4
                       OEC  20
                                               RE:  WCBCJ0411
           NON-CONFIDENTIAL BUSINESS INFORMATION
                 LISTING BACKGROUND DOCUMENT
   1,1-DIMETHYLHYDRAZINE (UDMH) PRODUCTION FROM CARBOXYLIC
                     ACID HYDRAZIDES
K107  Column bottoms from product separation in the manufacture
      of UDMH (1,1-dimethylhydrazine) using carboxylic acid
      hydrazides (C,T)
K108  Condensed column overheads from product separation and
      condensed reactor vent gases in the manufacture of UDMH
      (1,1-dimethylhydrazine) using carboxylic acid hydrazides (T)
K109  Spent filter cartridges from product purification
      manufacture of UDMH ( 1 ,1-dimethylhydrazine) using
      acid hydrazides (T)
                                                        in the
                                                        carboxylic
KllO  Condensed column overheads from intermediate separtion in
      the manufacture of UDMH (1,1-dimethylhydrazine) using
      carboxylic acid hydrazides (I,T)
                                              MAR

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                                                                28073
                  TABLE OF CONTENTS
                                            :" 2 0 /OP/I
I.  SUMMARY OF BASIS FOR LISTING	3

II. SOURCES OF WASTE AND TYPICAL DISPOSAL PRACTICES 	4
     A.  Industry Profile 	4
     B.  Manufacturing Process 	4
     C.  Waste Generation and Management 	5
     D.  Waste Composition 	8
III. BASIS FOR LISTING 	10

     A.  Hazards Posed by the Listed Wastes
         and Wastes Contituents 	10
     B.  Potential for Mismangement 	10
     C.  Environmental Fate and Transport;   Migration,
         Mobility, and Persistence 	11
     D.  Health Effects 	13
     E.  Existing Regulations and  Guidelines 	15

 IV.  REFERENCES 	18
                                                   ENVIRONMENTAL
                                                  PROTECTION AGENCY
                                                     REGION 9
                                                  MAR 1 'A 1985
                                                    LIBRARY

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                               •3
I.  SUMMARY OF BASIS FOR LISTING
                                                 20 /
     The unique proprietary manufacturing process to produce

1,1-dimethylhydrazine (UDMH) by Uniroyal, Inc.  generates four

liquid wastes containing hazardous concentrations of UDMH and in

some cases methanol, ethanol, and sodium hydroxide.  These wastes

are all toxic, and in some cases ignitable or corrosive.  The

Administrator has determined that these wastes are solid wastes

that may pose a substantial present or potential hazard to human

health or the environment when improperly treated, stored, disposed

of, or otherwise managed, and therefore should be subject to

appropriate management requirements under Subtitle C of RCRA.

This conclusion is based on the following considerations:

     1.  These wastes contain significant concentrations
         of 1,1-dimethylhydrazine (unsymmetrical dimethyl-
         hydrazine, UDMH), which has been determined by the
         U.S. EPA1s Carcinogen Assessment Group (CAG)  to
         be a potential  human carcinogen.

     2.  The condensed column overheads from product separation
         and condensed reactor vent gases also contain significant
         concentrations  of alcohols, making this waste ignitable.
         The column bottoms from product separation contain
         significant concentrations of sodium hydroxide, making
         this waste corrosive.

     3.  A significant volume of these wastes (5000 metric tons
         or 11 million pounds) are generated annually, increasing
         the opportunity for hazardous exposures if mismanagement
         occurs.

     4.  UDMH is mobile  and persistent in ground water under
         conditions approximating waste disposal.   Therefore,
         ground water contamination is possible under
         conditions approximating waste disposal if deep well
         injection  techniques (the current disposal practice for
         the purification column light ends and bottoms)  are
         improperly conducted or if the wastes are mismanaged
         during storage  or disposal in unlined or inadequately
         lined land disposal facilities.

