&EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
fPA-330/2-80-024
AUDIT OF PRODUCTION/WASTE GENERATION OPERATIONS
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
(September 18-28, 1979)
August 1980
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER—Denver
REGION IX—San Francisco
STATE OF CALIFORNIA
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EFA-330/2-80-024
AUDIT OF PRODUCTION/WASTE GENERATION OPERATIONS
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
[September 18-28, 1979]
August 1980
Thomas 0. Dahl
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER - Denver
REGION IX - San Francisco
STATE OF CALIFORNIA
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ACKNOWLEDGMENT
The author would like to extend his thanks to the other audit
members from NEIC, EPA Region IX and the State of California for their
herculean efforts and patience in reducing the thousands of pages of
documents reviewed to a usable meaningful end product. Without these
efforts, this report and subsequent technical efforts to systematically
define the extent of environmental problems and necessary remedies would
not have been possible.
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CONTENTS
I INTRODUCTION 1
II SUMMARY OF FINDINGS 3
PRODUCTION FACILITIES 3
MASTER LIST OF OXY-LATHROP CHEMICALS 4
WASTE SOURCES AND CONTROL/DISPOSAL 4
PRODUCTION RECORDS REVIEW 9
HISTORICAL GROUNDWATER AND SOIL DATA EVALUATION 10
AERIAL OVERFLIGHT OF OXY-LATHROP FACILITIES 11
III AUDIT FINDINGS 12
COMPANY HISTORY 12
PRODUCTION FACILITIES 12
MASTER LIST OF OXY-LATHROP CHEMICALS 26
WASTE SOURCES AND CONTROL/DISPOSAL 26
PRODUCTION RECORDS REVIEW 60
HISTORICAL GROUNDWATER AND SOIL DATA EVALUATION 83
AERIAL OVERFLIGHT OF OXY-LATHROP FACILITIES 90
APPENDICES
A ORGANIC SOLVENT EMISSIONS DATA AND INVENTORY OF AG CHEM
STORAGE TANKS
B SUMMARY OF ORGANICS DATA COLLECTED AT OR IN THE VICINITY
OF OXY-LATHROP FACILITY
TABLES
1 Fertilizer Operations 14
2 Ag Chem Active Ingredients from Oxy-Lathrop Master Lists. . . 27
3 Solvents and Oils from Oxy-Lathrop Master Lists 29
4 Inorganic Chemical Used and Produced from Oxy-Lathrop Master
Lists 29
5 Miscellaneous Products and Materials Oxy-Lathrop from
Master Lists 30
6 Products Purchased for Resale by Ag Chem Oxy-Lathrop but not
Used in Production 30
7 Miscellaneous Materials - Oxy-Lathrop 31
8 Sulfuric Acid Plant Emissions 33
9 Summary of Stack Test Data - Phosphoric Acid Plant Fume
Stack 35
10 Summary of Stack Test Data - Pellet Plant Fume Stack 37
11 History of Air Pollution Projects on Pellet Plant Dryer and
Blunger 38
12 Chronology of Units in the Ag Chem Area 42
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TABLES (Cont.)
13 Summary of Stack Tests on the Agricultural Chemical Stack . . 44
14 Annual NH3, P205 and K20 Losses 62
15 Estimates of Pond Percolation and Atmospheric Discharge
Losses 63
16 Fluoride Losses from Material Balance Data 65
17 Summary of Fluoride Losses to the Atmosphere 66
18 Sulfur Losses from Material Balance Data 67
19 Summary of Active Ingredients Handled at Oxy-Lathrop from
1971-1979 Yearly Totals 69
20 Summary of Solvents Handled at Oxy-Lathrop from 1971-1979
Yearly Totals 72
21 Summary of Active Ingredients Handled at Oxy-Lathrop from
1971-1979 Ranked by Pounds Handled 73
22 Summary of Solvents Handled at Oxy-Lathrop from 1971-1979
Ranked by Pounds Handled 74
23 List of Materials Handled at Oxy-Lathrop from 1971-1972 not
Included in Tables 19 and 20 76
24 Summary of Lost Raw Materials at Oxy-Lathrop ........ 78
25 Ag Chem Production Materials Balances at Oxy-Lathrop in 1973
and 1978 79
26 Tech DBCP Manufacturing at Oxy-Lathrop Record Summary
1971-1976 81
27 Oxy-Lathrop DBCP Production Summary of 1968-1977 82
28 Oxy-Lathrop Groundwater Monitoring Data - SO4 84
29 Organic Compounds Found in Vicinity of Oxy-Lathrop
Facilities 88
FIGURES
1 Interrelationship of Various Fertilizer Operations 15
2 Plant Flow Diagram - 7/18/79 46
3 Plant and Disposal Site Schematic 47
4 Plant Flow Diagram - 5/9/67 50
5 Location Map - Occidental Chemical Company 91
6 False Color Infrared Aerial Photograph 93
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I. INTRODUCTION
Occidental Chemical Company (Oxy), a subsidiary of Hooker Chemical
Corporation which in turn is a subsidiary of Occidental Petroleum Cor-
poration (Oxy Petroleum), owns and operates an agricultural fertilizers and
pesticides plant in Lathrop, California. This plant came into national
prominence in 1977 following discovery that a substantial proportion of the
pesticide workers were sterile. Presumably, the cause of this sterility
was from exposure to a nematocu'°, Dibromochloropropane (OBCP) which was
both formulated (1957 to July 1977) and manufactured (1963 to 1971, 1974 to
1976) at the plant. Subsequent to this discovery, the State of California
banned the sale and use of DBCP on August 12, 1977. This expanded into a
nationwide ban on the production and use of DBCP except in certain limited
uses.
