ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/1-77-009
Reconnaissance
Environmental Levels Of Nitrosamines
In The Southeastern United States
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER, :o:0RAD0 __

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Environmental Protection Agency
Office of Enforcement
EPA—330/1—?7—009
RECONNAISSANCE
OF
ENVIRONMENTAL LEVELS OF NITROSAMINES
IN THE SOUTHEASTERN UNITED STATES
August 1977
National Enforcement Investigations Center
Denver, Colorado

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CONTENTS
I. INTRODUCTION
II. BACKGROUND
1
2
III. FIELD STUDIES
Ciba-Geigy Corp
Martin-Marietta (SODYECO)
Proctor Chemical Co., Inc.
Velsicol Chemical Co.
Farmers Supply and Produce
4
4
13
18
30
32
IV. SUMMARY AND CONCLUSIONS .
REFERENCES
TABLES
35
37
1 Monitoring Site Description -
Ciba Geigy Corp. . . .
2 Monitoring Site Description -
Martin-Marietta Corp.
3 Monitoring Site Description -
Lumber Street Plant .
4 Monitoring Site Description -
Cedar Springs Plant .
5 Monitoring Site Description -
Velsicol Chemical Co.
FIGURES
. . . . . . . .
10
19
28
29
33
1 Wastewater Treatment Schematic -
Ciba-Geigy Corp.
2 General Plant Layout - Ciba-Geigy Corp.
3 Wastewater Treatment Schematic —
Martin-Marietta Corp. SODVECO Division
4 General Plant Layout -
Martin-Marietta Corp. SODVECO Division
5 General Plant Layout —
Proctor Chemical Co. Lumber St. Plant
6 General Plant Layout -
Proctor Chemical Co. Cedar Springs Plant
7 Typical Amine Reaction Sequences —
Proctor Chemical Co., Inc. Salisbury, N.C.
7
11
15
20
22
23
26

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I. INTRODUCTION
In 1976, the Environmental Protection Agency (EPA), National Enforce-
ment Investigations Center (NEIC) conducted investigations to determine
environmental levels of nitrosanhines in the Central United States.’ The
data from the investigations showed that there was little indication of
N—nitroso compounds in the air in the vicinity of the numerous sources ex-
amined, even on those occasions when these compounds were observed in
plant effluent. The water samples indicated that there were primary
sources of direct emissions to the environment of a number of N-nitroso
compounds. It was concluded that these compounds probably arose as im-
purities during the synthesis of other compounds and they were emitted to
the environment during the use or modification of these products. These
N—nitroso compounds were observed in chemical, pesticide and coke plant
effluents, some consistently.
The EPA Region IV Administrator identified potential dischargers of
nitrosanilnes in the southeastern United States, and because of the above
experience, requested that NEIC conduct air and water monitoring investi-
gations to determine if the compounds were being released to the en-
vi ronment.
The five industrial facilities monitored in April and May 1977 by
NEIC were:
1. Ciba-Geigy Corporation, McIntosh, Alabama
2. Martin—Marietta (SODYECO), Charlotte, North Carolina
3. Proctor Chemical Company, Salisbury, North Carolina
4. Velsicol Chemical Company, Chattanooga, Tennessee
5. Farmers Supply and Produce, Monticello, Kentucky

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II. BACKGROUND
Nitrosamines are a class of organic compounds containing the
N - N = 0 linkage and having the general structure
R -
R’’ - N — 0
Since Rand R’ can represent alkyl, aryl or cyclic groups, the nitro-
samine compounds have widely varying chemical, physical and toxicologi-
cal properties.
Nitrosamines are relatively stable, resisting reduction, moderate
temperature oxidation (less than 300°C) and pyrolysis at even higher
temperatures. They are very photoreactive in water or in the atmosphere.
Nitrosamines are formed naturally in moist air and in soil and
water in which secondary and/or tertiary amines and nitrites exist or
are being formed. Only two N-nitroso compounds have been produced in
significant quantities for industrial or manufacturing purposes.
Diphenylnitrosamine (DPN or N-nitrosodiphenylamine) is produced by the
rubber industry but has not proved carcinogenic to test animals. Di-
methylnitrosamine (DMN or N-nitrosodimethylamine) has been identified
as an air pollutant in Baltimore, Maryland and Belle, West Virginia.
Because 0MM has been shown to be carcinogenic to laboratory animals,
its presence as an air pollutant is cause for concern.
Following the studies of the only known primary source of the
carcinogenic nitrosamine (the FMC Corporation in Baltimore, Maryland),
investigations have turned to precursor sources, i.e. mainly sources
of secondary amines. Sources of primary and tertiary amines are of

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3
less interest if nitrosation is considered to occur via reaction with
nitrous acid in the environment. Unlike secondary amines which can
form nitrosamines, the primary aliphatic and aromatic aniines yield other
products and only a few tertiary anlines form nitrosamines. If other
reaction mechanisms are hypothesized to yield nitrosamines, e.g., with
metallic compounds, the number of possible precursors would be expanded.
However, there is no indication of measurable levels of these nitroso
compounds in environmental samples to date.
The health effects of the ambient levels reported to date are still
unknown. Of more than 100 of these N-nitroso compounds synthesized,
over 70% have been shown to be carcinogenic to some animal species. In
laboratory tests, this class of compounds has produced cancer in all -
animal species tested.

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III. FIELD STUDIES
*
Samples were collected from four of the five industrial facili-
ties to determine nitrosamine levels in both the ambient air and the
water. Air samples were collected over a 2-hr period using foil—
**
covered impingers filled with 60 ml of iN KOH. The air samples
were drawn through the impingers by a vacuum pump and the flows con-
trolled by a calibrated stainless steel hypodermic needle. Water and
wastewater samples were collected on a grab basis in amber glass quart
***
bottles with Teflon liners. The NEIC analytical procedure for ni-
trosamines is included in Appendix A.
Because the monitoring for nitrosamines was conducted on a
“screening” type basis to determine if the compounds were present,
detailed process evaluations were not made. In addition, due to the
proprietary nature of the processes, Company ‘personnel were reluctant.
to discuss processes or the types and amounts of materials used. In
several plants, N-nitroso compounds were found in wastewater samples;
in-plant sampling would be required to locate th& sources of these
compounds. With the exception of one sample at Ciba—Geigy Corporation,
N-nitroso compounds were not detected in the air samples.
CIBA-GEIGY CORPORATION
The Ciba-Geigy Corporation is an international organization which
* Samples were not collected from Farmers Supply and Produce.
** Impingers covered with foil to prevent photoreaction.
Teflon is a trade name.

