produced  by man, including radioactive elements in the
crust or  atmosphere  of the  earth, and cosmic radiations.

byproduct material;  Any radioactive material (except special nuclear
material) yielded in  or made radioactive by exposure to the radiation
incident  to the  process of  producing or utilizing special nuclear
material  (10 CFR 20.3).

curie (Ci); A  quantity of radioactive material  that undergoes nuclear
tranaformation at a  rate of 37  billion events per second; and
millicurie
(mCi) =  10-3 curie;  one microcurie  (uCi) =  10 curie; one picocurie
(pCi) =  10-2 curie.

half-life,  physical;  The time required for  one-half of an initial
quantity  of radioactive material to undergo nuclear .transformation;
the half-life  is a measure  of the persistence of a radioactive
material  and is  unique to each  radionuclide.

HARM: naturally-occurring  and  accelerator-produced radioactive
material.
      naturally-occurring radiaoctive material:  Material containing
radionuclides  naturally present in  the earth's  crust or atmosphere.
      accelerator-produced radioactive material: material produced
through  the nucelar' interactions made possible  by a nuclear particle
or election accelerator.

phosphogypaum: gypsum produced  as a byproduct of the phosphoric  acid
production  process.

radionuclide;  a  radioactive species of an element having a specific
mass, atomic number  and nuclear energy state.

fadiotoxicity; the  property of  a material by which it is capable of
"adversely affecting  biological  organisms through the mechanism of
nuclear  radiation.

source material; (i)  uranium or thorium, or any combination thereof,
in any physical  or chemical form; or (ii) ores which contain by  weight
one-twentieth  of one  percent (0.05$) or more of: (a) uranium, (b)
thorium,  or (c)  any  combination thereof.  Source material does not
include  special  nuclear material (10 CFR 20.3).

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                                  D-2
uranium tailings; material comprised of finely divided  sands  and clays
settled out ^df"and dried from uranium mill waste  slurries.

working level (WL): term used to describe radon daughter  product
activities in air.  Defined as any combination of short-lived radon
daughter products in one liter of air that can result in  the  ultimate
emission of 1.3 x 105 MeV of alpha energy.

working^level month (WLM); exposure to 1 WL for 170 hours  (a  working
month!.  Continuous exposure to radon daughters at  1 WL for one  year
is equal to about 36 WLM.

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BD-7
                           DRAFT
                    BACKGROUND DOCUMENT
          RESOURCE CONSERVATION AND RECOVERY ACT
          SUBTITLE C - HAZARDOUS WASTE MANAGEMENT
       SECTION 3001 - IDENTIFICATION AND LISTING OF
                      HAZARDOUS WASTE
          SECTION 250.14 - HAZARDOUS WASTE LISTS


                     INFECTIOUS WASTE
                                         DECEMBER 15, 1978
           U.S. ENVIRONMENTAL PROTECTION AGENCY
                  OFFICE OF SOLID WASTE

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     This document provides background information and

support for regulations which have been designed to identify

and list hazardous waste pursuant to Section 3001 of the

Resource Conservation and Recovery Act of 1976.  It is being

made available as a draft to support the proposed regulations.

As new information is obtained, changes may be made in the

background information and used as support for the regulations

when promulgated.

     This document was first drafted many months ago and has

been revised to reflect information received and Agency

decisions made since then.  EPA made some changes in the

proposed regulations shortly before their publication in the

Federal Register.  We have tried to ensure that all of those

decisions are reflected in this document.  If there are any

inconsistencies between the proposal (the preamble and the

regulation) and this background document, however, the

proposal is controlling.

     Comments in writing may be made to:

          Alan S. Corson
          Hazardous Waste Management Division (WH-565)
          Office of Solid Waste
          U. S. Environmental Protection Agency
          Washington, D.C.  20460

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                  Draft Background Document

         Hazardous Waste Identification and Listing

                      Infectious Waste



                                                       Page

3.1       Introduction                                   1

3.2       Solid Waste/Disease Relationships              2

3.3       Indicator Organisms                            3

3.4       The Source Approach                            4

3.5       The Current State Approach                     6

3.6       Related Federal Regulations                   22

3.7       Epidemiological Evidence                      26

3.8       Sources of Infectious Waste                   28

3.9       Definitions                                   29

3.10      Rationale for Regulation of Health Care
          Facilities Waste—Hospitals and Veterinary
          Hospitals                                     33

3.11      Rationale for Regulation of Laboratory Waste   59

3.12      Rational for Regulation of Unstabilized
          Sewage Treatment Plant Sludge                 °2

3.13      Methods for Biological Examination of  Solid
          Waste                                         83

3.14      References                                    ^'

          Appendix

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                  Draft Background Document
         Hazardous Waste Identification and Listing
                      Infectious Waste
 3.1 Introduction
     The purpose of this chapter of the background document
 is to present the Agency's rationale in determining the
 definition of infectious hazardous waste.
     To date it has been the policy of the Agency under
 Section 3001 of the Act, to define chemical and physical
 hazardous waste characteristics such as toxicity, flammability,
 and corrosivity, in quantitative terms; i.e. criteria have
 been chosen that best quantify each hazardous characteristic,
 with certain hazard levels specified for each tested parameter
 (e.g., flashpoint for flammability, pH for corrosivity).  For
 enforcement purposes, this method of quantitatively defining
 a hazardous waste is most desirable. It would follow then,
 that a similar type of definition for "infectious characteristics"
 would be the most useful one from a regulatory point of view.
     Unfortunately, such quantification of infectious
 characteristics is not possible, as will be discussed in
 this document.  Instead of specifying a certain number of
 infectious agents allowed to be present in a waste, the
Agency has chosen to define infectious waste by specifying
 the sources where disease microorganisms may occur.  After

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consultation with experts in the public health field and con-
sideration of current State regulatory programs, the Agency
has reached the conclusion that such source identification
of infectious waste is the most inclusive and enforceable
method of regulation.
3.2 Solid Waste/Disease Relationships
     Basic principles of epidemiology include a chain of events
necessary for the transmission of disease microorganisms.  In
the case of solid waste, the chain involves the production of
solid waste contaminated with disease agents, the transfer of
the disease agents from a waste to a host, and the manifestation
of the disease in a host.  The completion of this chain,
or transmission of disease, is dependent upon the optimization
of many variables.  For example, some variables include the
kinds and numbers of disease agents found in the solid waste,
the environmental conditions of the solid waste substrate,
and the capability of the disease agent to survive.  Some
variables that affect the host's susceptibility to disease
are the manner of contact with the waste, the general health
and age of the host, his or her previous contact with the disease
agent, and his or her response  (clinical versus subclinical)
to the disease agent.
     To specify a "safe" number of disease organisms allowed
in a waste would be to ignore the large number of variables
involved in the transmission of disease.  Additionally, for
certain viral and parasitic diseases, it is known that only
one organism, if successfully transmitted, can cause a
                               -2-

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 clinical  response  in a host; yet for other disease agents it
 is  known  that hundreds or even  thousands of organisms are
 necessary.  Therefore setting a safe number of organisms for
 solid  waste would  involve specifying a safe level for each
 disease agent and  providing a means to analyze for each one.
 Unfortunately,  dose levels for  all disease agents are not known
 at  present and methods of environmental sampling and analysis
 for many  disease agents have not been developed.
 3.3 Indicator Organisms
     Several  EPA contacts have  suggested the use of indicator
 organisms such as  Salmonella spp., fecal coliforms, or
 S.  aureus as  an index of overall (i.e. viral, bacterial,
 fungal, parasitic) biological hazard of a waste.  The problems
 associated with the use of indicator organisms have been
 recognized by EPA.  For water standards, the Office of Water
 program Operations originally suggested the use of fecal
 coliform  as an indicator organism to determine the effectiveness
 of  the chlorination process  (40 CFP. 133) .  This standard was
 later  deleted (FR  July 26, 1976) (1), with EPA recognizing that
 fecal  coliform is  "not an ideal indicator of pathogenic (sic)
 contamination"  but is "a practical indicator of relative disease
causing potential."
     While microbial concentration standards may be applicable
in  the evaluation  of the efficacy of wastewater treatment systems,
their  applicability as absolute quality standards remains to be
demonstrated.   A problem is that in some situations, the die-
                               -3-

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off or regrowth of indicator organisms does not always
parallel that of the disease organisms, the presence of which
they are supposed to indicate.  For example, it has been
found that certain pathogenic viruses are more resistant to
conventional wastewater treatment than are the coliforms
(Cooper and Golueke, 1977).   (2)  As such, it has been decided
that indicator organisms will not be used for purposes of
defining infectious characteristics in this regulation.
3.4  The Source Approach
     Ruling out the specification of "safe" microbial con-
tamination levels and the use of indicator organisms, EPA has
chosen to specify the solid waste sources where disease-
causing organisms are known to occur, and to define waste
from these sources as infectious waste.
     The disease-causing organisms are, for purposes of this
regulation,to be defined by CDC's "Classification of Etiologic
Agents on the Basis of Hazard."  (3)  Sources of waste where
Class 1 agents are known to occur are excluded from the definition
of infectious waste, since Class 1 agents are of no or minimal
hazard under ordinary conditions.  Sources where Class 2 (agents
of ordinary potential hazard) and up are known to occur are
included, since Class 2 agents are disease causing.  Descriptions
of the CDC Classes used to identify the infectious waste
sources are given below.
     Class 2
          Agents of ordinary potential hazard.  This class
     includes agents which may produce disease of varying
                              -4-

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     degrees of severity from accidental inoculation or
     injection or other means of cutaneous penetration but
     which are contained by ordinary laboratory techniques.

     Class 3
          Agents involving special hazard or agents
     derived from outside the United States which require
     a federal permit for importation unless they are
     specified for higher classification.  This class includes
     pathogens which require special conditions for containment.

     Class 4
          Agents that require the most  stringent conditions
     for  their containment because they are extremely hazardous
     to laboratory personnel or may cause serious epidemic
     disease.  This class includes Class 3 agents from outside
     the  United States when they are employed  in entomological
     experiments or when other entomological experiments are
     conducted in the same laboratory area.

     Class 5
          Foreign animal pathogens that are excluded from
     the  United States by law or whose  entry is restricted
     by USDA administrative policy.
NOTE:  It has been pointed out that the current CDC list does not
       include some agents of significance  (e.g. Giardia, Ascaris,
       Legionnaires bacterium) as well  as it does include one
       non-pathogen  (Naegleria gruberi).  The  reader should keep
       in mind that the  list  is periodically revised.  The most
       recently published list would be applicable.

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     The relationship between the agents in these classes
and the waste sources where these agents are found was
developed by using information found in the literature and
consultation with public health experts.  This approach
is in agreement with the Center for Disease Control, USPHS,
for sources other than health-care facilities waste; in agree-
ment with the Joint Commission on Accreditation of Hospitals
for sources of hospital waste; in agreement with NIH for
sources of laboratory waste; and with the various State
regulatory programs for other sources of infectious waste.
3.5  The Current State Approach
     Nine states have defined the infectious characteristics
of hazardous waste either wholly or in part.  Terms such as
"biohazardous," "health-services hazardous," "pathological,"
"biological," and "hazardous-infectious" are used to describe
infectious characteristics of the waste of concern.  These
examples of State definitions are shown in Table 1.
     The definitions are derived from one, or a combination,
of four methods:  a list of infectious (etiologic)  agents; a
list of infectious items that have a high probability of
being contaminated; a list of sources of infectious waste; or
a prose definition.  The one list of infectious agents
referenced is HEW's list of etiologic agents.  Table 2 shows
a composite matrix of infectious items and sources  of
infectious wastes, identifying the States that consider
each one.
                              -6-

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      It  is  interesting  to note  that not one of  these definitions
 attempts to quantify numbers of disease organisms  that would
 render a waste  infectious and that it is  these  same States that
 have  promulgated criteria for physical/chemical characteristics
 of hazardous waste on a quantitative basis similar to the
 ones  EPA is considering.  The approach that the Agency is
 taking to define infectious characteristics of waste, then,
 and the  deviance of this approach from that of defining
 other characteristics of hazardous waste, is in line with
 the thinking proposed by the most progressive State hazardous
waste management programs.
                              -7-

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                                                        TRHLB 1
                                        State Definitions Of Infectious Vfaste
        State Agency
Legislative
Authority
(if any)
        California Department
          of Health
i
CO
I
Title of
Regulation/
Guideline/
Document
Definition (s)
                  Proposed Revisions
                  to the Code, Title
                  22
                 Biohazardous waste  (infectious waste) shall
                 be defined as, but is not limited to;

                    (1)  Significant laboratory or pathology
                   waste of an infectious or experimental
                   nature which has not been autoclaved in-
                   cluding pathologic specimens  (which shall
                   include all human parts removed surgi-
                   cally or at autopsy, specimens or blood
                   elements, excreta and secretions obtained
                   from patients) and disposable fonites such
                   as bandages, dressings, casts, catheters,
                   and  tubing which has been in contact with
                   wounds, burns or surgical incisions and
                   which are suspect or have been medically
                   identified as biohazardous.

                    (2)  Surgical specimens and attendant dis-
                   posable fomites.

                    (3)  Similar disposable material from out-
                   patient areas and emergency rooms.
                           *              *«
                    (4)  Equipment, instruments, utensils and
                   fonites of a disposable fron the rooms of
                   patients with suspected or diagnosed com-
                   municable disease requiring isolation.

                    (5)  Sharps which include but are not
                   limited to needles, syringes and blades.

                   (6)  Dangerous drugs as defined in Section
                   4211 of the Business and Professions    e.

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                                                TABLE  1

                                State Definitions Of Infectious Waste
 State Agency
Legislative
AutiTority
 (if any)
 Title of
 Regulation/
 Guideline/
 Document
Definition (s)
Calif omia Department
  of Health
Assembly Bill No.
1593:  An Act to
amend Section
25116. Ch. 6.5.
Division 20, of
the Health and
Safety Code
                                      'Infectious" means containing pathogenic
                                      organisms,  or having been exposed, or
                                      reasonably  being expected to have been
                                      exposed, to contagious or infectious
                                      disease.  Articles which are "infectious"
                                      include, but are not limited to, the following:
                                               »•
                                        (1)  Wastes that xxsntain pathologic speci-
                                        mens, tissues, specimens or blood elements,
                                        excreta or  secretions from humans or
                                        animals at  a hospital, medical clinic, re-
                                        search center, veterinary institution, or
                                        pathology laboratory.

                                        (2)  Surgical operating room pathologic
                                        specimens and articles attendant thereto
                                        which may harbor or transmit pathogenic
                                        organisms.

                                        (3)  Pathologic specimens and articles
                                        attendant thereto  from outpatient areas
                                        and emergency rooms.

                                        (4)  Discarded equipment,' instruments utensils
                                        and other articles which may harbor or tran-
                                        mit pathogenic organisms from the rooms of
                                        patients  with suspected or diagnosed com-
                                        municable disease.

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                                State Definitions Of Infectious Waste
State Agency
   Legislative
   Authority
    (if  any)
Title of
Regulation/
                           Definition(s)
Illinois EPA
   Environmental
  Protection Act
Special Waste
Land Disposal
Disposal Criteria
Maryland Department
  of Natural Resource i
Safe Disposal of
  Hazardous Substance!
  Act of July 1976
OCMAR 08.05.05
  Control of the
  Disposal of
  Designated
                                              Substances
                                              Regulations
                                              .01-.18
                                              .18,  Designated
                                              Hazardous Sub-
                                              stances,  Class
                                              HI.  B (4)
                 Industrial Process Effluent - Any liquid,
                                                               solid,  send-solid or gaseous refuse gener-
                                                               ated as a direct or indirect result of
                                                               the creation of a project or the performance
                                                               of a service,  including but not limited to...
                                                               hospital pathological waste.
                                                               Hazardous Waste - Any refuse that...is
                                                               harmful or potentially harmful to human
                                                               health or the environment...due  to  its..
                                                               pathological.. .nature.
                 A "Designated Hazardous Substance" includes
                 pathological and medical wastes front
                 hospitals, laboratories, and similar
                 operations.

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                                               THSiii  1

                                State Definitions Of Infectious Waste
State Agency
Legislative
Authority
 (if sny)
Title of
Regulation/
Guideline/
Document
Definition (s)
State of Maryland
  Department of
  Health and Mental
  Hygiene
                    Proposed Regula-
                    tions for Medica
                    Waste Disposal,
                    "Subocranittee Re-
                    port to the Task
                    Force on Medical
                                             Waste Disposal -
                                             December 6, 1976
                   The term medical wastes, encompassing
                   Tnaterjgig^hjtherto rai ig^  "infectious"
                   "pathological", "contaminated", "special",
                   and "hazardous" shall be replaced with the
                   following new terms:

                    (1)  Hospital Medical Wastes - shall mean all
                    solid waste  generated within a hospital.
                    Blood and blood products  shall be included
                    in this solid waste category.

                    (2)  Nursing Hone Medical Wastes - shall
                    be defined in two categories, as follows:

                         (a)  All disposable  fonites from isola-
                         tion areas,  all dressings, pledgets,
                         swabs,  tongue depressors, plaster casts,
                         body tissues, laboratory wastes, needles,
                         syringes, I.V. apparatus, and medications
                         (as permitted under  Federal, State
                         and local regulations).

                         (b).  Additional items which nay be in-
                         cluded  in the above  category include
                         diapers and  perinea! pads.

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                                                            E  i
                                        State Definitions Of Infectious Waste
        State Agency
   Legislative
   Authority
   (if any)
         Minnesota Pollution
           Control Agency
           Division of Solid
           Waste
N)
I
Minnesota Statutes
1971:  Chapters 115,
116,400,4730
 Title of
 Regulation/
 Guideline/
 Document
       Definiticn(s)
Solid Waste Dis-
posal Regulations
Section SW-1
Hazardous Infectious Waste - Waste originat-
ing from the diagnois, care or treatment of
a person or animal that has been or nay have
been exposed to a contagious or infectious
disease.  Hazardous infectious waste includes,
but is not limited to,
          •*
   (1)  All wastes originating from persons
  placed in isolation for control and treat-
  ment of an infectious disease.

   (2)  Bandages, dressings, cases, catheters,
  tubing, and the like, which have been in
  contact with wounds, burns, or surgical
  incisions and which are suspect or have been
  medically identified as hazardous.

   (3)  All anatomical waste, including human
  and animal parts of tissues removed
  surgically or at autopsy.

   (4)  Laboratory and pathology waste of an
  infectious nature which has not been auto-
  claved.'             '   .

   (5)  Any other waste, as defined by the
  State Board of Health, which, because of its
  hazardous nature/ requires handling and
  disposal in a manner prescribed for (1)
  through (5).

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                               State Definitions Of Infectious Waste
State Agency
Legislative
AuUiorl-ty
 (if any)
Title of
Regulation/
Guideline/
Definition(s)
 Minnesota Depart-
   ment of Health,
   Health Facilities
   Division
                   Interpretive
                   Policies  for the
                   Physical  Plant:
                   Handling  and Dis-
                   posal of  Infect-
                   ious Waste

                   (Current  DOH
                   Guidelines)
                  Infectious Waste:
                     (1)   Hazardous Infectious Waste  (same
                     as above).'~

                     (2)   General Infectious Waste  (contaminated):

                          (a)  Bandages, dressing,  casts, catheters
                          tubing, and the like, which have in
                          contact with wounds, burns, or
                          surgical incisions, but are not sus-
                          pected or have been not medically
                          identified as being of a  hazardous
                          infectious nature.

                          (b)  Discarded hypodermic needles and
                          syringes, scalpel blades, and
                          similar materials, \
-------
                                                TUsBLE  1
                                 State Definitions Of Infectious Waste
State Agency
Legislative
Autiiority
 {if any)
Title of
regulation/
Guideline/
Docta-vsnt
Definition(s)
Minnesota Pollution
Control Agency



















I






















Proposed, but to
no longer be part
of the hazardous
waste regulations
HW-1

















Health services hazardous wastes: wastes
that originate from the diagnois, care, or
treatment of a human or an animal, and
wastes of similar composition, excluding
animal or human corpses but including:
(1) Laboratory wastes, including:
(a) Pathological specimens: tissues
and specimens of blood elements,
excreta, and secretions obtained
from patients.
(b) Infectious cultures: cultures t]
have been used in the detection, main-
tenance, or isolation of infectious
organisms or suspected infectious
organisms including, but not limited
to microorganisms and helminths
capable of producing infection or
infectious disease.
(c). Disposal fonaites: any waste thai
may harbor or transmit infectious
organisms.


-------
                                State Definitions Of Infectious Waste
 Stats Agency
Legislative
Authority
 (i£ any)
Title of
Regulation/
Guideline/
DoeoTient
Definition(s)
Minnesota Pollution
  Control Agency,
   (CCWT.)
                   Proposed, but to
                   no longer be  part
                   of the hazardous
                   waste regulations,
                   HW-1
                    (2)   Surgical and obstetrical wastes,
                    pathological speciirens, and disposal fonites
                    from surgical operating roans, outpatient
                    areas,  emergency rooms and similar areas
                    where such wastes are generated.

