U.S. DEPARTMENT OF COMMERCE
                     National Technical Information Service

                     PB-253 051
Survey  of Methods  Used  to
Control Wastes Containing
Hexachlorobenzene
TRW Systems Group
Prepared For
Environmental Protection Agency
1976

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 BIBLIOGRAPHIC DATA
 SHEET
                     I. Report No.
                        EPA/530/SW-120C
PB   253   051
4. Tide and Subtitle

  •SURVEY OF  METHODS USED TO  CONTROL WASTES  CONTAINING
    HEXACHLOROBENZENE
                                                                     5. Report Date
                                                                        November 1975
                                                                     6.
7. Author(s)
   S.  Quinlivan,  M.  Ghassemi.  H.  Santy
                                                                     &• Performing Organization Kepi.
                                                                       No.
9. Performing Organization Name and Address

  TRW  Systems, Inc.
  One  Space Park
  Redondo  Beach, CA   90278
                                                                      10-  Task no.
                                                                        68-01-3203
                                                                      II. Contract/Grant No.

                                                                        68-01-2956
 12. Sponsoring Organisation Name and Address
   Office of Solid Waste Management Programs
   U.S. Environmental Protection Agency
   Washington,  D.C.   20460
                                                                     13. Type of Report & Period
                                                                        Covered
                                                                     14.
 15. Supplementary Notes
 16. Abstracts
                 stuc|y presents  the results of a  survey of methods used to  control wastes
   containing hexachlorobenzene (HCB).  The  specific objectives were to  identify the
   sources and  characteristics  of manufacturing  wastes containing HCB, to  document
   methods used for treatment and disposal of HCB wastes, and  to evaluate  the environ-
   mental adequacy of the treatment and disposal  methods.
 17. Key Words and Document Analysis.  17a. Descriptors
  Hexachlorobenzene (HCB), disposal,  environmental  control,  hazardous wastes,
  industry survey.
 17b. Idemiflers/Opin-Lndcd Terms
  Chemical  waste survey,  chemical waste control  and  disposal.
17c. COSATI Fie Id/Group
18. Availability Statement
                                                         19. Security Class (This
                                                            Report)
                                                              UNCLASSIFIED
                                                         20. Security Class (This
            21. No. of PJRCS
           I    f"+
                                                             Pai
                                                              '8=
                                                               Ul
                                                               'NCLASSIFIED
FORM NTIS-35 (REV. 3-721
                                                                               USCOMM-DC 14gs2-P72

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                                SURVEY  OF  METHODS USED

                 TO CONTROL  WASTES  CONTAINING  HEXACHLOROBENZENE
            This final report (Sti-12Qo) describes work performed
for the Federal solid waste management programs under contract No.   68-01-2956
              and is reproduced as received from the contractor
                           U.S.  ENVIRONMENTAL  PROTECTION AGENCY
                                           1976

                                            i-fl

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     This report has been reviewed by the U.S. Environmental Protection
Agency and approved for publication.  Approval does not signify that
the contents necessarily reflect the views and policies of the U.S.
Environmental Protection Agency, nor does mention of commercial products
constitute endorsement by the U.S. Government.

An environmental protection publication (SW-120c) in the solid waste
management series.

                                ii

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               PREFACE AND ACKNOWLEDGEMENTS
     This report presents the results of a survey of methods used to
control wastes containing hexachlorobenzene {HCB).  The survey was
conducted by TRW Systems under Contract BOA 68-01-2956, Task Order
68-01-3203, for the EPA Office of Solid Waste Management Programs,
(OSWMP).  The project is deeply indebted to the EPA Project Officer,
Mr. Thomas Leshendok, Hazardous Waste Management Division, OSWMP,
for his continuing advice and guidance during the course of the study.
Thanks are also due to  other staff members of the Office of Solid Waste
Management Programs for their critical review of the draft final report.

     TRW wishes to express its sincere gratitude to the technical and
management personnel at industrial facilities and company headquarters
who participated in the survey and arranged for site visits and/or
provided information for use in the study.  The assistance received from
various State agencies (in particular, Louisiana State Health Department,
Section of Solid Waste and Vector Control, and Air Control Section) and
non-industrial organizations are acknowledged.  Special thanks are due to
Dr, W. Farmer of the University of California at Riverside for discussing
recent research findings on control of HCB volatilization at land disposal
sites.
                                iii

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                            TABLE OF CONTENTS
                                                                     Page
PREFACE AND ACKNOWLEDGEMENTS 	  111
LIST OF TABLES	   vi
LIST OF FIGURES	vlii
1.   SUMMARY	   1
2.   CONCLUSIONS 	   7
3.   INTRODUCTION  	   9
4.   METHODOLOGY	11
5.   RESULTS AND DISCUSSION	13
     5.1   HCB WASTE GENERATION SURVEY	13
     5.2   INDUSTRIAL OPERATIONS PRODUCING HCB WASTES  	  16
           5.2.1   Basic Production of HCB 	  16
           5.2.2   Chlorinated Solvents Production . 	  17
           5.2.3   Pesticide Industry  	  17
           5.2.4   Electrolytic Chlorine Production  	  20
           5.2.5   Ordnance and Pyrotechnics Production  	  22
           5.2.6   Sodium Chlorate Production  	  25
           5.2.7   Aluminum Manufacture  	  25
           5.2.8   Seed Treatment Industry	28
           5.2.9   Pentachlorophenol (PCP) Production  	  29
           5.2.10  Wood Preservative Industry  	  29
           5.2.11  Electrode Manufacture 	  31
           5.2.12  Cyanogen Chloride Production  	  33
           5.2.13  Vinyl Chloride Monomer (VCM) Production 	  33
           5.2.14  Synthetic Rubber Production 	  35
     5.3   CHARACTERISTICS OF HCB-CONTAINING WASTES  	  35
     5.4   ESTIMATED HCB WASTE QUANTITIES  	  37
           5.4.1   Total Waste Quantities and Comparison of
                   Estimates with Those Made in an Earlier
                   Study	37
           5.4.2   Chlorinated Solvents  	  40
                                    iv

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                       TABLE OF CONTENTS (CONT'D)
                                                                     Page
           5.4.3   Pesticide Industry 	    42
           5.4.4   Electrolytic Chlorine Production 	    44
     5.5   WASTE HANDLING, TREATMENT AND DISPOSAL 	    47
           5.5.1   Waste Handling (Storage and Transportation)  . .    47
           5.5.2   Waste Treatment	    55
           5.5.3   Ultimate Disposal  	    56
                   5.5.3.1   Land Disposal  	    58
                   5.5.3.2   Deep-Well Injection  . '.	    62
                   5.5.3.3   Drying Pond  	    63
                   5.5.3.4   Incineration 	    63
                   5.5.3.5   Miscellaneous Disposal Methods ....    67
           5.5.4   Resource Recovery  	    68
     5.6   ULTIMATE DISPOSAL TECHNOLOGY CLASSIFICATION AND
           EVALUATION	    68
     5.7   WASTE HANDLING AND DISPOSAL COSTS  	    71
6.   REFERENCES	    76
7.   APPENDIX	    80

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                              LIST OF TABLES

                                                                     Page

Table No.

   1          HCB Waste Generation Survey, Number of Firms
              Contacted and Responses Received 	   15

   2          Companies, Domestic Sites and Production Rates
              or Capacities for Carbon Tetrachloride,
              Perch!oroethylene, Trichloroethylene and
              Dlchloroethylene 	   18

   3          Producers, Formulators and the Number of
              Distributors for Mi rex, Dacthal, Simazine,
              Atrazlne, Propazine and PCNB 	   21

   4          Electrolytic Chlorine Producers Using Graphite
              Anodes and Production Sites  ...  	 ....   23

   5          Electrolytic Chlorine Producers Using DSA's or
              Other Non-Graphite Electrodes, and Production
              Sites	24

   6          Sodium Chlorate Producers, Production Sites and
              Type of Anode Used	26

   7          Aluminum Manufacturers (Smelters) and Company
              Headquarters 	   27

   8          Pentachlorophenol (PCP) Producers and Production
              Sites	30

   9          Electrode Manufacturers and Company Headquarters ...   32

  10          Vinyl Chloride Monomer Producers and Production
              Sites	34

  11          General Characteristics of HCB-Containing Waste
              Streams for Chlorinated Solvent and Pesticide
              Manufacturing Industries, Based on Data for
              Specific Production Sites  	  . 	   36

  12          HCB Waste Quantities	39

  13          Production Sites and HCB Waste Quantities for
              Chlorinated Solvents Production  	   41

  14          Chlorinated Solvents Producers Reporting no HCB
              Waste Generation or Having No Analytical Data  ....   43
                                    vi

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                         LIST OF TABLES (CQNT'D)

                                                                      Page

Table No.

   15         Quantities of HCB Hastes from Pesticide
              Manufacture	45

   16         Electrolytic Chlorine Producers Using Graphite
              Anodes Which Were Contacted in This Survey  	  46

   17         Methods of HCB Waste Treatment, Handling and
              Transport Based on Data for Specific Production
              Sites	4*a

   18         Prevalence of Methods Used for Ultimate Disposal
              of HCB Wastes	,	57

   19         Methods and Sites for Land Disposal of HCB Wastes ...  59

   20         Sites for the Incineration of HCB  Wastes  	  64

   21         Resource Recovery Methods for Processing HCB-
              Containing Wastes	'	69

   22         Disposal Technology Classification  	  72

   23         Costs for Off-Site Disposal  of HCB Wastes 	  74

   24         Costs for On-Site Disposal  of HCB  Wastes  	  75

   25         Costs for HOC Tars Concentration and Storage
              System at Plant Site D	75

  A-l         Key to Plant Sites, Their Locations and Sources
              of Wastes	80

  A-2         Key of Off-Site  Waste  Disposal  Contractors Handling
              HCB Wastes, Their Locations  and Plant  Sites  Serviced   .  82

  A-3         General  and Hazardous  Characteristics  of HCB  	  83

  A-4         HCB Waste Data  Requested  From Some Industries/
              Plants	84

  A-5         Non-Industrial  Agencies Contacted  for  Data
              Acquisition .	87
                                   vii

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                          LIST OF FIGURES
Figure No.
    1         Photographs of Drummed HCB Wastes at a
              Sanitary Landfill  	  52

    2         Tar Concentration  and Storage Facility
              At Plant Site D 	  53
                                  viii

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                              1.  SUMMARY

     Under a contract with the EPA Office of Solid Uaste Management Pro-
grams, Hazardous Waste Management Division, TRW conducted a survey of
methods used to control wastes containing hexachlorobenzene (HCB).  The
specific objectives of the study were to identify the sources and charac-
teristics of manufacturing wastes containing HCB, to review and document
methods used for treatment and disposal of HCB wastes, and to evaluate the
environmental adequacy of the treatment and disposal methods.

     The data collected and used in this study were obtained from the
following sources: (a) published literature; (b) telephone contacts and
formal correspondence with industrial firms; (c) visits to production sites
and waste disposal facilities; and (d) discussions and interviews with
technical staffs in academic institutions, research establishments, trade
organizations, and State and Federal agencies.   The initial phase of the
program concentrated on the identification of all possible sources for the
generation of HCB wastes.  Based on a literature search and some contact
with industry, the following fourteen industries/operations were initially
identified as possible sources of HCB wastes.

     Industry/Operation                   Potential Origin of HCB Wastes

Basic HCB production                HCB production operation
Chlorinated solvents production     Reaction side-product in the production
                                      of chlorinated solvents, mainly,
                                      carbon tetrachloride, perchloro-
                                      ethylene, trichloroethylene, and
                                      dichloroethylene
Pesticide industry                  Reaction side-product in the production
                                      of Dacthal, simazine, mirex, atrazine,
                                      propazine, and pentachloronitrobenzene
                                      (PCNB)
Electrolytic chlorine production    Chlorine attack on the graphite anode
                                      or its hydrocarbon coating

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      Industry/Operation
     Potential Origin of HCB Waste
 Ordnance and  pyrotechnics
   production
 Sodium chlorate  production
 Aluminum manufacture
 Seed  treatment  industry
 Pentachlorophenol production
Use of HCB in the manufacture of pyro-
  technics, and tracer bullets and
  other ordnance items

Similar to electrolytic chlorine pro-
  duction, where graphite anodes are
  used

Use of HCB as a fluxing agent in
  aluminum smelting

Use of HCB in seed protectant formu-
  lations

Reaction by-product of PCP production
  by chlorination of phenol
Wood  preservative industry

Electrode manufacture


Cyanogen chloride production

Vinyl chloride monomer
  production

Synthetic rubber production
Use of HCB as a wood preserving agent

Use of HCB as a porosity control in
  the manufacture of graphite anodes

Cyanogen chloride production process

By-product in the manufacture of vinyl
  chloride monomer

Use of HCB as a peptizing agent in
  the production of nitroso and
  styrene rubbers for tires
     Subsequent to the identification of the above listed industries,  a

number of firms in each industry were contacted and inquiries made regard-

ing HCB waste generation and quantities.  Of the total  of 232 firms reported

for the above listed industries, 80 firms (34 percent)  were contacted  in

this survey.  Of these 80 firms, 21 (26 percent) indicated that  their  waste

streams contained HCB, 40 (50 percent)  indicated that  their waste  streams did

not contain HCB, and 19 (24 percent) either indicated  that they  did not know or

that they preferred not to discuss the  matter.  The percentage distribution

of the three types of response varied for the various  industries.   Based

on the survey results, chlorinated solvents and pesticide industries were

identified as the major sources of HCB  wastes and were subsequently subjected

to in-depth evaluation from the standpoint of waste generation and treatment

and disposal methods.

                                     2

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     Based on the data collected In this survey, of the estimated 3,900
metric tons of HCB waste* which is generated annually in this country,
2,400 metric tons (2,650 tons) is produced as a by-product waste in the
production of chlorinated solvents.  Of the 16 companies manufacturing
chlorinated solvents, 5 representing 7 production sites and accounting  for
an estimated 37.3 percent of the total U.S. chlorinated solvents production
capacity, indicated that HCB was a constituent of their waste streams and
provided data (in some cases very limited) on waste quantities and treat-
ment and disposal methods.  These production sites are designated in this
report as Plant Sites A, B, C, D, E, F and J.f   HCB waste quantities
generated at three production sites (Plant Sites G, H, and I) were esti-
mated based on data provided by an off-site disposal contractor which had
previously handled HCB waste from Plant Site G and the data collected for
similar production operations at other plant sites.  Plant Sites G, H and
I account for an estimated 21.2 percent of the total U.S. chlorinated solvents
production capacity.

     Five additional chlorinated solvents production plants representing
an estimated 41.5 percent of the total U.S. chlorinated solvents production
capacity responded in one of the following ways: (a) they use the CS2 pro-
cess which does not generate HCB waste; (b) they have not detected HCB  in
their waste streams; and (c) they have not analyzed their waste stream  for
HCB content.  For the plants surveyed, HCB-containing waste streams are
usually in the form of heavy ends waste liquids from various distillation
or purification processes within the manufacturing operation. Two plants
    Except when noted as "HCB-Containing Waste", throughout this report
    all  quantitative data on HCB wastes refer to the HCB content of the
    wastes  (i.e.,  the amount of HCB contained in the waste stream).
    Many of the companies participating in the present study submitted
    data to TRW on a proprietary basis.  To protect the proprietary
    interests, where appropriate the participating companies (plant
    sites and waste disposal contractors) are referred to in this
    report by designated letters of alphabet (e.g., Plant Site A or off-
    site waste disposal contractor OC-1, etc.).  Tables A-l and A-2 in
    the Appendix identify the states in which the production sites and
    off-site contractors are located.

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recover HCB from chlorinated solvents wastes.  Each year approximately
240 metric tons (265 tons) of HCB is recovered for sale.   This  quan-
tity, however, accounts for only 10 percent of the total  HCB generated
by the chlorinated solvents industry; the other 90 percent is dis-
charged in the waste streams which are disposed of on  land or are
incinerated.

      In the pesticide  industry, the production of Dacthal, PCMB, nn'rex
simazine,  atrazine, and propazine result in the generation of HCB wastes.
At the present, Dacthal, PCNB, and mirex each is produced at only one pro-
duction site  and by a  different company.  Simazine, atrazine and propazine
are  produced  at one site by one company.  Pesticide production sites are
designated as Plant Sites Q, R, S and T.  The estimated total quantity of
HCB  waste  generated in the pesticide industry is 1,499 metric tons (1,655
tons) per year with wastes from Plant Sites R and Q accounting for 84.5
percent and 15.1 percent of the total, respectively,  The HCB is present
mainly in  tars and still bottoms from manufacturing operation.

      For a total of 2,870 metric tons (3,168 tons) per year of HCB waste
for  which  data were obtained from industry on waste handling methods, the
currently used waste storage methods and the percentage of waste handled
by each method are: storage of solid cubes under plastic cover, 44.2 per-
cent; water-covered open storage lagoons, 33.1 percent; drums which may
or may not be lined, 14.3 percent; insulated and heated storage tanks,
8.2  percent;  and nitrogen-blanketed steel tank, <0.1%.  Methods used for
waste transportation and the percentage of waste handled by each method
are: truck, 38.4 percent; forklift, 35.7 percent; pipeline, 19.1 percent;
heated tank trucks, 6.6 percent; and rail, 0.1 percent.  Loading,  storage
and  transportation of waste can result in environmental contamination if
the  operation is not managed properly or in cases of accidents  and spills.

     At some HCB waste generation and disposal sites some form  of  treatment
is utilized prior to ultimate waste disposal.   These treatment  methods
include use of storage lagoons to effect settling of HCB solids, distillation
to effect waste volume reduction and material  recovery, heating to effect

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fluidization during storage and bulk transportation by pipeline and trucks,
solidification and shaping into cubes for storage, dewatering for waste
concentration, and dilution and suspension by mixing with other wastes
prior to deep well injection.

     Methods currently used for the ultimate disposal of HCB wastes include
land disposal (sanitary landfill* industrial landfill, deep well injection
and drying ponds), incineration (with or without by-product recovery), open
pit burning, resource recovery, discharge to municipal sewage treatment
plants, and emission to the atmosphere.  Both on-site disposal  and off-site
contract disposal are used.  Based on a total waste quantity of 2,444 metric
tons (2,64? tons) for which data were obtained on waste disposal methods,
land disposal is  currently the most prevalent method for ultimate disposal of
HCB wastes.  Nine of the 22 sites surveyed use land disposal; approximately
1,389 metric tons (1,483 tons) of HCB wastes (56 percent of the total) are
disposed of by this method each year.  Among land disposal  methods,
industrial landfill is the most widely used method, accounting for the dis-
posal of 39.7 percent of all HCB wastes.  Ranked next to land disposal is
incineration which is used at nine of the sites surveyed for the destruction
of 1,055 metric tons (1,164 tons) per year of HCB wastes.  One incineration
site handling 680 metric tons (750 tons) of HCB waste per year, recovers
hydrochloric acid as a by-product.  No data were available  on the quantity of
HCB wastes which  is used at one site as a chemical feedstock for the pro-
duction of low-molecular weight aliphatic halogenated hydrocarbons.  Compared
to land disposal and incineration, the quantities of waste  discharged to
sewage treatment plants and to the atmosphere appear to be  very small.
Of the 22 sites surveyed, 6 use the services of commercial  off-site dis-
posal  contractors for the disposal of a total  of 655 metric tons (723 tons)
per year of HCB wastes.