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5
originates, manufactures and markets organic chemical specialties. The
McIntosh plant began operating in 1952 and produced only DDT. In the
early 60’s, DDT production ceased after newer and more effective in-
secticides were developed.
The McIntosh plant, one of the larger Ciba-Geigy facilities, pro-
duces more than 75 different products including agricultural chemicals,
dyestuffs, plastics and additives, and sequestrene products. Herbicides
include Triazine and Fluometuron; the basic insecticides manufactured
* *
are Diazinon, Spectracide, and Chlorobenzilate. Fluorescent whitening
agents are manufactured for detergents, and other optical brighteners
are produced for use in the textile and paper industries. The plant
operates 24 hr/day, 7 days/week.
Water Supply and Wastewater Treatment
Water used for cooling purposes is pumped to a large reservoir from
the Tombigbee River, and then pumped to the plant and used on a once-
through basis. The spent cooling water is returned to the river via
National Pollutant Discharge Elimination System (NPDES) Outfall 001; the
flow is variable, but averages 7.6 x 1O 4 m 3 /day (20 mgd).
Approximately 2.3 x l0 m 3 /day (6 mgd) of water is withdrawn from
the reservoir, clarified, filtered, and demineralized, and used for
boiler make-up. An additional 2.3 x 1O 4 m 3 /day is pumped from five
wells. The pH is adjusted with soda ash, the water is degassified and
chlorinated, and then is used in the processes and also as the potable
supply.
* Trade name.

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6
All process wastewater is collected in segregated sewers and dis-
charged to one of three treatment systems [ Figure 1]. Some process
wastewaters are collected in a common sewer and flow to an equaliza-
tion pond. An auxiliary pond, located upstream of the equalization
pond, receives process wastewaters high in ammonia; this wastewater is
released into the equalization pond under controlled conditions be-
cause the treatment system does not reduce the ammonia. This method
is used to bring the effluent into compliance with the NPDES limita-
tions for ammonia.
After equalization, the wastewater is neutralized, aerated for
10 days, and then polished an additional 5 days in another aerated
lagoon. Finally, the wastewater is clarified, neutralized, and dis-
charged through Outfall 001.
Wastewater from the Diazinon process and wastewaters containing
cyanide are discharged to the detoxification system. The acidic
wastewaters flow to the destruct basin for mixing purposes. After 20
*
days, the flow is sent to the alkaline chlorination system for CN
destruction. After detoxification, the wastewater is sent to the
equalization pond.
Dilute process wastewaters, designated by the Company as slightly
contaminated, along with stormwater runoff and water from the cascade
coolers, flow to a large holding pond. Since the dilute wastewater is
slightly acidic, spills are routed to the holding pond and mixed with
dilute wastewater. The spilled materials are less stable in an acid
environment.
* This system installed for plant upsets and is not required under
normal operating conditions. Acidic wastewaters are not mixed with
wastewaters containing cyanide.

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7
WA TC TWM
wig.AK A IO
A L LU
FIGURE 1
3A ve3
S64.l FRbM
sUE.Q W*TLL
r&eATMeN V
CIBA-GEIGY CORPORATION
McINTOSH, ALABAMA
WASTE WATER TREATMENT SCHEMATIC
0.2 .5 Acre
C RD U J D
0
r — — — — — — —
41 1 _____.*
— — E GUP Soi..to
TO
C TA W8*.

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8
All wastewaters combine with the spent, once—through cooling water,
and flow to the river, about 1.2 km (0.75 mi) from the treatment area.
Sanitary wastewaters are treated in 9 extended aeration package
plants which discharge to the equalization pond. The package plants
are designed to treat a total of 187 m 3 /day (49,500 gpd).
Solid Waste Disposal
The Company’s policy is that solid wastes are not to be removed
from the property for disposal or treatment. All flammable material,
toxic and nontoxic, is burned in a multipurpose, gas—fired incinerator
equipped with primary and secondary burners. Emission control equip-
ment consists of a water quench tank followed by a high-energy venturi
water scrubber and a packed tower using a caustic scrubbing solution.
Nonburnables are buried in a landfill located on the northeast section
of the property. The site has been classified by the State as accept-
able for hazardous and toxic wastes.
Processes
There are more than 25 processes, all batch operated. Products
from this facility include Diazinon, herbicides, thioherbicides,
atrazine, sequesterines and whitening agents. Raw or intermediate
materials containing amines used in their processes include:
Monoethyl amine
Isopropylamine
Secondary butylamine
n-methyl ethanol amine
Cyc 1 opropyl methyl —n-propyl amine
Propyl amine
Ethylene diamine
Anal me

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9
Morphal me
Di methyl amine
Tn ethanol amine
Di ethanolami ne
Meta amino benzo trifluoride
Diaminostilbene disulfonic acid
Diethylenetriami ne
Ami noethyl ethanol amine
Pyrrol idine
Other amines considered proprietary
These compounds are all active ingredients, but are not used all
the days the plant is operating. However, during the NEIC monitoring
period, processes using amines were operating. According to plant
personnel, the only nitrating agent used by the facility is sodium
nitrite for one of their brightener reactions. This agent is used
periodically. Insignificant quantities of nitric acid are used through-
out the plant; ammonia is used on—site for refrigeration and other
processes.
Monitoring Results
Monitoring was conducted on May 25, 1977; a description of the
air and water monitoring sites is given in Table 1 and shown in Figure 2.
The air speed varied between 4.8 and 16 km (3 and 10 mi)/hr, and the
wind was mainly from the southwest. The temperature during the monitor-
ing period was between 85° and 90°F; the sky was cloudy.
Nitrosamines were not detected in the untreated or treated well
and river water samples nor in the ambient air samples collected at
the east, north, and west monitoring sites. In the grab sample collected
*
from the treated wastewater effluent, 0.05 ugh dimethylnitrosamine
**
(DMN) and 0.63 pg/i nitrosopyrrolidine (NPyr) were detected. A mass
* Detection limit - 0.05 pg/i.
** Detection limit — 0.1 jig/i.