                    (3)   Equipment,  instruments, utensils,
                    and fonites of a disposable nature from
                    the roans of patients with suspected or
                    diagnosed ocmnunicable disease, or from
                    the roans of patients who by nature or
                    their disease are required to be isolated
                    by the  State Board  of Health.

                    (4)  Hypodermic needles and syringes,
                    scalpel blades,  suture needles and similar
                    materials.

                    (5)   Mixtures of any of the wastes in  (1)
                    through (5) and other wastes that have
                    been collected within the same container.

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                                State Definitials Of Infectious Waste
State Agency
   Legislative
   Authority
    (if any)
NSWM&.
New York Department
  of Environmental
  Conservation
Oregon Department of
  Environmental
  Quality
6 NTCRR Part 360,
Solid Waste Manage-
ment Facilities
Oregon Laws 1971
 (HB 1051), Chapter
648
 Title of
 regulation/
 Guideline/
 Document
       Definition(s)
                      Gaynor Ward Dawson
                      Draft of Model
                      Criteria for
                      Hazardous Waste
DEQ 41, Chapter
340
                   Materials or wastes which are capable of
                   transmitting infectious diseases at a
                   probability level above that from dally
                   life should be defined as hazardous wastes.
                   Criteria for identifying Hazardous Substances;

                     Infectious:  Materials containing infectious
                                  agents which are capable of
                                  causing death or severe illness,
                                  or which are highly contagious.
''Hazardous Solid Waste" includes "infectious",
but infectious not defined.

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                                               XAlilii  A
                              State Definitions Of Infectious Waste
State Agency
   Legislative
   Authority
    (if any)
 Title of
 Regulation/
 Guideline/
       Definition (s)
Pennsylvania Depart-
  ment of Environment
  al Resources
Texas Department of
  Health Resources
State of Washington
  Department of
  Ecology
Pennsylvania Solid
-  Management Act  (35
  (35 PS6-001),
  PL 241
Hazardous Waste
Management Profilfe
                       Comments to ANPR
                      Washington Admin-
                      istrative Code
                       (WC) Hazardous
                      Waste Regulation,
                      Chapter 173-302
                      WAC
General Classification of Hazardous Wastes

  (1)  Pathogenic Materials

      (a)  biological solids
      (b)  laboratory wastes
      (c)u infectious wastes

  (2)  Other Hazardous Solid Waste

      (a)  diseased animals
                   Hazardous biological waste should include all
                   pathological waste from chemical biological
                   and contagious wards as well as animals dead
                   of unknown disease and unstabilized domestic
                   sewage.
                   Waste containing etiologic agents are toxic
                   dangerous wastes.  Etiologic agent means
                   a viable microorganism or its toxin, which
                   causes oi: may cause human disease, and is
                   limited to those agents listed in 42 CFR
                   72.25(c) of the regulations of the
                   Department of HEW.

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                                       State Definitions Of Infectious Waste
        State Agency
 itla of
                                                                              Definition (s)
                                  (if
i
M
CO
        Ontario, Department
          of the Bwircnment,
          Waste Management
          Branch
        Ontario, Department
           of the Environment,
           Air Management
           Branch
Guideline/
Docurrent
                 Pathological waste - Waste resulting fron
                 the discard of tissue or of material or
                 equipment subject to contamination with
                 infectious' organisms.
                  Pathological Waste - Carcasses, human and
                  animal, solid  organic wastes from hospitals,
                  laboratories,  abattoirs,  and animal compounds,
                  disposable operating theatre garments and
                  swabs, maternity and incontient pads, dis-
                  posable diapers, and other similar  items
                  which might contain pathogenic bacteria.

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                              Table 2A.



Areas/Sources Identified as Sources of Infectious Wastes,  By State

Abattoir
Animal Compounds
Veterinary Hospitals
Health Services
Hospital, "pathological waste"
Emergency Booms
Isolation Booms
Laboratory
Outpatient Areas
Pathology Laboratory
Surgical Operating Boom
Mc*^'ioA1 f-iim'r's
Nursing Homes
Research Center
Sewage Sludge




X

X
X
X
X
X
X
X
X

X







X
















X

X
X




X







X

X
X
X


X







































i







X















X







X


















f
X
X


X


X








i
















                                      -19-

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Table 23.
         Dy State

Autopsy Specimens
Blood Specimens

Excreta
Human Carcasses
Obstetrical Waste

Pathologic Specimens
Secreta

Surgical Specimens

Tissues
Etiologic (infectious)
Agent-contaijiing items
Attendant Disposable
Fomites

Disposable Diapers
Instruments (disposable)
I.V. Apparatus
Perinea! Pads
Sharps
Utensils
Dangerous Drugs


X
X

X



X
X

X

X



X


x


X
X
X











i
X







1



















X



X

X

X
X
X

X


1
X
X
1
X

X

X
X

X

1
I
1
!








X



X


X


X
X





X







1






t



1

1


















1
















t




























1












X
X


i
1





X







X

X
1



1





X
























1
i
i j

!
j

        -20-

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                                /c.la 2 B (Cont.)
                          -s Jdentifiec), By State
Biological Solids
Incinerator Ash From
  Infectious Waste
Diseased Animals

1
— r

f
•


i
                                       -21-

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3.6 Related Federal Regulations and Guidelines

     No current federal regulations specifically address the

problem of infection as related to solid waste.  The Department

of Transportation has published Interim Hazardous Materials

Regulations (49 CFR Parts 171-177)(4)  in which "etiologic

agent" is defined (173.386)  for purposes of commodity transport.

The definition reads as follows:

          § 173.386  Etiologic agents; definition and scope.

               (a)   Definition.  For the purpose of Parts

          170-189 of this subchapter:

               (1)   An "etiologic agent" means a viable micro-

          organism,  or its toxin, which causes or may cause

          human disease,  and is limited to those agents listed

          in 42 CFR 72.25(c) of the regulations of the Depart-

          ment of Health, Education,  and Welfare.

     HEW's list (5)  consists of the following etiologic agents.

                      BACTERIAL AGENTS

                    Actinobacillus—all species.
                    Arizona hinsha'wii—all serotypes.
                    Bacillus anthracis.
                    Bartonella—all species.
                    Bordetalla—all species.
                    Borrelia recurrentis, B. vincenti
                    Brucella—all species.
                    ClostricTium botulinum, Cl. chauvpei, Cl. hae-
                      mplyticum, Cl.  histolyticum, Cl.~novyl,
                      Cl. septTcum,  Cl. tetani.
                    Corynebac ter mm diphtheriae, C. equi, c. hae-
                      molyticum, C.  pseudotuberculosis, C^ pyo-
                      genes, C^ renale.
                    Diplococcus (Streptococcus) pneumoniae.
                    Erysipelpthrix insidiosa.
                    Escherichia cHlT^all enteropathogenic sero-
                      types.
                    Francisella (Pasteurella) tulcrensis.
                                -22-

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Haempphilus ducreyi, H. influenzas.
Herellea vaginicola.
KlebsieTla—-all species and all serotypes.
Leptospira interrogans—all serotypes.
Listeria—all species.
Mima VpTymorpha.
Moraxella—ali~species.
Mycobacterium—all species.
Mycoplasma—a'll species.
Neisseria gonorrhoeae, N. meningitidis.
Pasteureila—all species
Pseudomonas pseudomallei.
Salmonella—all species and all serotypes.
Shigeila--all species and all serotypes.
Sphacrophorus necrophorus.
Staphylpcoccus aureus.
Streptobacillus moniriformis.
Streptococcus pyogenes.
Treponema careteum/ T. pallidum/ and T.
   ertenue.
Vibrio fetus, V. comma, including biotype
  El Tor, and V. parahemolyticus.
Yerscnia (Pasteureila) pestis.~~
              FUNGAL AGENTS
Actinomycetes  (including Nocardia species,
  Actinpmyces species and Arachnia propi-
  onica).
Blastomyces dermatitidis.
Coccidioides"linmitis."
Cryptococcus neofprroahs.
Histoplasma capsulatum.
Paracoccidioides brasiliensis.

   VIRAL, RICKETTSIAL, AND CHLAMYDIAL
                  AGENTS

Adenoviruses—human—all types.
Arboviruses.
Coxiella burnetii.
CoxsackTe A and B viruses—all types.
Cytomegaloviruses .
Dengue virus.
Echoviruses—all types.
Encephalomyocarditis virus.
Hemorrhagic fever agents/ including Crimean
  hemmorrhaglc fever  (Congo), Junin, and
  Machupo viruses, and others as yet un-
  defined.
                  -23-

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                Hepatitis-associated antigen.
                Herpesvirus—all members
                Infectious bronchitis-like virus.
                Influenza  viruses—all  types.
                Lassa virus.
                Lymphocytic choriomeningitis virus.
                Marburg  virus.
                Measles  virus.
                Mumps virus.
                Parainfluenza viruses—all types.
                Polioviruses—all types.
                Poxviruses —all  members,
                Psittacosis-Ornithosis-Trachoma-Lympho-
                 g^nuloma group of agents.
                Rabies virus—all strains.
                Reoviruses—all  types.
                Respiratory syncytial
                Rhinovirusies----aTl ^
                Rickettsia--all  species.
                Rubella  viruses—all types.
                Simian virus.
                Tick-borne encephalitis virus complex, in-
                 cluding  Russian spring-summer encepha-
                 litis, Kyasanur forest disease/ Omsk Kemor-
                 rfaagic fever,  and  Central European enceph-
                 alitis viruses.
                Vaccinia virus.
               Varicella virus.
               VariolcTinajpr and Variola minor viruses.
               Vesicular stomatis virusT
               Yellow fever virus.
     Comments addressing this Interim Regulation are filed

in DOT's Docket HM-142.  Many responses suggest that the

definition of etiologic agent be expanded to include agents

harmful to plants and animals.  DOT has not yet published a

response to comments.


     In considering the possibility of adopting this regulation

for defining infectious waste, EPA was concerned with the

enforceability of such a list because wastes cannot be adequately
                                 -24-

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tested.  EPA would prefer to rely on such a list as a way  to

identify sources that may contain these etiologic agents.

The CDC "Classification of Etiologic Agents on the Basis of

Hazard," a more complete list which includes animal etiologic

agents, will be used for source-identification purposes.   (See

Appendix VI of the regulation.)

     EPA has previously defined infectious waste in "Guidelines

for Thermal Processing and Land Disposal of Solid Waste/1

FR, August 14, 1974.(6)  The definition, which is reprinted below,

is felt to be unenforceable, as are most State definitions of

infectious waste.  Items specified in this definition would

be included in the "sources," under the proposed approach.

Also,  this definition ignores the sewage sludge problem.


                     "Infectious waste" means:
               (1)  Equipment, instruments,
               utensils, and fomites of a
               disposable nature from the rooms
               of patients who are suspected to
               have or have been diagnosed as
               having a communicable disease and
               must, therefore, be isolated as
               required by public health agencies;
               (2)   laboratory wastes such as
               pathological specimens (e.g.,  all
               tissues,  specimens of blood elements,
               excreta,  and secretions obtained
               from patients or laboratory animals)
               and disposable fomites (any sub-
               stance that may harbor or transmit
               pathogenic organisms)  attendant
               thereto;   (3)   surgical operating
               room pathologic specimens and dis-
               posable fomites attendant thereto
               and similar disposable materials
               from outpatient areas and emergency
               rooms.
                               -25-

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3.7  Epidemiological Evidence

     In 1967, for the first time solid waste was thoroughly

investigated as a reservoir for infectious microorganisms.

Thrift G. Hanks/ M.D., completed an exhaustive study entitled

Solid Waste/Disease Relationships;  A Literature Survey. (7)

Routes of transmission of human disease from solid waste were

described as "pathways," (see diagram below), and all evidence

from the literature on solid waste/disease correlation was

brought together.  Hanks summarizes his findings with the

following statement:
               The literature fails to supply data which
               would permit a quantitative estimate of
               any solid waste/disease relationship.  The
               circumstantial and epidemiologic informa-
               tion does support a conclusion that, to some
               disease, solid wastes bear definite, if
               not well defined, etiologic relationship.
               The diseases so implicated are infectious
               in nature; no relationship can be substan-
               tiated for noncommunicable disease agents
               associated with solid wastes, not because
               of negating data, but because of lack of data.
                                -26-

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                                                        fl .•: \^> 7
Solid
Waste
                         Biological __^
                           Vectors
                          Physical
                          and mech-
                           anical
                           Hazards
                          Airborne
                          Contami-
                            nants
Direct Contact
Human Disease
Disability
Malnutrition
                            Water
                           Supply
                            Food
                           Supply
                            Socio-
                          Economic
                           Factors
Figure  1.   T.G.  Hanks' Postulated Solid Waste/Human Disease Pathways


      There  appears  to be  a paucity of epidemiological data on

the  subject mainly  because funds have never been appropriated

for  gathering  such  data.  It has not been until recently that EPA

lias  undertaken any  epidemiologic studies related to solid

waste/  which will be completed  in several years.  Until then/

regulation  must be  based  on the microbiological data from

studies of  the various sources  of waste/ and on the principles

   epidemiology and solid waste-disease relationships.
                                 -27-

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3.8  Sources Identified

     For purposes of defining infectious waste,  the sources

of these wastes have been identified in the regulation by

SIC number with the corresponding industry.  These sources

are regrouped here for discussion purposes in this document

under the following headings:
          3.10      Rationale for Regulation of Health Care
                    Facilities Waste
                            Hospitals
                            Veterinary Hospitals

          3.11      Rationale for Regulation of Laboratory Waste

          3.12      Rationale for Regulation of Unstabilized Sewage
                    Treatment Plant Sludge
                                 -28-

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                                        .._  _
 3.9   Definitions  (8,  9,  10)
 For  clarification  the later discussions, the  following
 definitions  are provided:
      ANIMAL  WASTE  - Waste generated  from animal  care  or use;
 including bedding/ egestion, excretions, secretions,  tissue,
 remains, and any inedible by-products of animal  processing for
 food and fiber-production.
      AUTOCLAVE  -  An  apparatus for effecting  sterilization by
 steam under  pressure.  It is fitted with a gauge and  a mechanical
 system which automatically regulates the pressure and the
•temperature  to which  the contents are subjected.
      BACTERIA - Any of numerous unicellular microorganisms of
the  class Schizomycetes, occuring in a wide variety of forms,
existing either as free-living organisms or as parasites, and
having a wide range of biochemical, sometimes pathogenic, properties,

      ENTERIC - of  or  within the intestine.

      ETIOLCGIC AGENT  - A viable microorganism or its  toxin which
causes, or may cause  human disease.  In the case of DOT Regulations,
etiologic agents are  (or are suspected to be) in relatively small
concentrated samples  which are shipped to  special laboratories for
 identification.

      FOMITE  - An inanimate object such as  an  article  of clothing,
 a dish, a toy, or  a book, that is not itself  corrupted but
 is able to harbor  pathogenic organisms which  may by that means be
 transmitted  to others.

                                 -29-

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     FUNGUS - Any of numerous plants of the division or subkingdom
Tallophyta, lacking chlorophyll/ ranging in form from a single
cell to a body mass of branched filamentous hyphae that often
produce specialized fruiting bodies, and including the yeasts/
molds/ smuts, and mushrooms.
     INFECTION - The entry and development or multiplication
of an infectious agent in the body of man or animal.  Infection
is not synonymous with infectious disease; the result may be
inapparent or manifest.  The presence of living infectious
agents on exterior surfaces of the body or upon articles of
apparel or soiled articles is not infection, but rather is con-
tamination of such surfaces and articles.
     INFECTIOUS AGENT - An organism, mainly microorganisms
(bacterium, protozoan, spirochete/ fungus, virus, rickettsia,
or other) but including helminths/ capable of producing
infectious disease.
     INFECTIOUS DISEASE - A disease of man or animal resulting
from an infection.
     PATHOGEN - An organism capable of producing disease.
     PATHOLOGICAL WASTE - Tissues/ parts, and organs of humans
and animals.
                                -30-

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     PROTOZOAN - Any of the single-celled, usually microscopic
organisms of the phylum or subkingdom Protozoa, which includes
the most primitive forms of animal life.
     RICKETTSIA - Any of various microorganisms of the genus
Rickettsia, carried as parasites by many ticks, fleas, and lice.
Transmitted to man, they cause diseases such as typhus, scrub
typhus, and Rocky Mountain spotted fever.

     SOLID WASTE - Any garbage, refuse, sludge from a waste
treatment plant, water supply treatment plant, or air pollution
control facility and other discarded material, including
solid, liquid, semisolid, or contained gaseous material result-
ing from industrial, commercial, mining, and agricultural
operations, and from community activities, not including solid
or dissolved material in domestic sewage, or solid or dissolved
material in domestic sewage, or solid or  dissolved materials in
irrigation return flows or industrial discharges which are point
sources subject to permits under section 402 of the Federal Water
pollution Control Act, as amended (86 Stat. 880), or source,
special nuclear, or byproduct material as defined by the Atomic
Energy Act of 1954, as amended  (68 Stat. 923).
     SEWAGE Sludge - The residue resulting from wastewater
treatment.
                               -31-

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     SPIROCHETE - Any of various slender, nonflagellated,
twisted microorganisms of the order spirochaetales, many of which
are pathogenic, causing syphilis, relapsing fever, yaws, and
other diseases.
     SURGICAL AND AUTOPSY WASTE - Waste that includes tissue,
limbs, organs, placentas, and similar types of materials;
synonomous with pathogenic waste.

     VIRUS - Any of the various submicroscopic pathogens
consisting essentially of a core of a single nucleic acid sur-
rounded by a protein coat, having the ability to replicate only
inside a living cell.
     ZOONOSIS - An infection or infectious disease transmittable
under natural conditions from vertebrate animals to man.
                                -32-

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 3.10  Rationale for Regulation of  Health  Care  Facilities  Waste
      The nature of waste generated by health care facilities
 is of concern to EPA due to a certain amount of  potentially disease-
 contaminated materials found in the waste that are not normally
 found in other institutional solid wastes.  Some  studies have
 stated that the type and numbers of bacteria and viruses  found
 in health-care solid waste are little different  from that
 found in wastes generated from dwelling units, offices,
 factories and other institutions.   Other  researchers have
 given a completely opposite view and stated  that health care
 facility wastes may be potentially dangerous to  the  environment
 due to their  infectious content. (11)
      Both hospitals and veterinary hospitals (for more specific
 breakdown by  Standard  Industrial Classification Code  see  §250.14
 (b)  of the regulations)  are health  care facilities that are
 considered to be generators of  infectious waste for purposes of
 the regulation.   EPA realizes  that there are different problems
 associated with the infectious  wastes  from the treatment  of
 people vs.  animals and by  no means  does the Agency intend to
 imply that these two types of  health care facilities  generate
 the same types and amounts of  waste or  should treat or dispose
 of  their wastes by the same methods.  A discussion of each
 type of health care facility and sources of waste associated
with them are given below.
      Hospitals
      Theoretically,  the difference  between the biological
 jiazard of waste generated  in hospitsls, with their population
 Of  "sick" people,  and  the  waste generated by dwelling units
                              -33-

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and other buildings that are occupied basically by "well"



people, lies in the waste's content.  A proportion of the



waste materials generated by hospitals in the treatment of



patients has been exposed directly or indirectly to various



pathogens in concentrated forms.  From 2 to 8 percent of



hospital wastes, for example, consists of such materials as:



dressings from wounds, incisions, and burns; plaster casts;



infectious laboratory samples; bacteriological cultures and



media; pathological specimens; animal remains and biological



specimens; body fluids and secretions; blood, urine, feces,



and tissues;  needles and syringes; disposable treatment



devices made of plastic, metal, and glass; "sharps"; newborn,



pediatric, and geriatric diapers; and various contaminated



disposable containers.  (12)



     The leading generation points for these known infectious



wastes are surgical suites,  isolation wards for communicable



diseases, clinical and research laboratories, research animal



quarters, the autopsy suite and pathology laboratory, and the



renal dialysis department.  Another generation point is any



care and treatment area or room for a known infectious case—



inpatient, outpatient or emergency.  As these wastes come from



specific departments or sources, segregation is possible by



handling all wastes from these particular areas as being infectious,



The major problems in isolating possibly "infectious" wastes



arise from the general patient care and treatment areas, both



inpatient and outpatient, where large numbers of patients are



being cared for by nursing personnel and diagnosis is often





                              -34-

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 incomplete at  the  time.   It  is these areas  that  infection
 potential of most  waste  is unknown.  So, at some point,
 there is a reasonable possibility  that  infectious wastes can
 be intermixed  with other wastes.
      Three surveys have  been made  which cover quite  extensively
 hospital practices with  regard to  waste collection and disposal
 (Iglar and Bond, 1971;  (13)  Burchinal and Wallace, 1971;(14)
 Esco/Greenleaf,  1972  (15)).  The main interest,  however, has  been
 in evaluating  the  overall waste collection  and disposal
 systems, with  infectious  wastes being considered as  only one
 aspect of the  overall situation.   This  section is concerned
 with  discussing  the infectious wastes which are  identified in
 the literature.
      The composition of  infectious wastes is well known.
 They  include items from  surgery such as dressings, contaminated
 disposable items,  drapes, and human tissue  (amputated limbs,
 tissues, organs, placentas); items from pathology and the
 laboratory such  as tissues,  chemicals, bacteriological cultures,
urine,  blood,  and  feces;  animal remains and biological specimens;
 and general infected material from the wards such as gauze
 dressings and  bandages,  swabs, plaster  casts, sputum cups,
 paper tissues  soaked with nose and throat secretions, and
wound drainage.
      Some authors  distinguish between "pathological" wastes
 and "hazardous"  or "infectious" wastes  (Litsky,  et al., 1972). (16)
 They  call "pathological"  materials those from surgery, labora-
 tories, etc.,  and  "hazardous" waste everything else—everything
                              -35-

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from the hospital floor and everything that comes in contact

with patients.  Disposal systems in the hospital are often

different for the two types of waste, but for transport and

disposal away from the hospital these authors found that the

two cannot be separated.  The Esco/Greenleaf report (1972) (15)

had this to say:

     "Early in the study we concluded that there is no
     practical way of segregating contaminated and un-
     contaminated waste in a hospital, and that, with
     few exceptions, contaminated and uncontaminated
     wastes are co-mingled together either on purpose
     or accidently so that by the time these materials
     reach the back door of the hospital for disposal
     ...there is no distinction...Therefore everything
     ...from a hospital floor must be considered to be
     contaminated and should be classified as waste."