                                                                n

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                                                2


 II. SOURCES OF WASTE AND TYPICAL DISPOSAL PRACTICES


     A.  Industry Profile


     1,1-Dimethylhydrazine, commonly known as unsymmetrical


dimethylhydrazine (UDMH), is manufactured via a unique proprietary


process by Uniroyal, Inc.  This UDMH product is presently not


marketed commercially but is produced solely as an intermediate


for Uniroyal products.  Current production figures are unavailable.


     The Olin Corporation also manufactures UDMH by a different


chemical process than that employed by Uniroyal.  This process


will be evaluated separately because the process chemistry involved


is expected to yield wastes with different characteristics.


Olin's product is sold commercially, and finds use as a rocket


fuel, and to a smaller extent, as an absorbent for acid gases, in


the manufacture of various photographic chemicals, and as a stabilizer


for organic peroxide fuel additives.  Another use for Olin's product


is as an analytical reagent for aldehyde and ketone analysis.



     B.  Manufacturing Process



     A complete description of the Uniroyal manufacturing process


and process chemistry, provided by the manufacturer in response


to a questionnaire under Section 3007 of the Resource Conservation


and Recovery Act (RCRA), has been claimed to be confidential


business information by Uniroyal, and therefore is not presented


here.  Readily available information in the technical literature


(Kirk-Othmer), however, states that UDMH is probably made (by


Uniroyal)  by the reductive catalytic alkylation of a carboxylic


acid hydrazide with formaldehyde and hydrogen, followed by


basic hydrolysis of carboxylic acid dimethylhydrazide to

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remove the carboxyl group,  as shown in the following  equation.
               CH20/H20                  base
     RCONHNH2 	> RCONHN(CH3)2 	> (CH3)2NNH2
     Figure 1 shows this conversion with the associated waste and

process streams.  Triangles indicate streams in the gaseous state,

while circles indicate streams in the liquid state and squares

represent wastes in the solid state.  This figure has been

generalized so as to protect confidential process information.


     C.  Waste Generation and Management


     There are three liquid waste streams and one solid waste

stream generated by this process, described below and keyed to

Figure 1.

     The primary waste that is generated is the column

bottoms from the final purification step to produce commercial

UDMH (Liquid Stream 4, Waste No.  K107).  This waste is

currently managed by injection in a 3000 ft.  deep well on

the plant premise after holding  in a concrete-lined surface

impoundment.  Approximately 2,810 metric tons of this waste

are generated annually.  Sludges are accumulated  in the

concrete-lined  surface impoundment* from holding the product

purification bottoms along with other wastes from Uniroyal's

facility.
*  Uniroyal has  indicated they will  incinerate these  sludges
   pending completion of an on-site  incinerator.

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                                                  9Q
                                                       a*  i
     The second listed waste is the condensed overheads from a



combination of reactor vent gases (Gas Stream 1)  and product



separation vent gases (Gas Stream 2),  which are co-condensed to



generate a liquid waste (Liquid Stream 1+2, Waste No.  K108).



This waste is incinerated off-site or  injected in a deep



well off-site.  Approximately 91 metric tons of this waste



are generated anually.



     The third listed waste is spent filter cartridges from



product purification (Solid Stream 8,  Waste No.  K109).



This residual has not yet required removal and disposal.  At



the time when disposal is required, the company plans to use a



permitted hazardous waste diposal facility.  The quantity of



this waste is judged to be small, since only a small fraction



of the facility's UDMH is passed through filter cartridges.



     The fourth listed waste is condensed overheads from



intermediate separation columns (Liquid Stream 3, Waste No. K110)



which is codisposed with the product separation column



bottoms (Stream 4, Waste No.  K107) in the surface impoundment,



prior to deep well injection on-site.



     The uncondensed fractions of Gas  Streams 1, 2 and 3 are



flared at Gas Stream 5.