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10
Table 1
MONITORING SITE DESCRIPTION
CIBA-GEIGY CORPOR4TION
Mclntoeh, Alabc na
Sample Description Site Location
Untreated well water Well water surn , next
to degassifier, Drior
to degassification
Treated well water Primary pump station
Untreated river water Punp house at reservoir
Treated river water Clear well, east of
filtration niant
Treated wastewater effluent Effluent ditch, about
1/4 mile from river,
at bridge
Air - south of processes Ditch on south side of
plant at fence line
(around level)
Air - east of processes Roof of filtration building
Air - north of processes North side of chanqe room
#8 (ground level)
Air - west of processes North side of Brown and
Root iuard shack (qround
level

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c nn ouor,’8 0’
K
K
K
K
I I
L..J
Ii ’
K
K
I
K
M
K
FRo ES9Es
l a s
— — - — — — — — — — — — — —. — —
FIGURE 2 -‘
CIbA-GEIGY CORPORATION GENERAL PLANT LAYOUT
McINTOIH, ALAbAMA
TO WP TfW4 Til
Tt .ArM&,.r
$Y TEM
LI
PLANT
• AIR MONITORING SITE
-J

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12
*
of 0.02 pg DMN was detected in the air sample collected at the south
monitoring site. However, these levels were too low to be confirmed by
mass spectrometry. An unidentifiable nitrosamine was also detected in
the wastewater effluent, but in a lesser concentration than NPyr.
Since the intake waters did not contain nitrosamines, the source of
the N-nitroso compounds in the effluent must have originated in the
processes. The process wastewater comprises about 12% of the total
effluent flow of 93,000 m 3 /day (24.5 mgd). If the N-nitroso compound
concentrations are assumed to be constant in the effluent, then the
concentrations of DMN and NPyr in the process wastewater would be as
high as 0.42 and 5.3 pg/l, respectively.
The wind direction during monitoring was variable, but mainly from
the southwest. The DMN was detected in the air sample upwind of the
processes. Olin Chemical is located about 0.8 km (0.5 ml) south of the
Ciba-Geigy facility; however, whether the nitrosamine originated from
Olin, or Ciba-Geigy, is not known. Approximately 472 liters of air was
drawn through the impingers [ Appendix B - sample volumes], therefore,
the concentration of DMN was 42 ng/m 3 which is in the range of 40 to 300
ng/m 3 found at Baltimore, Maryland and Belle, West Virginia. 2 ’ 3 Based on
the one positive sample, it cannot be concluded that nitrosamines are
present at low levels or are ubiquitous in the plant’s environment. It
is equally incorrect to infer that nitrosamines are not present based on
the three negative samples. The negative results at the other three
sites indicate that: 1) nitrosamines are not emitted, 2) nitrosamines
were not emitted during sampling, 3) once in the atmosphere these com-
pounds decomposed rapidly, or 4) the compounds were present, but
not collected by the impingers due to environmental conditions. How-
ever, DMN is a known carcinogen to laboratory animals, therefore its
* Detection limit (in air sample) - 0.02 pg.

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13
presence indicates some degree of risk and Ciba-Geigy should take action
to eliminate the emission of nitrosamines. Since only a screening type
of monitoring was conducted, the maximum levels or sources, of N-nitroso
compounds emitted, cannot be determined. Ciba—Geigy personnel collected
air samples concurrently with NEIC; therefore, they have the monitoring
and analytical capability to determine sources and atmospheric levels of
nitrosamines.
MARTIN-MARIETTA (SODYECO )
The SODYECO Division of Martin-Marietta Corporation began manufac-
turing liquid sulfur dyes for the textile industry in 1936; the Company
was known as Southern Dyestuff Company. SODYECO now produces over 200
organic chemical compounds and textile dyes. There are between 30 and
40 organic chemicals produced, including pesticides. The pesticides are
prepared under contract to other companies while the dyestuffs are
prepared for general sales.
The plant is located on 182 ha (450 acres) on the east side of the
Catawba River and south of highway 27 in Mt. Holly (NW of Charlotte).
Approximately 12 to 14 ha (30 to 35 acres) of the site is dedicated to
manufacturing processes and supportive facilities. An additional 12 to
14 ha consists of lagoons for process wastewater treatment.
The plant operates 3 shifts, 7 days/week. There are approximately
190 processes used at the plant, all of which are batch operated. The
average production capacity is rated at 333,000 kg (734,000 lb)/day of
finished product.
Water Supply and Wastewater Treatment
All water used in the plant for domestic purposes is obtained from

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14
wells; the water is not treated. Process water and cooling water is
withdrawn from the Catawba River, coagulated and filtered.
Sanitary wastes are discharged to various septic tanks throughout
the plant; septic tank effluent is discharged to the process alkaline
wastewater sewers.
All process wastewaters are treated prior to discharge to the
Catawba River. The single outfall is authorized by a Federal NPDES per-
mit; currently the effluent complies with all of the limitations except
BOD. BOD limitations are generally met during the warmer months.
There are three process wastewater streams: the thiosulfate waste
stream, the weak acid stream, and the alkaline waste stream [ Figure 3].
The thiosulfate waste stream is collected in a holding pond and then
sent to a aerated lagoon where the wastewater is biologically converted
to 1% I-1 2 S0 4 and sodium thiosulfate at pH 1 to 2. The weak acid stream
is collected in two lagoons; the biologically converted effluent is
combined with the effluent from weak acid lagoons and neutralized with
ground limestone in a concrete basin. The neutralized effluent is sent
to a 6.9 ha (17 acre) lagoon and the gypsum settled. The supernatant
from the 6.9 ha lagoon is combined with the alkaline waste stream and
sent to a flow equalization and aeration basin. The flow is then
routed to an extended aeration-activated sludge lagoon; sludge is
settled in a steel Permutit Company clarifier. Post settling and post
aeration lagoons follow the clarification process. After final settling,
the effluent is discharged to the Catawba River, about 0.54 km (0.33 mi)
downstream from the final settling lagoon. The flow averages 7,570
rn 3 /day (2 rngd). The EPA has provided a grant to the Company to help
fund this treatment system.
All herbicide wastewaters are incinerated. The incinerator is
operated only when the holding tank for the wastewaters becomes full.

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15
FIGURE 3
MARTIN MARIETTA CORPORATION
SODYECO DIVISION
CHARLOTTE, N. CAROLINA
WASTE WATER TREATMENT SCHEMATIC
5LUP4e
FROM
•1 OX I C.
wkrea.
‘.0 £%VE
PIU)Tt EFcL.