This position is not uniformly held.  Burchinal and Wallace

(1971)  (14)  state that only 25 to 30 percent of the total

waste generated in a hospital can be considered dangerous,

and if this is kept apart from the remaining waste there is

no need to treat the total waste as contaminated.

     Surgery, autopsy, and the laboratories generate most of

the segregated pathologic waste.  The waste for the Los Angeles

County - USC Medical Center is given in Table 8 (Esco/Green-

leaf, 1972).  (15)

     An investigation by G.H. Reavely and P.G. Warwick of the

University of Western Ontario (Anon, 1972c)(17) defined pathological

wastes as "all substances which cannot be resterilized or

reused originating within or brought into patient care, labora-

tory and autopsy areas."  Patient care areas not only included
                              -36-

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those traditionally considered to be  sources of  infectious
waste, but also ward areas,  doctors'  offices, outpatient
clinics,  and treatment rooms.   Infectious waste  averaged 43  percent
of the total waste in the hospitals studied, and the general patient
care areas generated almost  three quarters of this infectious
waste.
                             -37-

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                           Table 8
      Quantities of Pathological Wastes Generated Daily
      at LAC-USC Medical Center from Various Divisions
                   (Esco/Greenleaf, 1972)
Areas                                   Quantity of Waste (gal/day)


Lab Services (Basement)                           30

Autopsy and Lab Areas  (2nd Floor)                 80

Laboratories (2nd Floor)                          45

Pathology Lab (16th Floor)                        30

Surgical Delivery (4th Floor)                    	2

                                        Total    187 gallons/day

Using a density factor of 5.2 Ibs./gal. based upon 70% moisture,

a calculated production of 1000 Ibs/day may be expected for the

pathology incinerator.
                               -38-

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     A survey in California (Anon, I972b)  (18)  concluded that
it was possible to safely separate and collect infectious waste
within a hospital, but this does result in increased costs
of waste handling.  With an average total waste per patient day
of 10.25 Ibs., the average infectious waste measured was
only 0.38 Ibs.
     Investigations by Bond and Michaelson (1964)(19) on the
effects of waste handling upon air and surface contamination
give some indication of what types of contamination to
expect.  They found that soiled laundry handling had by far
the most significant influence on increased airborne bacteria.
     Further investigations have been carried out on the solid
waste itself.  Armstrong (1969) (20) looked at refuse chutes with
respect to airborne bacteria.  Ee found that placing the refuse
in bags reduces the number of airborne bacteria generated, and
that the possibility exists for the transmission of viable
organisms to other parts of the hospital by way of the refuse
chute.
     Research at  the University of West Virginia Medical Center
(Burchinal and Wallace, 1971;  (14) Wallace, et al., 1972;  (21)
Smith, 1970;  (22) Trigg, 1971  (23)) revealed that pathogenic
organisms can be  present in hospital solid waste in significantly
high concentrations, and especially so if an organic substrate
is present.  Coliform counts ranged from less than one per gram
of refuse at some stations to as  high as 8.6 per gram.  Fecal
                              -39-

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streptococci ranged from less than 1 per gram to as high as



8.0 per gram; staphyloccocci from less than 2 per gram to



7.1 per gram; Candida albicans from less than 2 per gram to



3.8 per gram; Pseudomonas sp. from less than 2 per gram to



8.4 per gram/ and spore counts from less than 1.5 to 3.9 per



gram  (Trigg, 1971).



     Substantial numbers of organisms of human origin were



found, which suggests the presence of virulent pathogenic



bacteria and viruses living on the solid waste in undetected



numbers.  Bacillus organisms made up 80 to 90 percent of all



microbes observed with staphloccocci and streptococci each



composing between 5 and 10 percent of the population.



Staphylococcus aureujs was by far the most predominant pathogen



detected in the waste.  Spore forming organisms were not present



in sufficient numbers to constitute a potential hazard if



accepted methods of sterilization are followed.  Nursing stations,



such as the operating rooms, where pathological waste is separated



from other waste, show much lower microbial concentrations in



general refuse than other stations.   The stations generating the



refuse most highly contaminated with coliform bacteria are the



intensive care units and pediatrics.



     Virus survival studies indicate that almost all materials



found in the hospital solid waste could be vehicles for



transmission of viruses (Burchinal and Wallace, 1971; (14)  Wallace,



etal., 1972 (21)).  Various types of waste were artificially con-
                              -40-

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taminated with viruses to established recovery times and rates.



Vaccinia, Polio 1, Coxsackie A-9, and Influenza PR-8 were the



viral  strains used for inoculation.  Paper and cotton fabric



both held active viruses for long periods of time—from 5 to



8 days in most cases.  Virus titer decreased in most cases at a



steady rate with increasing time, implying that the agent



loses  its viability upon incubation.



     An air samplying program was carried out at the Los Angeles



County-USC Medical Center  (Esco/Greenleaf, 1972).(15) Results are



given  in Table 9 and substantiate the earlier findings of Bond



and Michaelson that laundry handling does generate considerably



greater aerosols than does trash handling.



     Estimates of the total waste generated by hospitals vary



widely, ranging from about 10 Ibs/patient/day to as much as



40-50  Ibs/patient/day  (Litsky, et al., 1972; (16)  Oviatt, 1969;(24)



Wallace, et al., 1972;  (21)  Anon, 1972b(18); Small, 1971(25)).



Tables 10 and 11 give a breakdown of the types of wastes generated



and the disposal costs for seven California hospitals.  The great



variation is caused by the quantity of disposable items used.



The trend has been toward greater use of disposables because



of decreased danger of cross-infection and supposedly greater



economy.  It has now become evident that "disposables" are



really merely "throw-aways"; and their actual disposal presents



a. large problem.  Even the cost advantage is open to question;



Table  12 indicates that disposables cost more to handle and



dispose of than reusables.
                              -41-

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                              Table  9
                of Air Sampling Data at IAC-USC Medical Center
                        (Esco/Greenleaf, 1972)
Station
Trash Chute Roan
     Inside
     Outside
Laundry Chute Footi
     Inside
     Outside
                         Number of
                         Observations
99
96

58
57
              Mean Coliforms
              per cubic foot
14.1
 8.8

38.3
31.4
              No. of  Samples with
              Colonies too Numer-
              ous to  Count    	.
2
0

2
5
 Sorting Area
 Station Utility Foon
 54
 55
 71.0
  5.0
 7
 0
                                     -42-

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Breakdown of Daily Waste Production  OEs/bay) By Types of Wastes  (Escx./Greenleaf,  1972)
Type of Waste
# of Beds
Sharps, Needles, Etc.
Path. & Surgical
Soiled Linen
(Reusable)
Rubbish
Reusable Patient Items
Non-conbustibles
Non-grindable (a) Garbage
Food Service Items
(Reusable)
Radiological
Ash & Residue
Animal Carcasses
Food Waste (Grindable)
Medical
Center
3000
75
1000
45,000
16,200
trace
1,500
1,800
9,000
trace
trace
25
2,600
Total Production 77,700
— — — — — _ ___ __ ____ _





Long Beach
General
Hospital
428
3
trace
3,740
540
trace
75
150
1,400
—
—
—
330
6,238



Harbor
General
Hospital
715
22
156
13,600
6,569
trace
465
660
2,400
trace
20
220
950
25,062



Ranches Los
Amigos Hos-
pital
1188
40
4
16,320
2,760
trace
725
875
4,200
trace
20
20
1,100
26,064



John
Wesley
Hospital
259
8
115
2,900
717
trace
80
160
800
_
50
10
210
Olive
View
725
20
6
5,630
1,722
trace
250
475
2,500
trace
20
23
1,860
5,050 12,506






Mira
Lctna
232
5
trace
1,120
362
trace
80
110
600
_
25
_^
150
2,452
•t ' ;
fe/ . ••
&"~~f

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                                          Table 10  (CCMT.)
Daily Production
  Disposable
23,000    1,098
9,062
5,554
1,350     4,376
 (a)  Predominantly garbage mixed with substantial quantities of paper, plastics, metal, etc.

 (b)  Per capita production based on equivalent 24-hour population.
                                                                             732
fUUnu£a J-XiL IJtJU
patient
Pounds per capita, (b)
Daily Production
Reusable
Pounds per bed
i patient
1 Pounds per capita (b)
11.6
3.75
54,000
27.2
8.75
3.6
2.08
5,140
16.9
9.74
16.7
5.57
16,000
29.6
9.73
6.0
2.80
20,520
22.1
10.20
7.9
3.44
3,700
21.7
9.41
7.8
4.32
8,130
14.5
8.08
5.1
3.37
1,720
11.9
7.93

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                                oaiiy, and Unit
Costs  (Esco/Greenleaf,  1972)

Quantity of Waste
Produced
Disposables
(Tons/Day)
Reusables
(Tons/bay)
Total Waste
(Tons/bay)
•—-*•» vww
Medical
Center




11.60

27.25

38.85
j-uiivj ucau
General
Hospital




0.55

2.57

3.12
" narDor
General
Hospital



4.53

8.00

12.53
Kaneno Los
Amigos
Hospital




2.77

10.26

13.03
John
Wesley
Hospital



0.68

1.85

2.53
Olive
View
Hospital



2.19

4.06

6.25
Mira
Lena
Hospital



0.37

0.86

1.23
Cost of System Operation
Annual
Daily
Average Daily Cost
Disposables
Reusables
Total Wastes
$2,396,850
$ 6,566
per Ton
$ 305
110
170
$223,600
$ 612

$ 325
168
197
$777,435 $656,340
$ 2,130 $

$ 327 $
82
170
1,798

364
77
168
$296,582
$ 813

$ 664
195
321
$750,585
$ 2,056

$ 516
229
329
$175,200
$ 480

$ 551
322
390
                                                                                 •*«.j.        ~>t.j        j;


Average Daily Cost/feed Patient [Calculated based on total nurrber of patients not total nunber of beds]



     Disposables     $        i476  $      o 58  $      9 7-? 
-------
                                            Table 12

                  Cost Comparison of Disposable and  Reusable Wastes at LAC-USC Medical Center
                                      (Esco/Greenleaf,  1972)

                               Daily Costs of  Handling  and Disposal
                                                                                        Ave. Cost
Type of Waste
Disposables
Rubbish
Other
Total
Reusables
Soiled Linen
Food Service Items
Other
Total
Total All Materials
Ave. Wt.
Ibs/day

16,200
7,000
23,200

45,000
9,000
trace
54,500
77,700
Labor

$2,235
1,027
$3,262

$1,255
1,403
312
$2,970
$6,232
Bldg. & Other (a>
Equip.

$104 $ 85
40 60
$144 $145

$ 45 	
— 	
__ —
$ 45 	
$189 $145
Total

$2,424
1,127
$3,551

$1,300
1,403
312
$3,015
$6,566
Per
ton

$300
322
$305

$ 57
312
	
$110
$170
Per
Bed

$1.22
.56
$1.78

$0.65
.70
.15
$1.50
$3.28
(a)  Miscellaneous expendable supplies and dumping fees.

-------
     Disposable items are found in all the areas of the
hospital, and have special application in burn therapy, aseptic
techniques, and isolation cases.  Typical items are found in
Table 13.  They are combinations of materials such as paper,
plastic, rayon, acrylic, cellulose, nylon, glass and metal.
The plastic content is much higher than the 2-3 percent found
in municipal solid waste; one study of infectious waste found
it to be 11.42 percent hard plastic and 7.09 percent soft
plastic  (Anon, 1972b).(18)  Expenditures have risen from $30
million in 1966 to $126 million in 1970, and may rise to an
estimated $900 million in 1978  (Fahlberg, 1973). (26)  Further
estimates say that a hospital can double its waste output by
completely switching to disposable linen (Salkowski, 1970).(27)
Disposables add two problems to the waste treatment process;
first they increase the volume so that disposal systems are
taxed and second the plastic components are hard to degrade.
Also, it may be that  some plasticizers are toxic.  The John
Hopkins School of Hygiene and Public Health in Baltimore has
found that plasticizers in blood bags leach into the stored
blood and go on to lodge  in lungs, spleen, liver, and
abdominal fat.  Tests of  embryonic heart cell cultures revealed
that the cells died when  plastic tubing was substituted for
rubber  (Anon, 1971b).  (281
     When a simple a  change as  supplying paper towels to
each patient's room was made at the Baylor University Medical
                              -47-

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                                    Table 13

                Cannon Disposable Items Used in the Hospital
 Catheters and catheterizaticn trays
 Cutting Blades
 Eating utensils
 Emesis basins
 Enema administration bags and buckets
 Examination gloves
 Exchange transfusion trays with tubing and  fittings
 Foley catheter trays
 Hypodermic syringes  with and without  attached  needles
 Hypodermic needles
 Hypodermic syringes  pre-filled with medication
 Irrigation trays
 Lumbar puncture trays
 Manometer trays
 OB and surgical packs
 Oxygen canopies
 Petri dishes
 Prefilled nursers
 Prepared enemas
 Sheets and pillowcases
 Spinal anethesia trays
 Surgeons  gloves
 Surgical  prep trays
 Suture removal  kits
Venous pressure trays
                                    -48-

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Center, it was found an additional wastebasket was then required.
The maintenance cost from plugged toilets increased, and the
labor charge for emptying and washing wastebaskets increased by
30 percent/ but the number of cloth towels used did not decrease
(Paul, 1964).(29)  The pure bulk of the disposables presents the
problem that most authors comment on, but other hazards are also
present.  Discarded needles and cutting edges remain a hazard to
collection personnel.  Scavenging of the dumping areas for
useable items and play items for children show that spread
of infectious disease is a real hazard in the disposal of
disposables (Walter, 1964; (30) Mattson, 1974 (31)).  Disease
organisms can also be introducted to a landfill in great
quantities via disposable linens and diapers  (Ostertag and
Junghaus, 1965;  (32) Peterson, 1974  (33)).
     Some indication of the numbers of disposable hypodermic
needles used by individual hospitals can be obtained from
•the literature.  Michaelson and Vesley  (1966) (34) found
from 14,000 to 833,000 used annually at various hospitals in
1966, and Baker  (1971)(35) found over 550,000 used annually
in 1968.  There are proper ways to collect and destroy these
items, such as collecting them at the individual nursing
stations and returning them to central storage to be crushed
and broken  into fragments, then incinerated.  They can also
be collected in  special boxes and sent directly to the
incinerator, or collected at the nursing stations and sent
to central  service to be autoclaved  and melted into one
mass  (Paul, 1964).  (29)   Some hospitals have even tried
                              -49-

-------
replacing the needles on a one for one basis as they are

used, then destroying the old ones (Deschambeau, 1967).(36)

Even though the users are aware of the need to destroy the

waste syringes and needles, many still escape unscathed.

Profit oriented hospital workers have been known to extract

these from the daily waste and sell them to street drug

users  (Hewer, 1971).(37)  Even at the final landfill site,

these needles can be reclaimed for drug users and children

who  find them to be  satisfactory squirt guns  (Healy, 1965) . (38)


     Based on the above discussion, the Agency concluded that

it is necessary to regulate only certain sources of infectious

waste within hospitals, rather than all waste from these facilities,

Further, the Agency  concluded that it is unnecessary to regulate

waste materials from these sources which have been properly

treated by the hospital to render them non-infectious  (see

§250 Subpart A Regulations, Appendix VII, Infectious Waste Treat-

ment Specifications.)

     The following departments of hospitals are subject to

Subtitle C regulation:

          Obstetrics department including patients' rooms
          Emergency  departments
          Surgery department including patients' rooms
          Morgue
          Pathology  department
          Autopsy department
          Isolation  rooms
          Laboratories
          Intensive  Care Unit
          Pediatrics department
                               -50-

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     Veterinary Hospitals
     While veterinary hospitals have some of the waste disposal
problems which hospitals caring for people have, these problems
are mainly confined to disposing of dead animals, animal waste,
and waste generated during treatment of animals.  Animal waste
includes waste generated from animal care or use, including
excretions, secretions, tissue, remains, and any inedible by-
products of animal processing for food and fiber production.
     It has been pointed out to the Agency that the majority of
diseases that could be transmitted through improper disposal of
veterinary hospital waste are primarily ones that are transmitted
only from animal to animal.  It is true that several hundred
diseases are transmitted from animal to animal, but more than
150 zoonotic diseases are transmitted between animals and man.
     Decker and Steele  (38a) report the human health problems
that are created by pathogenic zoonoses.  Some of the most
significiant bacterial zoonoses are salmonellosis, staphlococcal
and streptococcal infectious, tetanus, tuberculosis, brucellosis,
icptospirosis, and colibacillosis.  Animal wastes also play a
significant role in the distribution of fungal diseases by
providing nutrients for the survival and growth of fungi in
    s  environment.
                               -51-

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     Q fever, a rickettsial disease, is transmitted to man



primarily through air laden with dust containing animal



wastes.  It is largely an occupational disease of cattlemen,



slaughterhouse workers, and woolsorters, but may also attack



those residing adjacent to feedlots and stockyards.  A trouble-



some parasitic disease transmitted through animal wastes is



trichinosis which persists even though the practice of



feeding swine raw garbage has been greatly reduced in recent



years.



     Less is known regarding the role of animal wastes in



the direct transmission of viral diseases than in bacterial



diseases.  However, the importance of animal wastes in the



reproduction of insect vectors of many diseases is well



documented.



Anthrax



     Anthrax is one of the oldest diseases identified with



animals that is transmissible to man.  Anthrax has been



present in the United States for at least the last 100



years.  The disease is primarily an occupational hazard of



industrial workers who process hides, hair (especially from



goats), bone and bone products, and wool, and of veterinarians



and agricultural workers who handle infected animals.  (39)



     Infection of the skin is by contact with tissues of



animals (cattle, sheep, goats, horses, pigs,  and others)



dying of the disease; or contaminated hair, wool, hides,  and
                              -52-

-------
soil associated with infected animals. Inhalation anthrax
results from inhalation of anthrax spores.  Gastrointestinal
anthrax arises from ingestion of contaminated undercooked
meat.  Anthrax spreads among herbivorous animals through
contaminated soil and feed and among omnivorous animals
through contaminated meat, bone meal or other feeds.  Biting
flies and other insects are suspected of serving as vectors.
Vultures have spread the organism from one area to another.
The spores of Bacillus anthracis, the infectious agent,
which resist environmental factors and disinfection, remain
viable in contaminated areas for many years after the source-
animal infection has terminated. (39)
     Initial symptoms of inhalation anthrax are mild and
non-specific,  resembling common upper respiratory infection;
acute symptoms of respiratory distress, fever and shock
follow in from 3 to 5 days, with death shortly thereafter.
     Gastrointestinal anthrax is more difficult to recognize,
except that it tends to occur in explosive outbreaks? abdominal
distress is followed by fever, signs of septicemia, and death
in the typical case.
     Untreated cutaneous anthrax has a fatality rate of from
5-20%, tut with effective  antibody therapy,  few deaths
occur.  (39)
Salir.onellosis
     Although  this  disease is discussed  in the  section on
 sewage  sludge,  the  important role  that animals  play in the
 transmission of  the disease shall  be  stressed here.
                              -53-

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     Animal excreta and inedible by-products of food processing,



such as viscera, bones, and feathers are vehicles that carry



salmonella organisms from their animal hosts to man.(40)  Direct



contact with such wastes constitutes an occupational hazard



for livestock producers, slaughterhouse and rendering plant



workers; contamination of edible food products with feces



provides a means of carrying the organism to the consumer, to the



home, or to the institutional environment.