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FEEDSTOCK
^
w
                   REACTORS
FIGURE 1; PROCESS FLOW DIAGRAM,

UDMH BY THE UNIRQYAL PROCESS
SEPARATION
 COLIMNS
                                        PROFXCT
                                                         CONDENSATION
                                                            STEPS
                                                                                           FIARE
                                                                                                     r
                                                                                         INCINERATOR |
                                                                                        	I
    ©
Waste #107
                    RtJRFACE
                  IMPODNHMENT
              I
              |  OTHER PLANT
                                                                     I
                                                                                                                 I
                                                                                                       DERP WELL |
I   INTECTTON
                                                                                                                 I
                                        SPEOT FILTER
                                          CARTRIDGE
                                                          Waste
                             triangles = gaseous streams
                             circles = liquid  streams  .
                             squares = solid streams

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                               •8



     D.  Waste Composition                 L^S £.£ fi\ Em j



     Table 1 shows the approximate concentrations of the toxicant



of concern in the wastes generated by Uniroyal's proprietary UDMH



process, along with the volume generated.



     The bottoms from the product separation column (Waste



No. K107) contain approximately 0.01 per cent (100 ppm) of



UDMH, according to information supplied by Uniroyal.  This



waste is also corrosive, due to high sodium hydroxide content.



     The condensed overheads from product  separation and



condensed reactor vent gases (Waste No. K108) contain



1-10 per cent (10,000 to 100,000 -ppm) of UDMH,  according to



company supplied information.



     The spent filter cartridges from products purification



(Waste No. K109) are estimated by the Agency to contain'40-50



per cent (400,000 to 500,000 ppm) of UDMH.  This is based on



the concentrations of similar liquids entrained in filter



cartridges through which they are passes.



     The condensed intermediate separation column overheads



(Waste No. K110) have the possibilty of being contaminated with



traces of UDMH at some time, according to Uniroyal, and are therefore



handled as hazardous by Uniroyal because of this possibility.



This waste also contains sufficient concentrations of alcohols to



create an ignitable mixture.



     Bottom sediment sludges from the concrete-lined surface



impoundment are derived from two listed wastes, Waste No. K107



and K110, and,  therefore are also defined as a hazardous



waste by 40 CFR § 261.3(c)(2).  These sludges could contain



significant concentrations of UDMH, as well as toxic waste

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    Table 1.  SUMMARY OF UDMH CONCENTRATIONS IN WASTES & WASTE VOLUME DATA
              FROM THE PRODUCTION OF UDMH FROM CARBOXYLIC ACID HYDRAZIDES
              (Reference:  Industry Studies 3007 Data Base questionnaire)
Waste No.
K109


K110
Description
Concentrat ions*
  Total Estimated
  (metric tons)
K107
K108
Column bottoms from product
separation
Condensed column overheads
approx imately
0.01%
1-10%
2,810
91
from product separation and
condensed reactor vent gases.

Spent filter cartridges
from product purification

Condensed column overheads
from intermediate separation
40-50%
trace to 0.01%
not yet generated


  1,250
    Hazardous constituent for which the wastes are listed.  There is insufficient data to
    make an accurate determination of the presence of other compounds which should be
    considered hazardous constituents.  If such data becomes available in the future, at
    that point the may be listed as additional hazardous constituents.

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                               10



 constituents from other processes on the Uniroyal facility.





 Ill.  BASIS FOR LISTING





      A.  Hazards Posed by^ the  Listed Wastes and Wastes Contituents



      UDMH is capable of migrating from listed wastes, is mobile



 and persistant in the environment, and in situations similar



 to waste mismanagement it may  reach environmental receptors,



 posing a risk to human health  and the environment.  The following



 summarizes experimental information on the environmental fate



 and transport and health effects of UDMH.  More detailed



 information is available in the Health and Environmental



 Effects Profile (HEEP) for UDMH.



      UDMH is present in these  wastes in significant concentrations,



 typically in concentrations many orders or magnitude above the



 levels related to the adverse  health effects described in the following



 section.  For example, if the  condensed column overheads from



 product separation (the least  contaminated waste) were contaminated



 with  even one part per million UDMH, then the concentration would



 approach one million times the levels related to human health



 risks in drinking water.   The  concentration of UDMH in drinking



 water ingested over a lifetime resulting in a one per million



 increased risk of cancer is 4.03 x 10~6 milligrams per liter



 (parts per million),  or 4.03 x 10~10 percent.