Concurrent with the disturbing events occurring at the Occidental
Chemical Company plant at Lathrop (Oxy-Lathrop), Occidental Petroleum
Corporation was locked in an anti-trust suit with Mead Corporation over
attempts by Oxy Petroleum to take over Mead. This suit resulted in the
U.S. Securities and Exchange Commission's (SEC) acquisition of considerable
Oxy files regarding environmental affairs. One of the plants for which
these internal files were forthcoming was Oxy-Lathrop. This information
was made available to the U.S. Environmental Protection Agency (EPA). The
combination of the sterility issue and certain internal files indicating
potential adverse environmental effects caused EPA and the State of Cali-
fornia to launch an investigation of Oxy-Lathrop operations.
In July 1979, the State of California and EPA Headquarters requested
that the EPA-National Enforcement Investigations Center (NEIC) coordinate
the conduct of an audit of Oxy-Lathrop operations. The purpose of this
audit would be to review past and present practices drawn from existing
records and recollections regarding all waste generating production pro-
cesses, disposal practices, and monitoring data relating to possible
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effects of operations on the environment. Information gathered would be
used in case preparation, if that were warranted, and to develop a plan of
study to determine the extent of groundwater/soi1 contamination in the area
as well as necessary remedies.
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II. SUMMARY OF FINDINGS
During September 18 to 28, 1979 the EPA-NEIC, EPA Region IX and State
of California* conducted an audit of operations at the Occidental Chemical
Company, Lathrop, California. This audit, supervised and coordinated by
NEIC, determined that past production and disposal practices relating to
air emissions, and liquid and solid wastes were inadequate resulting in
contamination of the air, groundwater and soil in the vicinity of the plant
area. The findings of the audit are discussed below.
PRODUCTION FACILITIES
Production facilities at Oxy-Lathrop are divided into fertilizer and
Ag Chem (pesticide) operations. The fertilizer operation produces sulfuric
acid, phosphoric acid, ammonium sulfate, and a pelletized ammonium
phosphate-sulfate product. Gypsum and fluorosilicic acid are byproducts
from the production of phosphoric acid. In the past, ammonia**, normal
superphosphate and vanadium pentoxide catalyst were also produced at this
facility. Anhydrous ammonia and the vanadium pentoxide are now purchased
and normal, superphosphate operations were terminated in 1972.
The Ag Chem facilities consist of blending and packaging of concen-
trated pesticides into formulated, dilute pesticide products for
* State personnel included staff from the California Department of
Health Services and the Central Valley Regional Water Quality Con-
trol Board.
** Ammonia was produced at the California Ammonia Company (Calamco)
adjacent to the Oxy facility which is a co-op with 48% Oxy owner-
ship.
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agricultural, home and garden use. The only pesticide manufactured at this
site was l,2-dibromo-3-chloropropane (DBCP). This was done during the
years 1963 to 1971 and 1974 to 1976. DBCP was formulated at this site from
1957 until July 1977.
MASTER LIST OF OXY-LATHROP CHEMICALS
During the audit, a series of lists were provided by Oxy purporting to
contain the names of all chemicals thought to have been used or produced at
Lathrop. These lists were evaluated and summarized yielding 113 active
ingredients, 8 solvents and oils, 45 inorganics, and 18 miscellaneous prod-
ucts. During the audit, an additional 162 materials were encountered which
were not included in the master listing.
WASTE SOURCES AND CONTROL/DISPOSAL
Air Emissions
o An acid mist regulation was adopted on May 29, 1979 Ly the San
Joaquin Air Pollution Control District (APCD) and affected facilities had
until February 1980 to comply. Compliance testing at the Oxy-Lathrop
sulfuric acid plants was conducted by the California Air Resources Board in
August 1979, but the results were not available at the time of the audit.
• Measured S02 emissions from the sulfuric acid plants were very
close to the allowable emission of 2,000 ppm. Furthermore, during periods
of upset conditions between 20,000 to 30,000 ppm of S02 have been emitted.