     Animal wastes are also a vital factor in perpetuating



and extending the prevalence of animal hosts of the Salmonellae.



C41)  Feeding of animal feces to poultry, swine, beef, and



dairy cattle is one means of increasing the incidence of



animal salmonella hosts, as is the use of contaminated



animal protein supplements in animal feeds.



     In 1965 a waterborne outbreak in southern California



affected some 16,000 people.  How the water supply of the



city of Riverside became contamined is unknown, but Salmonella



typhimurium (Phage II), the cause of the outbreak, is widely



disseminated in animals not only in California but throughout



the world.  There has been speculation that contamination



could have originated  in feedlots where cattle were passing



Salmonella typhimurium hundreds of miles away, and due to



seepage along earthquake faults, the bacteria appeared in



the water supply. (38)
                             -54-

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Tuberculosis
     Tuberculosis must still be considered as an important
disease related to animal wastes.  While bovine tuberculosis
caused by Mycobacterium bovis has been effectively controlled
in  this country, it is occasionaly found in some wild animals,
as  well as in food animals and in pets.
     Mycobacterium tuberculosis, the human type of tubercule
bacillus, is capable of infecting cattle swine, and household
pets.
     Mycobacterium avium, the etiologic agent of tuberculosis
in  gallinaceous birds, is capable of producing tuberculosis
in  swine and of infecting cattle to such an extent that
reactions are produced in routine tuberculin testing of
cattle.
     The bovine tubercle bacillus is transmitted to man
through respiratory secretions, feces, and milk.  In those
few cases where infection of man with the bovine tubercle
bacillus is known, there usually is an occupational contact
with cattle. (38)
Brucellosis
     Brucellosis is commonly an occupational disease of
those with close contact with cattle and swine and their
viscera and excreta.  The disease in man and animals is
caused by any one of three species of Brucella.
                              -55-

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     Brucella abortus is predominantly of bovine origin,



Brucella suis of swine origin, and Brucella melitensis



primarily infects goats.  Cows may become infected with



Brucella suis or Brucella melitensis as well as Brucella



abortus.  Swine may become infected with all three species;



however, they are most susceptible to Erucella suis.  Many



outbreaks of brucellosis have been traced to contaminated



water courses from meat-processing plants, rendering plants,



and contaminated farms.  (38)



     The disease is systemic, with acute or insidious



onset, characterized by continued, intermittent or irregular



fever of variable duration, headache, weakness, profuse



sweating, chills, or chilliness, arthralgia, depression, and



generalized aching.  Non-purulent meningitis and pneumonitis



may occur.  The disease may last for several days, many



months, or occassionally several years.  Orchitis and vertebral



osteonmyelitis are uncommon but characteristic features.



Recovery is usual but disability is often pronounced.  The



fatality rate is 2% or less; higher for Brucella melitensis



infections than for other  species.  Clinical diagnosis is



often difficult and uncertain.  Death is rare in persons



without complications.  (39)



Leptospirosis



     Leptospirosis is a  spirochetal disease of large proportions



and is world-wide in distribution.  A number of animal
                              -56-

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species host the leptospira, including the domestic food-
producing species.  Cattle and swine are the principal
domestic animals involved—leptospirosis occurs in epizootic
form in stables and feedlot herds.  Dogs and rodents are
frequently infected.
     Leptospirae are transmitted from the animal host to man
through a number of routes.  Documented sources of human
infection are rice fields, swimming "holes", sewers, and a
number of occupations in which exposure to infected animals
is by direct contact. (38)
     The disease in man shows a wide range of symptoms and
severity, depending on the species of leptospira involved,
exposure, and the health of the individual.  It presents
symptoms similar to influenza, enteric viral infections,
infectious gastroenteritis, and a number of other diseases.
Fatality is low, but increases with advancing age and may
reach 20% or more in patients with jaundice and kidney
damage.  (39)
Tularemia
     The reservoir for Tularemia is normally wild animals,
but is occasionally found in sheep.  Mode of transmission is
t>y inoculation of the skin, conjunctival sac or anal mucosa
with blood or tissue while handling infected animals, as in
skinning, dressing, or performing necropsies; or by fluids
from infected flies, ticks, or other animals, or through the
     if arthropods including a species of deer fly.  The
                              -57-

-------
disease is characterized by sudden and dramatic onset of

chills and fever. Fatality in untreated cases is about 5%;

with treatment, negligible. (39)

     Although the above discussion of disease transmitted to man

from animal has centered on occupational hazard data, the same

types of wastes are generated from certain departments of veterinary

hospitals.  Again, as with hospitals/ the Agency has concluded

that only a portion of the total waste load of veterinary hospitals

is a source of infectious waste  (unless properly treated prior

to disposal to render non-infectious).

     For purposes of identifying sources of infectious waste, the

following departments of veterinary hospitals are subject to

Subtitle C regulation:

          Emergency department
          Surgery department including patients' room
          Morgue
          Pathology department
          Autopsy department
          Isolation rooms
          Laboratories
          Intensive care unit

NOTE:  The Agency realizes that  the names of the above departments

       are normally applied to hospitals for humans; the depart-

       ments of veterinary hospitals that are functionally

       equivalent would be applicable.
                              -58-

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3.11  Rationale for Regulation of Laboratory Waste
     Data are generally not available that can be used to show
evidence of disease associated with laboratory waste.  In a
recently published study at the University of Texas (Pike,
1975} (42), some waste/disease data can be extracted from the
50-year data base of published and unpublished cases of
laboratory-associated infections.
     As shown in the reproduced table (Table 7), 46 cases of
laboratory-acquired infections related to the  (waste) source
of discarded glassware are shown.  Of these cases, 34 were
related to bacteria, 10 related to viruses, and 2 to rickettsiae.
Of the total number of reported laboratory-associated infections
studied,  the 46 associated with discarded glassware represent
about 1%  of the total.
     The  Center for Disease Control has determined that
certain microorganisms are of potential hazard to human
health and the environment, as published in the "Classification
of Etiologic Agents on the Basis of Hazard."   Since it has
keen determined by HEV7 that classes 2 through  5 are of
potential hazard, then any laboratory dealing  with these
agents would be generating a potentially hazardous, infectious
waste.  Given that most hospitals and  laboratories know
which organisms are used  in their work, the list is appended
                               -59-

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to the regulation to indicate the type of laboratory which



would be included by the specified SIC codes.  It must be



recognized however, that many times in diagnostic work the



organisms involved are unknown.  By regulating laboratories



as the "source" of infectious waste, the unknown presence



of pathogenic organisms can be controlled.  Thus, the CDC



list is used as a basis for including laboratories as a source



of infectious waste, but the list cannot be used alone to



define this source, due to the nature of the waste from



diagnostic labs.
                            -60-

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7 - Distribution of Cases According to Proved car Probable Source of Infection
Agents
Sources
Accident
Animal or ectoparasite
Clinical specimen
Discarded glassware
Human autopsy
i
2 Intentional Infection
i~*
i
Aerosol
(forked with the agent
Other
Unknown or not indicated
Total
Bacteria
378
149
90
34
56
14
101
381
7
459
1669
Viruses
174
249
175
10
9
1
92
213
1
125
1049
Rickettsiae
45
66
2
2
4
0
217
100
7
130
573
Fungi
33
151
1
0
0
0
88
62
0
18
353
Chla-
ndiae
14
32
0
0
0
0
22
43
1
16
128
Parasites
38
11
19
0
1
4
2
28
0
12
115
Unspec-
ified
21
1
0
0
5
0
0
0
0
7
34
Total
703
659
287
46
75
19
522
827
16
767
3921
\
r .. "i

-------
3.12 Rationale for Regulation of Unstabilized Sewage Treatment
     Plant Sludge
     The Agency has decided to regulate "domestic" or "municipal"
sewage sludge form publicly owned treatment works under the
authority of Section 405 of the Clean Water Act, supplemented by
Section 4004 of RCRA.  Unstabilized sewage sludge from industrial
or other sources is considered to be a hazardous waste subject to
regulation under Subtitle C of RCRA.  Thus the following discussion
applies to sewage sludges from industrial and other sources, which
in many cases are similar or identical in character to domestic
or municipal sludges.
     The fact that pathogens do survive in sewage sludge has been
addressed by EPA in the November 1977 Federal Register notice
entitled "Municipal Sludge Management:  Environmental Factors;
Technical Bulletin."   (43)   In this publication, EPA recommends
that sewage sludge be "stabilized" before landspreading "to reduce
public health hazards and to prevent nuisance odor conditions."
Stabilization of sewage sludge is defines as chemical,  physical,
thermal, or biological treatment processes that result in the
significant reduction of odors,  volatile organics,  and pathogenic
organics.  EPA, in the same publication, recognizes that "although
these conditions can reduce the number of influent fecal coliforms
by 97 percent or more, the remaining levels of microorganisms iray
still have public health significance".  And, further,  that "under
certain conditions.  . .it may be necessary to achieve additional
bacterial, parasite, and/or virus reduction beyond that attained
by stabilization.'
                            -62-

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     In this bulletin general requirements for land application
of sludges are given.  Reference is made to "Process Design
Manual for Sludge Treatment and Disposal" (EPA 625/1-74-006;
October 1974) which specifies in more detail the techniques for
sludge stabilization.
     The bulk of the information presented in this section
of the background document is identical to that presented in
the background document for s257.4-5 (Land Criteria) to be
used for Section 4004 of RCRA.  (45)  Section 4004 regulations
will require sewage treatment plant sludge to be "stabilized"
to "reduce public health hazards."
     Pathogenic organisms occuring in sewage sludge cover a
wide variety of bacteria, viruses and intestinal parasites.
Their individual presence, as well as their numbers, will
vary considerably from community to community depending upon
rates of disease in the contributing population.   (46)  Routes
of infection to humans and animals from sewage sludge may be
through direct contact with contaminated environments or
through the  ingestion of contaminated food and water.
Bacteria
     Among the bacteria that are commonly found in sewage
sludge, is the group referred to as the "enteric bacilli"
that naturally inhabit the gastronintestinal tract of humans.
In their virulence for humans, the enteric baccilli fall into
three general categories:  pseudomonas species, salmonella
species, and shigella species.
                            -63-

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     Pseudomonas
     The pseudomonas species include the proteus organisms,
Pseudomonas aeruginosa, and Alcaligenes faecalis.  These
common inhabitants of the normal human gastrointestinal
tract are ordinarily non-pathogenicf causing disease (most
often of the urinary tract) only under special circumstances.
     Salmonella
     The genus Salmonella contains a wide variety of highly
invasive "species" pathogenic for humans or animals, and
usually for both.  Largely as the result of systematic
studies, over 700 Salmonella species have been identified on
the basis of specific antigens.  Three distinguishable forms
of salmonellosis occur in humans:  enteric fevers, septicemias,
and acute gastroenteritis.
     The prototype of enteric fever is caused by Salmonella
typhosa.  The organism is usally acquired by ingestion of
contaminated food or water, and the focus of occurence in the
United States is in the South.  There were 375 cases of
typhoid fever reported in the U.S. for the year 1976.(47)
     The second form of salmonellosis is Salmonella septicemia,
which is characterized by high, remittent fever and bacteremia,
ordinarily without apparent involvement of the gastrointestinal
tract.  The third form, gastroenteritis, is a disease confined
primarily to the gastrointestinal tract, and in most cases
is caused by the Salmonella sp. typhimurium.
                            -64-

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     Shigella
     The third category of enteric bacteria is the Shigella
genus.  The shigella cause in humans a disabling disease
known as bacillary dysentery.  This is an acute infection of
the large intestines, resulting in diarrhea, which, if
sufficiently severe, may be accompanied by bleeding from the
colon.  All known species of the genus Shigella are pathogenic
for humans, with the following being the most common:  S.
dysenteriae, S^ flexneri, and §_._ sonnei.
     None of the enteric bacilli form spores.  Spores are
resistant bodies produced by large number of bacterial
species that enable them to withstand unfavorable  environmental
conditions such as heat, cold, desiccation and chemicals.
Since enteric bacilli are not spore formers, their survival
span outside of their normal environment  (human intestinal
tract) is usually measured in days or months, compared to
years for spore forming bacteria.  Most sludge stabilization
processes would create an unfavorable environment  for enteric
bacilli to survive.
     A pathogenic bacterium  frequently found  in sewage
sludge, although not an enteric organism,  is  the tubercle
bacillus Mycobacterium tuberculosis.  This  organism  is
responsible  for nearly all cases of pulmonary tuberculosis.
Tubercle bacilli are very hardy organisms,  and can withstand
fairly  extreme environmental conditions.
                            -65-

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Viruses
     The second group of pathogenic organisms found in
sewage sludge are the enteric viruses.  Viruses present
certain differences from bacteria and possess many character-
istics peculiar to their own group.  Biologically, the most
important difference between viruses and bacteria is that
viruses must invade the living tissue cells or bacteria cells
to multiply within them, whereas the bacteria do not invade
the cells of their host.
     More than 70 serologically distinct human enteric
viruses can occur in sewage sludge. (48)  The major pathogenic
enteric virus groups are the Polio viruses, Coxsackie viruses,
Echoviruses and the Hepatitis virus.
     Poliomyelitis, caused by the poliovirus, is an acute
systemic infection which, in its clinically recognizable
form appears as an involvement of the central nervous system
and often results in a variable degree of permanent paralysis.
The escape of the virus from the body of the infected person
is in respiratory tract secretions and in the feces.
     Coxsackie viruses are responsible for common enteric
infections and a variety of illnesses, including several
clinically distinct ones in humans.
     Echoviruses comprise a group of biologic agents brought
together chiefly because they infect the human intestinal
tract.  Certain species are known to cause aseptic meningitis,
febrile illnesses and diarrheal diseases in infants and
children.
                           -66-

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     Infectious hepatitis is an acute infectious disease
that causes fever/ nausea, abdominal discomfort, followed by
jaundice.  It is caused by a resistant virus.   The Hepatitis
virus is shed from the body through the feces, and fecal-
oral spread is probably the most common method of transmission,
Parasites
     The third group of pathogenic organisms found in waste
water treatment sludges are the intestinal parasites.  Those
parasites of concern to humans can be subdivided into two
categories:  CD Protozoa, and (2) Helminths.   Subgroups of
the Protozoa group include amoebas, flagellates, and ciliates.
Subgroups of the Helminths include trematodes and nematodes.
     Protozoa
     At least five species of amoebae live in the intestinal
tract of humans, with Entamoeba histolytica being the only
proven pathogen.  Infection with E^ histolytica may produce
chronic diarrhea, amoebic hepatitis, abscess of the liver,
brain, lung, and ulceration of the skin. Amoebae have two
stages in their life cycles, a mobile form and a cyst form.
The cysts are infective upon passage from the body, and are
survive in a moist and cool environment.  Giardia lamblia,
another protozoan, is also found in sewage sludge.  Like the
amoeba, G. lamblia is a parasite of the human intestinal
tract and is responsible  for certain conditions such as
diarrhea or symptoms referable to the gall bladder.
     Balantidium coli is  the only ciliate human parasite
and is the largest of human protozoan parasites.  It invades
                           -67-

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a tissue and produces intestinal pathology  similar  to  that
of E. histplyticcx.
     Helminths
     Helminths are commonly referred to as worms.   In  a more
restricted sense the name worm, or preferably helminth, is
applied to a few phyla of animals, all of which superficially
resemble one another in being "wormlike," though in life and
structure they are widely different.  Ascaris lumbricoides
is the longest-known human parasite in this group.  It was
not until early in the present century that Ascaris was
recognized as being as injurious and sometimes dangerous
parasite.
     Ascaris lumbricoides is a large nematode; the females
commonly reach a length of 8 to 14 inches.  The adult normally
lives in the small human intestine, where it commonly bites
the mucous membrances to extract tissue juices.  Ascaris
produce a tremendous number of eggs (ova)  which are passed
out of the body in the feces.  Infection ordinarily results
from swallowing the embryonated eggs,  which are in most
cases conveyed to the mouth by food or water.  In heavy
infections the migration of the larvae through the lungs causes
hemorrhaging and sets up a severe pneumonia which may be fatal.
The ova of the Ascaris are extremely durable, and are capable
of withstanding severe environmental conditions.
     Other Helminths encountered in sewage sludge are the
tapeworms or Cestoidea.   Although 25 or 30 different species
of tapeworms have been recorded in man, only 4 adult species
are to all common.  These are Dibothriocephalus latus,  Taenia
                                -68-

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solium, !_._ saginatta, and Hymenolepis nana.  With the exception
of the species of Hymenolepis, infection with the common
human species results from eating raw or imperfectly cooked
beef, pork, or fish in which the larvae have developed.
Hymenolepis sp_. on the other hand, need no intermediate
host. It is able to complete its entire life cycle in a
single host; thus, when eggs are ingested by man, the larvae
migrate into the lumen of the intestine.
     Numerous studies report that pathogenic organisms
present in sludge are either killed or greatly reduced in
number when exposed to various stabilization methods used.
     The specific number of an organism necessary for the
establishment of the potential for disease is related to
various factors; etiologic agent, susceptibility of host
etc.  However, there is evidence that with many pathogens
this dose may be rather high, in particular the enteric
pathogens.  DuPont et. al  (49)  reported that approximately
10  Salmonella cells (including S typhi) are required to
cause a disease.  This would tend to support the premise
that by reducing the number of pathogenic organisms in
sludge, the public health hazards associated with its use
would be greatly minimized.
     A review of the literature  (7) has shown that there is a
paucity of epidemiclogical data linking disease transmission
of humans and animals directly to the landspreading of waste-
water  treatment sludges.  The data that do exist, indicate
                            -69-

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that the transmission of enteric disease or parasitic infestation
were related to the use of raw or unstabilized sludges on
cropland.  Sepp (50) in his literature review on the landspreading
of wastewater sludge, lists numerous reports of infection
both to humans and animals believed to be caused by ingestion of
raw vegetables fertilized by raw sludges. In specific cases,
Kreuz  C51> and Kroger (52) reported disease outbreaks caused
by Salmonella species on lettuce grown on soil fertilized by
raw sludge.  Such evidence indicates that there is a public
health risk associated with the landspreading of unstabilized
sludges.
     Data linking disease transmission to humans and animals
from the landspreading of stabilized sludges is virtually non-
existent.  This lack of data can possibly be attributed to
the fact that most individuals can tolerate the number of
pathogenic organisms that survive the sludge stabilization
process/ or the ingestion of these organisms result only in
sporadic cases of infection, of which the source is difficult
to trace.  Based on the knowledge of the human immune system,
the former is a more plausible assumption. Work by Dupont et
al (49) tends to support the former possibility, since their
studies indicated that with many pathogens the infective
dose may be rather high, in particular the enteric pathogens.
                              -70-

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     The stabilization process will reduce the pathogen
population in sludge;  the level of reduction will vary with
the process used and numerous other variables, e.g., time,
temperature, pH etc.  Since available epidemiological evidence
links disease transmission to the landspreading of unstabilized
sludge and not stabilized sludge, it is evident that there
is a correlation between the concentration of pathogens in
•the sludge and disease transmisssion.
     Wastewater sludge stabilization is normally accomplished
by anaerobic and aerobic digestion, and lime treatment.
Lesser used methods include heat treatment, ponding and long
time storage, chlorination, and composting.  The stabilization
of sludge by thermal irradiation is being addressed, but at
this time the process is.still in the experimental  state.
     As previously mentioned,  the extent to which pathogenic
organisms are reduced is related to the stabilization process
used as well as other variables.  Not all stabilization
processes affect pathogenic organisms in the  same manner,
therefore,  some processes  are  more effective  in  reducing  the
pathogen population than others.  Also the  levels of  stabiliz-
ation within a particular  process will vary as to their
effectiveness in reducing  pathogenic organism numbers, e.g.,
anaerobic digestion of  sludge  for a two week  period in the
                             -71-

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thermophilic range C125 F), is more effective in reducing



pathogens than sludge digested anaerobically for two weeks in



the mesophilic range (95 F) .



     The following is some of the information encountered



relative to the effectiveness of various sludge stabilization



processes in reducing pathogenic organisms.  Table 3 summarizes



these findings.