B.  Potential for Mismangement






     The high mobility and migratory potential of the



wastes (UDMH and  the  solvent alcohols in these wastes are

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                                             _/




miscible with water) increases the likelihood of harmful



exposures under conditions typical of waste management scenarios.



Only a fraction of the toxicants present in these wastes need



migrate and reach environmental receptors to pose the potential



for substantial harm if these wastes are managed improperly.



     For example, storage or treatment of these wastes in an unlined



surface impoundment could lead to sterilization of the



microbial population and the formation of anaerobic conditions



beneath the surface impoundment.  This could prevent degradation



or oxidation of UDMH and allow sufficient quantities to migrate



and contaminate ground water.  Improper deep well injection could



similarly contaminate ground water.



     Other examples of potential waste mismanagement practices



leading to hazardous exposures could be inadequate incineration



or disposal or storage in impoundments or tanks with large open



surface areas such that significant volatilization of UDMH



occurs.





     C.  Environmental Fate and Transport;  Migration, Mobility,



         and Persistence.





     UDMH is soluble in water in all proportions (miscible) (U.S.



EPA, 1980-1984) and is present in wastes which are liquids.  The



UDMH in these wastes thus has a high mobility and migratory



potential.  In addition, under conditions typical of waste



mismanagement, UDMH is persistent enough to cause harmful exposures.



Only a fraction of the toxicant present in these wastes need



migrate and reach environmental receptors to pose the potential



for substantial harm.

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                              12
     UDMH's low octanol-water partition coefficient and complete



miscibility with water indicate that UDMH in any waste contacting



soil may migrate and contaminate ground water without being



adsorbed onto the soil matrix.  UDMH has been shown to leach and



migrate in experimental soil columns (Braun, 1983).



     The primary degradation mechanism of UDMH in the unsaturated



soil zone or aerated surface waters is expected to be oxidation,



presumably with dissolved oxygen and free radicals.  In the absence



of microbial degradation, the hal^-life of UDMH was reported to be



10 to 14 days in ponds and seawaters (Zirrolli, 1983).  In



anaerobic conditions, such as in ground water, however, UDMH has



the potential for persisting for much longer periods.  UDMH was



found to be extremely stable in distilled water (Braun, 1983).



     The potential for aerobic biodegradation of UDMH in water



has not been explored thoroughly, but may be minor relative to



oxidation under neutral to basic conditions.  UDMH oxidation was



found to proceed at the same rate in sterile or non-sterile lake



water as well as in pure distilled water (Banerjee; 1977,  1981).



Under anaerobic conditions, the loss of UDMH with anaerobic bacteria



was 26% after a six-day bioassay.  Biodegradation of UDMH may also



be limited by its toxicity; aerobic bacterial degradation was



inhibited when UDMH concentrations were as low as 20 parts per million



(Kane, 1983).



     UDMH could also be released to the atmosphere by evaporation from



spills, leaks and venting during loading, transfer, storage, or



treatment.  Evaporation of UDMH from water solutions are expected to



be significant (MacNaughton, 1975; Stauffer, 1977).  Once volatilized,

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                             13
 UDMH may degrade by reaction with hydroxyl radicals (Pitts, 1981),

 NC>2 or ozone  (Tuazon, 1982).

     1,1-Dimethylnitrosamine is a potential degradation product

 of UDMH in the environment, and has also been determined by

 the U.S. CAG  to be a potential .human carcinogen.* A major

 product of the reaction of UDMH with ozone (Tuazon, 1982); however,

 1,1-dimethylnitrosamine appears to degrade rapidly in the atmosphere

 by sunlight (Hanst, 1977; Callahan, 1979; Tuazon, 1982).  The forma-

 tion of 1,1-dimethylnitrosamine may also result from the oxidation

 of concentrated aqueous solutions of UDMH (Banerjee, 1981), such

 as would result from spills.  The.subsequent environmental

 degradation of 1,1-dimethylnitrosamine is expected to be signifi-

 cantly longer than that of UDMH in water and soil (Tate, 1975;

 Callahan,  1979; Oliver, 1979; Mallik, 1981).