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16
The incinerator is fired with No. 2 fuel oil; it is equipped with once-
through, dilute caustic spray scrubber with two packed sections. The
spent caustic is sent to the wastewater treatment system.
Processes
Of the more than 190 processes, secondary amines are used in only
5 major process reactions; the end products are either sent out of the
plant as finished product or used in other plant processes. There are
also at least 25 other processes which use tertiary amines in the re-
actions. Company personnel stated that all of the reactions are pro-
prietary, therefore only a general description was provided with the
emphasis on the possibilities of amines being emitted to the air or
discharged in the wastewater.
There is a possibility of nitration of secondary amines released to
the environment because one of SODYECY’s specialties is nitration.
According to Company personnel, the adjacent industries do not use
nitric acid, nitrogen compounds, or secondary amines.
The 5 reactions using secondary amines are discussed briefly:
1. Di—n-propylamine. This amine is very volatile and the reaction
is conducted in a closed system. Safety valves and pop valves are
vented directly to the atmosphere. The amine attaches to the benzene
ring and becomes part of the product, Oryzalin, a powdered herbicide.
During the process, the product is filtered. The liquid filtrate
is sent to the incinerator. Other wastewaters generated in the process
before the herbicide becomes active are sent to the treatment ponds.
The flow, about 115 m 3 /day 30,000 gpd), could contain amines.

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17
The process(s) using this amine was operating during the monitoring
period.
2. n-cyanoethylorthochloroanaline. This amine is used as a coupler
in the production of a dispersed dye. Between 5 and 10% of the final
product consists of this amine. Since the emission sources from the
reaction train are not equipped with control devices, the possibility
exists that the amine may be emitted.
During the reaction, wastewater is discharged to the treatment
system; the majority of the flow originates from the plate and frame
filter press. The total flow is unknown, but is highly variable.
The process was operating up to the day of NEIC’s monitoring, but
was down on the monitoring day.
3. Diphenylamine. The amine is used in the production of sulfur
dyes. The off-gases from the reaction are vented to the atmosphere.
Filtrate, approximately 11 m 3 /day (3,000 gpd) from the plate and frame
filters, is sent to the treatment system. Since the process reaction
occurs at 0°C and the amine has a low vapor pressure, emissions to the
air are not probable.
The process was operating during NEIC’s monitoring.
4. Parahydroxyphenylamine. The amine is added in a rotary thionator
(closed system) in the production of dyes. The reaction occurs in a
high temperature ball mill; the off-gases are vented to caustic absorbers.
The spent absorbent is used in other process reactions and not discharged.
Thereare no wastewater streams from this process.
This process was operating during NEIC’s inspection.

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18
5. Carbazole. This low vapor pressure amine is used as a raw
material in several reactions, including the production of sulfur dyes
and organic chemicals. Company personnel stated that this amine could
possibly be emitted and also discharged in the wastewater stream.
The material was being used during NEIC’s monitoring.
Monitoring Results
Monitoring was conducted on May 5, 1977; a description of the air
and water monitoring sites is given in Table 2 and shown in Figure 4.
The air speed varied between 8 and 24 km (5 and 15 nii)/hr and the wind
was mainly from the southwest. The temperature was 75°F. Sky con-
ditions were clear; however, it had rained 0.11 inches overnight.
Nitrosamines were not detected in any of the ambient air samples
nor in the untreated well and river water samples. In the grab sample
*
collected from the treated wastewater effluent, 13 pg/l dipropylnitro-
samine (DPN) was detected, and confirmed by mass spectral analysis. This
amine probably originated in the process making Oryzalin. At this low
level concentration, DPN would not be detected in the Catawba River.
PROCTOR CHEMICAL COMPANY, INC .
In 1938, the Proctor Chemical Company was founded by Edward C.
Proctor. The Company became the wholly owned subsidiary of National
Starch and Chemical Corporation, Inc. in 1969. The Company manufactures
almost every chemical compound used in the textile industry, except for
* Detection limit — 0.2 pg/i.

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19
Table 2
MONITORING SITE DESCRIPTION
MARTIN-MARIETTA CORP.
Charlotte, North Carolina
Sample Description Site Location
Untreated river water Intake Dump house, from
the fish bioassay feed
line
Untreated well water Water fountain in Sales
Service Building
Treated wastewater effluent Canal, approximately 0.54
km (0.33 mile) downstream
from the final settling
lagoon, about 9 m (30 ft)
upstream from confluence
with river
Air - north site Roof of building 11, analytical
laboratory. About 45 to 60 m
(150 to 200 ft) from ñighway
27 (downwind site)
Air - wètt site Intake pump house, about 91 m
(100 yd) downstream from
highway 27 bridge; on intake
pipe superstructure dock,
about 3 m (10 ft) west of
stairs on dock (qround or
dock level)
Air - south site West side of preaeration nond
on SW side of oond.’ Upwind
site (ground level)
Air - northeast site About 30 rn (100 ft) south of
spur railroad tracks, behind
bldg. 39 (ground level)

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E J
2
FIGURE 4
MARTIN MARIETTA CORPORATION
SODYECO DIVISION
CHARLOTTE, N. CAROLINA
GENERAL PLANT LAYOUT
• AIR MONITORING SITE
N
t
.
N)
S

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21
dye stuffs, and produces over 500 products in varied lot sizes from
55-gallon drums to tank truck and railroad car bulk quantities. Proctor
Chemical has the capability to produce almost any chemical formulation
to a customer’s specification. The plant also produces custom chemicals
for larger chemical companies which do not want to invest capital for
new processes. About 40% of their products are manufactured for other
companies.
Proctor Chemical Company consists of two plants, situated approxi-
mately 8 kin (5 mi) apart. The Lumber Street Plant [ Figure 5] consists
of 4,600 m 2 (49,000 ft 2 ) of manufacturing, warehousing, shipping and
main offices while the new (1971) Cedar Springs Plant [ Figure 6] consists
of 5,000 m 2 (53,600 ft 2 ) of manufacturing and warehousing. The Cedar
Springs Plant is located on 16 ha (40 acres) in the rural area of
Salisbury while the Lumber Street facility is within the City limits
and bounded on all sides by other businesses. Both facilities operateS
5 days/week, 24 hr/day.
Water Supply and Wastewater Treatment
All water used at both plants is purchased from the City. Fresh
water used for condensers and reactors is recycled through cooling
towers; there are three towers at the Lumber Street Plant and one tower
at Cedar Springs.
Sanitary wastewater from the Lumber Street facility is discharged
directly to the municipal wastewater treatment plant. Sanitary waste-
water is discharged to a septic tank and leach field at the Cedar
Springs Plant.
Process wastewater is not discharged from either plant to receiving
waters. At the Lumber Street Plant, all wastewaters, clean-up waters,