     During anaerobic stabilization, the sludge temperature



may reach 149 F by microbial action.  However, the normal



range for essentially all digesters in the United States is



between 80 F to 100 F.  (44) Although conditions in the



digester are unfavorable for multiplication of most pathogenic



organisms, they are not lethal and the principal bactericidal



effect appears to be related to natural die-off with time. (44)



     Kabler (53)  reported that anaerobic digestion was compara-



tively ineffective in the inactivation of parasitic ova.  Viable



Ascaris eggs have been recovered following anaerobic digestion



for as long as three (54} and six (55) months. An analysis of



raw sludge from two community wastewater treatment plants



revealed the presence of helminth ova and salmonella species.



The same sludge after being stabilized by anaerobic digestion



tested negative for both organisms.(56)  Rudolfs et al.



reported that after 6 months exposure to the anaerobic



digestion process at 75 to 85 F, 46 percent of the ascarid



eggs appeared normal.  Other studies  (54,57) reported that



anaerobic digestion with different retention times removes
                             -72-

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the eggs of A. lumbricoides  0 to 45 percent.
     Two groups (58,59)  observed that there was 90 and 69
percent diminution of tubercle bacilli, while two others
(60,61) noted "survival" of M. tuberculosis after anaerobic
digestion.
     McKinney et. al(62) found in their studies that approximately
93 percent of £. typhosa were removed after being exposed to
anaerobic digestion process for 20 days.  Kenner (63) reported
that sludge treated by anaerobic digestion has been shown to
contain Salmonella and Pseudomonas organisms.
     Cram (54) reported from his studies, that activated
sludge treatment does not affect the viability of E. histolytica
cysts or ascarid eggs.  Aeration in the activated sludge
process for 5 months showed no effect on ascarid eggs except
a slow reduction in numbers (64), Kabler (53) reported that
studies indicate that activated sludge reduced §_._ typhosa
and strains of bacilli 91 to 99 percent.
                             -73-

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                             Table  3 Removal of Pathogens by
Total Counts
Colifoxm
Fecal Strep
Typhoid group
Shigella
Cholera

M. Tuberculosis
Polio
Coxsackie
ECHO
Infectious
  hepatitis

Tapeworm Ova
E. histolytica
  cysts
Ascaros
  lunfcricolides
Taenia saginata
Sewage Treatment Processes (53}
(Percent)
Trickling
Filter
70-95
82-97
84-94
84-99+
Activated
Sludge
Enteric
70-99
91-93
-
Present:
95-99.2
Anaerobic
Digestion
Bacteria
-
-
-
Not found:
25-092.4
Chlorina-
tion
96-99
99-99+
-
98-99
Stabiliza-
tion Ponds
.
59-99+
-
41/ml;N.D.
18-26
88-99.9
                ova
  97-98
Not found
   M. Tuberculosis
Survive;
66-99
.
Reduced;
60
Survive; Survive;
88 69-90
Entero viruses
Survive
Survive Survive
Survive;
99+
99
-
                                                                          Survive or
                                                                          inactivated
                                        Parasites
                                  Not removed
                97
No effect
                      62-70
                                                  45; reduced
Little effect; Very slow
                                          -74-

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     Enteric virus inactivation during  the  treatment of
wastewater by the activated  sludge process  has  been reported
extensively in the literature.  (65-70)  Carlson  (71)  et
al reported that after 6 months of aeration,  polioviruses
were removed or inactivated  to a  point  at which infectiousness
for mice was greatly reduced.  Sproul  (72)  reported that
virus removal of 90 percent  or more  has been obtained in a
number of studies with activated  sludge process.  Kelly et
al  (73) reported that Coxsackie virus  survived  activated
sludge treatment.
                           Table 4
      Removal of viruses by bench scale activated  sludge units
    Coxsackie virus A9                         Foliovirus 1
Test No.
1
2
3
4.
5
6
7
Volatile
solids
(irg/1)
600
650
1,000
1,100
1,500
1,500
Virus
Inactivated
(Percent)
98.8
96.1
99.2
99.1
97.4
99.4
Volatile
solids
(mg/1)
206
400
600
600
1,200
1,200
4,000
Virus
Inactivated .
(Percent)
79
88
90
91
92
91
94
      Bacterial  inhibition from caustic conditions has long been
known.(74)  Studies have shown that Salmonella typhosa did
survive in  concentrations in the range of pH 11.01-11.50
longer  than two hours,  while Shigella dysenteriae was destroyed
rapidly in  all  pH range studies; pH 11.01-11.50 produced 100%
]cill  in 75  minutes. (75)   However, the effectiveness of lime
treatment on parasitic  ova and viruses has not been demonstrated,
                              -75-

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     Destruction of pathogenic organisms in sludge or  in
sludge-refuse mixtures  by composting has been reported
extensively in the literature. (76-83)  Table 5 indicates
that 60 C  (140 F) for one hour appears to kill all pathogens,
with possible exception of Tubercle bacillus.  (84) M^
tuberculosis was shown  to be destroyed within two weeks at
temperature 60 C  (140 F)  or above. (55)
                       Table 5*
    Time-Temperatures Required for Organism Destruction (84)
                          Destruction
                     Time-Temperature
    Destruction
Time-Temperature
Organism

Salmonella typhosa
Salmonella sp.
Shigella sp.
Ent. histolytica cysts
Taenia saginata
Mycobacterium tubercu-
losis var. hominis
Necator americanus
Temp
C.F)
131-140
131
131
113
131
151

113
Ascaris lumbricoides eggs 122
Time
fain)
30
60
60
few
few
15-20

50
60
Temp
(.F)
140
140
—
131
	
152.6

	
	
Time
fcnin)
20
15-20
	
few seconds
—
momentary

—
—
*  Adapted from Gotass
     Long-term storage of sludge has been suggested as  one
of the  simplest methods of reducing pathogenic organism  numbers
(85).   Hinesly (86)  reported that after storage of sludge
for  30  days,  fecal coliforms were reduced by 99.9 percent.
However,  Dotson (87)  thought that parasites would probably
persist much  longer.
     Heat treatment is a well known method of destroying
pathogenic organisms. Three methods that have been applied
                              -76-

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to sludge treatment are low pressure oxidation, heat drying
and pasteurization.  During the low pressure oxidation (LPO)
process/ the sludge temperature is elevated to between 350
and 400 F, pressure is raised to 180 to 210 psi, and the
retention time is between 20 and 30 minutes.  The process
kills all pathogenic organisms due to the high temperature
achieved and the retention time.  Over 26 U.S. cities are
currently using the LPO process.
     Heat drying of sludge is presently being carried out in
a number of U.S. cities.  However, the numbers are declining
because of cost of fuel necessary for the drying process,
and also because the market for heat dried sludge did not
develop as hoped.  The temperature achieved during the heat
drying process kills most bacteria.
     Pasteurization is a process where the sludge is heated
to a specific temperature for a period of time that will
destroy pathogenic organisms. In most cases this is accomplished
by the use of steam.  Currently, pasteurization is used only
in Europe.
     While the technical literature presents some conflicting
data as to the degree that pathogenic organisms are reduced
by various sludge  stabilization methods, it does generally
indicate that the  stabilization process will reduce most
pathogenic organisms significantly.  This reduction, in turn
minimizes the public health risks associated with the
landspreading of stabilized sludges.
                               -77-

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     To survive and remain virulent, pathogenic organisms
usually depend on the favorable conditions of a host.  When
an organism encounters a situation in which it cannot
function normally, growth stops and the organism dies.
Numerous environmental conditions may affect the organism
after it leaves the natural host.  Although organic matter
in the sludge acts as a protective agent, organisms are
stressed by waste treatment and encounter unfavorable moisture
conditions, pH, temperature, sunlight, and nutrient levels
when applied to land.  Toxic substances in the sludge, soil
antibiotics, and antagonistic organisms may also present
obstacles to pathogen survival.
     In soils receiving sewage sludge, most pathogens will
disappear or be reduced to low numbers in two to three months.
Although some pathogens have long survival time in soil
(Table 6), most do not survive long on plant surfaces.  When
long survival times have been reported, initial inoculation
levels were high, most pathogens were subsequently detected
in low numbers, and no indication was given of the actual
disease potential. (88)
     Table 6 contains part of the data extracted by Dunlop (89)
from his literature review pertaining to the survival of
pathogenic organisms in soil, water and crops.  Except for
Ascaris ova, the table shows that most pathogenic organisms
die off within one year.  The two studies reporting Ascaris
ova living 2-7 years were both conducted in Europe.  Muller
(90)  reported in Germany that Ascaris ova survived up to 7 years
                              -78-

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                          Table 6
Survival times of Pathogenic Microorganisms in various media
Organisms
Ascaris Ova


Endamoeba
Histolytics
cysts
Enteroviruses



Salmonella












Salmonella, other
-than typhi









Shigella




ffutiercle Bacilli

Medium
Soil
Soil
Plants and Fruits
SoU
Tomatoes
Lettuce
Roots of bean
plants
Soil
Tomato & pea roots
Strawberries
Soil
Soil
Soil
Pea plant stems
Radish plant stems
Soil
Lettuce & endive
Soil
Soil
Lettuce
Radishes
Soil
Soil
Vegetables
Tomatoes
Soil

Potatoes

Carrots

Cabbage and
gooseberries
Streams
Harvested Fruits
Market tomatoes
Market apples
Tomatoes
Soil
Grass
Type of
Application*
Not stated
Sewage
AC
AC
AC
AC
AC

AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
Infected feces
Infected feces
Infected feces
AC
AC
AC
Sprinkled with
domestic sewage
Sprinkled with
domestic sewage
Sprinkled with
domestic sewage
Sprinkled with
domestic sewage
Not stated
AC
AC
AC
AC
AC
AC
Survival time
2-5 years
Up to 7 years
1 month
8 days
18-42 hours
18 hours
At least 4 days

12 days
4-6 days
6 hours
74 days
70 days
At least 4 days
14 days
4 days
Up to 20 days
1-3 days
2-110 days
Several months
18 days
53 days
74 days
15-70 days
2-7 weeks
Less than 7 days
40 days

40 days

10 days

5 days

30 minutes to 4 days
Minutes to 5 days
At least 2 days
At least 6 days
2-7 days
6 months
14-15 months
      Contamination
                               -79-

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in garden soil.  Gudzhabidze  (91) reported in the Soviet
Union that Ascaris ova survived 2-5 years in soil of irrigated
agriculture fields.  The literature reviewed does not reveal
any studies in the United States where Ascaris ova survived
in sludge amended soils for more than one year.
     Hess et al.(92) reported the survival of salmonellae on
grass contaminated with sludge for 40 to 58 weeks in a dry
atmosphere.  McCarty and King (93) found that enteric pathogens
could survive and remain virulent for up to two months.
Rudolfs et. al. (94) concluded from field studies that the
survival of representatives of the Salmonella and Shigella
genera on tomato surfaces did not exceed seven days, even
when the organisms were applied with fecal organic material.
He attributed their short survival time to the lack of
resistant stages;  thus making them more vulnerable to adverse
environmental conditions.
     Martin (95),  inoculating sterile virgin soils with E_.
typhosa, found they died out rapidly, but in sterilized
contaminated soils growth occurred and the bacteria survived
for numerous months.  Rudolfs (94) in his literature review,
found that the survival time of E_. typhosa ranged from less
than 24 hours to more than two years in freezing moist
soils, but generally less than 100 days.
     Approximately 90 different enteric viruses have been
recovered from municipal sewage.  However, there are few
                              -80-

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published reports on the survival of viruses in soil, and
persistence on crops.  Larkin et al. (96) described the
persistence of polioviruses for 14 to 30 days on lettuce and
radishes inoculated with sludge.  According to Cliver (97)
the soil is generally not a very adverse environment for
viruses.  Neither chemical nor biological inactivation
occurs very rapidly, but enteroviruses do lose infectiousness
as a function of time and temperature in the soil.  Poliovirus
1, retained in sand from septic tank effluent, was inactivated
at a rate of 13 to 18 percent per day at 20 to 25  C and at
1.1 percent per day at 6 C to 8 C.  (97)
     Rudolfs et al.  (94) reported that unlike pathogenic
bacteria, the parasitic amoeba, Endamoeba histolytica,
forms resistant cysts which enable the organism to survive
under adverse conditions.  However, on the basis of laboratory
and field studies on the survival of Endamoeba histolytica
cysts, the cysts proved to be extremely sensitive to desiccation,
Rudolfs concluded from his studies that field-grown crops
contaminated with cysts of E^_ histolytica are considered
safe in the temperate zone one week after contamination has
stopped and after two weeks in wetter tropical regions.
     It has been shown in the general survey of the literature
 (94) that certain parasite eggs, especially those of Ascaris,
are markedly resistant to external conditions.  Yoshida  (98)
found that mature eggs of A_._ lumbriocoides were still viable
after five to six months under  layers of soil in winter.  He
                                  -81-

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also found (99). that exposure to strong sunlight checked egg
development and eventually killed them.
     Brown C100J reported that the type of soil was an important
factor in the viability of Ascaris eggs.  Experiments showed
Ascaris eggs in feces deposited on sandy soil in the sun
were degenerated in 21 days.  In the shade, however, 91
percent of the eggs contained mobile embryos in 35 days, and
decreased to 69 percent in 54 days.
     Otto C1011. studied the moisture requirements of Ascaris
eggs and found they did not develop to embryonation in
atmosphere of less than 80 percent relative humidity, although
they remained viable for varying lengths of time in atmospheres
containing less moisture.
     Spindler  (102) in his studies on isolating Ascaris eggs
from soil, found the number of embryonated eggs to be suprisingly
small in spite of the fact that the soils were, in many cases,
being subjected to continuous application of sewage.  Vassilkova
(103) in his study of contamination of sewage farm vegetables
with helminth eggs, reported that the Ascaris eggs found on
vegetables, only 36 percent were viable.
     Except in  the two reported cases  (90,91) the literature
indicates that  the survival time of most pathogens found in
wastewater sludge is limited to weeks or months, depending on
environmental conditions.
                              -82-

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3.13  Methods for Biological Examination of Solid Waste
     Bacteria
     Mirdza L. Peterson of EPA has published "Methods for
Bacteriological Examination of Solid Waste and Waste Effluents."
(104)  After examining methods currently available for measuring
the bacteriological quality of solid waste, reliable methods
were established which are best suited to routinely measure,
under practical conditions, the bacteriological quality of
solid waste in and around waste processing areas.  These methods
were not developed to be an all-inclusive battery of tests for
microorganisms in solid waste; rather, these methods test for
only a few of the possible microorganisms in the solid waste.
     Three procedural lines of investigation were undertaken
in this effort:  (1)  to develop methods suitable for indicating
the  sanitary quality of solid waste before and after processing
or disposal;  (2)  to develop methods  suitable for determining
the  efficacy of operational procedures in removing or destroying
the microorganisms; and,  (3)  to develop methods suitable
for  indicating the health hazard of solid waste in which
pathogenic species may be present in  small numbers.  Methods
presented in  this publication are ones for determining:
total viable bacterial cell number, total coliforms, fecal
coliforms, heat-resistant spores, and enteric pathogens,
especially Salmonella sp.
     The determination of approximate total viable bacteria
multiplying at a temperature of 35 C may yield useful information
concerning the sanitary quality of a waste entering a processing
or a disposal site, and provide useful information  in judging
                              -83-

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the efficiency of procedures employed in solid waste processing
and/or disposal operations.
     The coliform bacteria have long been used in the United
States as indicators of fecal pollution in sanitary bacteriology.
Some members of the coliform group of organisms are found in
the feces of warm-blooded animals, in the guts of cold-blooded
animals/ in soils, and on many plants.  Studies have shown that
warm-blooded mammal feces from humans/ animals/ or birds may
at any time contain disease-producing microorganisms. (105)   It
was pointed out that cold-blooded animal feces are quantitatively
insignificant as a source of pollution/ but the coliform
bacteria from plants or soils that have the same  significance
as those from feces; on the other hand, the coliform bacteria
deriving from soils or plants that have not been exposed to
recent fecal contamination has less public health significance.
     The method for determining viable heat-resistant spore-
formers is used to detect spores that survive 80 C temperature
for as long as 30 minutes.  With respect to survival under
heat stress/ most microorganisms in an actively growing (vegetative)
state are readily killed by exposures to temperatures of around
70 C for 1 to 5 minutes.  (106)  Cells inside of material such
as discarded meat products may resist heat longer because the
heat does not penetrate immediately into the center of solid
masses.  Large masses of non-fluid solid matter require
                              -84-

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a long exposure time (1-1/2 to 2 hr) ,  even in an autoclave
(121 C) to be heated throughly so that the center reaches a
sporocidal temperature.  Other reports (107) point out that
although internal air temperatures of municipal incinerators
usually range from 1200 to 1700 F (650 to 925 C) in continuous
operation, intermittent use, overcharging of the incinerator,
and high moisture content of the waste may slow the process
and interfere with sterilization of the residue.
     Fecal pollution of the environment by untreated and
improperly disposed waste may add enteric pathogenic bacteria
to a body of water or a water supply.  The most common type
of pathogen which may be found in untreated waste is Salmonella.
The wide distribution of the many types of Salmonella in
many species of animals with which man has contact or may
use as food makes it difficult to prevent transmission to
man. (108)  Infections may occur through food,  milk, or
water contaminated with infected feces or urine, or by the
actual ingestion of the infected animal tissues. (109)   Salmonella
has been found in many water supplies (110), polluted waters
(111-113), raw municipal refuse and in incinerator residue (111-117)
     General laboratory procedures, sample collection and
preparation procedures, and bacteriological examination
procedures for the organisms mentioned above can be found in
Appendix A-3.1.
     Parasites
     The FDA has recently prepared a methodology for Ascaris
determination in vegetable and sludge samples  (118).  The
                              -85-

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presence of Ascaris eggs, which exit from their host via the
feces, is of concern to EPA in sewage sludge.  These eggs
are highly resistant to extreme temperatures, drying, and
chemical action, and have been known to remain alive in
digested sewage sludge for years.  Ascaris methodology is
presented in Appendix A-3.3.
     Viruses
     Since evidence exists that viruses can survive secondary
waste treatment processes including terminal disinfection,
as well as the sludge digestion process, a method for determining
enteroviruses in solid waste is given.  This method was developed
in an EPA study entitled "Evaluation of Health Hazards Associated
with Solid Waste Sewage Sludge Mixtures" (EPA contract No.68-
03-0128). (55)  The method was employed by the Tennessee
Department of Public Health Laboratories in Nashville to
determine the presence of ECHO, Coxsackie, and Polio viruses.
The methodology, although given in a descriptive form in the
study, has been broken down into steps in Appendix A-3.2.
Since sampling procedures in the report were given for a specially
prepared windrow of solid wastes, they are not included in
Appendix A-3.2. Appendix A-3.1 should be consulted for sample
collection procedures.
     Fungi
     A method for identifying pathogenic fungi in solid waste
samples was developed in the same EPA report sited for virus
methodology, above. (12)  Again, reference should be made to
Appendix A-3.1 for sampling procedures; the fungi methodology
is presented in Appendix A-3.4.
                             -86-

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3.14                    REFERENCES
     U.S. Environmental Protection Agency.  Water
       Programs:  Secondary Treatment Information.
       Federal Register, 41(144): 30786-30789,
       July 26, 1976.

     Cooper, R.C. and C.G. Golueke.  Public Health
       Aspects of On-Site Waste Treatment.  Compost
       Science, 18(3): 8-11.

     U.S. Department of Health, Education, and Welfare,
       Public Health Service, Center for Disease
       Control of Biosafety, Classification of
       Etiologic Agents on the Basis of Hazard.
       Atlanta, Georgia, July 1974.  4th edition  13p.

     U.S. Department of Transportation, Materials
       Transportation Bureau.  Hazardous Materials
       Regulations:  Interim Publication.  Federal
       Register, 41(229):  52086, November 26, 1976.

     U.S. Department of Health, Education, and Welfare,
       Public Health Service.  Code of Federal Regulations,
       42(72.25):   457-459, U.S. Government Printing
       Office,  1976.

     U.S. Environmental Protection Agency.  Thermal
       Processing and Land Disposal of Solid  Waste:
       Guidelines.  Federal Register 39(158); 29328-29338,
       August  14,       ^
      Hanks,  Thrift G.  Solid  Waste/Disease  Relationships;
        A Literature Survey.   Public  Health Service
        Publication No.  999-UIH-6,  Washington,  U.S.
        Government Printing Office. 1967. 179p.

      Morris,  William,  ed.  The American Heritage
        Dictionary of the English Language.   Boston,
        Houghton Mifflin Company,  1976.  1550p.

      Department of Health, Education,  and  Welfare,
        National Institutes of Health.   Recombinant  DNA
        Research Guidelines:   Draft Environmental  Impact
        Statement, Federal Register,  41(176):  38426-
        38483, September 9, 1976.
                               -87-

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10.  U.S. Environmental Protection Agency.  Solid
       Waste Management Glossary.  Environmental
       Protection Publication No. SW-108ts, Washington,
       U.S. Government Printing Office, 1972. 20p.