     D.  Health Effects


     The primary concern of the Agency for the hazardous nature

of these wastes is their contamination by significant concentrations

of 1,1-dimethylhydrazine (UDMH), which is currently listed in

Appendix VIII of Part 261.   The U.S. EPA's Carcinogen Assessment

Group (CAG)  has determined  that UDMH is a potential human carcinogen.

In addition,  N-nitrosodimethylamine (dimethylnitrosamine)  is a

potential  degradation product of volatilized UDMH,* and also has

been determined by CAG as a potential human carcinogen.

The major  contaminant of concern in these wastes, UDMH,
     The Agency is not listing 1,1-dimethylnitrosamine as a toxicant
     of concern because of uncertainty of the potential degradation
     pathways of UDMH in the environment.  However,  the Agency solicits
     comments as to whether or not 1,1-dimethylnitrosamine should be
     included as a toxicant of concern.

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                         1 4
 is currently  listed  in Appendix VIII of Part 261.



     When UDMH  was administered orally, it produced angiosarcomas,



 pulmonary adenomas or adenocarcinomas, malignant lymphomas, and



 kidney adenomas  in male and female Swiss mice (Toth, 1972, 1973);



 tumors in the cecum  and blood i'n Syrian golden hamsters (Toth,



 1977); lung tumors in female Swiss mice (Roe e_t al . , 1967); and



 liver tumors  in  rats (Druckrey e_t _al.f 1967).



     UDMH is  also teratogenic and mutagenic.  Teratogenic effects



 were observed in South African clawed toad larvae, xenopus laevis,



 following continuous embronic exposure to UDMH concentrations of



 2-20 ug/1 (Greenhouse, 1976).  UDMH was teratogenic during the



 neurulation period of embryogenesis, and the malformations affected



 the head, trunk  and  tail; the most frequent malformation was tail



 kinks .



     The overall weight of evidence from a variety of microbial



 and mammalian assays indicates that UDMH is also mutugenic.  In



 numerous Ames Salmonella assays, results were generally inconsistent,



 although most positive reponses were observed with strain TA98, a



 frameshift mutant (Bruce, 1979;  Parodi et_ a±. ,  1981;  de Flora,



 1981).   In mutagenesis assays with cultured mouse lymphoma cells,



UDMH caused forward mutation to thymidine (Brusick,  1976; Rogers,



1981),  but not to ouabain, thioguanine or cytosine arabinoside



resistance (Rogers, 1981).  Unscheduled DNA synthesis occurred in



human embryonic lung cells that were treated with UDMH ^n vitro



 (Brusick, 1976), and ir\ vivo exposure to UDMH inhibited testicular



DNA synthesis in mice (Seiler,  1977).  Ijn vivo  treatment of mice



also caused DNA fragmentation in liver and lung  cells (Parodi,



1981),  but did not induce micronuclei in bone marrow cells (Bruce,

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                       15
1979) or sperm abnormalities (Bruce, 1979;  Wyrobek,  1975).



     UDMH is rapidly absorbed from the lungs,  gastrointestinal



tract, injection sites, and skin.  Rats exposed to UDMH had grand



mal seizures, brain glycogen degradation, and  inhibition of



glutamic acid decarboxylase (U.S.EPA, 1984).



     The Agency has made a preliminary estimate that persons



face a 1 per million increased risk of cancer  as a result of



a lifetime daily dose of 1.15 x 10~7 milligrams UDMH per



kilogram body weight, or 8.05 x 10~6 milligrams for a 70



kilogram man.  The basis for this- estimate is  explained



further in the HEEP.   The corresponding concentration in drinking



water ingested over a lifetime resulting in a  one per million



increased risk of cancer is 4.03 x 10~6 milligrams per liter



(parts per million), or 4.03 x 10~10 percent.



     The potential of this contaminant to cause harm to human



health and the environment is described  in more detail in



the Health and Environmental Effects Profile for UDMH (available



at the RCRA Public Docket at EPA Headquarters and at EPA



Regional Libraries).