      Methods for the ultimate disposal  of HCB wastes were  evaluated in terms
of three levels  of technology representing the prevalent practice  (Level  I),
the best technology available in current commercial  practice (Level  II),
and technology currently known and assessed as  providing adequate  health
and environmental  protection  (Level  III).   Based  on  the  quantity of HCB

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wastes handled, Industrial landfill on a suitable geological formation and
with a cover consisting of 1.2 to 1.8 m (4 to 6 feet) of soil and a 0.025
cm (10-mil) thick polyethylene film placed at approximately mid-depth of
the soil cover would be the Level I technology.  However, based on the
number of sites which use a disposal method, incineration without by-
product recovery but with emission control would be the Level I technology.
Incineration with emission control and by-product recovery is considered
as Level II and Level III technology.  Data for operating sites indicate
that HCB can be effectively destroyed by incineration with little emission
of pollutants to the atmosphere.  An incineration system of proprietary
design at Plant Site G is reported to effect 99.94 percent destruction of
HCB and allows for recovery of HC1 as a by-product.

     Not all industries and waste disposal facilities which were contacted
furnished information on the costs for handling and disposal of HCB wastes.
Some of the companies and waste disposal facilities indicated that they
cannot break down their total cost to arrive at any meaningful  estimate of
the portion of the cost which can be attributed to the handling of HCB
wastes, which accounts for a small fraction of the total waste handled.  The
cost charged to waste generators by four off-site waste disposal contractors
employing landfill,  incineration and deep-well injection range from $22 to
$35 per metric ton ($20 to $32 per ton) of HCB-containing wastes.   At one
plant  site, the cost for the operation of a pretreatment lagoon,  removal
and transport of waste from the lagoon to an industrial  landfill,  and equip-
ment maintenance is estimated at $11 per metric ton ($10 per ton).

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                        2.  CONCLUSIONS

 •  Of  the  14  industries/operations identified as possible sources
   for HCB waste generation, chlorinated solvents production and
   pesticide  manufacturing are the two major sources of HCB wastes
   accounting for nearly all of the reported HCB waste generation
   quantities.

 t  HCB has been detected in waste effluents from electrolytic
   chlorine production, pyrotechnic and ordnance manufacture and
   seed treatment industries.  Adequate analytical data are not
   available  to assess the magnitude of HCB generation and spe-
   cific operations resulting in HCB production in these
   industries.

 •  The largest current use of HCB is as a peptizing agent in the
   manufacture of nitroso and styrene rubber for tires.  The use
   of  large quantities of HCB in the manufacturing of synthetic
   rubber is  very new and quantitative and qualitative data are
   not available on waste generation possibilities and environ-
   mental implications associated with such a usage.

 •  Based on contacts with a number of firms/plants in the aluminum
   manufacturing, pentachlorophenol production,  electrode manu-
   facture, and vinyl  chloride monomer production industries, HCB
   wastes are not associated with these industries »

•  Adequate data are not available to assess the magnitude of HCB
   problem in the wood preservative industry,  cyanogen chloride
   production, and sodium chlorate production.

•  The hauling of HCB  wastes  in open drums  and the dumping of the
   drums  in a normal sanitary landfill  operation can present a
   significant potential  for  contamination  of  air, land,  water
   and wildlife.

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•  Disposal of HCB in sanitary or industrial landfills can be
   environmentally acceptable if an adequate soil cover which
   includes an intermediate layer of plastic is provided and
   the geology of the site is suitable for waste and leachate
   containment.

•  Incineration with emission control and by-product recovery
   appears to be the most desirable and environmentally accept-
   able technology for the destruction of HCB wastes.   Design
   data, operating conditions and cost data are not available
   on the only unit of this kind currently in operation at one
   plant site.

•  Very limited actual disposal  cost data are available on
   existing facilities handling  HCB wastes.

•  At most facilities which generate HCB wastes, these wastes
   account for only a fraction of the total  waste effluent.
   At these facilities, the handling of HCB wastes  cannot be
   considered as  an isolated problem requiring a separate
   solution, but  rather should be viewed as  an element in the
   total  waste management plan for the facility.

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                              4.   METHODOLOGY

      The data collected and used in  this  study were  obtained  from the
 following sources:   (a) published literature; (b)  telephone contacts and
 formal  correspondence  with  industrial  firms; (c) visits to production sites
 and waste disposal  facilities; and (d) discussions and interviews with
 technical  staffs  in  academic institutions,  research  establishments, trade
 organizations, and  State and Federal  agencies.  In the body of the report,
 the source or sources  of data are identified, where  appropriate.

      The first step  in data gathering was a preliminary literature survey
 in  which industries, plants, and operations suspected of generating HCB
 wastes were identified.   This was  then followed by telephone inquiries and
 submission of formal requests for data to the company headquarters and
 plants.   The specific  data  which  were requested from some industries/plants
 contacted  are illustrated in  the  questionnaire form shown as Table A-4 in
 the Appendix.   The requested  data  included information on source(s)  of HCB
 wastes;  commodity production  and  HCB generation rates; physical  and  chemical
 characteristics of waste  streams  containing HCB; and waste handling,  treat-
 ment, and  disposal methods  and associated costs.   Overall, a total  of 80
 companies  (some operating more than one production site)  were contacted.  A
 listing  of the  non-industrial agencies contacted are presented in Table  A-5
 in  the Appendix.

     Six site visits were made for data collection.  These included visits
 to  two major waste generation sites (designated  as plants B and F in
 Table A-l  in  the Appendix), two  visits to waste  disposal  sites  (designated
 as OC-1  and OC-4 in Table A-2 in  the Appendix),  one trip  to  New Orleans,
 Louisiana,  for discussions with  the personnel at  the  Louisiana State  Health
 Department  (Section of Solid Waste and Vector Control, and Air Control
Section),  and one trip to the University  of California at  Riverside
 (California) to discuss research  findings  on control  of HCB  volatilization
at land  disposal sites.
                                    11

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     The data which were collected In the survey were collated  and
evaluated, and are presented (in summary form)  and  discussed  in the
sections of this report which follow.
                                   12

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                       5.  RESULTS AND DISCUSSION

     This Chapter presents and discusses the data obtained on industries
and operations which produce HCB-containing wastes, quantities and charac-
teristics of the wastes, and methods and procedures used for handling, treat-
ment, and disposal of the wastes.  A discussion of the environmental
adequacy of waste treatment/disposal methods is also presented in the per-
tinent sections of this Chapter.

5.1  HCB WASTE GENERATION SURVEY

     The following 14 industries/operations were identified as possible
sources for the generation of HCB wastes:
      (1)  Basic HCB production
      (2)  Chlorinated solvents production
      (3)  Pesticide industry
      (4)  Electrolytic chlorine production
      (5)  Ordnance and pyrotechnics production
      (6)  Sodium chlorate production
      (7)  Aluminum manufacture
      (8)  Seed treatment industry
      (9)  Pentachlorophenol  production
     (10)  Wood preservative industry
     (11)  Electrode manufacture
     (12)  Cyanogen chloride production
     (13)  Vinyl  chloride monomer production
     (14)  Rubber manufacturing
     A number of firms in each of the industries  listed  above were contacted
and Inquiries were made regarding the presence  of HCB  in their waste  streams.
The number of firms in the first 13 industries  listed  above which  were
                                   13

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contacted, the estimated number of firms in each industry,  and the number
of responses received from the firms contacted are summarized in Table 1.
(It is only very recently that large quantities of HCB have been used in
the manufacturing of synthetic rubber.   Very little data are available on
HCB use, and waste generation and treatment in the rubber manufacturing
industry.  Although identified here as  a possible source of HCB wastes, the
synthetic rubber industry was not included in this survey.)  Relative to
the estimated total number of firms in  the various industries, the number
of firms contacted in general represent an adequate sampling of the indus-
tries reviewed.  Indeed, for some industries, more than 50 percent of the
estimated total number of firms were contacted (e.g., for chlorinated
solvents production and vinyl chloride  production).  Some of the firms con-
tacted own and operate more than one plant; some of these firms provided
information on more than one or all of  their facilities.  Of the total of
80 firms surveyed, 21 (26 percent) indicated that their waste streams con-
tained HCB, 40  (50 percent) indicated that their waste streams did not
contain HCB, and 19 (24 percent) either indicated that they did not know
or that they preferred not to discuss the matter.  The percentage distri-
bution of the three types of response varied for the various industries.
Thus, for chlorinated solvents production, of the 11 firms contacted, 6
(55 percent) indicated that they generated HCB-containing  wastes,  and 5
(45 percent) indicated that they did not generate HCB-containing wastes;
whereas for electrolytic chlorine production, 2 (14 percent) of the 14
firms contacted indicated that they generated HCB-containing wastes and
7  (50 percent)  indicated that they did not know or that they preferred not
to discuss the matter.  The survey results shown in Table 1 indicate that
not all plants  (firms) within a given industry generate HCB wastes.  This
may be explained in a number of ways including:(a) that there are differ-
ences in processes/operations utilized, and  (b) not all plants monitor their
waste streams for  HCB or utilize the analytical procedures with the same
detection levels.

     Based on the  survey results and the data on waste quantities  (which
are presented and  discussed  in Section 5.4), the chlorinated solvents and
pesticide industries are the major sources of HCB wastes.  The electrolytic
chlorine  industry  can be considered as a minor  source of HCB wastes.   (See
                                     14

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                                         TABLE  1
               HCB WASTE GENERATION SURVEY, NUMBER  OF FIRMS
                       CONTACTED AND  RESPONSES  RECEIVED
Industry
Basic production/
Distribution
Chlorinated
Solvents Production
Pesticide Industry'
Formulatl on/Distribution
Electrolytic Chlorine
Production
Ordnance and Pyrotechnics
Production
Sodium Chlorate Production
Aluminum Manufacture
Seed Treatment
Industry
Production
Formulation/
Distribution
Seed Treatment
Houses. Nurseries
PCP Production
Uood Preservatives
Industry
Electrode Manufacture
Cyanogen Chloride
Production
VCH Production
(Total )
Mo of
firmi
Contacted
in Each
Industry
3
11
4
2
14
7
5
4

3
3
1
5
2
5
0
11
(80)
Total No
of Firms
Repoi ted
For the
Indus try"1
3
11
4
46
34
i
9
10

8
8
4
6
52
23
2
12
(232)
No Of
Contacted
Firm
Generating
HCB Waste-.
1
6
4
2
2
3
0
1

0
1
0
0
0
1
n.a.
0
(21)
No Of
Contained
Finns Not
Generating
HCa Wastes
2
5
0
0
7
1
0
3

3
2
0
3
2
4
n.a.
8
(10)
No of
Contacted
Firms Not
Sure /Would
Hot Disclose
0
0
0
0
5
3
5
0

0
0
1
2
0
0
n.a.
3
(19)
    • Some of the firms operate more than one production facility.
    t Based on data in references 9 through 1?.
    < Includes only those firms involved in production/formulation  of Dacthal, mirrx,  sunazine,
atrazlne. propo?inc and PCIIO.  These t>cs tic ides and operations related to their production/
formulation arc Suspected sources of HCB waste.
    > No exact estimates available due to fluctuations  in munitions needs whfcn involve
activation and dcactivation of many military production sites.
    n.e. Indicates not applicable.
                                          15

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also the discussion below for the Individual  industries.)   Because of this
consideration, only these three industries were subsequently subjected to
1n- depth evaluation from the standpoint of waste quantities generated and
treatment/ disposal methods employed.

     The following section briefly reviews the industries  which  were  sur-
veyed as possible sources of HCB wastes.  The information presented is
based on (a) response to inquiries which were directed to  various  companies,
(b) literature search and (c) in some cases,  field visits  and discussions
with plant technical personnel.

5.2  INDUSTRIAL OPERATIONS PRODUCING HCB WASTES

5.2.1  Basic Production of HCB

     Although there are known methods for direct synthesis of HCB  (e.g.,
by chlori nation of benzene or treatment of isomers of hexachlorocyclohexane
with sulfuryl chloride), the current industrial  production of HCB  involves
recovery of HCB from wastes generated in the  production of chlorinated sol-
vents (see below).

     The 1975 Stanford Research Institute Directory of Chemical  Producers'  '
and the Oil, Paint and Drug Chemical  Buyers  Directory1   '  list  Dover
Chemical Company (Dover, Ohio) and Hummel  Corporation  (South  Plalnfield,
New Jersey) as manufacturers of HCB.   In 1974,  the Dover facility  in Ohio
                                                       f 1 A \
produced approximately 50 metric tons (55 tons) of HCB.^  ' The produc-
tion process involves recovery of HCB from chlorinated  solvent  wastes.*   '
Hummel is only an HCB supplier/distributor,  handling primarily  Dover's
product. ^^

     wastes in the production of HCB  are expected to originate  from the
actual manufacturing operations and from equipment and  spill  clean-up acti-
vities.  Using a carbon absorption/solvent extraction method  for sample
concentration, followed by gas chromotographic  analysis of the  concentrate,
no HCB has been detected in the aqueous waste streams  from the  Dover plant
at a detection level of 0.1 ppm;  '

                                   16

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5.2.2  Chlorinated Solvents Production

     Based on industry-furnished data (see Section 5.4), over half of the
3,909 metric tons (4,316 tons) of HCB which is generated annually in the
country is produced as a by-product waste in the production of chlorinated
solvents (mainly, carbon tetrachloride, perchloroethylene, trichloroethylene,
and dichloroethylene).  In the production of chlorinated solvents, HCB is
formed as a reaction side product in the course of thermal chlorination,
oxychlorination and cracking operations.  HCB-containing waste streams are
usually heavy ends waste liquids from various distillation or purification
processes within the manufacturing operations.  As will be discussed in
Section 5.4.2, because of differences in the manufacturing processes, not
all chlorinated solvent producers generate HCB in their waste streams.

     Table 2 lists companies, domestic sites and annual production capaci-
ties (or quantities) for the production of carbon tetrachloride, perchloro-
ethylene, ethylene dichloride and trichloroethylene.   Carbon tetrachloride
is produced by seven companies at 12 different locations; perchloroethylene
is produced by eight firms at 11 different production sites; ethylene di-
chloride is manufactured by 12 firms at 18 sites; and trichloroethylene is
produced by 5 companies at 5 different sites.  Of the total of 16 companies
manufacturing chlorinated solvents, only one recovers HCB from its waste
streams at one of its facilities (Plant Site A).  Each year approximately
190 metric tons (210 tons) of HCB is recovered at this site for sale.  When
this quantity of HCB is added to the 50 metric tons (55 tons) per year of
HCB produced at the Dover Plant (see Section 5.2.1),  the total quantity of
HCB recovered from chlorinated solvent waste is 240 metric tons (265 tons)
per year which accounts for only 10 percent of the estimated 2401 metric
tons (2650 tons) per year of HCB waste which is generated annually in the
production of chlorinated solvents.  The other 90 percent of HCB which is
not recovered is discharged in the waste streams which are disposed of on
land or are incinerated (see Section 5.5).

5.2.3  Pesticide Industry* (Excluding Seed Treatment  Industry)

     Based on the data collected in this study, approximately 38.6 percent
of the total HCB generated annually in the U.S. is produced by the pesticide
     *See Section 5.2.8 for a discussion  of the seed treatment  industry.
                                    17

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                                    TABLE 2
     COMPANIES,  DOMESTIC SITES AND  PRODUCTION RATES OR  CAPACITIES
              FOR CARBON TETRACHLORIDE, PERCHLOROETHYLENE,
                  TRICHLOROETHYLENE,  AND DICHLOROETHYLENE
Company
Carbon '« trachltiride
Allied Chemical Corp.
Do* Chcinicel U.S.A.
Dow Chemical U.S.A.
Dm Chemical U.S.A.
E. I. duPont de Nemours t Co.. Inc.
FMC Corp.
Inland Chemical Corp.
Stauffer Chemical Co,
Stauffer Chemical Co.
Stauffer Chemical Co.
Vulcan Material? Co.
Vulcan Materials Co.
Perch lorocUiylenc
Diamond Shamrock Corp.
Dow Chemical U.S.A.
Dew Chemical U.S.A.
Oow Chemical U.S.A.
E. I. duPont de Nemours t Co., Inc.
Ethyl Corp.
Hooter Chemical Co., Subs id.
Occidental Petroleum Corp.
PPG Industries. Inc.
Stauffer Chemical Co.
Vulcan Materials Co.
Vulcan Materials Co.
Site
'Moundsville, U.V.
freeport, 7x.
Pittsourg, Ca.
Plaqueminc, La.
Corpus Chris tl, Tx
So. Charleston. U.V.
Kjnati , P.R.
Louisville, Ky.
LeHoyne. Al.
Niagara Falls, N.r.
Geismar, La.
Wichita, Ka.