11.  Block, S.S., J.C. Netherton, and J.B. Sharp.  Non-
       industrial Toxic and Hazardous Wastes.  University
       of Florida, Dept. of Chemical Engineering, Final
       Report.  EPA grant No. R800189, 197_.

12.  Ross Hofmann, Associates.  A Study of Pneumatic
       Solid Waste Collection Systems as Employed in
       Hospitals.  U.S. Environmental Protection Agency,
       EPA/530/SW-75C, 1974.

13.  Iglar, A.F. and Bond, R.G. 1973 Hospital Solid Waste
       Disposal in Community Facilities.  U.S. Environmental
       Protection Agency, Office of Research and Develop-
       ment.  EPA-670/2-73-048.  NTIS-PB-222-018.

14.  Burchinal, J.C. and Wallace, L.P. 1971  A Study of
       Institutional Solid Wastes.  Department of Civil
       Engineering, West Virginia University.  234p.

15.  Esco/Greenleaf 1972 Solid Waste Handling and Disposal
       in Multistory Buildings and Hospitals.  Vol. 1 and
       III from U.S. Government Printing Office,
       Washington, D.C. Vol. II and IV from National
       Technical Information Service, Springfield, Virginia.

16.  Litsky, W.; Martin, J.W.; Litsky, B.Y.  1972
       Solid waste:  a hospital dilemma.  Am. J. Nurs.,
       7_2,  (Oct.), 1841-7.

17.  Anonymous  1972c  Canadian study shows that it's
       cheap and safe to burn and dispose of infectious
       wastes at the hospital.  Modern Hospital, 119,
       (Sept.), 53.

18.  Anonymous  1972b  When is infectious waste not
       infectious waste?  Hospitals, JAHA, 46,  (iMay),
       56, 60, 64, 65.

19.  Bond, R.G. and Michaelson, G.S. 1964 Bacterial
       Contamination from Solid Hospital Wastes.  Report
       on Study Performed under Research Grant EF 00007-
       04.  Minneapolis, Univ. of Minnesota, School of
       Public Health, Aug.  1964.

20.  Armstrong, D.H. 1969  Hospital Refuse-Chute
       Sanitation.   (M.S. Thesis)  West Virginia University.
                             -88-

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21.  Wallace,  L.P.;  Zaltzman,  R.;  Burchinal,  J.C.   1972
       Where solid waste comes from;  where it should go.
       Modern Hospitals, 118,  (Feb.), 92-5.

22.  Smith,  R.J.   1970 Bacteriological Examination of
       Institutional Solid Wastes.  (M.S. Thesis)   West
       Virginia University.

23.  Trigg,  J.A.   1971  Microbial Examination of Hospital
       Solid Wastes.  (M.S. Thesis)  West Virginia
       University.

24.  Oviatt, V.R. 1969 How to dispose of disposables.
       Med.-Surg. Rev. Second Quarter, 1969,  p. 58.

25.  Small,  W.E.   1971  Solid waste:  please burn, chop,
       compact, or otherwise destroy this problem.
       Modern Hospital,   117,  (Sept.), 100-10.

26.  Fahlberg, W.G.   1973  The hospital  (disposable)
       environment.   In Phillips,  G.B. and Miller, W.S.
       ed. Industrial Sterilization.  Duke University
       Press,  Durham, NC.  p.   399-412.

27.  Salkowski, M.D.  1970  Disposal of Single-Use Items
       from Health Care Facilities;  Report of the Second
       National Conference, Sept.  23-24, 1970.

28.  Anonymous 1971b  Plastic leachate found harmful.
       Journal of Environmental Health, 34, (2), 196.

29,  Paul, R.c.  1964  Crush,  flatten, burn,  or grind?
       The not-so-simple matter of disposal.   Hospitals,
       JAHA, 3£,   (1 Dec.), 99-101, 104-5

30.  Walter, C.W.  1964 Disposables, now and tomorrow:
       for the surgeon, many advantages, but still some
       problems.   Hospitals, JAHA, 38,  (1 Dec.), 69, 70,
       72.                         —

31.  Mattson, G.   1974  Handling potentially dangerous
       throwaways in Swedish hospitals.  Solid Wastes
       Management, 17,  (2), 23, 46,  54.

32.  Ostertag, H. and Junghaus, W. 1965  Use and
       elimination of disposable linen in hospitals
       and convalescent homes.  Stadtehygiene, 16, (10)/
       213-8  (Ger,).
                                -89-

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33.  Peterson, M.L.  1974  Soiled disposable diapers—a
       potential source of viruses.  Am. J. Public
       Health, 64_,  (9) , 912-4.

34.  Michaelson, G.S.  and Vesley, D.  1966  Disposable
       hospital supplies:  some administrative and
       technical implications.  Hospital Management, 10^,
       (Jan.), 23-8.

35.  Baker, H.J.  1971 Unpublished paper.  Cited in Iglar,
       A.F. and Bond,  R.G., Hospital Solid Waste Disposal
       in Community Facilities. School of Public Health,
       University of Minnesota.

36.  Deschambeau, G.L.  1967  No more stray shots.
       Modern Hospitals, 109,  (Sept.), 80.

37.  Hewer, C.L.  1971  Disposing of the undisposable.
       British Medical Journal, 3_, (25 Sept.), 766.

38.  Healy, J.J. 1965 Disposable hypodermic syringes and needles,
       Journal of the American Medical Association, 191, (Jan.),
       JL5J..

38a. Decker, W.M. and J.H. Steele.  Health Aspects and
       Vector Control Associated with Animal Wastes.
       Management £f Farm Animal Wastes.  Proceedings
       National Symposium, May 5-7^1966; p. 18-20 St.
       Joseph, Michigan, American Society of Agricultural
       Engineers.

39.  Beneson, Abram S., ed. Control of Communicable
       Diseases in Man.  American Public Health
       Association, Harrisburg, Virginia, 1975.

40.  Pomery, B.J., Siddiqui,  Y., and Grady, M.K.
       Salmonella in animal feeds and feed ingredients.
       Proceedings of the National Conference on Salmon-
       ellosis, U.S. Dept. of Health, Education and Welfare,
       74-77, 1964.

41.  Steele, J.H. and Quist,  K.D.   Chain of infection-
       animal to human.  Proceedings of the National
       Conference on Salmonellosis,  U.S. Dept.  of
       Health, Education,  and Welfare, 71-73,  1964.

42.  Pike,  Robert M. "Laboratory-associated Infections:
       Summary and Analysis of 3921 cases,"  Health
       Laboratory Science, vol. 13,  No.  2,  April 1976,
       reprinted by U.S.Department of HEW, PHS.
                             -90-

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43.  U.S. Environmental Protection Agency, Municipal
       Sludge Management:  Environmental Factors; Technical
       Bulletin. Federal Register 22532-36, June 3, 1976.
       42(211): 57420-27, November 2, 1977.

44.  U.S. Environmental Protection Agency, Office of
       Technology Transfer, Process Design Manual for
       Sludge Treatment and Disposal.  EPA Publication
       No.  625/1-74-006.  Washington, U.S. EPA,
       October  1974.

45.  Office of  Solid Waste, Background Document for
       §4004, P.L. 94-580: §257.4-5, Land Criteria,
       June 24, 1977  (Draft.)

46.  Love,  G.L., Tompkins E. and Galke, W.A. "Potential
       Health Impact of Sludge Disposal on Land" Nat.
       Conf. on Sludge Management and Disp. (1975)

47.  Morbidity  and Mortality Weekly Report, NCDC, PHS,
       December 1976.

48.  Malherbe,  H.H.,-Cholemly, M. (Quantitiative Studies
       on Viral Survival in Sewage Purification Process

49.  Dupont, H.L. and Hornick, R.E., Clinical Approach
       to Infectious Diarrheas.  Med., 52(1973), 265.

50.  Sepp.  E.   The Use of Sewage for Irrigation.  A
       Literature Review.  Bureau of Sanitary Engineering,
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51.  Kreuz, A.  Hygienic Evaluation of the Agricultural
       Utilization of Sewage.  Gesundheitsing. 76:206-
       211, 1955.

52.  Kroger, E. Detection of S. Barelly in Sewage Sludge
       and  Vegetables from an Irrigation Field after
       an Epidemic.  & Hyg. Infektkr. 139:202-207,  1954.

53.  Kabler, P. Removal of pathogenic microorganisms
       by sewage treatment processes.  Sewage and
       Industrial Wastes 31:1373, 1959.

54.  Cram,  E.B., "The Effect of Various Treatment
       Processes on the Survival of Helminth Ova
       and  Protozoan Cysts in Sewage."  Sewage Works
       Jour., 15, 6, 1119  (Nov. 1943).
                             -91-

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55.   Gaby/  W.L.   Evaluation of health hazards associated
       with solid waste sewage sludge mixtures.  EPA
       Contract No. 68-02-0128.

56.   Environmental Assessment of Municipal Wastewater
       Treatment Sludge Utilization Practice"EPA
       Contract No.68-01-3265.

57.   Newton, W.L., Bennett, H.J., and Figgat, W.B.,
       "Observations on the Effects of Various Sewage
       Treatment Process upon Eggs of Taenia Saginata"
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58.   Pramer, D., Heukelekian, H., and Ragotzkie,  R.A.,
       "Survival of Tubercle Bacilli in Various Sewage
       Treatment Processes.  I. Development of a
       method for the Quantitative Recovery of
       Mycobacteria from Sewage."  Pub. Health Rept. 65,
       851, 1950.

59.   Heukelekian, H., and Labanese, M., "Enumeration and
       Survival of Human Tubercle Bacilli in Polluted
       Waters. II.  Effects of Sewage Treatment and
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       (Sept. 1956}

60.   Jensen, K.E., "Presence and Destruction of Tubercle
       Bacilli in Sewage."  Bull. World Health Org., 10,
       171  (1954)

61.   Greenber, A.E., and Kupka, E. "Tuberculosis Trans-
       mission by Waste Waters--A review."  This
       Journal,  29, 5, 524 (May 1957)

62.   McKenney, N.E. Langley, H.E., and Tomlinson,  H.D.
       "Survival of Salmonella Typhosa During Anaerobic
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       31,  1959

63.   Kenner, B.A. et al.  Simultaneous quantitation
       of Salmonella species and Pseudomonas aeruginosa.
       USEPA, NERC, Cincinnati, Ohio,  1971.

64.   Rudolfs, W., Faulk, L.L., and Ragotzkie, R.A.
       Literature Review on the Occurrence and Survival
       of Enteric, Pathogenic, and Relative Organisms
       in Soil,  Water, Sewage, and Sludges and on
       Vegetation.  Sewage and Industrial Wastes.   II
       Animal Parasites 22:  1417-1427.  1950
                            -92-

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65.  Clark,  NA.,  et al.,  "Human Enteric Viruses  in Water:
       Source,  Survival,  and Removability."   In  Advances
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66.  England,  B., et al., "Virological Assessment of
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67.  Kelly,  S.M., et al., "Removal of Enteroviruses from
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68.  Mack, W.N.,  et al.,  Entervorus Removed by Activated
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       34, 1133  (1962)

69.  Lund, E., et al.,  "Occurrence of Enteric Viruses in
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70.  Clarke, N.A., et al., "Removal of Enteric Viruses
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71.  Carlson, H.J., et al., "Effect of the Activated Sludge
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72.  Sproul, O.J. "Removal of Viruses by Treatment
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73.  Kelly, S.M., Clark, M.E., and Coleman, M.B.,
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       Amer. Jour. Pub. Health, 45, 1438 (1955)

74.  Morrison, S.M., Martin, K.L. and Humble, D.E.
       "Lime Disinfection of Sewage Bacteria at Low
       Temperature" EPA Contract No.  660/2-73-017.

75.  Wattie, E., and C.W. Chambers.  Relative Resistance
       of Coliform Organisms and Certain Enteric
       Pathogens to Excess-lime Treatment.  J. Amer.
       Water Works Asso. 35:709-720, 1943.
                             -93-

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76.  Amrami,  A.,  "Agricultural Utilization of Sewage
       and Public Health Problems."  Tauriah (Israel).
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77.  Anon., "Sewage in the Sea.  4: There is a Future
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78.  Golueke, C.G., and Gotaas, H.B., "Public Health
       Aspects of Waste Disposal by Composting."
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79.  Gotass,  H.B., "Composting—Sanitary Disposal and
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80.  McCauley, R.F., "Recent Developments in the
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81.  Snell, J.R., "The Future of Composting."  Proc. Loc.
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82.  Truman,  H.A., "Disposal of Wastes—Composting."
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83.  Wylie, J.zC., "Mechanized Composting."  Inst. of
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84.  Gotass,  H.R. Composting - sanitary disposal and
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85.  Berg, G., 1966.  Virus Transmission by the Water
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86.  Hinesly, T.D., O.C. Braids, J.A.E. Molina, R.I.
       Dick,  R.L. Jones, R.C. Meyer, and L.Y. Welch,
       1972a.  Agricultural Benefits and Environmental
       Changes Resulting from the Use of Digested Sewage
       Sludge on Field Crops.  Annual Report, University
       of Illinois and City of Chicago, EPA Grant DO
       l-Ul-00080, unpublished.

87.  Dotson,  G.K., "Constraints of Spreading Sewage
       Sludge on Cropland.  EPA-NERC pub. May 1973.
                            -94-

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88.  Doran,  J.W.,  Ellis,  J.R.,  and McCalla,  T.M.  "Microbial
       concerns when wastes are applied to Land"  Proc.
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89.  Dunlop, S.C., July 1968.  Survival of Pathogens and
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       gation, Louisiana Polytechnic Institute, Huston,
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90.  Muller, G. "Investigations on the survival of
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       Bakteriol.   159:377  (1953).

91.  Gudzhabidze,  G.A. "Experimental observations on the
       development and survival of Ascaris lumbricoides
       eggs in soil of irrigated agricultural fields"
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       4:979  (19601.

92.  Hess, E., Lott, G., and Breer, C., "Klarschlamn and
       Freilandbiologie von Salmonellen,"  Zentralbl
       Bakteriol.  Hyg., 1 Abt. Orign. B. 158  (1974), 446.

93.  McCarty, P.L., and King, P.H., "The Movement of
       Pesticides in Soils," Proc. 21st Ind. Waste Conf.,
       Purdue Univ., Lafayette, Indiana,  (1966),  156.

94.  Rudolfs, W., Falk, LL., and Ragotzkie, R.A.,
       "Contamination of Vegetables Grown in Polluted
       Soil I.  Bacterial Contamination Sew. Ind. Wastes.
       23(1951),  253.

95.  Martin,  S., Annual Reports of the Medical Officer
       of the Local Government Board  (1897-1900).

96.  Larkin,  E.P., Tierney,  J.T., and Sullivan,  R.,
       Persistence of virus on sewage-irrigated
       vegetables.  Jour. Env. Eng. Div., Proc.  Amer.
       Soc. Civil Eng., 1976,  102; 29-35

97.  Cliver,  D.O. "Surface  Application of Municipal
       Sludges."  Proceedings on Virsus Aspects  of
       Applying Municipal Wastes to Land.  Symposium
       June,  1976, University of Florida.

98.  Yoshida,  S., "On the Resistance of Ascaris  Eggs."
       Jour.  Parasit. 6, 132 (1920)
                             -95-

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99.  Yoskida, S., "On the Development of Ascaris
       Lumbricoides L" Jour. Parasit., 5, 105 (1919)

100. Brown, E.W., "Studies on the Rate of Development
       and Viability of the Eggs of Ascaris Lumbricoides
       and Trichuris Trichiura under Field Conditions."
       Jour. Parasit., 14, 1 (1927)

101. Otto, G.F., "A Study of the Moisture Requirements
       of the Eggs of the Horse, Dog, Human and the
       Pig Ascarids."  Am. Jour. Hyg., 10, 497 (1929)

102. Spindler, L.A., "On the Use of a Method for the
       Isolation of Ascaris Eggs from Soil."  Am. Jour.
       Hyg., 10, 157 (1929)

103. Vassilkova, Z.G., "Evaluation of the Contamination of
       Vegetables with Eggs of Helminths in Sewage Farms
       with Different Methods of Cultivation."  Med.
       Parasit. and Parasitic Dis., Moscow, 10,  217
       (1940); Trop. Dis. Bull., 40 318  (1943);  Pub Health
       Eng. Abs., 23, 11, 18 (1943)

104. Peterson, M.L. Methods for Bacteriological
       Examination of Solid Waste and Waste Effluents
       U.S. Environmental Protection Agency publication
       SW-68r.of, 1972, 30p.

105. Clark, H.F. and P.W. Kabler.  Revaluation of the
       significance of the coliform bacteria.  Journal
       of Am. Water Works Assoc., p. 931-936, 1964.

106. Frobisher, M.  Fundamentals of microbiology.  6th
       edition, p. 151, 152, 1957.

107. Barbeito, M.S. and G.G. Gremillion.  Microbiological
       safety evaluation of an industrial refuse
       incinerator.  Appl.  Microbiology 16: 291 - 295,
       1968

108. Dauer, Carl C. 1960 Summary of Disease outbreaks
       and a 10-year resume.  Public Health Report,
       Vol. 76, No. 10, p. 915, Oct. 1961

109. Dubos, Rene.  Bacterial and mycotic infections of
       man.  J.B. Lippincott, Philadelphia, 1958.

110. Weibel, S.R.F.R. Dixon, R.B. Weidner, and L.J.
       McCabe.  Waterborne-disease outbreaks 1946-1960.
       J. Am. Water Works Association.  Vol. 56, p. 947 -
       58, August, 1964.
                             -96-

-------
 111. Spino^D.F   Elevated- temperature techniques for
                                    from
 112. Scarce, L.E. and M.L. Peterson.  Pathogens in streams
        tributary to the Great Lakes.  In Proc.  Ninth
        Conf. on Great Lakes Res.,  March 28-30  1966,

                       -  Public No*  15  An
 113.  Peterson,  M.L.   The occurrence of Salmonella in
        streams  draining Lake Erie Basin,   in Proc
        Tenth Conf.  on Great Lakes Res., Apr? l5-12  1967
        Toronto,  p.  79.   Ann Arbor,  Univ.  of Mich" '19 ll.'
            . of Health, Education, and Welfare  PHS
       Communicable Disease Center, Laboratory branch,
       Atlanta, Georgia, p. 1 - 39, September 1962
       eva?Sa;io;L;f^d ^J' ftutzenberger.  Microbiological
       evaluation of incinerator operations.  Appl.
       Microbiological, Vol. 18, No.l, p. 8 - 13, 1969

117. Spino, D. Bacteriological study of the New Orleans
       East incinerator.  U.S. Environmental Pro?ectiSn
       Agency.  Office of Research and Monitoring? 1971.

118. Jackson, G'.J., j.w. Brer, W.L. Pavne  T A  f^rrM™

       tsc?ri? Method^W.  Chapter N?U977] I  Bac?er£?'
       logical Analytical Manulal. U.S. Pood and D?ug
       Administration,  Washington, 1977. (in press)
                            -97-

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                                              DRA1
                  APPENDIX A-3
Methods for Biological Examination of Solid Waste*
     A-3.1          Bacteriological Examination
     A-3.2          Virological Examination
     A-3.3          Determination of Ascaris spp. Eggs
     A-3.4          Determination of Pathogenic Fungi

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                                     A-3-1
                    METHODS FOR BACTERIOLOGICAL EXAMINATION
                       OF SOLID  WASTE AND WASTE EFFLUENTS*
                                           Mirdza L. Peterson
                                  Germ* Laboratory fnctdum

    Glassware washing.

      All glassware known to contain infectious material must be sterilized by autoclaving before
    washing. All glassware that is to be used in microbiological tests must be thoroughly washed before
    sterilization, using a suitable detergent and hot water, and followed by hot water and distilled water
    rinses. Six to  12 rinses may  be required to remove all traces of inhibitory residues from the glass
   Sterilization.

      Dry heat is  used  for  the sterilization .of glass, sampling  bottles, foil-covered flasks, beakers,
   graduates, pipettes packed tightly in sealed cans, or articles that are corrosively attacked be steam.
   Recommended time-temperature ratio for dry heat sterilization is 170 C for 2 hr.