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22
AIR MONITORING SITE.
S
A LARGE REACTORS (OVER 2 GAL) [ ] ( )
B SMALL REACTORS (UNDER 2 GAL)
C DISTILLAIION
o STOR*GE
(MIXING O.EANJNG fTl ® In
F CEP4TRIR CE LW
G OR RS—
H PILOT REACTORS C
S STEAk) BOtLERS(t6O C)
J NOTOLBOILERSI3 °C t:)
R REFRIGERATION COOLING C7
U WASTE TREATMENT I CE)
I . COOLING (_7
N FIRE PROTECTION
o TRUCJc CALES
P ION EXOIANGE £
o ORUMFLAJCER
LA
2.GIa (g
LA
LA
tj
a,
I
a-
1.1
LA
•Soh nI R .erp U F ictO lcli
— V Arfl w d Fluid Bid
49.406 SQ. Ft
1j®EJ
FIGURE 5
PROCTOR CHEMICAL COMPANY, INC.
SALISBURY, N. CAROLINA
LUMBER STREET PLANT
GENERAL PLANT LAYOUT
5PcQ 4IOU
CEXE)®e o7 ( ®

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• AIR MONITORING SITE
‘Jr
53.590 SO. FT.
R LLR ROOM
ElElEI ill
00
0
000
00
O Mu1
0
0
i
1 0 T ’J
0
0
0
0 0
e IO( TAla T GI
00
0
ACT SC SC
TIR ROOM
0
OJT$JDE TM I ETOR I
A LARGE REACTORS (OVER 2 GAU
o SMAU. REACTORS (UNDER 2XOGM )
C D ISTIU .AT1ON
o STORAGE
E MIXING
F CENTRIFUGE
6 DRYERS
H PILOT REACTORS
I S E.AM BOILERS(1SCRC)
J HOT OIL BOILERS (3
K REFRIGERATION COOUE4
L C ING
M WASTE TREATMENT
N PIPE PROTECTION SYSTEM
O TRUOXSCA(.ES
p ION EXO4ANGE
0 DRUM FLANER
1 Su ES
2GIau MISC
4-LaRd M
• p4 RacC 4fy ld Ffi aRd
TalAlly Br d
VRQAJP FkRd Bud
FIGURE 6
PROCTOR CHEMICAL COMPANY, INC.
SALISBURY, N. CAROLINA
CEDAR SPRINGS PLANT
GENERAL PLANT LAYOUT
.
ullunu
El
El
Of CE M O
OIJA&ITY
nRCLL 4a
A To 4
C.
C.
C®
‘LI
. 00 0lo I

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24
rainwater, cooling tower and boiler bleedoff are discharged to the
municipal wastewater treatment facility. Prior to discharge to the
municipal sewer, the wastewaters flow to two 530 m 3 (140,000 gal) ca-
pacity tanks, operated in parallel; the wastewaters are aerated with
surface aerators. The flow averages 380 liters/mm (100 gpm). The two
aeration tanks are located above ground and are open to the atmosphere.
A portion of the wastewater flows through a 76 m 3 (20,000 gal) under-
ground holding tank located in the drum cleaning area, before discharge
to the two surface tanks.
Process wastewaters are not discharged from the Cedar Springs
facility. All wastewaters drain to two settling and separation pits,
each about 3 m square x 0.9 m deep (10 ft square x 3 ft deep), operated
in series. Material is either recovered from the pits or pumped to one
of two unlined lagoons, operated in parallel. There are actually three
lagoons; however, one does not receive plant wastewater, and contains
storm water runoff. The wastewaters in the two lagoons are continually
recycled through spray nozzles into the air to assist in evaporation.
There is no known discharge from either lagoon.
Six wells, ranging in depth from 6 to 12 m (20 to 40 ft) deep, are
used for monitoring on the Cedar Springs property to determine if the
wastewater from the lagoons is seeping into the ground water. The wells
are monitored weekly for pH, manganese, chloride, COD, total hardness,
total solids, and total volatile solids; to date the data has not indi-
cated that the wastewater is entering the ground water.
Processes
The total production capacity of both plants is 27 million kg (60
million lb)/yr. Originally, the Company sulfonated animal oils and fats
for the textile industry; however, the chemical formulations for textiles

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25
have grown to include dye auxiliaries, thermosetting resins, wetting
agents, etc. Formulations include concentrates, fluids, flakes, small
chunks, and waxy materials. All processes are operated on a batch basis
using stainless steel, glass—lined steel, or lead-lined reactors. In
addition, specialized systems such as distillation columns and enclosed
centrifuge and solids handling equipment are available for formulations
with specialized requirements. Units processes include:
Al coholysis
Al kyl ation
Am i dat i on
Crystall ization
Distillation
Esterification
Flaking
Hydrolysis
Oxidation
Phosphation
Product categories include:
Antistatic Agents
Antistick Agents
Catalyst
Detergents
Dye Assistants
Dye Fixatives
Emul sifiers
Flame Retardants
Lubricants for Yarn
Propoxyl ation
Reduction
Sulfonation (O°-230°C)
Vacuum Drying
Chlorination
Quaterni zation
Organometal 1 ic Condensation
Etheri fi cation
Sul fation
Reactants
Resins
Sanforizing Agents
Scouring Agents
Softeners
Sulforiated Fats and Oils
Weighers
Wetting Agents
Due to the large number of batch processes available at Proctor
Chemical, detailed process evaluations were not conducted. However,
typical process descriptions for reactions using amines fall into three
categories.
1 . Diethanol Amine Reaction [ Figure 7-A] - This process is located
at the Lumber Street facility only, in the synthetic area. The only
source of amines would be to the atmosphere as there is no wastewater
discharge. The air emissions are not controlled.