Deer Park, Tx.
Freeport, Tx.
PHtsburg, Pa.
Plaquenine, La.
Corpus Chris t1 , Tn.
Baton Rouge, La.
Taft. La.
Lake Charles, La.
Louisville. Ky.
Gefsmar, La.
MichiU, Ks.
PruducCiorr Hjte or Capacity*
Maine Tons/Vu.ir [Ions/Year]
3,630, (4,000)
5^,000, (65.000)
20,400, (22,500)
45.400, (50,000)
22J.ODO. (P50.DOO)
136.000, (150,000]
(Not available)
2?,700. (25,000)**
90,600, (100.000)
68,000, (75,000}
16,000, (17,500)
IB. 000, (20,000)

73,100, (10,500)**
54.500. (60.000)
9,100, (10,0"1)
68,100, (75.00C)
72,600, (80,000)
22,900, (25,000)
2Z.900. (25,000)
91.000, (100,000)
25.000, (27.500)
60.000, (75,000)*
Z2.900, (25. COO:
Reference
10
10
10
10
10 &
10 I
10
17
10
10
10
10

..
"
10
10
10
10
10
10
17
10
10
    * Unless marked by ** these figures are the production capacities reported in Reference (10);
the figures marked by •• are the actual production rates as supplied by the industry.
                                      18

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                                   TABLE Z
    COMPANIES, DOMESTIC  SITES AND PRODUCTION RATES OR  CAPACITIES
             FOR  CARBON TETRACHLORIDE, PERCHLOROETHYLENE,
           TRICHLOROETHYLENE, AND DICHLOROETHYLENE (CONT'D)
Company
Tricnloroetliylenc
Diamond Shamrock Corp.
Dou Chemical JJ.S A.
Ethyl Corp
Hooker Chemical Co , Subsld
(Occidental Petroleum Corp. )
PPG Industries, Inc.
Dichloroethylene
Allied Chemical Corp.
Continental Oil Co.
(Conoco Chemicals)
Diamond Shamrock Corp.
Dow Chemical U.S.A.
Dow Chemical U.S.A.
Dow Chemical U.S.A.
Ethyl Corp.
Ethyl Corp.
B. F. Goodrich Co.
PPG Industries, Inc.
PPG Industries, Inc
Stauffer Chemical Co.
Shell Chemical Co.
Shell Chemical Co.
Texaco, Inc.
Union Carbide Corp.
Union Carbide Corp.
Vulcan Materials Co.
Site
Deer Park. Tx.
Freeport. Tx.
Baton Rouge, La.
Taft, La.
Lake Charles, Li.
Baton Rouge. La.
West lake, La.
Deer Park, Tx.
Freeport, Tx.
Oyster Creek, Tx.
Plaquemlne, it.
Baton Rouge. La.
Pasadena, Tx.
Calvert City, Ky.
Lake Charles, La.
Cuayanflla. P.R.
Carson, Ca.
Deer Park, Tx.
Norco, La.
Port Heches, Tx.
Taft. La.
Texas City. Tx.
Geismar. La.
Production Rate or Capacity
.'It'lnr Tons/Y<>
-------
industry, primarily in the  manufacturing  of Dacthal, mirex, simazine,
atrazine, propazine, and pentachloronitrobenzene  (PCNB).   HCB  is  produced
as a waste product and is also present in the product  as  an impurity.
Based on industry-furnished data, it is estimated that 99.4 percent of  the
estimated 1,509 metric tons (1,666 tons)  per year of HCB  associated with
the pesticide industry is contained in the process waste  streams  (tars,
still bottoms, etc.) from production operations,  and 0.6  percent  (9 metric
tons or 10.5 tons per year is contained in the product as an impurity.
HCB contained in the wastes from the manufacturing of  simazine, propazine,
and atrazine has been attributed to the presence  of HCB impurities in the
cyanogen chloride which is used as a raw  material. Direct use of, and  for-
mulation operations involving HCB-containing pesticides can result in the
introduction of HCB into the environment.  Table  3 lists  the producers,
production sites, formulators and the number of distributors for  each of
the above-mentioned pesticides.  The list of formulators  and the  number of
distributors are based on the data published in the Farm  Chemicals Handbook.^   '
Some of the formulators operate more than one formulation site.

5.2.4  Electrolytic Chlorine Production

     The electrolytic processes for the production of  chlorine (diaphragm
and mercury cells) generate HCB (and other hydrocarbon wastes) in the crude
chlorine gas when graphite electrodes are used as the  anode.      HCB produc-
tion is believed to result from direct attack of  chlorine on the  graphite
and/or from the reaction of chlorine with the hydrocarbon oils (e.g., linseed
oil) which are used as anode coatings. When crude chlorine is liquified and
purified by distillation, most of the chlorinated hydrocarbons (including
HCB) are separated from chlorine and remain as components of the  "heavy ends."
Some HCB may also be present in the recycled spent brine  and in the brine
purification mud.  Some manufacturers do  not purify chlorine on site.   The
undistilled product is used in a number of industrial  applications (e.g.,
as a flux in aluminum smelting) not requiring a highly pure chlorine gas.
When the unpure liquified chlorine is vaporized at the application site
orior to use, HCB and other hydrocarbon impurities remain as residuals  in
the storage tank and/or vaporization equipment.  Thus, industrial sites
vJhere unpurified chlorine is used may be  regarded as  secondary potential
sources  for HCB waste generation.
                                     20

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                                                       TABLE  3
                           PRODUCERS,  FORMULATORS AND THE NUMBER OF DISTRIBUTORS FOR MIREX,
                               DACTHAL,  SIMAZINE, ATRAZINE, PROPAZINE AND PCNB  (10, 11)
Pesticide
Dacthal

PCNB

Mi rex

Simazine
Atrazine
Propazine
Producer
Diamond Shamrock
Corporation

01 in Corporation

Nease Chemical

Ciba-Geigy
Corporation
Production
Site
Greens Bayou,
Tx.

Me In tosh, Al.

State College,
Pa.

St. Gabriel,
La.
Formula tor
Agway, Inc.
Brockville Chemical
Industries, Ltd.
Lebanon Chemical
Company
Uoodbury Chemical
of Homestead
Wool folk Chemical
Works, Ltd.
Hooker Chemical
Company
Allied Chemical
Company
™
Location of
Company
Headquarters
Syracuse, N.Y.
Montreal ,
Quebec
Lebanon, Pa.
Princeton,
N.J.
Ft. Valley,
Ga.
Niagara Falls,
N.Y.
Morris town,
N.J.
"
Number of
Distributors*
22

10

2

33
ro
            * A complete listing of these  distributors  and  their  locations can be  found  in  the  Farm  Chemicals
       Handbook (11)

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     Electrolytic chlorine production operations which use metallized
anodes, such as the so-called dimensionally stable anodes (DSA's),  do not
generate HCB.  Since about 1969, many modern plants have been converted to
the use of the DSA's.  In the present survey, 67 plants were identified as
sites for the electrolytic production of chlorine; graphite anodes  are cur-
rently used at 32 of the sites (see Table 4); the remaining 35 sites (see
Table 5) currently use or are scheduled to use DSA's or other types of non-
graphite electrodes.

5.2.5  Ordnance and Pyrotechnics Production

     HCB is used in the manufacture of various pyrotechnics (e.g.,  signal
flares) for military and civilian use and in the production of certain
ordnance items (e.g., tracer bullets).  Some HCB-containing wastes  are thus
expected to be generated at pyrotechnic and ordnance manufacturing/loading
facilities which handle HCB-containing raw materials or products.   Except
for the major facilities which are identified below, all of the pyrotechnic/
ordnance production sites which may generate HCB wastes could not be ideni-
fied because of the limited data available (mainly due to the classified
nature of munitions production operations).

     HCB has been used in the manufacture of Navy Mark 13 Day and Night
Distress Signals, Mark 99 Marine Markers, Army hand signals (eliminators)
and commercial highway emergency flares by Kilgore Corporation (Toone,
Tennessee).  Between 1962 and 1975, approximately 2.7 metric tons (3 tons)
of HCB was loaded for Army hand signals, 0.6 metric tons (0.65 tons) HCB
for commercial flares, and an additional undisclosed quantity for the Navy
Marine  Mark Series at this site.^20*  Mark 99 Marine markers have also
been loaded at the Crane Naval Ammunition Product Engineering Center (Crane,
Indiana).  Three other pyrotechnic and ordnance manufacturers (Apache,
Benson, Arizona; Aerojet-General, El Monte, California; and Security Signals,
Cordova, Tennessee) which are involved in the production of similar items
may also generate HCB wastes.  Longhorn Army Ammunition Plant (Marshal,
Texas) and Crane Naval Ammunition Center are reportedly using or have used
                                                                 (21 22)
HCB in pilot scale testing of certain ordnance/pyrotechnic iterns.v  •
                                     22

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                                  TABLE 4
ELECTROLYTIC CHLORINE PRODUCERS USING GRAPHITE ANODES AND PRODUCTION SITES
              Company
          Site(s)
Allied Chemical Corp.

BASF Wyandotte Corp.
Champion International Corp.
Dow Chemical U.S.A.

E. I. duPont de Nemours & Co., Inc.
Ethyl Corp.
Ft. Howard Paper Co.
Hooker Chemical Corp., Subsid.
(Occidental Petroleum Corp.)
Hooker-Sobin Chemicals, Inc.
Inland Chemical Corp.
Jefferson Chemical Co.
Linden Chlorine Products, Inc.
Mobay Chemical Corp.
01 in Corp.

Oregon Metallurgical Corp.
PPG Industries, Inc.
RMI Company
Stauffer Chemical  Co.
Vicksburg Chemical Co.
Brunswick, Ga., Baton Rouge, La.,
Syracuse, N.Y., Acme, N.C.
Wyandotte, Mi.
Houston, Tx.
Midland, Mi., Plaquemine, La.,
Freeport, Tx., Pittsburg, Ca.
Niagara Falls, N.Y., Memphis, Tn.
Baton Rouge, La., Houston, Tx.
Green Bay, Wi.
Montague, Mi., Taft, La., Tacoma,
Wa.
Niagara Falls, N.Y.
Newark, N.J.
Port Neches, Tx.
Linden, N.J.
Cedar Bayou, Tx.
Augusta, Ga., Mclntosh, Al., Niagara
Falls, N.Y., Charleston, Tn.
Albany, Or.
Barberton, Oh., Corpus Christi, Tx.
Ashtabula, Oh.
Henderson, Nv.
Vicksburg, Ms.
li
L
I
     * Based on data in Reference 9, supplemented by direct contact with
industry; seven of the companies listed were contacted in the survey.
                                     23

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                                TABLE 5
          ELECTROLYTIC CHLORINE PRODUCERS USING DSA'S OR OTHER
             NON-GRAPHITE ELECTRODES, AND PRODUCTION SITES*
              Company
              Site{s)
Aluminum Company of America
Allied Chemical Corp.
BASF Wyandotte Corp.
Brunswick Pulp and Paper Co.
Champion International Corp.
Diamond Shamrock Corp.

Detrex Chemical Industries, Inc.
Georgia-Pacific Corp.
B. F. Goodrich Co.
Hercules, Inc.
Hooker Chemical Corp.,Subsid.
(Occidental Petroleum Corp.)
Kaiser Aluminum & Chemical Corp.
Monsanto Co.

Pennwalt Corp.

FMC Corp.
PPG Industries, Inc.

Shell Chemical Co.
Sobin Chemicals, Inc.
Stauffer Chemical Co.
Vulcan Materials Co.

Weyerhaeuser Co.
Ft. Comfort, Tx.
Moundsville, W.V.
Fort Edwards, Wi., Geismar, La.
Brunswick, Ga.
Canton, N.C.
Painesville, Oh., Deer Park, Tx.,
Delaware City, De., Muscle Shoals,
AT.. Mobile, Al.
Ashtabula, Oh.
Billingham, Wa.
Calvert City, Ky.
Hopewell, Va.
Niagara Falls, N.Y.

Gramercy, La.
E. St. Louis, II., Pisgah Forest,
N.C.
Calvert City, Ky., Tacoma, Wa.,
Portland, Or., Wyandotte, Mi.
S. Charleston, W.V.
New Martinsville, W.V., Lake
Charles, La.
Deer Park, Tx.
Orrington, Me.
LeMoyne, Al., St. Gabriel, La.
Denver City, Tx., Wichita, Ks.,
Geismar, La.t
Longview, Wa.
     * Based on data in Reference 9, supplemented by direct contact with
industry; nine of the companies listed were contacted in this survey.
     t Not yet on stream.
                                    24

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 HCB wastes  generated by the ordnance/pyrotechnic industry are relatively
 small  in quantity and are primarily in the form of HCB scrap and contami-
 nated  containers.  At the Kilgore plant in Toone, Tennessee, approximately
 1.5 percent of drummed dry scrap waste generated in the manufacturing of
 HCB-containing products 1s HCB.  The total amount of scrap generated is
 not known.

 5.2.6  Sodium Chlorate Production
     Sodium chlorate is manufactured by the electrolysis of saturated brine
 solutions containing sodium dichromate and acidified with hydrochloric acid.
 As with the electrolytic chlorine production, two types of electrodes are
 commonly used as the anode:  graphite and metallized anodes (such as the
 DSA).  Because of the use of graphite anode, sodium chlorate production by
 the electrolytic process can be a potential source of HCB production.  Waste
 streams from the process which may contain HCB are the mud wastes (graphite
 stub residue) from spent cell liquor.

     Table 6 presents a list of the 15 sodium chlorate manufacturing facili-
 ties in the U.S.  Five companies representing seven sites (four sites using
 graphite anodes and three sites using non-graphite anodes) were contacted
 in this survey and inquiries were made about HCB production.   The companies
 contacted indicated that they had not tested their waste streams for HCB
 and had no qualitative or quantitative data available on HCB.   Based on
 contact with industry and the information contained in a recent publica-
 tion^ ', all sites which currently use graphite electrodes will  soon convert
 to DSA's or other types of non-graphite electrodes.   Accordingly, the sodium
 chlorate industry is expected to be eliminated as a potential  source of HCB
 production.

 5.2.7  Aluminum Manufacture

     HCB has been reported to be used as a fluxing agent in the smelting
 operating associated with the primary manufacture of aluminum.   In  the
 present survey, four of the ten major aluminum manufacturing companies which
were contacted (see Table 7 for a complete list of domestic aluminum
                                    25

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                                 TABLE 6
                   SODIUM CHLORATE PRODUCERS, PRODUCTION
                       SITES AND TYPE OF ANODE USED*
           Company
       Site
  Type of
 Anode Used
Brunswick Pulp and Paper
Company
Huron Chemicals of America,
Inc.
Georgia-Pacific Corp.
Kerr-McGee Chemical Corp.
Hooker Chemical Corp., Subsid.
of Occidental Petroleum Corp.
Pacific Engineering and
Production Company of Nevada
Penn-Olin Chemical Co.
Pennwalt Corp.

PPG Industries, Inc.
Riegel Paper Corp.
Brunswick, Ga.

Butler, AT.

Bellingham, Wa.
Hamilton, Ms.
Henderson, Nv.
Columbus, Ms.
Niagara Falls, N.Y.
Taft, La.
Henderson, Nv.

Calvert City, Ky.
Portland, Or.
Wyandotte, Mi.
Lake Charles, La.
Naheola, Al.
Riegelwood, N.C.
Graphite

N.A.

DSA
Graphite
Graphite
N.A.
DSA
N.A.
Graphite

DSA
DSA Scheduled
Not Disclosed
N.A.
N.A.
N.A.
     *Based on the data in References  9 and 10,  supplemented  by  direct
contact with industry; five of the companies listed  were  contacted in this
survey.
     N.A. indicates not available.
                                    26

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                             TABLE 7
   ALUMINUM MANUFACTURERS (SMELTERS)
AND COMPANY HEADQUARTERS
            Company
       Headquarters
Kaiser Aluminum & Chemical Corp.
Howmet Corp.
01 in Corp.
Satchelder, Charles E.
Manufacture Systems Inc.
Martin Marietta
Revere Copper and Brass
Ormet
Reynolds Metals
Aluminum Co. of America
     Oakland, Ca.
     Brunswick, Ct.
     Stanford, Ct.
     Newton, Ct.
     Great Lakes, Mn.
     New York City, N.Y.
     New York City, N.Y.
     Hannibal, Oh.
     Richmond Va.
     Pittsburgh, Pa.
;i
     * Based on data in Reference 12;  four of the companies
listed above were contacted in this survey.
                               27

-------
 manufacturers) indicated that they do not use HCB as a fluxing agent and
 they envisioned no likelihood for the generation of HCB in the smelting or
 fabrication of aluminum by the currently used technology.  Alcoa is cur-
 rently conducting pilot plant tests on a new proprietary smelting process.
 To date, tests conducted on waste streams from the pilot plant have failed
 to indicate the presence of HCB.

     As was indicated above in Section 5.2.4, aluminum manufacturing plants
which use impure chlorine (alone or in combination with other gasses as a
flux in smelting) may be a source of HCB waste, since any HCB present in
the liquified chlorine feed tank may accumulate as residue which may
require disposal.

5.2.8  Seed Treatment Industry

     In the past, the principal use of HCB has been as a seed protectant or
as an ingredient in seed protectant formulations for the control  of wheat
bunt and smut fungi of other grains.   '  (Currently, HCB is mainly used as
a peptizing agent in the manufacturing of certain types of synthetic rubber.)
In 1971, an estimated 6.2 metric tons (6.9 tons) of HCB were used as a  grain
fungicide primarily in California, Washington and Oregon."'  HCB is also
                                                     (23)
used in quarantine centers and in seed certification.*  '  Seed treatment
formulation houses which formulate HCB-contaim'ng seed protectants,  and
quarantine and seed treatment houses, as well as the use of treated  seeds
(particularly the cotton seed) are sources for HCB waste generation  and
introduction of HCB into the environment.

     According to the Farm Chemicals  Handbook/  ' there are at least eight
major seed treatment formulators in the country (and at least four seed
treatment nurseries*  ').  Each of the companies and nurseries presumably
formulate and operate at more than one site.   Three of the seed treatment
formulators were contacted in the present survey.   Two of the formulators
indicated that they do not use HCB in any of  their seed treatment formula-
tions.   One formulator (Production Site AD) indicated that it uses HCB  in
two formulations but declined to identify the products or provide data  on
                                    28

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their compositions.  This formulator formulates about 45.3 metric tons
(50 tons) per year of each product.   According to California State Depart-
ment of Food and Agriculture/  '  HCB is also an ingredient of Grannox,
a specific seed treatment formulation, which is imported from United Kingdom
and distributed for use in this country by ICI America.   ICI reports no
                                                    (25)
waste generation in the distribution of the product.    '

5.2.9  Pentachlorophenol (PCP) Production
     According to one report,  ' HCB is produced as a by-product in the
production of pentachlorophenol (PCP).  This assertion, however, is not
supported by the industry-furnished data collected in this survey.

     There are six reported major domestic producers of PCP.^  '  These are
                                                       (26 27)
listed in Table 8.  Based on the plant analytical data/"'  ' HCB is not
generated at two sites (Vulcan Materials Co., Wichita, Kansas; and Reichold
Chemicals, Inc., Tacoma, Washington) which produce PCP by the chlorination
of phenol.  This same PCP synthetic route is also used by Monsanto Co.  at
its Sauget, Illinois plant and by Dow Chemical U.S.A. at its Midland,
Michigan facility.  No analytical data have been obtained at the Sauget
plant to assess the presence of HCB in the waste streams.   '  The fifth
producer of PCP, Dover Chemical Company, which is also an HCB producer,
may produce PCP through hydrolysis of HCB.  As discussed in Section 5.2.1,
at a detection level of 0.1 ppm, no HCB has been detected in the effluent
discharges from the Dover plant.  The sixth reported domestic producer of
PCP, Sonford Chemical Company, has indicated it is only a representative
                      /2Q}
for PCP manufacturers.*  '

5.2.10  Wood Preservative Industry

                                                             (9)
     HCB has been reported to be used as a wood preservative.* '  There are
at least 52 domestic sites for wood preservation treatment. *  ^  Two com-
panies (J.H. Baxter Co., San Mateo, California, and Honolulu Wood Treatments
Company, Honolulu, Hawaii) which were contacted in this survey, reported
that HCB is not used at any of their treatment sites and that to the best
of their knowledge HCB is not in use domestically, at least not in large
                                    29

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                         TABLE 8                      *
PENTACHLOROPHENOL (PCP) PRODUCERS AND PRODUCTION SITES
           Company
   Site
Dover Chemical Company
(Subsidiary of Ansul Company)
Dow Chemical U.S.A.
Monsanto Company
Reichhold Chemicals, Inc.
Sonford Chemicals Company
Vulcan Materials Company
Dover, Oh.
Midland, Mi.
Sauget, II.
Tacoma, Wa.
Houston, Tx.
Wichita, Ks.
      With the exception of one, all of the above
companies were contacted in this study.
                            30

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 wood treatment centers.    *'  According to one industry contact,  °' the
 apparent confusion regarding the use of HCB as a wood treatment agent may
 stem from the fact that HCB is often confused with t-BHC (gamma-benzene
 hexachloride or gamma-hexachlorocyclohexane) which has been used both in
 this country and in Europe as a wood preservative.  (Note:  the British
 Wood Society Register of Mood Preservatives, also does not list HCB as a
 wood preservative.^  ')

     Pentachlorophenol  (PCP) is used as wood preservative in this country.
 If  it is assumed that technical grade PCP produced by hydrolysis of HCB
 contains HCB as an impurity, the use of PCB for wood preservation may con-
 stitute a source for the generation of HCB wastes.  However, no analytical
 data are available on the HCB content of technical grade PCP to test the
 validity of this assertion.