      Saturated steam under pressure (or autoclaving) is the most frequently used sterilization method.
   Media, dilution water,  and  materials (rubber, paper, cotton, cork, heat-stable plastic tubes, and
   closures, for example) are sterilized by autoclaving at 121 C. Sterilization time for media and dilution
   water (for volumes up  to 500 ml) is 15 min; 1,000-ml quantities are held for 20 min, instruments
   for 15 min, gloves for 20 min, and packs for 30 min (measured from the time the autoclave temper-
   ature reaches 121 C).
      Membrane filters are sterilized for 10 min at  121 C with  fast steam exhaust at the end of the
   sterilization process.
      Heat-sensitive carbohydrates and other compounds are sterilized by pasvsji through a cellulose
   either	ibisau or Motim bacteria-retaining filter.
* rroa Phvaical. Ch«mie*lf and Microbiological  Method, Qg
  Solid waana  Taitlna. n.«,  PP&                            	

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                                                                          r^r% r
                                                                          ,.  t>.h*S f :
Culture media.
  The use of dehydrated media is recommended whenever possible, since these products offer the
advantages of good consistency from lot to lot, require  less labor in preparation, and are more
economical. Each lot  should be tested for performance before use.
  Measurement of the  final  pH of a  prepared culture medium  should  be accomplished  colon-
metrically after autodaving and cooling. Acceptable pH range is 7.0 ± O.I.

  Media should be stored in a cool, dry, and dark place  to avoid dehydration, deterioration, and
adverse light effects. Storage in the refrigerator usually prolongs the shelf-life of most media. Media
should not be subjected to long periods of storage, because certain chemical reactions ma/ occur in
a medium even at refrigerator temperatures.
  Many of the media referred to below can be obtained from commercial sources in a dehydrated
form  with complete information on their preparation. These media will therefore be listed but not
described  in this  section.  Described in this section are  those media that are  formulated from
ingredients or from  dehydrated materials. Culture media (Difco  or BBL  products) are listed  as
follows:
     Bacto-agar
     Bismuth  sulfite agar
     Blood agar
     Brain heart infusion broth
     Brilliant  green  agar
     Brilliant  green  lactose bile, 2 percent
     Coagulase mannitol agar
     Dextrose
     E. C. broth
     Eosin methylene blue agar, Levine
     Fluid thioglycollate medium
     Gelatin
     H-broth
     Indole nitrite medium
     KCN medium

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                                                                          DRA
  Lactose
  Lactose tryptose broth
  Lauiyl tryptose broth
  Lysine decarboxylase medium
  M-Endo broth
  M-FC broth
  MacConkey's agar
  Malonate broth, Ewing modified
  Maltose
  Mannitol
  Mannitol salt agar
  Methyl red-Voges Proskauer medium
  Nitrate broth
  Nutrient agar
  Phenol red broth base
  Phosphate buffer, APHA, pH 7.2
  Sabouraud's dextrose agar
  Salmonella-Shigella agar
  SBG enrichment broth
  Selenite-F enrichment broth
  SIM medium
  Simmons citrate agar
  Sucrose
  Triple sugar iron agar
  Ttypticase soy agar
  Tryptone glucose extract agar
  Urea agar base concentrate (sterile)
  XLD agar
Culture media requiring preparation.
.   Blood Agar: Suspend 40 g of trypticase soy agar in a liter of distilled water. Mix thoroughly.
tat with agitation and boil for 1 min. After solution is accomplished,, sterilize by autoclaving for
(Kin at 121 C. Cool agar to 45 to SO C, and add 5 to 7 percent sterile, defibrinated sheep blood,
being evenly throughout the medium. Four into sterile Petri dishes. After solidification, invert
foes  and incubate overrate.
   phenol Red Broth Base: Dissolve 15 g in a liter of distilled water. Add 5 to 10 g of desired carbo-
rdrate. Use Durham fermentation tubes for detection of gas formation. Arrange tubes loosely hi
(table containers and sterilize at 116 to 118 C for IS min.
   phosphate  Buffer Solution: To  prepare stock phosphate buffer  rotation,  dissolve  34.0 g
Xassium dihydrogen phosphate, KH, PO4, in 500 ml distilled water, adjust to pH 7.2 with IN NaOH,
tt dilute to 1  liter with distilled water. Add 1.25 ml stock phosphate buffer solution to 1 liter
Willed water. Dispense in amounts that will provide 99 ± 2.0 ml or 9 ± 0.2 ml after autoclaving
 121 C for 15 min.

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                                                                          DRAs
                                                                  Bacteriological Examination
                 COLLECTION AND PREPARATION OF SAMPLES
                Method for Collection of Solid Waste or SemirSolid Waste Samples

Equipment and materials.
Necessary items are as follows:
1 .   Sample containers, specimen cups, sterile, 200-ml size (Falcon Plastics, Los Angeles)
2.   Sampling tongs, sterile (stainless steel, angled tips, 1 8 in. long)
3.   Shipping container, insulated, refrigerated, 6 by 12 in. IJD.
4.   Disposable gloves

Procedure.
1.   Using sterile tongs, collect 20 to 40 random 100- to 200-g samples and place in sterile sampling
containers. When collecting  samples from contaminated sources, wear disposable gloves and avoid
contaminating the outside of the container.
2,   Identify samples on tag and indicate time and date of sampling. If incinerator residue samples are
taken, record operating temperatures of incinerator.

3.   Deliver samples to laboratory. It is recommended that the examination be started preferably
within  1 hr after collection;* the time elapsing between collection and examination should in no
case exceed 8 hr.
          Method for Collection of Liquid Samples-Quench and Industrial Waters or Leachate

 Equipment and materials.
   Necessary items include a screw-capped, 250-mi, sterfle sample bottle or a 16-oz, sterile plastic
 bag.

 Procedure,
   Collect sample in bottle or plastic bag, leaving an air space in the container to facilitate mixing of
 the sample before examination. When collecting samples from contaminated sources, wear disposable
 gloves and avoid contaminating the outside of the container.
   Identify and  deliver samples to laboratory. When shipping samples to laboratory, protect con-
 tainers from crushing and maintain temperature below  IOC during a maximum transport  time
 of 6  hr. Examine within  2 hr. If water sample contains  residual chlorine, a dechlorination agent
 such  as sodium thiosulfate is added  to collection bottles to neutralize any residual chlorine and to
 prevent a continuation of the bactericidal action  of chlorine  during the  time the sample is in
 transit to the laboratory. Enough sodium  thiosulfate is added  to the clean sample bottle before
 sterilization to provide an approximate concentration of 100 mg per liter in the  sample.
 •If ample is shipped to a laboratory for analysis and examination cannot begin within 1 hr of collection, the
  
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                                                                            DRAr
                      Method for Collection of Incinerator Stack Effluents
Equipment and materials.
  Necessary  items  include an Armstrong portable sampler (2), equipped with sampling assembly
(Figure 1). The sampler is mounted on a steel plate (6 by  12 in.) and can be enclosed by a metal
cover with a handle attached. On one side of the base is a vacuum pump  with a 6-ft cord and
switch. The pump is capable of drawing up to 1 cu ft per min of air (vacuum of 5.6 in. 1 1 4.3 cm]  of
water). On the other side of the base, a 700-ml, wide-mouth, Pyrex bottle contains 300 ml of 0.067
M phosphate buffer solution (pH 7.2) prepared by standard methods (3).  The two-hole rubber
stopper has  a 1-in. (2.54 cm) piece of cotton-plugged glass tubing  in one of the two holes. The
stopper, Bias* tube, and contents of  the bottle are maintained sterile. The  bottle is held to the
base plate by three removable spring clips, which are attached at the  base and at a wire triangle
slipped over  the top of the bottle. The sampling probe is made of stainless steel tubing of appropriate
diameter (e.g., 0.25-in.  I.D. [0.64 cm]). The probe end has a right-angle bend so that the opening
faces the stack-gas current. The tubing must be long enough to reach all parts of the stack; The tubing
is coiled to permit  additional cooling of the gases and is straight for I or 2 ft (30.48 or 60.96 cm) at
a right angle to the other straight length. Before use, the  sampling probe is  sterilized  by dry heat
sterilization.  It is important  to keep the inside of the probe dry to minimize adsorption of micro-
organisms on the walls  of the tubing. When sampling, the probe is inserted into the stack at locations
that will yield a representative sample. The other end of  the sterile probe is inserted  through the
sterile rubber stopper to approximately 0.5 in. (1.27 cm) above the  buffered water. This is done to
reduce the frothing that would occur  if the probe were inserted below the surface; enough froth
        in capturing the microorganisms.
  jocedure.
 1.    Draw  stack effluent through the sterile stainless steel  tube by a 1.0 cfm vacuum pump; cool
 the tube with a water jacket.
 2    Obtain a 10-cu-ft sample by drawing the stack effluent for 10 min.
 3]    Identify sample on tag and examine within 4 hr. The Armstrong portable sampler provides
 a" method  for  qualitative,  nonisokinetic sampling and is adjustable to isokinetic conditions.
                          Method for Collection of Dust Samples


 Equipment and materials.
 Necessary items include the following:
 ?|p   Andersen sampler (4)
 2.   Trypticase soy agar containing 5 percent sheep blood (6 plates per sample)
 3,   Eosin methylene blue agar
 froeedure.
 I.   Draw air through the sterile, assembled sampler at 1.0 cfm with a vacuum of 15 in. of mere
 £   Remove agar plates from the sampler, cover, and incubate at 35 ±0.5 C. Use aseptic techniq
 throughout the procedure.

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             81
CARRYING CASE
                            6"
             PHOSPHATE BUFFER
                                        II
                                        II
                                            SAMPLING PROBE

                                                          FLOWMETER
      VACUUM
       PUMP
                                                                 	Q=
12'
   Figure I. Portable sampler for microorganisms in incinerator stack emission.

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               Method for Preparation of Solid and Semi-Solid Samples for Analyses

 Equipment and materials.
 Necessary items are as follows:
 1.   Cold phosphate buffer, 0.067 M, pH 7.2, sterile (3)
 2.   Blender, Waring (Model 1088), sterile
 3.   Balance, with weights, 500-g capacity
 4.   Tongs, sterile
 5.   Beakers, two, 5,000 ml and 1,000-ral sizes, sterile, covered with aluminum foil before sterili-
 zation.

procedure.
 \.   Using  aseptic technique, composite  all random samples into a 5,000-ml beaker. Mix well.
 2!   Weigh 200 g  of the subsample into a 1,000-ml beaker.
 3.   Transfer the  weighed sample to a sterile  blender.
 4.   Add  1,800 ml of sterile, phosphate buffered solution to the blender.
 5]   Homogenize  for 15  sec at 17,000 rpm (5).
 5*   Prepare a series of decimal dilutions as described below in "Methods for Preparation of Decimal
 Dilutions of a Solid, Semi-Solid, or Liquid Waste Material."
Solid waste and residue samples for enteric pathogenic bacteria are examined directly without homog-
 •nization.
BACTERIOLOGICAL  EXAMINATION OF WASTE AND RELATED  MATERIALS

     Method for Preparation of Decimal Dilutions of a Solid, Semi-Solid, or Liquid Waste Material

   Immediately after homogenization of any sample (see procedure under Method for Preparation of
 Solid  and Semi-Solid Samples for Analyses) transfer a 1-ml portion of the homogenate (10M  dil)
 to a dilution bottle containing 99 ml of phosphate buffered solution. Stopper and shake the bottle
 25 times.
   Prepare dilutions as  indicated in Figure 2. Again shake each dilution vigorously 25 times after
 adding an aliquot of sample.
   These dilutions are used to inoculate a series of selected culture media for the detection of various
 groups of microorganisms as described  in the following sections of this paper.

                         Methods for Total Viable Bacterial Cell Number

   The chief cultural method for determining total viable bacterial densities has been the agar plate
 method (3, 6, 7). Experience  indicates that an enumeration of total number of viable bacteria
 multiplying at a temperature of 35 C  may yield useful information concerning  the sanitary quality
 of  the waste entering a processing or a  disposal site and provide useful information in judging the
 efficiency of procedures  used in solid  waste  processing  and/or disposal operations. The viable
 microbial  count also  provides valuable information  concerning the  microbiological quality of
   nvironmental  aerosols existing in or  around a waste processing plant or  a disposal site.

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Solid or semi- solid
waste sample
20(
QMS
Blend with
1800ml
buffered water
                   Liquid sample
                       90ml
                      buffered
                       water
                                               99ml
                                             buffered
                                               water
 99ml
buffered
 water
Figure 2.  Preparation of decimal dilutions.

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Equipment, materials, and culture media.
I.   Pipettes,  1.1 ml with 0.1 ml and 1 ml graduations
2.   Dilution blanks, phosphate buffered solution, 99 ml ± 1 ml (cold)
3.   Culture dishes (100 x 15 mm), plastic, sterile
4.   Water bath for tempering agar, 45 ± 1 C
5.   Incubator 35 ± 0.5 C
6.   Colony counter, Quebeck
7.   Sterile glass spreader, bent rod
8.   Trypticase soy agar with 7 percent defibrinated sheep blood (TSA + blood)
9.   Tryptone glucose extract agar (TGE)
   Prepare TGE agar as indicated on label and hold in a melted condition in the water bath (45 C).
   Dissolve ingredients of TSA and heat to boiling. Sterilize by autoclaving at 121 C for 15 min.
Cool to 45 C and add sheep blood. Dispense in Petri plates and allow to solidify. Invert plates and
place them in incubator overnight to dry.

  ocedure for bacterial count by pour plate.
     Pipette 1 ml, 0.1 ml, or other suitable volume of the sample into each of appropriately marked,
Duplicate culture plates,  being sure to shake each dilution bottle vigorously 25 times to resuspend
material that may have settled  out
2.   Add 10 to 12 ml of melted TGE agar to the sample in the Petri plate.
3.   Mix dilution and the agar medium by rotating or  tilting the plate.
4.   Allow plates to solidify as rapidly as possible after pouring.
5.   Invert plates and incubate them at 35 C ± 0.5 C for 24 ± 2 hr.
6.   Count all colonies  using  Quebeck  colony counter, the objective being to count plates with
30 to  300 colonies.
7.   Compute the colony count per  gram of waste (wet weight) or related solid material, and  per
100 ml  of water. The number of bacteria should not include more than two significant figures.

Procedure for bacterial count by streak plate.
1.   Dispense 0.1 ml samples of the serially diluted homogenate (or liquid) on the surface of each
of appropriately marked, duplicate TSA + blood agar plates.
2.   Using a sterile glass spreader and starting with the highest dilution plates, spread  the inoculum
evenly over the agar surface.
3.   Invert plates and incubate them at 35 C for 24 hr ± 2 hr.
4.   Count the number of colonies on plates with 30 to 300 colonies.
5.   Select and mark colonies for further testing.

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                  Methods for Presence of Members ofColiform Group


   The presence of fecal matter in "waste and related materials is determined by the standard tests
 for the coliform group described in Standard Methods for the Examination of Water and Waste
 Water (3). The completed Most Probable Number (MPN) procedure is employed, The testing method
 includes the elevated temperature test (44.5 C) that indicates  the  fecal or nonfecal origin of
 cohform bacteria. Comparative laboratory studies conducted showed that the MPN estimate is the
 most suitable method for  achieving a representative enumeration of the coliform organisms in solid
 waste and waste effluents (9).                                                    ...
Equipment and materials.
1.   Pipettes, sterile-deliveries to 10 ml, 1 ml (1.1 ml), and 0.1 ml
2.   Media prepared in fermentation tubes:          f
         Lauryl tryptose broth
         Brilliant  green  lactose bile broth, 2 percent
         Lactose tryptose broth
         E.G. broth
3.   Media for plating:
         Eosin methylene blue ngur plates
         Nutrient agar slants
4.   Dilution blanks, phosphate buffer solution, sterile, 99-mi or 90-ml amounts
5.   Incubator, adjusted to 35 C ± 0.5 C
6.   Water bath, adjusted to 44.5 C ± 0.2 C

Procedure for total coliform group.
  Presumptive Test.
1.   Inoculate a predetermined volume of sample into each of 5 lauryl tryptose broth tubes. The por-
tions of the sample used for inoculation should be decimal multiples and submultiples of 1 ml.
2.   Incubate the fermentation tubes at 35 ± 0.5 C for 24 i 2 hr.
3.   Examine for the presence of gas. If no gas is formed, incubate up to 48 ± 3 hr. Record the
prsscr.ci or absence  of gas formation at each examination of the  tubes, regardless of the amount.
  Confirmed Test.
1.   Submit all presumptive  test  tubes showing any amount of gas at the end of. 24- and 48-hr
incubation  to the confirmed test. Using a sterile platinum loop 3 mm in diameter, transfer one loop-
fui  of medium from, the presumptive test fermentation tube to  a fermentation tube containing
brilliant green lactose bile broth.
2.   Incubate the inoculated  brilliant green lactose bile broth  tube for 48 ±3 hr at 35 ± 0.5  C.
The presence of gas  in any  amount in  the  fermentation  tube of the brilliant green lactose bile
broth within 48 ± 3  hr  indicates a positive  confirmed test.

-------
                                                                                         r •:>•
                                                                                         T t
   Completed Test.
 1.   Submit all  confirmed test tubes showing any amount of gas to the completed test. Streak an
eosia msthylene blue agar plate from each brilliant green bile broth tube as soon as possible after
the appearance of gas.
2.   Incubate the plates at 35 ± 0.5 C for 24 ±2 hr.
3.   Fish one or more typical or atypical colonies from plating medium to lactose tryptose broth
fermentation tubes and nutrient agar slants.
4.   Incubate the broth tubes and the agar slants at 35 ± 0.5 C for 24 ± 2 hr or 48 ± 3 hr if gas is
not produced in 24 hr.
5.   Prepare gram stained smears from  the nutrient agar slants if gas is produced in any amount
from lactose broth.
6.   Examine smears under oil immersion. If typical coliform staining and morphology are found
on the slant, the test may be considered completed and the presence of coliform organisms demon*
strated.

Procedure for fecal coliform group (E. C broth).
1.   Submit all  gas  positive tubes  from the Standard  Methods presumptive test (lauryl tryptose
broth) to the fecal coliform test. Inoculate an E. C. broth fermentation  tube with a 3-mm loop of
broth from a positive presumptive tube.
2.   Incubate the  broth  tube in a water bath at 44.5 ± 0.2 C for 24 hr.  AH E. C. tubes must be
  laced in the water bath  within 30 min  after planting.
     Gas production in the E. C. broth fermentation tubes within 24 hr ± 2 hr is considered a posi-
  ve reaction indicating fecal origin.

Computing and recording most probable number (MPN).
   The calculated  estimate and  the 95 percent confidence limits of the MPN  described in the
13th edition of Standards Methods for Examination of Water and  Waste  Water (3) are presented in
Table 1. This table  is based on five 10-ml, five 1.0-ml, and five 0.1-ml sample portions.When the series
of decimal dilutions such as 1.0, 0.1, and 0.01 ml are planted, record 10 times the value in jthe table;
if a combination of portions of 0.1, 0.01, and 0.001 ml are' planted, record 100 times the value  in
the table. MPN values for solid samples  are calculated per g of wet weight; MPN for liquid  samples
are recorded per 100 ml.
             Method to Determine the Presence of Viable Heat-Resistant Spore Number


 Equipment and materials.
  1.   Test tubes, sterile, screw capped, 20 x 150 mm
  2.   Pipettes, sterile, graduated, 10-ml
  3.   Water bath, electrically heated,  thermostatically controlled  at 80 ± 0.5 C, equipped with
  thermometer (range 0 to  110 C), NBS certified.  Volume  of water should be sufficient to absorb
  cooling effect of rack of tubes without drop in temperature greater than 0.5 C.
  4.   Test tube support for holding tubes

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                                   TABLE 1.
              MPN INDEX AND 95 PERCENT CONFIDENCE LIMITS FOR
         VARIOUS COMBINATIONS OF POSITIVE AND NEGATIVE RESULTS
           WHEN FIVE 10-ML PORTIONS, FIVE 1-ML PORTIONS, AND FIVE
                          0.1-ML PORTIONS ARE USED.*
No. of Tubes Giving
Positive Reaction out of

5 of 10
ml Each
0
0
0
0

1
1
1
1
1

2
2
2
mm
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
4
5 of 1
ml Each
0
0
I
2

0
0
1
1
2

0
o
w
i
A
1
2
3
0
0
1
1
2
2
3
0
0
1
1
1
2
5 of O.I
ml Each
0
1
0
0

0
1
0
1
0

0
1
&
o
w
1
0
0
0
1
0
1
0
I
0
0
1
0
1
2
0

MPN
Index
per
100 ml
<2
2
2
4

2
4
4
6
6

5
7
r
9
9
12
8
11
11
14
14
17
17
13
17
17
21
26
22
95% Con-
fidence Limits

Lower

<0.5
<0.5
<0.5

<0.5
<0.5
<0.5
<0.5
<0.5

<0.5
i
4
1
A
2
2
3
1
2
2
4
4
5
5
3
5
5
7
9
7
Upper

7
7
11

7
11
11
15
15

13
17
* /
21
21
28
19
25
25
34
34
46
46
31
46
46
63
78
67
































No. of Tubes Giving
Positive Reaction out of

5 of 10
ml Each

4
4
4
4

5
5
5
5
5
5
5 of 1
ml Each

2
3
3
4

0
0
0
1
I
I
t
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
2
2
2
3
3
3
3
4
4
4
4
4.
5
5
5
5
5
5
5 of 0.1
ml Each

1
0
1
0

0
1
2
0
1
2

0
1
2
0
1
2
3
0
1
2
3
4
0
1
2
3
4
5

MPN
Index
per
100ml

26
27
33
34

23
31
43
33
46
63

49
70
94
79
110
140
180
130
170
220
280
350
240
350
540
920
1600
52400
95% Con-
fidence Limits

Lower

9
9
11
12

7
11
15
11
16
21

17
23
28
25
31
37
44
35
43
57
90
120
68
120
180
300
640

Upper

78
80
93
93

70
89
110
93
120
150

130
170
220
190
250
340
500
300
490
700
850
1,000
750
1,000
1,400
3,200
5,800

'Source: Staiuhnl MetJtotJs fur the Examination of Water and Wauewuter.  13th cii.
 Published, 1971. p. 673. Reproduced by permiuion. American Public Health Akocution.
 American Water Works Association, and Water Pollution Control Federation.