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26
EJ 4vff 0z 1•
+
_t, p P .AIN J TO A TiOI4 TAP&I(S
I-
9 AMiO P O c. ’lDN
Sc Ru8 4 1 _ 1 , PHO PMORiC ACID
TO I-AGOOH
PLUMS; 40 lb C.AeT0 JS)
ea om R AcTjON
FIGURE 7
PROCTOR CHEMICAL COMPANY, INC.
SALISBURY, N. CAROLINA
TYPICAL AMINE REACTION SEQUENCES
A. p ETl4p.NOLAMpr aE R A 1ION
C. Tt%METI$TLAMIN . R . craoH

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27
2. Amide Production [ Figure 7—B] - This process is conducted at
both plants. Air emissions are vented through a shell and tube conden-
ser; condensables are discharged to the wastewater system while non-conden-
sables are vented to the atmosphere.
3. Trimethylamine Reaction [ Figure 7-C] - Air emissions from the
reactor are vented to a shell and tube condenser and then to a counter-
current fume scrubber, packed with ben saddles. Phosphoric acid solu-
tion cascades through the scrubber from the top. About 180 kg (400 lb)
of acid, mixed with 1,500 liters (400 gal) of water; is used each day.
The spent scrubbing solution is discharged to the lagoon system. This
process is used only at the Cedar Springs Plant.
The raw and intermediate materials used in the processes were pro-
vided to NEIC, however, Company personnel consider these materials pro-
prietary and requested that they not be identified in the report.
Monitoring Results
Monitoring was conducted on May 3, 1977; a description of the air
and water monitoring sites for both plants is given in Tables 3 and 4,
and shown in Figures 5 and 6. The air speed varied between 6 and 15 km
(4 and 9 mi)/hr and was out of the southwest. The temperature during
the monitoring period was between 75° and 80°F; sky conditions were
partly cloudy.
Nitrosamines were not detected in the ambient air samples at either
process facility nor in any water/wastewater sample from the Lumber
*
Street Plant. A concentration of 0.1 pg/l of dimethylnitrosamine (DMN)
was detected in the municipal water supply sample at the Cedar Springs
* Detection limit = 0.2 pg/i.

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28
Table 3
MONITORING SITE DES CRTh’ TION
PROCTOR CHEMICAL COMPANY
LUMBER STREET PLANT
Salisbury., North Carolina
Sample Description Site Location
Municipal water supoly Main office building, sink
in men’s roon
Process wastewater effluent Valve from aeration tank
after 24 hr of aeration closest to the research
building, farthest from
nlant (filled 5-2-77)
Process wastewater effluent Valve from aeration tank
before aeration to the plant (being
filled on 5-3-77)
Air - south of processes, Inside of fence line,
upwind of site approximately 0.6 m
(2 ft) off of Lumber
Street, about 6 m (20 ft)
west of alley entrance
(Unit on top of 55 gal.
drum)
Air - west of orocesses 38 to 46 m (125 to 150 ft)
downwind of the two aerated
storage tanks, about 3 m
(10 ft) in ide of fence
line (unit elevated about
2 m (7 ft) off of ciround)
Air - northeast of processes, !lortheasternmost section of
downwind of site plant, adjacent to drum
cleaninq facility (unit
elevated about 6 m (20 ft)
above ground)
Air - east of processes On N 1 corner roof of Lower
Warehouse

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29
Table 4
MONITORING SITE DESCRIPTION
PROCTOR CHEMICAL COMPANY, INC.
CEDAR SPRINGS PLANT
Salisbury, North Carolina
Sample Description Site Location
Municipal water supply Fresh water intake at burner
shed sniciot, adjacent to
lagoons
Process wastewater, untreated From second settling and
separation pit (closest
to lagoons)
Process wastewater from east About 7.6 rn (25 ft) east of
lagoon puma house on west side of
lagoon #1
Process wastewater from middle From middle of lagoon #2
lagoon (lagoon almost dry)
Grant’s Creek Creek as it leaves north side
of property, about 30 m (100 ft)
off property at bridge
Air — south of processes, Midway between settling
upwind site and separation Dits and
lagoons near east end of
lagoon #1 (unit on 55 gal.
drum)
Air - east of processes ApDroximately 15 m (50 ft) north
of scale house, about 4.6 m
(15 ft) east of road (unit
at ground level)
Air — north of processes Between ammonia burner and
1ant building, about 12 m
(40 ft) north of building
across road (unit at ground
level)
Air - west or processes On tank truck ramp (unit at
ground level)

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30
Plant, but was not detected in any of the process wastewater samples, nor in
the Grant’s Creek sample. Also, DMN was not detected in the municipal
water supply at the Lumber Street Plant, and both fresh water supplies
are from the Salisbury utility. Therefore, DMN was most probably not
present in the sample, but was detected due to the solvents used in
*
extraction.
Nitrosaniines were not detected in the Grant’s Creek sample nor in
the sample collected from the middle lagoon (lagoon #2); this lagoon
**
was almost dry. However, 8.2 pg/i propylbutylnitrosamine (PBN) and
3.2 pg/i PBN were detected in the wastewater effluent from the settling
and separation pit (influent to lagoon #1) and in the sample collected
from lagoon #1), respectively. The PBN could not be confirmed by GC/MS
at the levels detected due to a masking effect by a large number of
components at higher concentrations. Although a number of occurrences
of prominent PBN masses were found, the spectra of those peaks were not
PBN. Of the amines used at the plant, the precursor of PBN was not in
the inventory.
VELSICOL CHEMICAL COMPANY
Velsicol Chemical Company operates two plants at Chattanooga. These
are designated as the Semi—works and Main Plant, located across the -
street from each other.
Water Supply and Wastewater Treatment
Fresh water for both plants is supplied by the City of Chattanooga.
The amount of water was not provided during the NEIC inspection.
* The solvents used in NEIC’s extraction method produces peaks that
appear similar to DMN and nitrosomorpho line in the presence of
residual chlorine.
** Detection limit = 0.2 pg/i.

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31
Sanitary wastewaters from both plants are discharged to the municipal
sewer system.
Process wastewater, water used to clean reaction vessels, mix
tanks, etc., from the Semi-works are discharged into a holding tank.
After neutralization, the wastewaters are discharged to the municipal
sewer system. Sediments from the holding tank are landfilled. If the
process wastewater contains materials such as toluene, the wastewater is
discharged into drums and hauled away for incineration by a private
contractor. Process wastewater and wastewaters from air scrubber
systems at the Main Plant are discharged to the City sewer. The waste-
waters are pretreated; however, the Company considers the treatment to
be confidential. At the time of the survey, the sewer was being re-
placed because the wastewater had apparently dissolved the pipe.
Storniwater and seepage from the north side of the Main Plant are
discharged to the Tennessee River via a drainage ditch.
Processes
The Semi-works develops new products through research and also
manufactures some specialty products. These products include esters of
berizoic acid, dicyclopentadiene, methendic alcohol, dimethylchlorperitacine,
dimethylchlorendate, and sucrose benzoate. One product, designated as
*
MAADMA contains amine compounds. The majority of the processes are
conducted on a batch basis in 1.9 m 3 (500 gal) vessels. Other equipment
use consists of stills, autoclaves, neutralization tanks, and mix tanks.
The Main Plant produces benzoic acid, benzoic acid esters, benzo
nitrile, benzo guanamine, benzo alcohol, benzo trichioride, benzoyl
* Chemical name is considered confidential.