     In wood treatment operations, the wood is steamed in the presence of
 treatment chemicals or is pressure-treated with solutions containing such
 chemicals.  The wood is then drained and the residual liquid is removed by
 the application of a vacuum.  If PCP contaminated with HCB is used in these
 processes, probable sources of HCB-containing wastes may include the non-
 recyclable spent liquor, mechanical losses, spills and overflows, equipment
 clean-up, etc.

 5.2.11  Electrode Manufacture

     HCB has been reported to have been used as a porosity control  agent in
                                                       io\
 the manufacture of graphite anodes for industrial  uses.   '  There are 23
 domestic manufacturers of carbon and graphite products,  including electrodes
 (see Table 9).  Five of the electrode manufacturers were contacted in this
 survey.   One manufacturer (Stackpole Carbon Company,  St.  Marys,  Pennsylvania)
 indicated that the company has  stopped using HCB in its  electrode manufac-
 turing operations.*  ^  Two other companies (Carborundum Corporation,
Sanbornne,  New York and Airco-Speer Corporation, St.  Marys,  Pennsylvania)
 indicated that they do not use HCB in their operations,  but suggested that
HCB may be an ingredient of the heat transfer materials,  primarily chlori-
nated organic compounds, such as chlorinated biphenyls,  which are used  by
the industry.(33»34)   These sources,  however,  added that the  use of
                                   31

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                              TABLE 9                  *
       ELECTRODE MANUFACTURERS AND COMPANY HEADQUARTERS
                  Company
  Headquarters
Airco Speer Co., Carbon-Graphite Division
Becker Bros. Carbon Co.
Carbone Corp.
Carborundum Co.
Electro-Nite Co.
Great Lakes Carbon Corp.
Helwig Carbon Products, Inc.
Kennametal Inc.
Keystone Carbon Co.
Kirkwood Comnutator Co.
Lukens Steel Co.
Morganite  Incorporated
Ohio Carbon Co.
Pure Carbon Co., Inc.
Saint Marys Carbon Co.
Stackpole  Carbon Co.
Superior Carbon Products, Inc.
Teeg Research,  Inc.
Textool Products,  Inc.
Ultra Carbon Corp.
Union Carbide Canada Limited
Union Carbide Corp.
United States Graphite Co.
St. Marys, Pa.
Cicero, II.
Boonton, N.Y.
Sanborne, N.Y.
Philadelphia, Pa.
New York, N.Y.
Milwaukee, Wi.
Milwaukee, Wi.
St. Marys, Pa.
Cleveland, Oh.
Coatesville, Pa.
Dunn, N. C.
Cleveland, Oh.
St. Marys, Pa.
St. Marys, Pa.
St. Marys, Pa.
Cleveland, Oh.
Easton, Md.
Irving, Tx.
Bay City, Mi.
Toronto, Canada
New York, N.Y.
Saginaw, Mi.
      Five of the companies listed were contacted in this survey.
                                 32

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chlorinated organic compounds as heat transfer materials is apparently
becoming outdated in the industry.   Of the remaining two firms, one
(Keystone Carbon Company, St. Marys, Pennsylvania)  indicated that it now
makes metal anodes, rather than graphite anodes.    '  The other firm (Helwig
Carbon Products, Inc., St. Marys, Pennsylvania) indicated that it is not
involved in the manufacturing of electrodes.*   '

5.2.12  Cyanogen Chloride Production

     As discussed in Section 5.2.3, HCB contained in the wastes from the
manufacture of three pesticides (simazine, atrazine, and propazine) has
been attributed to the HCB impurities in the cyanogen chloride which is
used as a raw material.  At one site, HCB emission  was significantly reduced
when a higher purity cyanogen chloride was used in  the process.  The presence
of HCB in cyanogen chloride suggests that cyanogen  chloride manufacturing
may be a potential source of HCB generation.  This  possibility for HCB gen-
eration was not discussed with the two reported domestic manufacturers of
cyanogen chloride (Nilok Chemicals Inc., Memphis, Tennessee^  ' and DuPont
                                     (37)
and Co., Inc., Wilmington, Delaware)/  ;

5.2.13  Vinyl Chloride Monomer (VCM) Production
                             /Q\
     According to one report/ ' HCB may be produced as a by-product in the
production of vinyl chloride monomer (VCM).  The  industry-furnished data
collected in this study, however, do not support  such a possibility.

     There are 12 major producers of VCM and 17 production sites in this
country (see Table 10).  Based on industry-furnished analytical data (and
some independent testing by one state laboratory),  tests with ppm (parts
per million) sensitivities, have indicated no detectable amount of HCB in
the waste streams at 5 of the 17 sites.  At four  of the sites HCB has been
detected in waste streams containing VCM wastes,  but in these cases the VCM
wastes are in combination with wastes from chlorinated solvent production
which may be the real sources of HCB.  The data supplied by one company for
two production sites indicate that at a detection level  of 10 ppm, no HCB
was found in its waste streams.

                                    33

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                                TABLE 10                   *
       VINYL CHORIDE MONOMER PRODUCERS AND PRODUCTION SITES
                                                   (10)
                                              Baton  Rouge, La.
                                              Carson, Ca.
Allied Chemical Corp.
American Chemical Corp.
(Stauffer Chemical Co.)
                                              Westlake,  La.
Continental Oil Co.
Dow Chemical U.S.A.
                                              Oyster  Creek,  Tx.
                                              Freeport,  Tx.
                                              Plaquemine,  La.
                                               Baton  Rouge,  La.
                                               Pasadena,  Tx.
Ethyl Corp.
                                               Calvert  City,
B. F. Goodrich Co.
PPG Industries, Inc
                                               Lake  Charles,  La.
                                               Guayanilla,  P.  R.
                                               Deer Park,  Tx.
                                               Norco,  La.
Shell Chemical Co.
                                               Houston,  Tx.
                                               Texas  City, Tx.
                                               Geismar,  La.
                                               Geismar,  La.
Tenneco, Inc.
Union Carbide Corp.
Borden, Inc.
Monochem, Inc.
     * Except for one,  all  companies listed
survey.
                                  were contacted in this
                                    34

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     Of the remaining six VCM production sites,  two reported  they are
phasing out of production.   Information was not  available for the remaining
two companies representing  four production sites.

5.2.14  Synthetic Rubber Production

     According to a 1975 publication,^ the largest supplier of HCB in the
U.S., has committed its entire HCB production output on a multi-year con-
tract basis for use as a peptizing agent in the  production of nitroso and
styrene type rubber for automobile tires.  The use of HCB on  such a large
scale in the manufacture of synthetic rubber is  very new and  very little
information is available on sites using HCB, processes involved, and pollu-
tant emission quantities.

5.3  CHARACTERISTICS OF HCB-CONTAINING WASTES

     Table 11 summarizes the data collected in this survey on HCB waste
characteristics.  As indicated in this table, in most cases HCB is present
as a constituent of the distillation residue and heavy ends (tars) from
product purification operations.  The HCB content of the waste mixtures
varies, depending on the nature of the operation and the specific products
produced.  In general, as discharged from the process, HCB-containing wastes
are viscous organic fluids containing little or  no water.  When cooled to
ambient temperature, HCB solidifies and separates from the mother liquor.
Depending on the nature of the liquid component, some HCB may remain in
solution in the liquid phase.  (See Table A-3 in the Appendix for properties
of HCB.)

     As indicated in Table 11, HCB-containing wastes from chlorinated
solvents production also contain hexachlorobutadiene (HCBD) as a major
ingredient.  Indeed, HCBD for commercial use was formerly produced as a
                                                            / Q \
recovered by-product in the production of perchloroethylene.      (In 1974,
all commercial quantities of HCBD, 91 to 227 metric tons or 100 to 250 tons
per year, were imported from Germany^9').  HCBD is liquid at ambient tem-
perature (melting range -19 to 22°C; boiling range 210 to 220°C), is con-
siderably more volatile than HCB  (vapor pressure  1.5 mm  Hg at 40°C)  and

                                     35

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                                                        TABLE  11
                               GENERAL CHARACTERISTICS OF HCB-CONTAINING WASTE STREAMS
                                  FOR  CHLORINATED SOLVENT AND PESTICIDE  MANUFACTURING
                               INDUSTRIES, BASED ON DATA FOR SPECIFIC PRODUCTION  SITES
Industry (and Products)
Carbon tetrachlonde,
ps cMcroethyieie.
cnlc'oretnane solvents
Carbon tetrachlonde,
perchloroethy 1 ene,
ethy'iene dichloride
Perchloroethy lens,
tnchloroethylene,
ethylene dichloride
Perchloroethylene,
tnchloroethylene
Ethylene dichloride
Pesticides
Pesticides
Pesticides
Pesticides
Site
Designation
A

F
D
Q
R
S
T
Process Waste Source
Heavy ends from solvent
recovery system (recy-
cle, stripping)
Heavy ends from purifi-
cation stills
Still bottoms,
("heavies") from purifi-
cation stills
Heavy ends
Distillation tars and
residue
Distillation residue
Liquid still bottoms
Distillation tars
Stack emissions
HCB-Contalnlng '
Waste Composition
74r, HCB, K- hexachloro-
butadiene (HCBD), 102 hexa-
chloroethane (HCE)
15% HCB,* 75X HCBD. 10%
HCE
1.65 HCB. 791 HCBO, 3.5t HCE,
3.51 tetrachlorobutadiene,
3.4t pentachlorobenzene.
3.3Z trichlorobenzene.
2.4% perchloroethylene,
0.9X tetrachlorobenzene.
0.8% pcntachlorobutadiene.
1.62 sand and carbon
6* HCB, 20-901 HCBD, 4-14%
C4-Cg chlorinated organic
conpounds
10-40 ppm HCB. 15% 1,2-
trichloroethylene, 41S
chlorinated C4.Cs, compounds
4% miscellaneous solids
75% HCB, ?S% product
80% HCB. 20% lower
chlorinated benzenes
IS HCB
No data available
Miscellaneous Waste Stream Characteristics
Grayish or whitish in color
Grayish-white solid settles out when cooled
(with viscous red-brown liquid supernatant
containing concentrated organics)
Viscous tars, vapor pressure <690 newtons/
m* absolute (0.1 psla) at 38°C (100"F);
viscosity (at 24°C or 75°F) » 0.025 newton-
second/ms- density =1.6 g/cr->
Viscous tar. black 1n color; density •
1.8 g/cm3
Similar to above
Viscous > el low liquid when discharged (hot);
yellow crystalline solid formed at ambient
temperature
Grayish-white; HCB separates from mother
liquor as an opaque solid when cooled
No data available
No data available
OJ
Ol
              * Indeoendent analysis of this waste has indicated an HCB content of as high as 758. (38)

-------
has some of the toxic and biological properties of HCB.   The present survey
has concerned itself primarily with the HCB which originates in the produc-
tion of a greater number of chemicals.  General information and sources and
characteristics of HCBD waste can be found in Reference 9.

     In one pesticide production site, HCB is emitted from the process in
the scrubber emission which is vented to the atmosphere.   These HCB emis-
sions, however, are from cyanogen chloride which is used  as a raw product
and which contains HCB as an impurity (see Section 5.2.12).  No data (quali-
tative or quantitative) could be obtained on possible HCB emissions to the
atmosphere for other production operations.

5.4  ESTIMATED HCB WASTE QUANTITIES

5.4.1  Total Waste Quantities and Comparison of Estimates with
       Those Made in an Earlier Study	

     Under a contract with EPA Office of Toxic Substances, Midwest Research
Institute (MRI) conducted a study of hexachlorobenzene and hexachlorobu-
tadiene (HCBD) in U.S. industrial wastes, by-products, and products/  '
The study identified the following 11 industrial/agricultural chemicals
which contain HCB and/or their production results in the  generation of HCB
      With the exception of one plant site producing pesticides,  the possi-
bility of direct HCB discharges to the air has not been documented.   Several
of the firms contacted in this survey indicated that measurements of HCB
levels in gaseous emissions and other process waste streams have  been made
and no HCB has been detected.  For example, at Plant Site B, stack gases had
been monitored several times monthly since the 1973 episode of HCB contami-
nation in the Southern Lousiana area.  The periodic monitoring has since
been discontinued, since only 1-2 parts per billion (ppb) HCB has been the
maximum ever detected.  At Plant Site F, a spot check of miscellaneous
effluent streams showed 2.2 ppb of HCB in the "No. 3 Outfall." The firm
also indicated it does not normally check its effluent waste streams for
HCB.  Thus, if HCB has been detected in miscellaneous plant effluent and
stack discharges in the chlorinated solvents and pesticide industries, it
would appear to be the exception rather than the rule, and is not likely to
be documented.
                                    37

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wastes:  perch!oroethylene, trichloroethylene,  carbon tetrachloride,
chlorine, Dacthal, vinyl  chloride, atrazine,  propazine,  simazine,  penta-
chloronitrobenzene, and mirex.  These chemicals fall  into the "chlorinated
solvents production," "electrolytic chlorine  production," "pesticide  indus-
try", and "vinyl chloride monomer production" which were discussed in
Sections 5.2.2, 5.2.4, 5.2.3 and 5.2.13, respectively.   Although in the
present survey 14 industries/operations were  identified  as sources of HCB
wastes, based on the discussion in Section 5.2, only three industries,
namely, chlorinated solvents production, electrolytic chlorine production,
and pesticide industry can be regarded as significant sources for HCB waste
generation.  Data obtained in the present survey on the  vinyl chloride
monomer industry indicate that this industry  is probably not an important
source of HCB production (five production sites which were contacted indi-
cated  that  they  had  not detected  any HCB in  their waste streams).

     Based on reported or estimated chemical  commodity production capacities
for the U.S., some waste composition data obtained from selected production
sites, and assuming  that the quantity of waste generated is proportional to
production capacity, estimates were made by MRI of the total quantity of
HCB waste generated  in 1972 in the U.S. by each of the major HCB waste pro-
ducing industries.^  The MRI data which are reproduced in Table 12,
consist of  "high" and "low" estimates with the "low" values generally
assumed  to  be  50 percent of the "high" estimates.  The industry-furnished
data on waste quantity collected  in the present survey are also presented
in Table 12.   At some plant sites where more than one of the three listed
chlorinated  solvents are manufactured, the waste streams are not  segregated
and only the combined plant effluent is sampled and analyzed for  HCB con-
tent.  Accordingly,  the industry-furnished waste quantity data  for chlori-
nated  solvents  shown in the Table, represent the total for perchloroethylene,
trichloroethylene, and carbon  tetrachloride  production.  These  waste quanti-
ties are from  selected sites which participated in the present  survey and do
not  include waste  from all  production  sites.   Comparison of  the industry-
furnished  data with  the MRI estimate indicates  that, with few exceptions,
the  industry-furnished data are  significantly  higher  than the  "high"  esti-
mates  reported in  the  earlier  study  by MRI.  Of particular  interest  is
pentachloronitrobenzene  production  for which the "high"  estimate  is
                                     38

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                                                                                TABLE  12         *
                                                                       HCB  WASTE QUANTITIES
                                            (A COMPARISON  OF  THE  EARLIER  MRI ESTIMATES       AND  THE DATA
                                                    COLLECTED AND ESTIMATES MADE  IN THE  PRESENT STUDY)
Industry/Product
Chlorinated Solvents
Perchloroethylene
Trichloroetnylene
Carbon tetrachlonde
Subtota 1
Pesticides
Dae thai
Simazine,
Atrazine, and
Propazlne
PCNB
HI rex
Subtotal
Electrolytic
Chlorine Hfr
Vinyl Chloride
Total
MRI Data for 1972
Estimated Total
1972 Production HCB Quantity
Rate
High Low
332,000 (367.000)
193,400 (213,500)
151,600 (498,500)
977.000 (1,079,000)
900 (1,000)
50,700 (56.000)
1,350 (7,500)
450 (500)
53,400 (59,000)
8,940,000 (9,668,000)
2,305,000 (2,544,000)
-
1,585 (1.750)
204 (275)
181 (200)
1,970 (2,175)
45 (50)
4.1 (4 5)
2 7 (3)
0.9 (1)
53 (59)
180 (195)
12 (13)
2.215 (2,442)
793 (875)
104 (115)
91 (100)
988 (1,090)
36 (40)
2 3 (2.5)
1 4 (1 5)
0.4 (0.5)
40 (45)
72 (BO)
0
1,100 (1,215)
1975 Production
Rate
1,530,000 (1,689,000)
2,300 (2,500)
**
N A.
t
1,532.000 (1,692,000)
10,872,000 (12,000,000)
3,162,000 (3,490,000)

Indjs try-Furnished
Waste Quantities
HCB
Waste
2,401 (2,650)
226 (250)
25 kg (55 lb)
1,268 (1.400)
5 0 [5 5)
1,499 (1,555)
2 7 kg (6 lb)
0
3,900 (4.305)
HCB-Containlng
Haste
21,440 (23.665)
302 (131)
N.A.
1,585 (1.750)
500 (550)
2.387 (2,633)
141 (156)
0
(23 ,'968 (26,454
Projected
Waste
Quanti ty
for the U S
3,937 (4,345)
226 (250)
25 kg (55 lb)
1,268 (1.400)
5 0 (5.5)
1 499 (1,651)
t
i
5.323 (6.000)
Projected Waste
Quantity Adjusted
to 197Z Products
Level
2,514 (2.775)
91 000)
N C
N C
N.C.
91 (100)
t
*
Z.605 (2,875)
U)
                   * Except as noted,  values not enclosed in parenthesis are metric  tons,  those enclosed in parenthesis are tons   AD HCB waste values indicate  the
               amount of HCB contained in the waste and not the total waste stream quantities which would be significantly larger.
                   '• Production data is not available, since U S  Tariff data does  not cover products manufactured at only one site
                   * Production of Mi rex at the one domestic production site (Nease  Chemical Co ) was stopped In mid-1974.
                   t No valid projection can be made from the one available data point.
                   N A  indicates Not Available   N C  Indicates Not Calculable from the  given data

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2.7 metric tons (3 tons) per year of HCB whereas the Industry-furnished
data indicate an HCB waste generation rate of 1,268 metric tons (1,400 tons)
per year.  Since a greater number of plants were surveyed in the present
study and the industry-furnished data represent those collected through
actual sampling and waste analysis, the industry-furnished waste quantities
shown in the table, are probably closer to actual values than those esti-
mated in the earlier study.  Indeed much higher values would be obtained,
if, using the earlier approach, the industry-furnished waste data are pro-
jected to a national level using the total estimated national production
capacity and assuming that the quantity of waste generated is proportional
to production capacity, (see the last two columns in Table 12).