-------
 1.   Transfer 10 ml from each original sample and from each successive dilution thereof to screw-
 capped test  tubes, being careful to avoid contaminating the lip and upper portion of tube with
 sample.
 2.   Place tubes in a rack.
 3.   Place rack of tubes  in water bath at 80 C for 30 min. Tubes should be immersed so that the
 water line is approximately  l'/i in. above the level of samples in the tubes.
 4.   At the  end of the 30-min holding period, remove the rack of tubes from the water bath  and
 place in cold water for 5  min to cool.
 5.   Determine viable heat-resistant spore count by agar pour-plate method (see, Procedure for
 Bacterial  Count by Pour  Plate under Methods for Total Viable Bacterial Cell Number).
 6.   Report  results as "viable heat-resistant spore count per  gram."
                          Methods to Detect, Enteric Pathogenic Bacteria
Equipment, materials and media.
I.   Incubator, 37 C
2c   Water baths, constant temperature, 39.5 C and 41.5 C
     Flasks, wide-mouth, 500-ml
     Membrane filter holder
     Flasks, vacuum, 2,000-ml
xj.   Balance, with weights, 100-g capacity
7.   Needle, inoculating _
8.   Media and reagents"'
        Selenite brilliant green/sulfa enrichment broth
        Selenite F enrichment broth
        Eosin methylene blue (EMB) agar
        Salmonella-Shigella (SS) agar
        Bismuth sulfite (BS) agar
        McConkey's agar
        Brilliant green (BG) agar
        Triple sugar iron (TSI) agar
        Urea medium
        XLD agar
        Salmonella antiserums
        Shigella antiserums
        Biochemical media (IS)
 9.   Diatomaceous earth (Johns-Manville, Celite SOS), sterile


Procedure to detect pathogens in solid waste and incinerator residue.
 1    Add a previously  weighed, 30-g sample to each of two flasks containing 270 ml Selenite F
 enrichment broth, and also  to each of two flasks containing 270 ml Selenite brilliant green/sulfa
 'SBG)  enrichment broth. Sliakc to mix.
      Incubate one Selenite F and one SBG flask at 39.5 C and the other two at 41.5 C for 16 to
 ,3 hr.

-------
                     Solid wait* or residua
                        Sample 30 gms
      SolonitoF
        270ml
                    VDC
                                 Selenite brilliant
                               Or««n/Sulfa270ml
                                        I
         Incubate at 39.5 C and 41.5 C
                SS
               Agar
      I             I
      BS           BG
    Agar         Agar

•4 plates each—-
                                                   I
                                             MacConkey's
                                                Agar
                       Incubate at 37 C
                    TripU Sugar Iron ogar
    I
                  Uroo medium (Chr8t»>m«n)
                               I
            |2- to 4-hour reading of urea medium )
   *
Prefect

group
                                               1
                                     (R*incwbal» n«gativ«
                                     ur«a mvdium)
                          (TSI agar)
  Salmonella polyvaUnt
       antisorums
I
          1
                          5hig»llo polyvalent antUarwmi
                          Salmon»//a polyvaUnt antiwrumi
+
Identify ••rolog<*
icolly; confirn
blechomically.
Do biochemical
te»t$.
                            I
                                        I
                           Identify »erologically;
                           confirm biochemically.
                                1
                                           Do biochemical
                                               tostt.
                  I
           If not readily identifiable,
           proceed to biochemical tests.

         Figure 3.  Isolation and preliminary identification.
                             14

-------
              TABLE 2. DIFFERENTIATION OF ENTEROBACTERIACBAE BY BIOCHEMICAL TESTS.
TEST or SUBSTRATE
INMIL
tlt.TNYl.IH>
VOCES -PIOSCAUCI
SWMOKf* CITIATS
•VDftOGEN WtnU (IB)
llEAiC
•CM .
UOTIt-ITY
OCLATIN (MO
L1TMIC OrCUXUYLAK
ACCtMBiC DfOTMOLASt
OtJlTHIKe PECA«WX«.*«
PKiJfYUILAfrB'C OFAMMASC

tuLMATC
C«5 riOM CttCOM
LACTOSC
sucaosc
MANDITOL
PULCnrOL
»AUCUI
AMKITOL
omnw.
nunot
ABAUHOX
•ArnMX
UAUHOSC
EsaiEmaiiEAE
.-*
4
<•
-
-
-
-
-
*«t-
-
d
d
d
-
-
4
4
d
4-.
d
d
.
-
*
*
d
d
-
~» 4
4
•
-
-
-
-
-
-
-
[-M
din
-
-
-«"
.««»
.<«
+ •-
d
-
.
-
d
d
, d
d
EDWARD
SIELLEAE
—
4
4
-

4
-
-
4
-
4
-
4
-
-
4
-
-
-
-
-
-
-
-
-
-
-

Ti «. M inml «» ••» M«llfc» It 1 • 1 1..*. ..Mu>
SALMONELUAE
«-~
•
4
•
A
t
•
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4
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.
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4
4
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*
KLEBSIELLEAE
ri»t«i>M>
• •»
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4
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4
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•
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-
*
-
*
*
*
4
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4-
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4
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r-.»i^«
—
-
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ne
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-
-

4

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— M
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-
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IIC
-
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-

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-*w
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+ •
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•


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.
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.
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4


-
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.
.
.
.
.
.
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ttttftn
4


-
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-
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-
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.
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d
4
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.
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*.«*.«<
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4
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-
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.
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4
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•Source: Identification of t'nterobaetrriaceae by P-R- Edwards and W.H. Ewing. Thltd edition. 1972. p. 24. Reproduced by pentiUdtm.

-------
                                                                                J9 >4
                                                                                * ?,«>• - * -: « ••'
                                                                              W ift A3  3
      3.   After incubation, streak one loopful from each enrichment medium on each of four plates of
      Salmonella-Shigella and other selective enteric media.
      4.   Incubate the plates at 37 C for 24 to 48 hr and pick suspicious colonies to triple sugar iron
      agar slants.
      5.   Incubate the slants at 37 C for 24 hr and complete identification by appropriate methods as
      described by Edwards and  Ewing (20). Isolation, preliminary identification, and biochemical testing
      are described in Figure 3 and in Table 2.


      Procedure to detect pnthcsstis in quench or Industrial waters and in leachate.
      1.   Place enough sterile  diatomaceous earth on the screen of a stainless steel membrane filter
      holder to form a 1-in.  layer.
      2.   Filter 800-ml sample through the earth  layer.
      3.   Remove one-half the diatomaceous earth layer with  a sterile spatula and place into 90 ml of
      Selenite  F enrichment  broth; place  other half of the earth layer into 90 ml of Selenite brilliant
      green/sulfa enrichment  broth. Shake both flasks to mix.
      4.   Incubate both flasks  in a water bath at 39.5  C  for  16 to 18 hr.
      5.   Proceed as directed in steps 3 through 5 of Procedure to Select Pathogens in Solid Waste and
      Incinerator Residue.


                        Method for Examination of Stack Effluents                              ~~
              "" °f "" "toocuu"«1" """"h". b«ffer»l»tkmtlm,u1Ih,0.45B HA men*™.
:                MSISS^
                                                                                  •

                            Method for Examination of Dust








                "•""• **** 1"taobial —•-*•*.«- —     ^

-------
                                      REFERENCES

 ..   Hanks, T.G. Solid waste/disease relationships. U. S. Dept. of Health, Education, and Welfare,
     Public Health Service Publ. No. 999-UIH-6, Cincinnati, National Center for Urban and Indus-
     trial Health, 1967.
 2.   Armstrong, D.H. Portable sampler for microorganisms in incinerator stack emissions. Applied
     Microbiology, 19 (1): 204-205, 1970.
 3.   American  Public Health Association. Standard  methods for the examination of water and
     waste water. New York, American Public Health Association, 1971.   :
 4.   Andersen,  AJL New sampler for the collection, sizing and enumeration of viable airborne
     particles. Journal of Bacteriology, 76:471-484,  1958.
 5.   Peterson, M.L. and FJ. Stutzenberger. Microbiological evaluation of incinerator operations.
     Applffl Mirmhinlngv  lflnV.8-13. 1969.                            	          -•	
o.   American  Public Health Association, Inc.  Standard  methods for the  examination of dairy
     products microbiological and chemical New York, American Public Health Association, Inc.
     1960.
7.   Harris,  A.H., and M.B. Coleman. Diagnostic procedures and reagents..New York, American
     Public Health Association, Inc. 1963.
8.   Clark, H.F., and P.W. Kabler. Revaluation of the significance of the coliform bacteria. Journal
     of American Water Works Association, 56:931-936,1964.
9.   Smith, L.,  and MJL Madison. A brief evaluation of two methods for total and fecal coliforms
     in municipal solid  waste and related materials. Cincinnati,  U.  S. Environmental Protection
     Agency, National Environmental Research  Center.  Unpublished  data, 1972.
 10.  Frobisher,  M. Fundamentals of microbiology, 6th ed. Philadelphia, W. B. Saunden Co.,  1957.
     p. 151-152.
     Barbeito, M. S. and G.G. Gremillion. Microbiological safety evaluation of an industrial refuse
     incinerator. Applied Microbiology, 16:291-295, 1968.
 i z.  Dauer, Carl C. 1960 Summary of disease outbreaks and a 10-year resume. Public Health Report,
     76, no. 10, Oct. 1961. p 915.
 13.  Dubos, Rene. Bacterial and mycotic infections  of man. Philadelphia, J. B. Lippincott,  1958.
 14.  Weibel,  S.  R., F.R. Dixon, R.B. Weidner, and LJ. McCabe. Waterborne-disease  outbreaks
     1946-1960,  Journal of the  American Water Works Association, 56:947-958, Au*.  1964.
 15.  Spino,  D.F. Elevated-temperature techniques for the isolation  of Salmonella from.streams.
     Applied Microbiology,  14:591, 1966.
 16.  Scarce,  L.E. and M.L. Peterson. Pathogens in streams tributary to the Great Lakes. In:
     Proceedings; Ninth Conference  on Great Lakes  Research,  Chicago, March 28-30,  1966.
     Public  No.  15. Ann  Arbor, Univ.  of Mich.,  1966.  p. 147.
 17.  Peterson, M.L. The occurrence of Salmonella in streams draining Lake Erie Basin. In: Proceed-
     ings; Tenth Conference on Great Lakes Research, Toronto, Apr. 10-12,1967, Ann Arbor, Univ.
     of Mich., 1967. p. 79.
 18.  Peterson,  M.L.  and AJ.  Kie*. Studies on the detection of salmonellae in municipal solid
     waste and  incinerator residue. International Journal of Environmental Studies, a: 125-132,1971.
 19.  Spino, D. Bacteriological study of the New Orleans East Incinerator. Cincinnati, U.S. Environ-
     mental Protection Agency, National Environmental Research Center, 1971.
 20.  Edwards,  P.R. and WJi Ewing. Identification of Enterobacteriaceae. Minneapolis, Burgess
     Publishing Co., 1972.

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A-3.2  METHOD for VIROLOGICAL EXAMINATION of SOLID WASTE

     1.  Place 2 g of sample in flask containing 20 ml of
     cold, sterile distilled water and glass beads.

     2.  Vigorously shake flask.
     3.  Pour contents into sterile centrifuge tube.

     4.  Clarify suspension by centrifugation in a refrigerated
     centrifuge (4 C) at 1500 rpra for 20 minutes.
     5.  Pour off supernate and recentrifuge for 1 hr. at
     3000 rpm.

     6.  Remove clear supernate from sediment.
     7.  Add an antibiotic solution to give a final concentration
     per ml of 1000 units of penicillin and 1000 ug of
     streptomycin.
     8.  Hold sample at room temperature for 30 rain.

     9.  Inoculate sample into 3 tubes of primary monkey
     kidney cells (e.g. African Green).
    10.  Inoculate sample also into 3 tubes of  Hep 2 cells.
    11.  Incubate tubes in roller drum at 98.6 F  (37 C) for
    8 to 9 days.
    12.  Observe cell cultures daily for virus activity.

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A-3.3  DETERMINATION OF ASCARIS spp. EGGS in SOLID WASTE

1.  Materials
     1.1  Balance:  10 g *- 1 kg capacity.
     1.2  Beakers:  150 ml & 600 ml
     1.3  Bottle:  125 ml, Wheaton.
     1.4  Bottle shaker.
     1.5  Brush:  B-8695 Scientific Products.
     1.6  Centrifuge:  rotor radius 14.6 cm.
     1.7  Centrifuge tubes:  15 ml and 50 ml.
     1.8  Cheesecloth:  FSN 8305-00-205-3496.
     1.9  Counter:  differential
     1.10 Culture dish:  with 2 mm grid.
     1.11 Inverted microscope
     1.12 Pipettes:  Pasteur type and 5 ml serological.
     1.13 Rubber bulb:  ca. 2 ml
     1.14 Tray:  round, 10.5 inches diameter, 3 inches high
          e.g., Beckman Instrument Co.  82-018.
2.  Reagents
     2.1  Saline:  0.85% NaCl in HjO.
     2.2  Nacconol:  0.4% of concentrate in H20
     2.3  Hydrochloric acid:  2% solution in H20.
     2.4  Solvent:  alcohol:acetonerxylene in 1:1:2 ratios.
3.  Sample Preparation
     3.1  Vegetable Samples
          3.1.1  The sample size for vegetables is 1 kg.
     Leafy vegetables occuring in heads  (cabbage, lettuce

-------
 etc.)  are first  separated  into  individual leaves.
      3.1.2  Dispense 250 ml of  the nacconol solution
 into  the tray.
      3.1.3  Individual vegetables are placed  in  the
 tray,  and thoroughly scrubbed with the brush.
      3.1.4  Allow  the vegetable to drain for  10  seconds
 and then set aside.
      3.1.5  Steps  3.1.2 &  3.1.3 are repeated  until the
 entire sample is washed; nacconol solution is replaced
 as necessary.
      3.1.6  Pour the contents of the tray into a 600 ml
 beaker.
      3.1.7  Rinse  the tray 3 times with 25 ml of the
 nacconol solution  and add  each  rinse to the beaker.
      3.1.8  Distribute the suspension into 50 ml centrifuge
 tubes.
      3.1.9  Rinse  the beaker 3  times with 10  ml  nacconol
 solution, then add each rinse to the centrifuge  tubes or
 to an additional centrifuge tube.
 3.2   Sludge Samples
      3.2.1  Weight out 10  g of  sludge and add it to 90
 ml of  saline in  the 125 ml bottle.
      3.2.2  Place  the bottle on the shaker; shake
 vigorously for 5 minutes  (the speed control of an
 International Size-2 Shaker  ( International Equipment
 Company, Model 2)  is set at the midpoint).
      3.2.3  Pour the suspension through 1 layer  of wet
cheesecloth into a 150 ml beaker.

-------
      3.2.4  Rinse the bottle 3 times with 5 ml saline
 and add each rinse to the beaker.
      3.2.5  Transfer the contents of the beaker to
 seven 15 ml centrifuge tubes.
      3.2.6  Rinse the beaker 3 times with 5 ml of
 saline and add each rinse to the centrifuge tubes.
Centrifugation Procedure
 4.1  Centrifuge the tubes collected in 3.1 and/or 3.2
 at 2,000 rpm (radius 14.6 cm) for 4 minutes.
 4.2  Remove and discard the supernatant.
 4.3  Add 2 ml of saline to each tube.
 4.4  Combine the sediments into one tube using a Pasteur
 pipette to transfer the sediment and to rinse each tube
 3 times with 2 ml of saline.  Each rinse is also added
 to the collecting tube.
 4.5  When the collecting tube is full, it is balanced
 with a blank, centrifuged at 2,000 rpm for 4 minutes;
 supernatant is discarded. Repeat if necessary.
 4.6  Add saline to the 15 or 50 ml graduation mark on
 the collecting tube and resuspend the sediment; centrifuge
 at 2,000 rpm for 4 minutes.
 4.7  Discard the supernatant; add 2 ml of saline and
 resuspend the sediment.
 4.8  Transfer the suspension to the culture dish; rinse
 the tube 3 times with 2 ml of saline and add each rinse
 to the culture dish.  Add 8 ml of the 2% hydrochloric
 acid to the dish (to prevent mold growth)  and cover the
 dish.

-------
5.  A Warning
     Ascaris app. ova are infective to humans.  Areas which
     become contaminated should be wiped with the solvent
     solution*
6.  Viability Determination
     6.1  Culture dishes from step 4.8 are allowed to incubate
     at room temperature (ca 24 C) for 3 weeks.

     6.1  Check the fluid levels in the culture dishes twice
     weekly; a depth of 3 ma should be maintained by addition
     of H2).
7.  Microscopic Examination
     7.1  Systematically search the bottom of the dish with
     the aid of an inverted microscope, using the grid
     markings as guides.
     7.2  With American Optical 1810 equipment 24X objective
     and 10X eyepieces, the 2 no grid width is just spanned.
     7.3  Count the embryonated and the unembryonated eggs
     with the differential counter.
     7.4  Ascaris spp. eggs are usually 60 to 70 urn long and
     40 to 50 mm wide; the outer covering, a rough albuminous
     coat, is often yellowish brown in color; beneath the
     coat there is a thick layer of clear shell.  If the
     center of the egg is amorphous orslightly granular,
     the egg was not fertilized and will not develop.  An
     organized center indicates a fertilized egg.  With

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 incubation (step 6 above),  fertilized eggs develop into
 embryonated eggs which contain a second-stage nematode
 larva in a cuticular sheath.  Types of Asearis spp.
 eggs are illustrated in the following references.
References
 8.1  Faust, B.C. Beaver, P.C., Jung, R.C. 1968.  Animal
 Agents and Vectors of Human Disease.  Lea and Febiger,
 Philadelphia.
 3.2  Markell, E.K. and Voge, M. 1971.  Medical Parasitology,
 Saunders, W.B., Philadelphia.

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A-3.4  METHODS FOR IDENTIFYING PATHOGENIC FUNGI IN SOLID WASTE
      1. ""^Sample Preparation
           1.1  Add 5 g of composite sample to 100 ml of sterile
      physicological saline (0.85% salt solution).
           1.2  Shake to suspend sample.
           1.3  Separate supernatant and centrifuge at 2500 rpm for
      15 min.
           1.4  Decant supernatant
           1.5  Thoroughly mix sediment and add to sterile
      screw cap vials containing 10,000 units of penicillin
      and 10 mg of streptomycin.
           1.6  Allow suspension to stand at room temperature
      for 20 min.
      2.  Swiss Mice Inoculation
           2.1  Inoculate three white Swiss mice (4 to 6
      weeks of age)intraperitoneally with 0.5 ml of concentrated
      sediment.
           2.2  At the end of 3 weeks sacrifice mice.
           2.3  Remove liver and entire spleen and place in
      sterile petri dish.
           2.4  Mince tissues.
           2.5  Use small portions of minced tissues to
      inoculate two tubes of Sabouraud's agar and two tubes of
      Sabouraund's agar containing 0.5 mg of Actidione
      (cycloheximide) per ml and 0.05 mg of chloromycetin per
      liter.

-------
     2.6  Incubate cultures for 4 weeks, making weekly
examinations (make smears of suspicious colonies;
identify fungi by cultural characteristics.)
 3.  Actidione and chloromycetin inoculation
     3.1  Prepare two tubes of Sabouraud's agar and two
tubes of Sabouraud's agar containing 0.5 mg Actidione
per ml and 0.05 g of chloromycetin per liter.
     3.2  Inoculate with a small portion of concentrated
sediment.
     3.3 Incubate all tubes at 25 C and examine weekly.
     3.4  At the end of 6 weeks make smears of suspicious
colonies and identify by cultural characteristics.

-------