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32
chloride, benzoyl alcohol, and similar chemicals. Production figures
are considered confidential.
Process vapors in the Semi-works plant are normally returned to
the reaction vessel. However, some vapors, including fugitive, are
vented to the atmosphere. Air pollution control at the Main plant is
by means of scrubbers. The Company indicated however, nitrogen is
emitted to the atmosphere from the benzoic acid process. They indicated
that stack tests have been conducted at the Main Plant to determine if
manufactured compounds were being emitted. The results were not avail-
able at the time of the NEIC survey.
Monitoring Results
A description of the air and water monitoring sites for both
plants is given in Table 5. The air speed ranged between 4.8 and 11 km
(3 and 7 mi)/hr and varied in direction. The temperature was about 80°F.
N—nitroso compounds were not detected in the ambient air, water or
wastewater samples.
FARMERS SUPPLY AND PRODUCE
Farmers Supply and Produce, a retail store, supplies hardware,
feed, seed, fertilizer, pesticides and herbicides to the general public.
The pesticides and herbicides are purchased pre-packaged and are either
sold as-received or mixed with liquid nitrogen or dry fertilizer. On
an average basis, the store sells about 2,700 kg (6,000 lb)/yr of pesti-
cides and herbicides with only 900 kg (2,000 ib) being pre-mixed at the
store with fertilizers. The amount of these compounds sold in 1976 are
as follows:

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33
Table 5
MONITORING SITE DESCRIPTION
TTELSICOL CHEMICAL COMPANY
Chattanooga, Tennessee
Sample Description
Site Location
Semi -Works
Air - south of processes
Air - west of processes
Air - north of processes
Air - east of processes
At fence line
At fence line
At fence line
Roof of office building
Main Plant
City water supply
Process wastewater after
pretreatment
Runoff
Air - south of processes
Air - west of processes
Air - north of processes
Air - east of processes
Main office building
Discharge to the municipal
sewer
North side of plant
South side of plant
At fence line next to
office building
At fence line adjacent to
Coke Plant
East side of plant near
wastewater discharge to
sewer

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34
Liquid atrazine 300 1 (80 gal)
Atrex 80 W 900 kg (2,000 ib)
Paraquat 380 1 (100 gal)
Lorax 90 kg (200 lb)
Balan 450 1 (120 gal)
Princep 80W 110 kg (250 gal)
At the time of NEIC’s inspection, atrazine powder (Atrex 80W) was
being mixed in water and added to ammonia. Mixing is conducted outside;
only a very small amount of dust was lost during mixing due to the care
taken by employees. The total mixing time takes less than 5 minutes;
the number of batches varies daily, depending on customer orders.
Water is only used for mixing of the compounds; the operation does
not have any process discharge. Empty chemical containers are placed
in trash containers and removed by a contractor.
Due to the limited amount of materials being used and the nature
of the operation, ambient air and water samples were not collected.

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IV. SUMMARY AND CONCLUSIONS
Ambient air and water samples were collected at four industrial
facilities and analyzed for N—nitroso compounds. Farmers Supoly and
Produce, a retail store, was not sampled.
Except for one sample collected at the Ciba-Geigy Corporation
plant at McIntosh, Alabama, N—nitroso compounds were not detected in
the ambient air samples. The wind direction during monitoring at
Ciba-Geigy was variable, but mainly from the southwest. About 40 ng/m 3
of dimethylnitrosamine (DMN) was detected in the upwind monitoring site
sample. This concentration is in the range found at Baltimore, Md., and
Belle, W. Va. Olin Chemical is located south (upwind) of Ciba-Geigy’s
property and has nitrating facilities. However, whether the DMN originated
from Olin Chemical, or Ciba-Geigy, is unknown. Based on one positive sample,
it cannot be concluded that nitrosamines are present at low levels or are
ubiquitous in the plant’s environment. The negative results indicate that
1) nitrosamines are not emitted, 2) nitrosamines were not emitted durinq
sampling, 3) once in the atmosphere the N-nitroso compounds decomposed
rapidly, or 4) the compounds were not collected by the sample train due to
environmental conditions. DMN’s presence indicates some deoree of risk and
Ciba-Geigy should eliminate the emission. The Company has the capability
to monitor and analyze nitrosamines.
Water samples collected from Ciba-Geigy Corporation, ? artin-Marietta
(SODYECO), and Proctor Chemical Comoany indicate that there are primary
sources of direct emissions to the environment of a number of M-nitroso
compounds. The compounds probably arise as impurities during the synthesis
of other compounds and are emitted to the environment during the use or
modification of these products. The source and types of nitrosamines
detected are as follows:

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36
Conc.
Facility Sample Description ugh N-Mitroso Compound
Ciba-Geigy Treated wastewater
effluent 0.05 Dimethylnitrosamine
0.63 Nitrosopyrrolidine
Martin-F•larietta Treated wastewater
effluent 13.0 Dipropylnitrosamine
Proctor Chemical’s
Cedar Springs
Plant City water 0.1 Dimethylnitrosamine
Process wastewater
influent to Propylbutylnitros-
evaporation lagoon 8.2 amine*
Wastewater in Propylbutylnitros-
evaporation lagoon 3.2 amine*
* PBN could not be confirmed by CC/MS due to macking by the Zarge number
of components at higher concentrations and because a PBN standard zx s
not availcbl-e at a high enough concentration to measure the exact retention
time and detection limits by CC/MS.
In-plant sampling would be required to locate the sources of these
compounds; however, at th levels observed, it is doubtful that this
effort would be useful expenditure of EPA’s resources.
There is a lack of data indicating the level at which health’
effects are observed and what these effects are. One cannot safely
speculate as to the significance of the numbers ‘or the population at
risk. Where these compounds are discharged into waterways, it is
possible that they may find their way into drinking water supplies.
This has been routinely demonstrated with other compounds. Where
health effects data are lacking, the safest posture is to assume no
threshold level exists, and to minimize the environmental impact of
known carcinogens wherever possible.’

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37
REFERENCES
1. “Reconnaissance of Environmental Levels of Nitrosamines in the
Central United States,” EPA Office of Enforcement, National Enforce-
ment Investigations Center, Denver, Colorado, January 1977, EPA-
330/1 -77-001.
2. Fine, D. H., Rounbehiet-, D. P., Beicher, N. M., Epstein, S. S.,
“International Conference on Environmental Sensing and / ssessment,”
Catalogue #75-CH 1004-1 ILESA, pp. 30—7, IEEE, New York, New York,
1976.
3. Fine, D. H., Rounbehier, 0. P., Beicher, N. M., Epstein, S. S.,
SCIENCE , 192, 1328 (1976).