     The present survey indicates that approximately 3,909 metric tons
(4,316 tons) per year of HCB is produced at major industrial plants and
that major sources of HCB are chlorinated solvents production (2,401  metric
tons or 2,650 tons per year), pentachloronitrobenzene manufacture (1,268 metric
tons or 1,400 tons per year) and Dacthal production (226 metric tons  or
250 tons per year).  A more detailed description of the data collected in
this survey on waste quantities and waste generation rates follows.

5.4.2  Chlorinated Solvents

     In the present survey, seven companies representing 10 chlorinated
solvents production sites indicated that HCB was a constituent of their
waste.  These plant sites which are designated as Sites A through J and the
reported or estimated waste quantities for these sites are listed in
Table 13.  With the exception of Plant Site D, where only one product
(ethylene dichloride) is manufactured, more than one type of chlorinated
solvent are manufactured at the production sites listed in Table 13.   Since
at most sites waste streams from all chlorinated solvent production opera-
tions are combined and the combined effluent is tested for HCB, HCB waste
quantities shown in the table are not broken down for the individual  products.
Although ethylene dichloride is included in the HCB waste data for the
majority of the sites, based on the data for Site D, ethylene dichloride
production is not a significant source of HCB wastes.
                                    40

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                             TABLE  13
               PRODUCTION SITES  AND  HCB  WASTE          *
     QUANTITIES FOR CHLORINATED SOLVENTS  PRODUCTION
   Site
Designation
          Products
Quantity of HCB Waste
  Metric Tons/Year
    (Tons/Year)
     I


     J
Carbon tetrachlonde,                  378 (418)
perch!oroethylene,  (methyl
chloride, chloroform, d1-
chloromethane)
                                         t
Carbon tetrachlorlde,                  734  (810)
perchloroethylene,  ethylene
dichloride (EDC)

Carbon tetrachlorlde,                  217 (240)
perch1oroethy1ene

Ethylene dichloride                   0.35 (0.39)

Perchloroethylene,  tri-                0.14*  (0.16)
chloroethylene. ethylene
dichloride

Perchloroethylene,  tri-                236 (260)
chloroethylene, ethylene
dichloride

Carbon tetrachlorlde                   6805 (750)
perchloroethylene,  ethylene
dichloride

Carbon tetrachloride,                  7701 '850)
perchloroethylene,  trichloro-
ethylene. ethylene  dichloride

Carbon tetrachlorlde,                  3171 (350)
perchloroethylene

Ethylene dichloride, perchloro-        157 (173)
ethylene, trichloroethylene          	
                Total               3.489 (3.851)
     * All  waste quantities refer to the amount of HCB  contained  in
the waste and not the  total waste mixture which would be  significantly
larger.
     t Based on industry-furnished data that waste contains 15% HCB. (33)
However, a  recent independent analysis of the waste has found 75% HCB.
       Estimated based on waste generation data for Plant Site D.
     i Based on 1971 data on the quantity of waste hauled away from the
site.
     i Estimated based on plant production capacity and the calculated
waste generation factor  for Plant Site G.
                                 41

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     The data in Table 13 indicate that approximately 2,401 metric tons
 (2,650 tons) of HCB wastes are generated each year at plant sites for which
 industry has supplied waste generation quantities.  For Plant Sites H and I,
 for which no industry-supplied data were available, estimates were made of
 the waste generated based on production capacities.  When the estimates for
 these two major production sites are included, the total industry-supplied
 and estimated waste quantities would be 3,489 metric tons (3,851 tons) per
year of HCB.  The plant sites listed in Table 13 represent an estimated
 total chlorinated solvents production capacity of 892,000 metric tons
 (985,000 tons) and account for 58.5 percent of the total U.S. production
 capacity for 1975.

     Table 14 lists a number of additional plant sites for which data on
 HCB waste production quantities were solicited in the present survey.
These sites represent 41.5 percent of total U.S. chlorinated solvents
production capacity.  Three of the sites representing a production capacity
 294,500 metric tons (325,000 tons) per year of carbon tetrachloride use the
 CS2 process which reportedly does not generate HCB as a by-product.  *9'
One small plant (production capacity 3,624 metric tons or 4,000 tons per
year of carbon tetrachloride) has not detected any HCB in its waste stream.
According to the company representing Plant Site L, the waste from this
plant probably contains HCB at parts per million (ppm) concentration levels;
 the waste, however, has not been tested for HCB content.  No quantitative
 data were available on wastes from Plant Site P, which, according to one
       (37}
 source,v°'y contains "small quantities" of HCB.

 5.4.3  Pesticide Industry

     Pesticide industry is the second most important source of HCB wastes.
As was indicated in Section 5.2.3, production of Dacthal, PCNB, mirex,
simazine, atrazine and propazine result in the generation of HCB wastes.
At the present, simazine, atrazine and propazine are produced at one pro-
duction site by only one company and each of the remaining three pesticides
 is produced by a different company at only one production site.  The four
production sites, designated as Plant Sites Q through T, and industry-
 furnished data on HCB waste quantities generated at these sites, are
                                    42

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                                                      TABLE 14
            CHLORINATED SOLVENTS PRODUCERS REPORTING NO HCB WASTE GENERATION OR HAVING NO ANALYTICAL DATA
Site
Designation
K
L
M
N
0
P
Product
Carbon
tetrachloride
Carbon tetra-
chloride
Perch! oro-
ethylene
Carbon tetra-
chloride
Carbon tetra-
chl ori de
Carbon tetra-
chloride
Perch lo ro-
ethylene
Trichloro-
ethyl ene
,
Production Capacity" '
Metric Tons/Year
(Tons/Year)
3,624 (4,000)
226,500 (250,000)
72,500 (80,000)
135,900 (150,000)
90,600 (100,000)
67,950 (75,000)
22,650 (25,000)
18,120 (20,000)
-r .-i"-5 . j'i.r. •.:'.. .r.-1.1 r ssii..*---" "E-~- .: •.-•<•
Comments
None detected
HCB may be generated
in ppm quantities;
wastes have never
been analyzed
Uses CS2 method
Uses CS2 method
Uses CS« method
Produces HCB in /,7v
"small quantities"^''
co

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 presented  in  Table  15.  The data  indicate a total HCB waste quantity of
 1,499  metric  tons  (1,655  tons) per year with wastes  from Sites R and Q
 accounting for 84.5 percent and 15.1  percent of  the  total, respectively.

     As was discussed  in  Section  5.2.3, both Dacthal and PCNB contain HCB
 as  an  impurity (estimated at 9 metric tons or  10.5 tons per year in the
 final  products) which  should be considered as  a  potential source for the
 introduction  of HCB in the environment.  No quantitative data were obtained
 in  this study on the HCB  content  of wastes generated at formulation plants
 which  handle  these  products.

 5.4.4  Electrolytic Chlorine Production

     As indicated in Section 5.2.4, electrolytic chlorine production using
 graphite anodes generate  HCB wastes.   Of the 67  domestic electrolytic
 chlorine production sites, 32 have been identified as using graphite anodes
 (see Table 4).  Table 16  lists eight  sites which use graphite electrodes
 and which were contacted  during this  survey.

     As indicated in Table 16, HCB has been detected in the waste stream
 from at least two sites (designated as U and U).  At Plant Site U, HCB has
 been determined to  be  close to the 20 ppm level  in the still bottoms from
 chlorine distillation  operation.  Because of the small volume of the waste,
 however, the  quantity  of  HCB generated is very small (2.7 kg/year or 6 lb/
 year).  At  Plant Site W,  HCB has  been detected in the product chlorine which
 is  not purified but sold  directly.  No qualitative data are available on
 HCB waste  for this  site.  No HCB  has  been detected in waste from two other
         *
 plant  sites (V and  X).  The waste from Plant Site Y has never been analyzed
 for HCB.   Three other plants (G,  H and I) which did not discount the possi-
 bility for  the presence of HCB in their waste  stream did not submit data
 on HCB quantities.

     Based on  the waste generation data for Site U, the HCB produced in the
 electrolytic  chlorine industry should be very  small relative to the waste
quantity in the chlorinated solvents  and  pesticide industries.  Since  data
were not available on production  capacities for the 32  plants which  use
                                     44

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                       TABLE  15
  QUANTITIES OF HCB WASTES  FROM  PESTICIDE MANUFACTURE
   Site
Designation
Quantity of HCB in
Discharged Wastes
            (Tons/Year)
     Q
     R
     S
     T
    226 (250)
  1,268 (1,400)
      5 (5.5)
   0.02 (0.03)
                           45

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                           TABLE 16
            ELECTROLYTIC CHLORINE PRODUCERS USING
             GRAPHITE ANODES WHICH WERE CONTACTED
                        IN THIS SURVEY
Site Designation
    Industry-Furnished Data
        I

        H

        G

        W



        X


        Y
20 ppm HCB in distillation
  tars (2.7 kg/yr or 6 Ib/yr)

No HCB detected using gas
  chromatography

No data submitted

No data submitted

No data submitted

HCB detected in unpurified
  chlorine product.  No quanti-
  tive data submitted

No HCB detected using infrared
  spectroscopy

Never analyzed for HCB
                             46

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graphite anodes, no projection could be made of the total quantity of HCB
produced on a nation-wide level.  Some of the sites which currently use
graphite anodes plan to convert to DSA anodes which do not generate HCB
wastes.

5.5  WASTE HANDLING, TREATMENT, AND DISPOSAL

5.5.1  Waste Handling (Storage and Transportation)

     Loading and temporary storage of HCB wastes in containers, tank trucks
and lagoons, and .the transportation of HCB wastes from the point of waste
generation to loading/storage or ultimate disposal facilities provide poten-
tial for environmental contamination through possible accidental spills,
mismanagement of the operation and use of inadequate environmental safe-
guards.  Accordingly, as part of the present survey, data were collected on
methods of HCB waste storage and transportation.  These data which are sum-
marized in Table 17, are briefly discussed below.   (The information con-
tained in Table 17 on methods of waste treatment will  be discussed in
Section 5.5.2.)

     Based on the data in Table 17, for the total  of 2,870 metric tons
(3,168 tons) per year of HCB waste for which data were obtained from industry
on waste handling methods,  the currently used waste storage methods and the
percentage of waste handled by each method are as follows:
     Storage of solid cubes under plastic   44.2 percent
     cover
     Water-covered open storage lagoons     33.1 percent
     Drums which may or may not be lined    14.4 percent
     Insulated and heated storage tanks      8.2 percent
     Nitrogen-blanketed steel  tank          <0.1 percent
      This quantity of HCB represents 74.4 percent of the estimated total
national  HCB waste production quantity based on data furnished by industry
(see Table 12).
                                    47

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                                                           TABLE 17
                                  METHODS  OF HCB WASTE TREATMENT, HANDLING, AND TRANSPORT'
                                         BASED ON DATA FOR SPECIFIC PRODUCTION  SITES
00
Site Designation
A
B
C
0
Z
E
HCB Quantity
metric tons/year
(tons/year)
188 (208)*
734 (810)
217 (240)
0.35 (0.39)
Not Disclosed
0.14 (0.16)
Treatment
No pre- treatment for bulk
HCB wastes; spills washed
to a collection pit
Storage lagoon for solid-
liquid separation
Distillation for waste
concentration and
resource recovery; heat-
Ing to effect waste
fluldlzatlon
Distillation for waste
concentration and
resource recovery
Distillation for waste
concentration and
resource recovery
Handling and
Storage Methods
Drums covered with plastic
bags; drums stored in a
metal truck body with other dry
trash
Open concrete pit with water
cover; waste dredged with a
crane or clan-type shell
equipment
Nitrogen blanketed steel storage
tank
Storage tank
Not known
Transportation
Method
Trucks used to haul truck
body containing druimed
waste to a dispose! site
16 kilometers (10 miles)
away
Trucks used to haul waste
to an on-site burial site
Waste hauled to Site E In
tank trucks
Waste hauled by ship to
Site E
Piped to Incinerator (prior
to pipeline construction,
trucks were used to trans-
port waste to onslte
storage tank, then to
Incineration)
                   * Does not Include 190 metric tons (210 tons) per year which Is recovered and sold.

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                        TABLE 17
METHODS OF HCB WASTE TREATMENT, HANDLING,  AND TRANSPORT
  BASED ON DATA FOR SPECIFIC PRODUCTION SITES (CONT'D)
Site Designation
F
G
Q
R
s
AA
AB
HCB Quantity
metric tons/year
(tons/year)
236 (260)
680 (750)
227 (250)
1,268 (1.400)
5 (5.5)
Not available
Not available
Treatment
Distillation for waste
concentration; heating
to effect fluldlzatlon;
spills washed off to a
collection sunp; waste
dilution and suspension
by the off-site disposal
contractor prior to deep
well Injection
Not disclosed
Not disclosed
Solidification and
shaping Into cubes
Distillation for waste
reduction and notarial
recovery
Not disclosed
Dewatertng by filtration
Handling and
Storage Methods
Heated, Insulated storage tank,
with 3-ro (10- ft) pipeline for
truck hook-up
Not disclosed
113-liter (30-gal) "fiber-
pale" drums
Cubes stored under plastic
cover
Not disclosed
Drums
Not disclosed
Transportation
Ceihod
Heated tank trucks
Piped to Incinerator; metal
truck bodies were used 1n
1970-71 to haul the waste
to off-site disposal
Truck transport to off-site
disposal site
Waste 'orkllfted to storage
area
Rail and/or truck transport
to a neighboring state. 'by
an off-site disposal
contractor
Truck transport
Not disclosed

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     At pesticide production Site R, heavy still  bottom tars containing
80 percent HCB from the distillation operation are discharged into a 1-cubic
yard mold and allowed to cool to the ambient temperature.   The cooling
results in the solidification of the waste into 1-ton blocks which are then
removed and transported by a forklift to a storage area.   As of the date of
this survey, approximately 3,171 metric tons (3,500 tons)  of the HCB-
containing waste blocks (2,537 metric tons or 2,800 tons  of HCB) have been
accumulated at this storage site.  The blocks are covered  with a plastic
tarpaulin sheet as a rain cover.  The company is  currently evaluating a
number of possible alternatives, including incineration and material
recovery, for disposal of the accumulated wastes.  The handling and storage
of the waste blocks can involve some environmental contamination (e.g.,
resulting from possible fragmentation and dust formation  during handling,
and volatilization through sublimation during handling and storage).

     Three-meter (10-foot) deep rectangular concrete lagoons are used for
temporary storage of HCB-containing wastes at Plant Sites  B and C.  At these
sites waste discharges from process operations enter the  lagoons through
steam-jacketed fiber-cast pipes.  The waste is not pumped  and flows through
the pipe by means of process-generated pressure.   The waste is distributed
along the length of the lagoon by a submerged mobile discharge pipe.
Ordinarily, a water cover of 0.3 to 0.6 meter (1  to 2 feet) is maintained
above the waste to minimize volatilization.  Periodically, a portion of the
HCB waste is "scooped" and removed from the lagoon (using  a crane or a clam-
type shell equipment) and transported by a dump truck to an on-site land-
fill location.  Since some water is also scooped  out with  the waste, this
water acts as a seal in the dump truck during transportation.

     The operation of lagoons at Sites B and C provides some potential for
environmental contamination.  Although compared to soil and polyethylene
film, a water cover has been shown to be most effective to reduce HCB vola-
                                 /3o\
tilization and loss to atmospherev   , it is difficult to  maintain an
effective layer of water cover at all times.  Moreover, HCB is soluble to
some extent in the aqueous cover (6.2 ug.l for distilled water at 23.5°Cr
and can be lost to atmosphere through evaporation and wind action.  Mass
balance calculations around the lagoon at Plant Site B have indicated
                                  (38)
leaching into the subsurface soil,   ' possibly due to deterioration of
concrete lining.

-------
      Both lined and unlined drums are used for temporary storage/
 transportation of HCB wastes.   In some cases, a drum containing HCB is
 placed in a thin plastic bag which also serves to cover the open drum.
 During handling, transportation and land disposal of these drums, there is
 a strong possibility for spillage, generation of dust,  and volatilization.
 Some actual photographs of the drums containing HCB wastes as delivered to
 a sanitary landfill are shown in Figure 1.

      At Plant Site F, HCB waste is stored on-site in a  41,600-liter (11,000-
 gal) insulated and steam-jacketed tank.  The waste is maintained in a fluid
 state by heating to 116°C (240°F).  The waste is removed from the tank and
 transferred to heated tank truck via 3-meter (10-foot)  discharge pipe to
 which the trucks can connect their intake.   The 3-meter (10-foot) distance
 between the storage tank and the tank truck  intake pipe is considered an
 adequate safety measure.  The tank sits on  a concrete base and any spillage
 flows to a collection sump and the contaminated area is washed with water
 which also flows to the collection area.  The material  collected in the
 sump is removed, the organic material  is  recovered by steam stripping and
 the aqueous portion is  discharged to an on-site waste treatment facility
 which discharges its treated effluent to  a receiving water.

      Figure 2  presents  a schematic flow diagram for the HCB  waste concentra-
 tion and storage at Site D.   The storage  tank at this facility  is a nitrogen
 blanketed 226,800-liter (60,000-gal)  steel tank.   Environmental  safeguards
 provided include:   (a)  use  of  dike around the storage tank,  (b)  return of
 truck  loading  vent  to the storage  tank, (c) collection  and discharge of all
 the  surface drains which might accidentally contain  tars to plant secondary
 waste  treatment  system,  and  (d)  use of personnel safety equipment including
 full-face  shield and rubber gloves by personnel while handling the tars.