     E.  Existing Regulations and Guidelines



     The Resource Conservation and Recovery Act currently controls



the handling (treatmentt, storage, disposal) of the commercial



chemical product, 1,1-dimethylhydrazine  (UDMH) under



40 CFR §261.33(f); and it is also listed as a hazardous constituent



under Appendix VIII of 40 CFR Part 261.



     The Comprehensive Environmental Response, Compensation,



and Liability Act of 1980 (CERCLA or "Superfund"), requires

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                              16
that persons in charge of vessels or facilities from which



hazardous substances have been released in quantities that



are equal to or greater than the reportable quantities (RQs)



immediately notify the National Response Center of the release.



(See CERCLA Section 103 and 48 FR 23552, May 25, 1983.)   Since



the statutory RQ for UDMH is one pound, the four waste streams



(K107, K108, K109 and K110) will also have RQs of one pound.



(Criteria are currently being developed for potential carcinogens



such as UDMH to adjust the one pound RQ to a level adequately



protective of human health and the environment.)



     The Agency's  Office of Pesticide Programs (OPP) is also



conducting a Special Review (RPAR) process to fully evaluate



any dietary risk to human health posed by pesticides containing



UDMH or having the possibility of conversion to UDMH.  The process



was initiated by the finding that UDMH was found to be oncogenic



in laboratory animals and that UDMH has been found in raw agricultural



commodities (i.e., apples and peaches) and processed foods (i.e.,



apple sauce and apple juice).  In Position Document 1 49 CFR 29136,



July 18, 1984, the Agency solicited comments on the risks and



benefits associated with all uses of these pesticides, and announced



that potential adverse effects associated with the use of these



pesticides have been identified and will be examined further  to



determine their extent and whether, in light of the benefits of



the pesticides, such risks are unreasonable.  (See 49 CFR 29136,



July 18, 1984.)

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                              17
                                                    T
     In addition, The Occupational Safety and Health



Administration (OSHA) has set a Permissible Exposure Limit (PEL)



time-weighted average concentration for UDMH at 1  milligram per



cubic meter of air (0.5 parts per million).  The National Institute



for Occupational Safety and Health (NIOSH)  has recommended that



this limit be lowered to 0.15 milligrams per cubic meter.



West Germany recommends an occupational exposure limit of 0.1



parts per million.



     The Department of Transportation (DOT) regulates UDMH as a



hazardous flammable materiaj..

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                              18


                           REFERENCES
Banerjee, S.,  H.C.  Sikka and R. Gray.   1977.   Environmental
  degradation  of 1,1-dimethylhydrazine.   Proc.  Conf.  Environ.
  Chem. Hydrazine Fuels, Tyndall AFB,  FL.  NTIS AD-AG54194.

Banerjee, S.,  E.J.  Pack, H. Sikka and  C.M.  Kelly.   1981.   Kinetics
  of oxidation of methylhydrazines in  water.   Factors controlling
  the formation of  1,1-dimethylnitrosamine  from the corresponding
  hydrazine.  unpublished study.  Syracuse  Research Corporation,
  Syracuse, NY.

Braun, B.A. and J.A. Zirrolli.  1983.   Environmental  fate of
  hydrazine fuels in aqueous and -soil  environments.  Eng. Serv.
  Lab., Air Force Eng. Serv. Center, Tyndall  AFB,  FL. Rep. No.
  ESL-TR-82-45.  NTIS AD-A125813.  23  p.

Bruce, W.R. and J.A. Meddle.  1979. The  mutagenic activity of  61
  agents as determined by the micronucleus, Salmonella and sperm
  abnormality  assays.  Can. J. Genet.  Cytol.   21:319-334.

Brusick, D. and D.W. Matheson.  1976.   Mutagen and oncogen study on
  1,1-dimethylhydrazine.  Prepared for the  Aerosp. Med.  Res.  Lab.,
  Aerosp. Med. Div., Air Force Systems Command, Wright-Patterson AFB,
  Dayton, OH.   Litton Bionetics, Inc., Kensington, MD.  NTIS  AD-A035475

Callahan, M.A., M.W. Slimak, N.W. Gabel,  et a^.  1979.  Water
  related environmental fate of 129 priority pollutants.   Vol.  II.
  Dimethyl nitrosamine.  EPA-440/4-79-0296.

de  Flora, S. 1981.   A "spiral test" applied to bacterial  mutagenesis
  assays.  Mutat. Res. 82:213-227.