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APPENDIX A
NEIC ANALYTICAL PROCEDURE FOR NITROSAMINES

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NEIC ANALYTICAL PROCEDURE FOR NITROSAMINES
Air Samples
Air samples were collected in foil-covered imDinQers (S(A catalog
#JV8550) filled with 60 ml of lN KOH. Air samples were drawn through
the impinger by a vacuum pump and the flows controlled by a calibrated
stainless steel hypodermic needle (B&D 1 /21). Normal collection volumes
ranged from 200 to 250 liters of air per needle. Dual impinaers were
used to collect samples at each monitoring locations. The two samoles
were combined in the NEIC Laboratory prior to analysis.
All laboratory work was carried out under low UV “bug” lights to
minimize the possibility of light catalyzed degradation of the nitro-
samines. The KOH solutions were extracted in a 250 ml separatory funnel
with three 8 ml portions of dichloremethane (Burdick and Jackson,
“distilled in glass”). The combined extracts were concentrated to 0.5
ml in Kuderna-Danish evaporative concentrators, each consisting of a
three-ball Snyder column attached to a specially made 50 ml concentrator
flask which in turn was attached to a 4 -ml calibrated receiving tube.
The column and receiving tube are available through Kontes ‘ lass
Company; the 50-mi flask was custom made locally. Before concentration,
0.5 ml of 2,2,4 trimethylpentane was added as a keeoer. A hot water
bath maintained at 59 to 60°C was used as the heat source.
Microliter aliquots of the concentrates were injected into a Varian
Model 600D gas chromatograph attached to a modified Thermal Energy
Analyzer (GC/TEA). An n—propanoi/liquid nitrogen cold trao was used in
conjunction with the modified TEA.

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Where possible, samples thought to contain nitrosarnines were spiked
with known standards to confirm retention time and to help establish
concentrations. P 10% Carbowax 20M, 1% KOH on 60/80 n’esh Chromosorb WAW,
column was employed for analysis. The retention time of the sample peaks
matched those of the standard solutions of nitrosamines.
Quantitation of compounds reported was made by peak height comparison
with authentic standards, obtained through the Food and Drug Administration,
Washington, D.C.
Water Samples
Grab samples were collected in amber glass 0.946 liter (quart)
bottles with Teflon liners. Two 50-mi portions of dichioromethane were
used to extract each sample in a 2,000-ml separatory funnel. The combined
extracts were concentrated as above, only using a 250—mi concentrator -
flask and 1 nil of 2,2,4 trimethylpentane as a keeper. Volumes injected
into the GC/TEA were kent as small as possible.
Granular anhydrous sodium sulfate (Mallinkrodt AR) was used to
treat emulsions when they occurred during extractions.

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QUALITY CONTROL
During these studies, the following quality control considerations
were evaluated:
Solvent Blanks
Methylene chloride (dichioromethane) was concentrated from at least
three different bottles from 100 ml to 1 ml using an isoctane keeper and
was found to contain no peaks which specifically interfere with the
analyses. Similarly, unconcentrated Burdick and Jackson methylene
chloride and isoctane were analyzed with the GC/TEA system and found to
be free from interferences.
Nitrosamines Free Water
Nitrosamine free water was taken to the field and used to prepare
the 1 N KOH solution for the impingers. Twenty to fifty ml of the
nitrosamine free water was used to wash each impinger sample into sample
containers. The sample bottles were capped (caps had Teflon liners) and
were sealed with electrician’s tape.
The riitrosamine free water was analyzed in the NEIC laboratory to
confirm the absence of N-nitroso compounds.
Extraction Efficiencies
Quart samples of water were spiked with DMN, DEN (diethyl-N-nitrosamine)
and DBN (dibutyl-N-nitrosamine), extracted and concentrated in the normal
manner to determine recovery from water samples. The average recoveries

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were as follows: DMN 32%, DEN 87%, and DBN 96%. The addition of NaC1
to increase recovery during water extractions was studied but found
ineffective.
Overall collection and extraction efficiency was determined for
air samples by passing known quantities of dimethyl—N-nitrosamine,
ethylrnethyl-N-nitrosamifle, diethyl—N-nitrosamine, dipropyl—N-nitrosamine,
ethylbutyl-N-nitrosamine, nitrosopyrrolidine, and nitrosomorpholine
through KOH impingers at ambient temperatures of -2°C and 20°C, then
extracting and concentrating as usual. For these compounds, the average
recovery at -2°C was 65% and at 20°C, 78%. There were no apparent
differences in efficiencies between the various compounds examined.

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APPENDIX B
SAMPLE VOLUMES

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APPENDIX B
SAMPLE VOLUMES
April—Play, 1977
Location Station Description and Date Sample
Sample Type Volume
( liters )
Ciba-Geigy Untreated well water 5/25 0.946
Treated well water 5/25 0.946
Untreated river water 5/25 0.946
Treated river water 5/25 0.946
Treated wastewater 5/25 0.946
South site--air 5/25 471.6
East site--air 5/25 471.6
North site--air 5/25 478.8
West site--air 5/25 484.8
Martin Marietta Untreated river water 5/5 0.946
Well water 5/5 0.946
Treated wastewater 5/5 0.946
North site--air 5/5 462.6
West site--air 5/5 477.0
South site--air 5/5 467.4
Northeast site-—air 5/5 505.8
Proctor Chemical
Lumber Street Municipal water 5/3 0.946
Wastewater after aeration 5/3 0.946
Wastewater before aeration 5/3 0.946
South site--air 5/3 62.6
West site—-air 5/3 477.0
Northeast site--air 5/3 467.4
East site—-air 5/3 505.8
Cedar Springs Municipal water 5/3 0.946
Untreated wastewater 5/3 0.946
Wastewater--east lagoon 5/3 0.946
Wastewater--middle lagoon 5/3 0.946
Grant’s Creek water 5/3 0.946
South site--air 5/3 462.6
East site--air 5/3 477.0
North site—-air 5/3 467.4
West site—-air 5/3 505.8
Velsicol
Semi—works South site--air 4/19 434.1
West site--air 4/19 565.8
North site--air 4/19 572.5
East site—-air 4/19 494.1
ham Plant Runoff water-north 4/19 2.0
Wastewater 4/19 2.0
City water 4/20 2.0
South site--air 4/20 465.6
North site--air 4/20 491.5
West site-—air 4/20 524.4
East site-—air 4/20 471.1

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