     As  indicated in Table  17, the methods currently used for the transpor-
 tation of  HCB wastes include trucks (for drummed or bulk solid waste),
 heated  tank trucks  {for  bulk liquid), pipeline (for in-plant transportation
 and  transfer to handling trucks), forklift (for solidified blocks of HCB
waste), ship (for bulk fluid), and rail (for tars).  Based on the data
                                     bl

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Figure 1.   Photographs  of Drummed HCB  Wastes  at a  Sanitary  Landfill
                                  52

-------
to
            FROM EOC PURIFICATION
         (EDC  + HEAVY CHLORINATED
          HYDROCARBONS)

                        STEAM
                  CONDENSATE
                                                 VAPOR
                                                                                 EDC RECYCLE
                                                                                   TO WASH
                                                                                   SYSTEM
  LIQUID
 TAR STILL
  COLUMN
  C-104
  10 TRAYS
2'6" 9 x 25'0" TT
   STEEL
             N2
          BLANKET
                                                                                                 PRESSURE
                                                                                               VACUUM VENT
   STIRRED
STEAM JACKETED
   VESSEL
                                                                                 VINYL
                                                                                 TARS
         HEAVY CHLORINATED
                                                     HYDROCARBONS TO STORAGE
                          T-405
                                            TRANSFER
                                             PUMP

                                      EDC TAR
                                      STILLS
                                     S-104 A/B
                                   (TWO VESSELS)
                                  6'6" 0 x 7'6" TT
                                      STEEL
                                          HEAVY  CHLORINATED
                                             HYDROCARBON
                                            STORAGE TANK
                                             60,000 GAL.
                                                STEEL
                                           LOADING
                                         VENT RETURN
                                                                     -IV'/Vt
                                                                            TRUCK
                                                                           LOADING
                                                        LOADING
                                                         PUMP
                                       Figure 2.   Tar Concentration and  Storage  Facility
                                                    At Plant  Site  D

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shown in Table 17, for the total of 3,555 metric tons (3,924 tons) per
year of HCB wastes for which data were obtained from industry on waste
                      *
transportation method,  the percentages of the total HCB waste quantity
handled by the above-listed methods are as follows:
     Truck                          38.4 percent
     Forklift                       35.7 percent
     Pipeline                       19.1 percent
     Heated tank trucks              6.6 percent
     Rail                            0.1 percent

     Although no documented incidents of accidents involving transportation
of HCB by the above methods have been reported, the possibility of such
accidents occuring in the future cannot be ruled out.   Because of the haz-
ardous nature of the HCB-containing wastes, precautions should be taken to
avoid spillage and losses due to wind action during transportation.   During
site visits in this survey, it was observed that some  waste haulers  use
open trucks to transport open drums or drums enclosed  in loose plastic bags
containing HCB waste.  This method of transportation presents a definite
potential for environmental contamination.   A major episode of HCB contami-
nation in cattle occurred in southern Louisana in 1973 due partly to the
spillage of HCB from the sides of open dump trucks as  the trucks crossed
railroad tracks, hit bumps in the country roads, etc., on the way to a
landfill.^7'  Pipelines used to transport HCB waste are usually heated to
permit fluid flow.  Any malfunction in the heating system can result in
waste solidification and accidental discharge (flow-back-up) due to  system
failure.
     This quantity of HCB represents 91.1 percent of the estimated total
national HCB waste production quantity based on data furnished by industry
(see Table 12).
                                     54

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5.5.2  Waste Treatment

     A number of sites for which data were collected in this survey utilize
some form of treatment prior to ultimate disposal of HCB wastes.   These
treatment methods which are listed in Table 17 include use of storage lagoons
to effect solidification and settling of HCB (Sites B and C), distillation to
effect waste volume reduction and material recovery (Sites D, E,  F, S, Z);
heating to effect fluidization during storage and bulk transportation by
pipeline and trucks (Sites D and F); solidification and shaping into cubes
for storage (Site R); dewatering for waste concentration (Site AB); and
dilution and suspension by mixing with other wastes prior to deep well injec-
tion (Site OC-3, see Section 5.5.3.3).

     The use of storage lagoons, solidification, and heating systems were
discussed above in connection with waste handling.   At one off-site disposal
site (OC-3, see Section 5.5.3.3) HCB waste from Plant Site F is mixed with
a range of liquid wastes (chlorinated solvents, acids, alkali, rinse waste,
etc.) from other industrial clients prior to deep well injection.   At an
electrolytic chlorine production facility (Plant Site AB), the mud from
brine purification operation which contains graphite stub residues is
dewatered by vacuum filtration prior to contract disposal.  Based on the
data in Table 17, for the total of  2,649 metric  tons (2,924 tons)  per year
of HCB for which data on waste treatment were obtained from industry,  the
percentage of total HCB waste quantities handled by the above-mentioned
methods are as follows:
     Solidification and shaping into cubes                     47.9 percent
     Storage in lagoons to effect solidification and settlina  35.9 percent
     Distillation to effect volume reduction and material        9.0 percent
     recovery and/or heating to effect fluidization
     No treatment                                               7.1 percent
      This quantity of HCB represents 68.7 percent of the estimated total
national HCB waste production quantity based on data furnished by industry
(see Table 12).
                                    55

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No data were available on methods of pretreatment (if any) used at Site G
where approximately 680 metric tons (750 tons) per year of HCB waste is
disposed of by incineration.

5.5.3  Ultimate Disposal

     Based on the industry-furnished data, methods currently used for the
ultimate disposal of HCB-containing wastes include land disposal  (sanitary
landfill, industrial landfill, deep well injection and drying ponds),
incineration, open pit burning, resource recovery, discharge to municipal
sewage treatment plants, and emission to atmosphere.   Both on-site disposal
and off-site contract disposal are used.  The prevalence of various disposal
methods are shown in Table 18 in terms of the quantity of HCB (and HCB-
containing wastes) handled and the number of facilities (on-site and off-
site) which utilize the disposal methods.

     The data in Table 18 indicate that based on the  total  quantity of
waste handled, currently land disposal is the most prevelant method for
ultimate disposal of HCB wastes.  Nine of the sites  surveyed use  land dis-
posal; approximately 1,389 metric tons (1,483 tons)  of HCR waste  (56 percent
of th« total) which is contained in a waste mixture  of 17,362 metric tons
(19,164 tons) is disposed of by this method each year.   Among land disposal
methods, use of industrial landfills is the most prevalent method, account-
ing for the disposal of 39.7 percent of all HCB wastes.   Ranked next to land
disposal is incineration which is used at nine of the sites surveyed for the
destruction of a minimum of 1,055 metric tons (1,164  tons)  per year of HCB
contained in a waste mixture in excess of 4,763 metric tons (5,257 tons) per
year.  Compared to land disposal and incineration, the quantities  of waste
discharged to sewage treatment plants and to atmosphere are very  small.   No
data were available on the quantity of HCB waste which is  used at  one site
(Site L) as a chemical feedstock for the production of low-molecular weight
aliphatic halogenated hydrocarbons.   Of the 22 sites  listed in Table 18,
six use the services of off-site disposal contractors, which handle 655
metric tons (723 tons) per year of HCB wastes.   A discussion of the various
disposal methods follows.
                                    56

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                                                TABLE  18
                        PREVALENCE  OF  METHODS  USED  FOR  ULTIMATE
                                      DISPOSAL  OF  HCB  WASTES
Disposal Method
Land Disposal
Sanitary Landfill
Industrial Landfill
Deep Well
Drying Pond
(Subtotal )
Incineration
Without by-product
recovery
With by-product
recovery
(Subtotal )
Open Pit Burning
Resource Recovery
(excluding
Incineration)
Discharge to Haste
Treatment Plants
Emission to
atmosphere
Total
HCB Waste
Quantity
metric tons/year X of Total
(tons/year)

188 (208) 78
997 (1,050) 39.7
204 ( 225) 8 5
Not available
1,389 (1.483) 56 0
375* ( 414) 15 6
680* ( 750) 28.3
1.055 (1,164) 43 9
13 kg (29 Ib) <0 1
Not available
Small, data on
exact quantity
not available
25 kg (55 Ib) <0.1
2.444S(2.647) 100X
HCB - Containing Haste
Quantity
metric tons/year I of Total
(tons/year)

254 ( 281) 1.1
6.544 ( 7,223) 29 6
10,564 (11,660) 47.7
Not available
17.362 (19.164) 78.4
3.857*( 4.257) 17.4
906' ( 1.000) 4.1
4.763(5.257) 21.5
165 kg (365 Ib) <0.1
Not available
Not available
Not available
22.1255(24.421) 100S
Plant Sites
Number 1 of Total

1 4 5
5 22.7
2 9 1
1 4.5
9 40.8
'I
8f 36.4
1 4 5
9 40 9
1 4 5
1 4 5
1 4 5
1 4.5
22 100X
     • Includes an estimated 0.50 metric tons  (0.55 tons) per year  of HCB from plant sites D and E.
These wastes are extremely dilute (10 to 40 ppm HCB content) and were not Included in the total waste
quantities to avoid gross distortion of percent of "HCB-Contalning  Waste" handled by Incineration.
     t Includes sues H and I for which data on actual waste quantities were unavailable
     i Waste quantities is for 1970-71, data supplied by the off-site waste disposal contractor then
handling  the waste  Waste assumed to contain  75 percent HCB based  on data for other plants.
     § Does not Include 1,268 metric tons (1,400 tons) per year of  HCB waste (1,586 metric tons or 1,750 tons
of HCB-containinn waste) temporarily  stored under  cover at  Plant  Site R.   Also does  not  Include 190 metric tons
(210 tons) of HCB vhich is recovered for sale from 257 metric tons  (284 tons)  of HCB-conta1n1no wastes  at Plant Site A.
                                                   57

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5.5.3.1  Land Disposal

     The data collected In this survey on sites employing land disposal and
the quantity of HCB wastes handled at each site are summarized in Table 19.

     As used in this report, sanitary landfills are those off-site landfills
which accept both municipal refuse and industrial wastes.  Industrial land-
fills are those which accept only industrial  wastes.  Industrial  landfills
may be located on-site or off-site.  The American Society of Civil Engineers
defines sanitary landfill as:  "a method of disposing of refuse on land
without creating nuisance or hazards to public health or safety,  by utiliz-
ing the principles of engineering to confine  the refuse to the smallest
practical area, to reduce it to the smallest  practical volume, and to cover
it with a layer of earth at the conclusion of each day's operation or at
                                           (39)
such more frequent intervals as necessary."x   '  Not all landfills which
are commonly referred to as sanitary landfills conform to this definition
or meet the high operating standards which are implied.   Industrial  land-
fills are generally waste burial  sites consisting of pits or trenches which
are excavated in suitable ground and into which the waste is deposited and
subsequently covered with dirt.  To provide protection against possible
infiltration of leachate into the subsurface  soil and contamination  of
groundwater, the burial  sites may be lined with impervious materials such
as dense clay, concrete  or plastic liners.

     The data collected  in this survey on sites using sanitary landfills,
industrial  landfills, deep well injection, and drying ponds  are presented
below.

     Sanitary Landfill

     HCB wastes from Plant Site A are handled by an off-site contractor
(designated as OC-1) which operates a 603-hectare (244-acre) sanitary
landfill and handles household refuse and manufacturing wastes from
a metropolitan area.  Approximately 255 truck loads of wastes are
received at the site each day, including seven to ten loads of HCB wastes
per month from Plant Site A which is located  about 16 kilometers  (10 miles)

                                    58

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                    TABLE 19
METHODS AND SITES FOR LAND DISPOSAL OF HCB WASTES
Method of
Land Disposal
Sanitary Landfill
Industrial Landfill




Deep Well Disposal
Drying Pond

Disposal Site
Designation
Off -site: OC-1
Off-site: OC-2
On-site: B
On-site: C
On-site: P
On-site: U
Off -site: OC-3
On-site: J
On-site: AC
	
Quantity of
HCB Waste
metric tons/year
(tons/year)
188 (208)
45 (50)
734 (810)
217 (240)
Not available
2.7 kg (6 Ib)
47 (52)
157 (173)
Not available
••MMMMMHiMH
Source of Waste ;
(Plant Site .
Designation) .
i
4
A i
Q ':
B i
'»
P P
IF'
U '
F ^
J
i
AC 'i
	 3
                        59

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away from the landfill.  The HCB wastes are received in open drums, some
enclosed in plastic bags.  The disposal contractor's haul  trucks containing
the drums merely "dump" their loads at the site.   These drums along with
other loads of  refuse and industrial  trash are then compacted on a 4.7
meter (15-foot) high slope by a bulldozer.  A 15-centimeter (6-inch) earth
cover is provided at the end of each working day.   Since the plastic bag
enclosures for the drums do not provide a  tight seal, in some cases the
wastes are spilled from the drums and physically mixed with other wastes
during the dumping and bulldozing operation.  Because of the powdery nature
of the waste, some of the HCB material  may be blown away by wind action
and this constitutes a potential health hazard to the equipment operators
and presents possibilities for the contamination  of air and adjacent land.
(See Figure 1 and discussion in Section 5.5.1).   HCB wastes from Site A
have been hauled to this landfill since early 1974; it is  estimated that
about 282 metric tons (311 tons) of HCB has been  deposited at this landfill
to date.

     The operation at the OC-1 waste disposal site was started about 24
years ago.  The area was originally an uncleared swamp which has since
been cleared and filled with dirt and sections of it used for waste dis-
posal.  The section which is in operation currently has an anticipated
service life of 3-5 more years.  The drainage ditches which pass through
the property provide water for waste compaction and dust suppression during
the operation.  A hydrogeological study conducted by an independent con-
sulting engineering firm has indicated that the site is suitable for use as
a sanitary landfill and that the soils and bedrock are essentially imper-
meable  to water (run-off) infiltration.  The State Department of Health has
been conducting periodic sampling of the ambient air in the vicinity of the
site and of the drainage ditches above and below the operating dump.

     Industrial Landfills

     Based on the data collected in this study, five industrial landfills
accept  HCB wastes.  Four of the sites are on-site landfills and one is
operated by an off-site disposal contractor.  The off-site disposal facility
(designated as OC-2) receives HCB wastes from Plant Site Q.  Prior to the

                                    60

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 current  use  of  landfill, HCB  wastes were incinerated at OC-2 disposal  site
 along  with other  industrial wastes.  However, because of certain operational
 difficulties and  high cost of supplementary fuel, the incineration as a
 method of ultimate disposal was abandoned in favor of landfill operation.
 The  site is  located on a 593-hectare (240-acre) parcel and is classified
 as a Texas Class  I site which, under Texas Water Quality Control Board
 regulations, is suitable for  the disposal of hazardous chemicals.  Approxi-
 mately 20 percent of the HCB  waste  from  Plant Site Q is hauled to this
 facility by  the disposal contractor.   (The other 80 percent  is sent to
 another  off-site  facility, OC-5, for incineration; see below.)  Since Plant
 Site Q is expected to join a  regional waste disposal authority which will
 use  incineration  as the disposal method, no HCB waste will be taken to the
 OC-2 site after about 1976.

     Although the practice has been stopped, during 1970-71, approximately
 680  metric tons (750 tons) of HCB waste  from Plant Site G was disposed
 of in  an off-site disposal facility (OC-4).  The waste was originally de-
 posited  in two 38 x 38 meter  (125 x 125  foot) pits.  One of  the pits, which
 had  become full,  was subsequently covered with 0.61 meter (2 feet) of soil
 and  0.61 meter (2 feet) of dry trash.  The other pit in which HCB had been
 deposited was still active receiving other industrial wastes.  During the
 HCB  contamination episode in  Louisiana in 1973 (see Section  3), the opera-
 tion at  this site was suspected as a possible source for environmental  con-
 tamination.  This suspicion was later confirmed when samples of the soil
 from selected locations at the site were tested.   A cleaning operation
 which was financed by the company representing Plant Site G was then ini-
 tiated which included removal of the dirt and trash covers from the first
 pit and their replacement with a new cover consisting of a total  of 1.9
 meters (6 feet) of fresh soil with a 0.025-centimeter (10-mil) sheet of
 polyethylene film placed approximately at the middle of the  soil  cover.

     On-site industrial landfill  is used for the disposal of HCB wastes at
 Plant Sites B and C.   The HCB wastes are scooped from the settling lagoons
 and brought to the burial site in dump trucks.   The disposal  sites at the
 two facilities are essentially identical.  The landfill  at Plant Site B,
which is the larger of the two landfills, was visited during this survey.

                                    61

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 HCB wastes  are  deposited  in  excavated  pits  3.1  to  3.7 meters  (10  to  12  feet)
 deep and  roughly  6.2 x  9.3 meters  (20  x  30  feet) in  size.  Each pit  is  of
 sufficient  capacity to  handle all  the  waste which  is scooped  from the set-
 tling pond  in a lagoon  emptying operation.  The deposited waste is covered
 with 1.2  to 1.9 meters  (4 to 6 feet) of  soil and a 0.025-centimeter  (10-mil)
 thick polyethylene film placed approximately at the mid-depth of  the soil
 cover.  The subsurface  structure at the  site includes impermeable strata
 which are considered adequate to prevent groundwater contamination.  Soil
 boring  tests have indicated  that the top soil down to a depth of about
 19  meters (60 feet) consists of a  clay-silt mixture with very little sand.
 Periodic  sampling and analysis of  water  from several wells in the area  have
 indicated no contamination of groundwater with  HCB.

      Prior  to the use of  on-site land  disposal, HCB wastes from Plant Site B
 were handled by a private off-site contractor and deposited in a nearby
 sanitary  landfill.  The landfill received 500 to 600 m3 of material every
 three months for  2.5 years ending  in January 1973.   During much of this time
 the  HCB waste was spread  in a thin coat over the entire dump to serve as a
 fly  repellent.  This operation was later identified as the major source of
 environmental contamination  in the Louisiana HCB contamination episode of
 1973  (see Section 3).   The site has since been closed and the wastes buried
 under polyethylene sheeting in an isolated section  of the landfill.

     Two other  sites which utilize on-site landfills for the disposal of
 HCB wastes are  Plant Sites P and U.  According to the Louisiana  State Health
 Department/37^  the on-site facility at Plant Site  P has been  in operation
 for a number of years.   The quantity of HCB  waste generated at this  site is
 considered very small.   Tars and still  bottoms from the chlorine purifica-
 tion operation at Plant Site U contain a very small quantity of  HCB (20 ppm
 or  2.7 kg/yr).  These wastes are buried on-site in  the desert  land.

 5.5.3.2  Deep-Well Injection

     At the off-site waste disposal facility OC-3,  deep-well  injection  is
used for the disposal  of certain types  of industrial  wastes.   Among  the
wastes handled is  approximately  780 metric  tons (860  tons)  per year  of  tars

                                    62

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 containing 6 percent HCB from Plant Site F.  The waste is hauled to the site
 by  the contractor in 18,900-liter (5000-gallons) vacuum tank trucks.  The
 HCB-containing tars are mixed and diluted with wastes from other industrial
 sources prior to deep-well injection.   The disposal stratum is about 1.6
 kilometers (1 mile) below the surface and the average injection rate is
 522 liters per minute (138 gpm).   Depending on  the  nature  and quantity of
 the wastes,  some wastes are injected underground as soon as received at
 the site; other wastes may be stored for a period of several  days prior
 to injection.  The injection operation meets all requirements for deep-well
 disposal  set by the Texas Water Quality Board and is carried  out under a
 Board permit.