Druckrey, H.,  R. Preussmann, S. Ivankovic and D. Schmahl.  1967.
  Organotrope carcinogene Wirkunen bei 65 verschiedenen N-Nitroso-
  Verbindungen and BD ratten.  ^. Krebsforsch.  69:103.   (Ger.)
  (Cited in IARC, 1974.)

Greenhouse, G.  1976.  The evaluation  of  the toxic effects of
  chemicals in freshwater by using frog embryos and larvae.  Environ.
  Pollut.  11(4):303-315.

Hanst, P.L., J.W. Spence and M. Miller.  1977.  Atmospheric chemistry
of  N-nitroso dimethyl amine.  Environ.  Sci.  Technol.  11:403-405.

Kane. D.A. and K.J. Williamson.  1983.  Bacterial toxicity and
  metabolism of hydrazine  fuels.  Arch.  Environ. Contain. Toxicol.
  12:447-453.

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                              19           "  "


MacNaughton, M.G., J. Zirrolli,  T.B.  Stauffer and D.A.  Stone.
  1979.  Environmental chemistry of hydrazine fuels.   Proc.
  9th Conf. Environ. Toxicol.,  March.   Aerosp.  Med.  Res.  Lab.,
  Aerosp. Med. Div., Air Force  Systems Command, Wright-Patterson
  AFB, Dayton, OH.  AMRL-TR79-68.   p.  121-128.

Mallik, M.A.B. and K. Tesfai.   1981.   Transformation  of nitro-
  samines in soil and in vitro  by soil microorganisms.   Bull.
  Environ. Contain. Toxicol.   27:115-121.

Oliver, J.E., P.C. Kearney and  A.  Kontson.   1979.  Degradation
  of herbicide related nitrosamines in aerobic soils.  J_. Agr ic.
  Food Chem.  27:887-891.

Parodi, S., S. De Flora, M.  Cavanna,  et^ a±.  1981.  DNA-damaging
  activity in vivo and bacterial mutagenicity of sixteen hydrazine
  derivatives as related quantitatively to their carcinogenicity.
  Cancer Res.  41:1469-1482.

Pitts, J.H., Jr., E.G. Tuazon,  W.P.L.  Carter, £t al,.   1981.   Atmos-
  pheric chemistry of hydrazines:  Gas phase kinetics and mechanitic
  studies.  Prepared by the  Statewide Air Pollut. Res.  Center,  Univ.
  Calif., Riverside, CA, for the Air  Force Eng. Serv. Center,
  Tyndall, AFB, FL.  NTIS AD-A093486.

Roe, F.J.C., A.G. Grant and  D.M. Millican.   1967.  Carcinogenicity of
  hydrazine and 1,1-dimethylhydrazine for mouse lung.  Nature
  216(5113):375-376.

Rogers, A.M. and K.C. Back.   1981.  Comparative mutayenicity  of
  hydrazine and 3 methylated derivatives in L5178Y mouse lymphoma
  cells.  Mutat. Res.  89(4) :321-328.

Seiler, J.P.  1977.  Inhibition of testicular DNA synthesis  by  chemical
  mutagen and carcinogens.  Preliminary results in the validation of
  a novel short-term test.  Mutat. Res.  46:305-310.

Stauffer, T.B.  1977.  Hydrazine Evaporation.  Proc.  Conf. Environ.
  Chem.  Hydrazines Fuels, Tyndall AFB. NTIS AD-A054194.   p.  25-38.

Tate, R.L. and M. Alexander.  1975.  Stability of nitrosamines  in
  samples of lake water, soil  and sewage.  J. Natl.  Cancer Inst.
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Toth, B.  1972.  Comparative studies with hydrazine derivatives.
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