      Deep-well  disposal is also employed at an  on-site  facility (Plant Site
 J) in Louisiana for the disposal  of  HCB wastes  from a  chlorinated solvents
 production plant.   No data are  available on the actual  disposal  operation
 at this  site.

 5.5.3.3   Drying Pond

      At Plant Site AC,  the  graphite  stub residue  from the electrolytic
 sodium chlorate production  is dewatered  by  filtration and the filter cake
 which consists  of the graphite  stub  loss, perl He filter aid, and insoluble
 calcium sulfate is taken  to on-site drying  ponds.   In addition to the filter
 cakes, these  ponds receive a number of other process wastes.  When a pond
 is full, the  operation  is transferred to a  new pond.  Although the dried
 material in some of  the abandoned ponds  Is  not currently covered, the com-
 pany  plans to cover  the dried material with dirt in the future.

 5.5.3.4  Incineration

      Incineration as a method for ultimate disposal  of HCB wastes is used
 at six facilities listed in Table 20, along with the sources and quantity
 of waste handled at each site.  The largest quantity of HCB wastes is han-
 dled at Plant Site G, which uses an on-site incinerator of proprietary
design.  The  system reportedly effects  99.94 percent destruction of HCB
and recovers  hydrochloric acid as a by-product.   The incinerator is  equipped
                                    63

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                          TABLE  20
         SITES FOR THE  INCINERATION OF  HCB WASTES
Disposal Site
Designation
On-site: G
Off-site: OC-5

On-site: E
Off -site:* OC-6
On-site: AD
On-site: Y
^•^•^•^^^^^•^^^•i
Quantity of Waste
metric tons/year
(tons/year)
680 (750)
189 (208)
182 (200)
Min 0.45 (0.5)
5.0 (5.5)
Not available
Not available
Source of Waste
(Plant Site
Designation)
G
F
Q
E, D, Z
S
AD
Y
^^^^^^^^^^^^^^^^^^^^^^^^^^^•^BMH
^^^••^^^^^^^^^^^^^•^^^^•^"^
No HCB waste has been hauled to the  site  since mid-1974.
                             64

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with scrubbers to minimize emissions to the atmosphere.  Prior to the
installation of the incinerator, HCB wastes were stored in metal drums;
the stored wastes are now fed to the incinerator.  The company plans to
install similar incinerators at its facilities at two other locations.

     The OC-5 off-site disposal contractor handles HCB wastes from Plant
Sites F and Q.  The wastes are hauled from these plants in heated tank trucks
and stored in storage tanks prior to incineration.  The incineration is
essentially a destruction operation and does not include any by-product
recovery.  The solid and semi-solid wastes are handled in a Bartlett Snow
rotary kiln incinerator which has a rated capacity of 1.8 metric tons (2
tons) per hour and operates at a temperature of 816 to 1,093°C (1,500 to
2,000°F) or higher.   Low to medium viscosity waste liquids are fed at a
rate of up to 3,780 liters (1,000 gallons) per hour to a Loddby liquid
incinerator which operates at a burner temperature close to 1,093°C
(2,000°F).  All exhaust gases from the rotary kiln incinerator and the
liquid waste burner are mixed and passed through an afterburner which
operates at 1,316°C (2,400°F).  The combustion gases are then cooled in
a water quench chamber, scrubbed with an alkali solution and discharged
to the atmosphere through a stack.   Gases exist the stack at 77°C (170°F)
and at a linear velocity of 539 meters (1770 fpm) per minute.  When Plant
Sites Q and F join a regional waste disposal  authority (possibly in 1976),
they will no longer use the services of the off-site contractor (OC-5)  for
the disposal  of the HCB wastes.

     The incinerator at Plant Site E handles  HCB-containing wastes from
chlorinated solvents production at this site and at two other production
sites (D and Z).   The incinerator  is a Thermal Research  unit having two
trains, one for the destruction of gases and  one for the  combustion of
liquids.  The liquid train was designed to incinerate 19  metric tons (22
tons) per day of waste tars containing 98.5 percent chlorinated hydrocar-
bons.  The gas train was designed to incinerate 48 metric tons (53 tons)
per day of waste gases containing 20 percent  chlorinated  hydrocarbons.
The incinerator is equipped with water and alkali scrubbing systems for
the removal  of acids from combustion gases.   The scrubbed gases are exited
to the atmosphere through a 1.2-meter (4-foot) diameter stack at a
                                    65

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temperature of about 57°C (135°F) and an exit velocity of 3 meters per
second (10 fps).  Monitoring of stack gases has indicated the following
emission rates:
                                        Emission Rate,
                     Pollutants         kg/hr (Ib/hr)
                        HC1                2.8  (6.2)
                        CO                1.5  (3.2)
                        NOX               5.7 (12.6)
                        C12               0.3  (0.6)
                    Particulates          3.3  (7.2)

     Up until mid-1974, the off-site contractor OC-6 in New York,  handled
approximately 5.0 metric tons (5.5 tons) per year of HCB from Plant Site S
in Pennsylvania.  No HCB wastes have since been handled at this site because
of the discontinuation of the production of an HCB waste producing chemical
at Plant Site S.

     At Plant Site AD, liquid waste from formulation of HCB-containing
pesticides are destructed, along with wastes from some other process sources,
in an incinerator designed for pesticide wastes.  The incinerator  is bottom-
fed, refractory-lined, and of up-right design.  The dimensions  for the lower
section of the combustion chamber are 2.4 m I.D. x 7.5 m long (8 x 25 feet).
Above this, the combustion chamber tapers to 1.2 meters (4 feet) I.D.  at the
top.  The exhaust gases are quenched to less than 121°C (250°F) by means of
water sprays and are scrubbed in a Venturi scrubber which normally operates
with a pressure drop of about 1.4 x 10  Newtons/m  (2 psi).  The incinerator
is pressurized with a forced air feed (125 percent excess air)  and is de-
signed for a heat release of 3.2 x 1010 Joules/hr (30 x TO6 Btu/hr).   There
are two spray nozzles at the bottom of the incinerator for introducing
wastes and a gas burner at the pilot flame level.  The quantitative rate at
which supplementary fuel gas is used can be adjusted to obtain  desired tem-
peratures.  Ordinarily, the incinerator is operated at 871°C (1600°F).  The
residence time in the combustion chamber is 2 to 3 seconds, based  on an
exit gas volume of 1,528 actual cubic meters per minute (54,000 ACFM) at
the operating peak load.  Under normal operating conditions, the exit gas
flow rate is 764 actual cubic meters per minute (27,000 ACFM) and  the gas
                                   66

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exits at 85°C (185°F).  The residence time is reduced to 1 to 1.5 seconds
under maximum loadings.  From the Venturi, the gases pass through a
"disengager" where the scrubbing solution is separated and recycled to the
quench tower and the Venturi scrubber.  A sodium hydroxide solution is
used as make-up which also adjusts the pH to 9.5 to 10.0.

     All brine wastes from the electrolytic production of chlorine at Plant
Site Y are destroyed in an on-site incinerator.  Detailed information on
this incinerator was not available.

5.5.3.5  Miscellaneous Disposal Methods

     Miscellaneous methods which are currently in use for the disposal of
HCB wastes include resource recovery (discussed in Section 5.5.4), open-
pit burning, discharge to sewage treatment plants, and stack discharge to
the atmosphere.  Except for resource recovery, the quantity of HCB wastes
handled by these miscellaneous methods is very small.

     As at most munitions manufacturing sites, the combustible production
wastes generated at Plant Site AA, are disposed of by open-burning; the
scrap containing HCB is placed in waste cans which are covered with fuel
and burned in an open pit.  The open pit burning at this site is conducted
under a State permit.

     At Plant Site AE wastewater from the clean-up of equipment used for
pesticide formulation enters a local sewage treatment plant which discharges
its treated effluent to a receiving water.  Beacuse of the refractory (resis-
tant to biodegradation) nature of HCB/ ' it is doubtful that biological
treatment per se can result in destruction of HCB in wastewaters.

     At Plant Site T, a small  amount of HCB (25 kg/year or 55 Ib/year)
which originates from the use  of impure raw material  (see Sections 5.2.3
and 5.2.12) is emitted to the  atmosphere through stack discharges.
                                    67

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5.5.4  Resource Recovery

     If a waste can be processed to recover energy or salable products,
or If it can be directly used as a chemical feedstock in the production
of commercial products, such resource recovery methods would be preferred
to waste disposal such as incineration aimed solely at the destruction of
organic wastes or landfilling.   Table 21 lists a number of resource recovery
methods which are currently used in connection with processing HCB-containing
wastes.  Because of the proprietary nature of the resource recovery opera-
tions currently in use, detailed information could not be obtained on raw
material requirements, operating conditions, system efficiencies, and costs
associated with various resource recovery methods.  In general, the appli-
cability of a specific resource recovery method to the processing of HCB-
containing wastes would be dependent on the waste characteristics (HCB con-
centration, nature of other constituents, and total  waste quantity) and
should be evaluated on a case-by-case basis.  As indicated in Table 21, at
two Plant Sites (A and AF) HCB  is recovered for sale from processing HCB-
containing wastes generated in  the manufacturing of chlorinated solvents.
The recovered HCB is now largely used as a peptizing agent in the manufac-
ture of nitroso and styrene rubber for tires.   The incineration system at
Plant Site 6 reportedly effects 99.94 percent destruction of HCB and recovers
hydrochloric acid as a by-product.   At Plant Site L, the  wastes from chlori-
nated solvent production are used as a raw material  in a  process for the
production of freon.  The freon process apparently includes recovery of
HC1  as a salable product.   The  inorganic waste from freon production
operations (silica gel, metallic salts, etc.)  are encapsulated  in concrete
in a landfill.

5.6  ULTIMATE DISPOSAL TECHNOLOGY CLASSIFICATION AND EVALUATION

     The technology of waste disposal  for the  management  of hazardous  wastes
is often described on the  basis  of the following classification standards:
     Level  I  Technology:     The  typical  broad  average  practice  for the
                            industry or product group  (i.e.,  prevalent
                            practice).
     Level  II Technology:    The  best technology available in  current
                            commercial  practice.
                                    68

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                                 TABLE 21
               RESOURCE RECOVERY METHODS FOR PROCESSING HCB
                            CONTAINING WASTES
   Resource Recovery
        Method
Plant Site Where
  Method Used
Quantity of HCB
     Handled
metric tons/year
  (tons/year)
Recovery of HCB for sale
from chlorinated solvent
wastes


Use of recovered HCB for
seed treatment
Use of recovered HCB
in the manufacture of
synthetic rubber
 Incineration including
 recovery of HC1
Use in production of
freon, including HC1
recovery
 A

 AF
 Seed treatment
 houses
 Data not
 available
   190 (210)

    50 (55)


   6.2 (6.9)



   190 (210)




   680 (750)*



   Not available
      This method is also scheduled for use at Plant Sites H and I which
generate 770 metric tons (850 tons) and 317 metric tons (350 tons) of HCB
waste, respectively.
                                    69

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     Level III Technology:  Technology currently known and assessed
                            as providing adequate health and environ-
                            mental protection.
Depending on the technology and the nature of the industry or specific waste
stream, in some cases the three levels of technology may be the same or
there may not be significant differences between Level I and Level II, or
Level II and Level III technologies.

     The quantitative data on the prevalence of various methods used for the
disposal of HCB wastes are presented in Table 18 and were discussed in
Section 5.5.3. Land disposal and incineration appear to be of equal preva-
lence from the standpoint of the total number of sites using each of the
two disposal methods.  However, based on the quantity of HCB waste handled,
a greater quantity of waste (56.0 percent of the total) is disposed of on
land, as compared to that destroyed by incineration (43.9 percent of the
total).  When the land disposal method is subdivided and considered as
four separate technologies (sanitary landfill, industrial  landfill, deep
well injection and drying pond), and the incineration is considered as
technologies with and without by-product recovery,  incineration without
by-product recovery (but with emission control) is  the most prevalent
method in terms of its usage at different plant sites.   In terms of the
quantity of HCB wastes handled, however, a greater  quantity of HCB wastes is
handled by industrial landfills than by an other single disposal method.
The industrial landfills at Plant Sites B and C are designed and operated
with due consideration to abatement of environmental  contamination.  The
subsurface structure at the sites includes impermeable strata which are
considered adequate to prevent groundwater contamination.   Subsequent to
waste deposition, the wastes are covered with 1.2 to 1.8 meters (4 to 6 feet)
of soil with a 0.025-centimeter (10-mil) thick polyethylene film placed
approximately at the mid-depth of the soil cover.

     Incineration with emission control and by-product recovery is considered
to correspond to both Level  II and Level III  technologies  as defined above.
The incinerator at the Plant Site G is reported to  effect  99.94 percent des-
truction of HCB and to permit recovery of HC1  as a  by-product.   The system
is of a large capacity and handles about 680 metric  tons (750 tons) per year

                                    70

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of HCB.  Based on the very limited data which are available on the operation
of this particular incinerator, the applicability of the system for handling
smaller quantities of HCB wastes (at other production sites) cannot be deter-
mined.  The incinerator used at Plant Site E handles 7,112 metric tons (7,350
tons) per year of tars containing 314 pounds of HCB.  Based on the stack
monitoring data presented in Section 5.5.3 for this incinerator, emissions of
HC1, CO, NOX, C12 and participates are estimated at 0.002, 0.001, 0.005,
0.0002, and 0.003 kg/kg of tar input, respectively.

     Table 22 summarizes the technology levels identified for the disposal
of HCB wastes.  The technology classification levels identified in this
table are subject to certain limitations which should be considered in
interpretation of the data and in developing regulations for the control
of HCB wastes.  The wide variety of systems which are in current use for
the disposal of HCB-containing wastes reflect the differences in:  (a) waste
stream characteristics; (b) manufacturing and formulating methods; (c) size
and geographic location of the plants; and (d) applicable environmental reg-
ulations.  Because of the differences in waste quantities of characteristics
and in plant locations and operations, it is almost impossible to arrive at
a "broad average" HCB waste disposal method representative of the current
practice at a "typical" plant.   An equally impossible task is to define or
prescribe a disposal system which would be applicable to the management of
wastes at all HCB waste generation sites.   At some large chemical  production
facilities or at off-site disposal sites,  HCB wastes are only a very small
portion of the total waste handled.   In such facilities, the management of
waste from a specific production operation Is not usually an isolated
problem requiring a separate solution, but rather an element in the  total
waste management plan for the facility.

5.7  WASTE HANDLING AND DISPOSAL COSTS

     Not all  industries and waste disposal  facilities which  were contacted
in this  survey furnished information on  the costs for handling  and disposal
of HCB wastes.   In some cases where  cost data were supplied, the information
                                   71

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                                 TABLE 22
                      DISPOSAL TECHNOLOGY CLASSIFICATION
Technology
  Level
                     Technology
 Level I
Industrial landfills with a 1.2 to 1.8 m (4 to 6 ft) of
soil cover and a 0.025 cm (10-mil) thick polyethylene
film placed approximately at mid-depth of the soil cover
(based on the quantity of HCB handled)

Incineration without by-product recovery but with
emission control (based on the prevalence of number of
sites)
 Level II
 and
 Level III
Incineration with emission control  and by-product
recovery
                                    72

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was fragmented and Inconclusive.  Some of the companies and waste disposal
facilities indicated that although they can probably provide data on their
overall cost of waste handling and disposal, they cannot break down the
cost to arrive at any meaningful estimate of the portion of the cost which
can be attributed to the handling of HCB waste which accounts for a small
fraction of the total waste handled.

     Table 23 presents the cost charged to waste generators by four off-
site waste disposal contractors employing landfill, incineration and deep-
well injection.  The data indicate a disposal fee ranging from $22 to $35
per metric ton ($20 to $32 per ton) of HCB-containing wastes.  The range
in the disposal fee is understandable in the light of differences in the
quantities of waste handled, method of disposal, haul distance, and labor
costs in different locations.

     Table 24 presents the very limited data which were furnished by two
Plant Sites (B and E) on on-site waste disposal by landfill and incinera-
tion.  The $T1 per metric ton ($10 per ton) operating cost at Plant Site B
includes costs for the operation of pretreatment lagoon, removal and trans-
port of waste from the lagoon to the landfill site and equipment maintenance.
No data were available on the cost of lagoon construction, and value of
land used for lagooning and landfill ing.   The waste which is incinerated at
Plant Site E is a chlorinated solvent waste containing a very small con-
centration of HCB (10-40 ppm).

     The most comprehensive cost data collected in this study are for the
ethylene dichloride (EDC) waste concentration and storage facility at Plant
Site D (see Figure 2 for schematics of the operation).  The system handles
8,833 metric tons (9,750 tons) per year of waste containing 40 ppm of HCB.
The concentrated tar is hauled by tank trucks to Plant Site E for incinera-
tion.  A breakdown of the cost for the EDC concentration and storage system
are shown in Table 25.  The system was installed in 1967, and the cost data
are in 1967 dollars.
                                    73

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                                                TABLE 23
                               COSTS FOR OFF-SITE DISPOSAL OF HCB WASTES
     Disposal Method
           and
   Disposal  Contractor
Source of Waste
 (Plant Site)
    Quantity
metric tons/year
  (tons/year)
$/metric ton ($/ton)
    of HCB Waste
$/metric ton ($/ton)
       of HCB-
  Containing Waste
Landfill:  OC-1
Landfill:  OC-4
Deep Well Injection: OC-3
Incineration:  OC-5
      F,Q
                     188 (208)
                     680 (750)


                     47 (52)
    371  (408)
                   $57 ($52) [$33 ($30)
                   for users fee, and
                   $24 ($22) for con-
                   tainer rental]
                   $40 ($36)
                      $35 ($32) [$20 ($18)
                      for users fee, and
                      $15 ($14) for con-
                      tainer rental]
                       $30  ($27)
                                         $22 to $33  ($20  to
                                         $30)  for  all  chlor-
                                         inated solvent wastes
                                         including those
                                         containing  HCB.
                      $22  ($20) for all
                      chlorinated solvent
                      wastes
     * Data are for 1971  operation and the costs were adjusted to 1975 dollars assuming
an escalation factor of 8%  per year.

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                                TABLE 24
                COSTS FOR ON-SITE DISPOSAL OF HCB WASTES
Plant
Site
B
E
Disposal
Method
Industrial
Landfill
Incineration
metrl c
tons/year
1 tnn*i
734 (810)
142 (157)
Costs
Operating Cost: $11 /metric ton
($10/ton) of HCB waste
$2,000,000 investment cost for
incinerator
                                TABLE 25
           COSTS FOR EDC TARS CONCENTRATION AND STORAGE SYSTEM
                     AT PLANT SITE D (SEE FIGURE 2)
Major Equipment

     EDC Tar Stills (S-104A and B)
     Tar Still Column and Condenser (C-104)
     Transfer and Loading Pumps
     Tars Storage Tank (T-405)

          1967 Major Equipment Cost

Installed Cost (Estimated:  3X Major Equipment Cost)


Utilities Requirements

     Steam (1.03 x 106 Newtons/m2 gage; 150 psig) -
     634 kg (1400 pounds) per hour

     Cooling Water - 794 liters per minute (210 gpm)

     Pumps (2) - 3.7 kW (5 hp) each

     Agitators (2) - 15 kW (20 hp) each

Maintenance (Estimated at 6% of Installed Cost Per Year)


Insurance and Taxes (1.535 of Installed Cost)


Operating Labor
1967 Cost

 $28,562
  13,294
  14,000
  15,000

 $70,856


$213,000
 $12,800


  $2,700


  $6,000
                                    75

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                                G.   REFKRENCES

  1.   National Research Council, Ocean Affairs Board. Assessing potential ocean
          pollutants.  Washington, National Academy of Sciences, 1975.  438 p.

  2.   Booth, N. H., and J. R. McDowell.  Toxicity of hexachlorobenzene and asso-
          ciated residues  in edible animal tissues.  Journal of the American Veteri-
          nary Medical Association. 166(6);591-595, Mar. 15, 1975.

  3.   Beck, J., and K.  E. Hansen.  The degradation of quintozene, pentachloroben-
          zene, hexachlorobenzene and pentachloroaniline in soil. Pesticide Science,
          5(l):41-48,  Feb. 1974.

 4.   Taylor, I. S., and F. P.  Keenan.  Studies on the analysis of hexachlorobenzene
          residues in foodstuffs. Journal of the Association of Official Analytical
          Chemists. 53(6):1293-1295,  Nov.  1970.

  5.   Siyali, D. S., and P. Strieker.  Hexachlorobenzene and other organochlorine
          pesticides in milk. Australian Journal of Dairy Technology, 28(2):55-58,
          June 1973.

  6.   Siyali, D. S.  Hexachlorobenzene and other organochlorine pesticides in human
          blood.  Medical Journal of Australia, 2(19):1063-1066, Nov. 4, 1972.

 7.   Burns, J. E., and F. M. Miller. Hexachlorobenzene contamination: its  effects
          in a Louisiana population.  Archives of Environmental Health, 30(l):44-48,
          Jan.  1975.

 8.   Hexachlorobenzene (HCB) emissions in Geismar, Louisiana vicinity, 4 June 73;
          status report.  [New Orleans], Louisiana Air Control Commission and
          Louisiana Division of Health Maintenance and Ambulatory Patient Services,
          1973. 33 p.  (Unpublished report.)

 9.   Mumma,  C.  E., and E. W. Lawless [Midwest Research Institute].  Survey of
          industrial processing data.  Task I-hexachlorobenzene and hexachloro-
          butadiene pollution from chlorocarbon processes; final report.  Washington,
          U.S.  Environmental Protection Agency, Office of Toxic Substances, June
          1975. (Distributed by National Technical Information Service,  Springfield,
          Va.,  as  PB-243 641.)

10.   1975 directory of chemical producers - United States of America.  Menlo  Park,
          Calif., Stanford Research Institute,  Chemical Information Services, 1975.
          1050  p.
                                       76

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11.   Farm chemicals handbook - 1972.  Willoughby, Ohio, Meister Publishing Co.,
          1972.  424 p.

12.   Dun & Bradstreet million dollar directory - 1975.  New York,  Dun & Bradstreet,
          Inc., 1975. 7089 p.,  app.

13.   Oil, paint and drug reporter.  1975-76 OPD chemical buyers directory.  63d ed.
          New York, Schnell Publishing Company, Inc., 1975.   1616 p.

14.   Personal communication.  B. Cohen, Dover Chemical Company, to S.  Quinlivan,
          TRW Systems, Inc., Sept. 19, 1975.

15.   Personal communication.  Mr. Schultz,  Hummel Chemical Company, to
          M. Ghassemi, TRW Systems, Inc.,  Dec. 4, 1974.

16.   Personal communication.  B. Cohen, Dover Chemical Company, to S.  Quinlivan,
          TRW Systems, Inc., Feb. 7, 1975.

17.   Data supplied to TRW Systems, Inc., by Stauffer Chemical Company in connec-
          tion with EPA Contract 68-01-2919:  Gruber, G. I., and M.  Ghassemi.
          Assessment of industrial hazardous waste practices,  organic chemicals,
          pesticides and explosives industries. Washington, U.S. Environmental
          Protection Agency.  (In preparation; to be distributed by National Technical
          Information Service, Springfield, Va.)

18.   Personal communication.  H. E.  Everson,  Diamond Shamrock Corporation,
          to S. Quinlivan,  TRW Systems, Inc., July 8, 1975.

19.   Personal communication.  J.  D.  Lunn, Jr., Continental Oil Company, to
          S. Quinlivan, TRW Systems, Inc., Mar. 5, 1975.

20.   Personal communication.  A. Jordan, Kilgore Corporation, to S. Quinlivan,
          TRW Systems, Inc., Feb. 19,  1975.

21.   Personal communication.  D. Maley, Longhorn Army Ammunition Center, to
          S. Quinlivan, TRW Systems, Inc., Feb. 21, 1975.

22.   Personal communication.  Mr. Fitch, Crane Naval Ammunitions Center,  to
          S. Quinlivan, TRW Systems, Inc., Feb. 15, 1975.

23.   Personal communication.  B.  Rollins, Dept. of Food and Agriculture,  State of
          California, to S. Quinlivan, TRW Systems, Inc., Feb. 25, 1975.
                                      77

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24.  Standard & Poor's register of corporations, directors and executives.  New
         York, Standard & Poor's Corporation, 1975.  3 v.

25.  Personal communication.  Mr. Hanson, ICI America, to S.  Quinlivan,  TRW
         Systems, Inc.,  Feb. 28,  1975.

26.  Personal communication.  Messrs. Vlacos and Gilbert, Vulcan Materials Com-
         pany, to S. Quinlivan, TRW Systems, Inc., July 7, 1975.

27.  Personal communication.  B. Walker, Reichhold Chemicals, to S. Quinlivan,
         TRW Systems, Inc., Feb. 21, 1975.

28.  Personal communication.  C. F.  Buckley,  Monsanto Company, to S. Quinlivan,
         TRW Systems, Inc., Feb. 24, 1975.

29.  Personal communication.  Sonford Chemicals Company, to S. Quinlivan,  TRW
         Systems, Inc.,  Feb. 24,  1975.

30.  Personal communication.  C. Bests, J. H. Baxter Company,  to S. Quinlivan,
         TRW Systems, Inc., Feb. 1975.

31.  Personal communication.  D. Nicholas, Honolulu Wood Treatment Company, to
         S. Quinlivan, TRW Systems, Inc., Feb. 10, 1975.

32.  Personal communication.  Mr. Raleigh,  Stackpole Carbon Company, to
         S. Quinlivan, TRW Systems, Inc., Feb. 11, 1975.

33.  Personal communication.  R. Newman, Carborundum Corporation,  to
         S. Quinlivan, TRW Systems, Inc., Feb. 13, 1975.

34.  Personal communication.  F. Fier, AirCo-Speer Corporation, Niagra Falls
         Research Center, to S. Quinlivan, TRW Systems, Inc., Feb. 11, 1975.

35.  Personal communication.  Mr. O'John, Keystone Carbon  Company, to
         S. Quinlivan, TRW Systems, Inc., Feb. 11, 1975.

36.  Personal communication.  Mr. Konitzer, Helwig Carbon Products,  to
         S. Quinlivan, TRW Systems, Inc., Feb. 11, 1975.

37.  Personal communication.  G. von Bodungen, Louisiana State Department of
         Health,  to S. Quinlivan,  TRW Systems, Inc., July 8,  1975.
                                      78

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38.  Farmer, W. J.  A study of volatilization and vapor phase transport of hexa-
          chlorobenzene from industrial wastes deposited on land; progress report -
          Jan. 16, 1975-Apr.  13, 1975.  Cincinnati,  U.S.  Environmental Protection
          Agency, Solid and Hazardous Waste Research Laboratory, 1975.  13 p.
          (Unpublished report.)

39.  Baum, B.,  and C. H. Parker.  Solid waste disposal,  v. 1.  Incineration and
          landfill. Ann Arbor, Mich., Ann Arbor Science Publishers, Inc., 1973.
          397 p.
                                       79

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           7.   APPENDIX
             TABLE A-l
KEY TO PLANT SITES, THEIR LOCATIONS
       AND SOURCES OF WASTES
1 Plant Site
Designation
A
"
c
D
E
F
IG
R
1
J
K
L
M
N
0
P
Location
(State)
Ky.
La.
Ks.
La.
La.
Tx.
La.
Tx.
Ca.
La.
W.V.
Tx.
W.V.
Al.
N.Y.
La.
Operations Producing or Likely to I
Produce HCB Waste [
Chlorinated solvents production E
Chlorinated solvents production; electro- jj
lytic chlorine production E
P
L
Chlorinated solvents production; PCP pro- E
duction; electrolytic chlorine I
production f
Chlorinated solvents production; VCM ;
production '
Chlorinated solvents production; electro- !
lytic chlorine production; sodium chlorate
production
Chlorinated solvents production; electro-
lytic chlorine production
Chlorinated solvents production; electro- 1
lytic chlorine production; VCM production |
Chlorinated solvents production; electro- |
lytic chlorine production; VCM production jj
Chlorinated solvents production; electro- 0
lytic chlorine production n
Chlorinated solvents production; electro- 3
lytic chlorine production; VCM production |
Chlorinated solvents production; electro- I
lytic chlorine production |
Chlorinated solvents production; electro- |
lytic chlorine production i
Chlorinated solvents production B
Chlorinated solvents production; electro- jj
lytic chlorine production |
Chlorinated solvents production 3
Chlorinated solvents production; electro- •
lytic chlorine production; sodium chlorate |
production |
                80

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             TABLE A-1
KEY TO PLANT SITES, THEIR LOCATIONS
  AND SOURCES OF WASTES (CONT'D)
Plant Site
Designation
Q
R
S
T
U
V
W
X
Y
Z
AA
AB
AC
AD
AE
AF
Location
(State)
Tx.
Al.
Pa.
{La.
Nv.
•Oh.
Al.
Wa.
J0r.
P.R.
Tn.
Or.
Ms.
Ca.
N.Y.
Oh.
Operations Producing or Likely to
Produce HCB Waste
Pesticide production
Pesticide production
Pesticide production
Pesticide production
Electrolytic chlorine production
Electrolytic chlorine production
Electrolytic chlorine production
Electrolytic chlorine production
Electrolytic chlorine production
Chlorinated solvents production
Ordnance and pyrotechnics production
Sodium chlorate production; electrolytic
chlorine production
Sodium chlorate production
Seed treatment chemicals formulation
Pesticide production; electrolytic chlorine
production; sodium chlorate production
HCB production; PCP production
                81

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                     TABLE A-2
KEY TO OFF-SITE WASTE DISPOSAL CONTRACTORS HANDLING
           HCB WASTES, THEIR LOCATIONS
              AND PLANT SITES SERVED
Contractor
Disposal Site
Designation
OC-1
OC-2
OC-3
OC-4
OC-5
OC-6
Location
(State)
Ky.
Tx.
Tx.
La.
Tx.
N.Y.
Waste Disposal
Method Used
Sanitary landfill
Industrial landfill
Deep well injection
Industrial landfill
Incineration
Incineration
Plant
Site(s)
Served
A
Q
F
G
F, Q
S
                          82

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                                 TABLE A-3
               GENERAL AND HAZARDOUS CHARACTERISTICS OF HCB
 Synonym:  percnlorobenzene

 Appearance (Pure HCB):  monoclinic prisms (white needles)
 Formula:  CCC1C
                    (Q\
 Physical constants:* ;

      Molecular weight:  284.80
      Melting point:     230°C
      Boiling point:     326°C
      Flash point:       116. 7°C
      Density:            1.5        j.
      Vapor pressure:    1.089 x 10"D mm Hg,  20°C
                         1  ran Hg, 114. 4°C
      Vapor density:     9.8

 Stability:  highly stable  and unreactive; is not hydrolyzed in aqueous
             solutions(9)

 Volatility:  sublimes readily and evaporates  readily when  exposed  to  air(9)
 Vapor pressure of HCB: ^8)

           Temperature (°C)           Vapor Pressure (mm Hg)
                 15                        4.47  x ID'6
                 25                        1.91  x 10'5
                 35                        6.36  x 10"5

                 45                        2.09  x 10"4
 Heat of vaporization:   23.4
 Solubility
      (i)   in distilled water:   6.2 yg/1  at
      (ii)   in landfill  leachate:   5.1  pg/1  at 23.5°C'l
 Bioaccumulation:   accumulative  in  aquatic and terrestrial organisms^1 >

 Environmental  persistence:   resistant  to biological degradation^'9'

Experimental results on volatilization  of HCB at 25°C  through various
types of cover materials :(38)

                                                   Volatilization  Rate
                     Type of  Cover                      kg/ha/yr _
     No cover                                            317
     Polyethylene film, 0.15  ram                          255
     Soil,  1.9 cm                                         4.56
     Composite soil and polyethylene film, 1.915 cm       3.29
     Water, 1.43 cm                                       0.38
     Soil,  60 cm                                          0.13 (calculated)!
                                   83

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                              TABLE A-4
         HCB WASTE DATA REQUESTED FROM SOME INDUSTRIAL PLANTS
CHARACTERISTICS OF WASTES
1.  General Information
    a.  Quantities of HCB/HCB-containing wastes handled
    b.  Sources of waste (company and location)
    c.  Characteristics of wastes:
        •  physical description
        •  concentration
        •  chemical composition/analysis (BOD, COD, pH, etc.)
    d.  Quantities and characteristics of other types of wastes (non-HCB)
        handled (in conjunction with HCB wastes).
2.  Waste Pretreatment Facilities and Processes
    a.  Process types (sedimentation, chemical treatment, filtration,
        etc.).  Describe.
    b.  Costs associated with waste pretreatment (i.e., capital invest-
        ment costs, direct and indirect operating costs).
3.  Materials Recovered
    a.  Form, characteristics, quantities, etc.
    b.  Residues generated (quantities, characteristics)
    c.  Cost analysis of resource recovery methods:
        •  capital investment costs
        •  direct operating costs
        t  indirect operating costs
4.  Waste Handling and Storage Facilities and Methods
    a.  Description of methods and facilities
    b.  Costs associated with waste handling and storage
DISPOSAL METHODS
1.  Incineration of Wastes
    a.  Historical background (start-up date, etc.)
    b.  Type of incinerator used
                                   84

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                               TABLE A-4
     HCB  WASTE  DATA  REQUESTED  FROM SOME  INDUSTRIAL PLANTS  (CONT'D)
     c.   Process and equipment description  (copies requested,  if
         available)
         •  process flow diagram
         •  sketch or picture of incinerator layout
         •  controls schematic
         •  sampling points
     d.   Safety provisions used
       ,  •  Equipment, controls, interlocks, etc.
         •  Standard operating procedures.  Description.
     e.   Equipment or methods for controlling pollution from off-gases
         •  afterburner?  Describe.
         t  stack gas cleaning?  Describe.
         •  characteristics and treatment/disposal of scrubber solutions.
     f.   Sampling and instrumentation capabilities
         •  has any HCB been determined in burner off-gases?
         t  has any HCB been detected in other sampling positions?
     g.   Costs associated with incineration
         •  capital investment costs (i.e., equipment, facilities, land,
           etc.)
        •  direct operating costs  (i.e., power, labor, chemicals,
           equipment for related pollution abatement methods)
        •  indirect operating costs (equipment depreciation, taxes,
           insurance,  etc.)
2.   Landfill  Operations  Associated with HCB-Containing Wastes  or Residues
    a.  Site  characteristics and historical background (size,  depth,
        location,  topography, geological formation,  distance to ground-
        water, start-up  date, etc.)
    b.  Quantities of  wastes handled
                                   85

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                              TABLE A-4
    HCB  WASTE  DATA  REQUESTED FROM SOME  INDUSTRIAL PLANTS  (CONT'D)
    c.   Costs  associated with  landfill
        0  capital  Investment  costs (i.e., equipment,  land, facilities,
           etc.)
        •  direct operating costs (i.e.,  power,  labor, chemicals,
           equipment)
        t  indirect operating  costs (equipment depreciation, taxes,
           insurance,  etc.)
    d.   Disposal fee associated  with waste handling
    e.   Safety provisions:  shower, eyewash,  etc.
    f.   Registration (reporting  requirements  to  regulatory agencies)
    g.   Environmental  safeguards:   leachate collection?   monitoring
        systems, etc.
3.  Any other disposal processes associated with HCB-containing  wastes:
    deep well  injection,  lagooning, ocean dumping, etc.
    a.   Description
    b.   Cost analysis, as  above.
                                   86

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Q
to
o
                       TABLE A-5
NON-INDUSTRIAL AGENCIES CONTACTED FOR DATA ACQUISITION
Agency Naiie
EPA.
Pesticide and Toxic Effects Laboratory
Louisiana State Health Dept.
Chlorine Institute
State of California.
Dept. of Food and Agriculture
Aluminum Association of America
Midwest Research Institute
Cdgewood Arsenal
Frankford Arsenal
Plcatlnny Arsenal
Surgeon General ,
"icdical R&3 Command.
SanUary Engineering Research Branch
Crane Naval Ammunition Center
Lone Star Amy Amnunltlon Plant
Naval Ship Parts Control Center
Naval Civil Information Laboratory
Longhorn Army Amnunltlon Center
ARKCOH.
Installation and Services Group,
Rock Island Arsenal
Texas Hater Quality Board
Location
Research Triangle Park. N.C.
New Orleans. La.
New York City. N.Y.
San Francisco, Ca.
New York City. N.Y.
Kansas City. Mo.
Baltimore. Hd.
Philadelphia, Pa.
Dover, N.J.
Washington, D.C.
Crane, In.
Texarkana, Tx.
Nechanlcsburg, Pa.
'Port Huenene, Ca.
Cornak. Tx.
Rock Island, 11.
Houston, Tx.
Person(s) Contacted
J.B. Mann
G. Von Bodungen
Nr. Lowbush
Hr. Col strum;
B. Rollins
Dr. Balgord
Or. Splgarelll
A. Hlllsmeyers
Dr. P. Brody
G. Escalln
Col. L.H. Reuter
K. Wnorral ;
Mr. Fitch.
Industrial Hygenlst
J. Alexander
0. Wagner
T. Culbertson
D. Maley, Chief Engineer
T. Walsh
Chief of Environmental Group
B. Taylor
Tel ephone
(919)-549-8411
(5041-527-5115
(212J-MU2-4322
(916J-445-2742
(9161-322-5130
(212)-972-1800
(816J-561-0202
(30D-671-3133
(215)-831-6130
(201 )-328- 3906
(202)-693-8061
(812)-854-1603
(812)-854-1847
(214)-838-1626
(717)-766-8511
(865)-982-5071
(214)-679-3181
(309)-794-6244
(512)-475-2500

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