Recent continuous monitoring data indicated the plant to be in compliance
during normal operating conditions.
• A project to control particulate and opacity emissions from the
pellet plant dryer and blunger was completed in June 1979. Control
equipment appeared to be functioning properly at the time of the audit.
However, the fluorine emissions from this stack have exceeded the standards
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(0.02 lb F/ton P205) adopted on January 29, 1979 by the APCD. Oxy-Lathrop
was granted an extension to May 18, 1979 for submitting a final control
plan. The plan was reportedly scheduled to be completed in the Spring of
1980.
® The ammonium sulfate plant was down for its annual turnaround at
the time of the audit so visible emissions from the stack could not be
observed. However, in the past, high production rates of ammonium sulfate
have caused stack emissions to exceed the 20% opacity limitation. If this
is true for the present operation, additional control equipment or oper-
ation at a reduced rate may be needed to maintain compliance.
• On July 1, 1979, Oxy-Lathrop filed a plan with the APCD to
control fugitive dust emissions from warehouses 1, 4, 5, 6 and 9. The
fugitive dust emissions from the loadout stations often exceeded the
visible emission limitation of 20% opacity during loading operations. The
control plan is intended to bring these emissions into compliance with the
regulations and remedial measures were scheduled to be completed in Karch
1980.
9 Tests conducted by Oxy-Lathrop showed that under certain oper-
ating conditions, the organic emissions from the agricultural chemicals
stack (old scrubber) exceeded the 18 kg (40 lb)/day limit established by
the APCD. In addition, it was determined that the emulsifiable concentrate
(EC) plant could not be operated in compliance with the APCD regulations
until a control system was put into use. A VIC carbon adsorption system
was purchased and installed and at the time of the audit, Oxy-Lathrop was
awaiting local APCD approval of the system in order to operate it for a
test period.
Liquid Wastes
Fertilizer Operations
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• Considerable water reuse is presently practiced within fertilizer
operations at Oxy-Lathrop. Process wastewaters go to one of three water
cycles: the unlined Gypsum Ponds, the lined Pellet Plant Pond or the
unlined Concentrator Pond.
• In-plant spills and rainfall runoff within fertilizer manu-
facturing areas are returned directly to in-plant use or sent to the waste
pond systems for reuse or percolation/evaporation. When the ammonia plant
is operating, a portion of the drainage goes to a Rainwater Pond east of
the plant for percolation/evaporation.
• Rainfall runoff from non-manufacturing areas is discharged to
either the unlined Concentrator Pond system or the Rainwater Pond.
• Historical water use was largely once-through, resulting in
discharge to unlined ponds for percolation/evaporation. Gypsum Ponds
existed since the beginning of operations in 1953. Decant waters from
Gypsum Ponds were siphoned to an unlined percolation/evaporation pcnd
called the Southwest Wastewater Pond. The Concentrator Pond system became
operational in 1964 followed by the Pellet Plant Pond in 1975. Ir 1978,
Gypsum Pond decant water was segregated from Pellet Plant waters, affording
direct reuse of pellet plant waters.
Ag Chem Operations
• Current liquid disposal practices within Ag Chem operations
result in essentially a no-discharge system. Waste liquids and rainfall
runoff are collected in a series of sumps and are pumped to hazardous waste
holding tanks for subsequent disposal at a California approved Class 1
site.
• In-plant waste liquid generation is minimized through maximizing
production runs, use of multi-directional spray nozzles, dry cleanups where
possible and concerted liquid conservation practices.
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• Pesticide workers' clothing is laundered onsite. The resulting
laundry water is treated with caustic and discharged to a septic tank. The
overflow from this tank is discharged to a leach field and percolates.
• Although present liquid waste handling results in essentially a
no-discharge system, this has not been the situation for long. Pesticide
formulation began in 1957 (DBCP) and liquid wastes were discharged to the
Southwest Wastewater Pond for percolation/evaporation. The first hazardous
waste disposal tank was brought on-line on May 24, 1976 with the second
following in 1977. Some liquid wastes may have been discharged to the
Southwest Wastewater Pond as recently as 1979, although exact dates could
not be ascertained.
• Currently, hazardous waste liquids from processing total ap-
proximately 1,100,000 liters (300,000 gal)/ year. In 1976, seven months
after installation of the first hazardous tank, they were estimated to be
2,560,000 liters (676,000 gal)/year. Prior to installation of the tank,
they were estimated to be three times as high as this.
• Some hazardous waste liquids may have been incinerated on< ite in
1970; however this practice continued for no more than six months.
• In 1970 a large number of drums, some apparently containing
liquids, were being stored onsite. In conjunction with the construction of
the incinerator, a drum-handling area was also constructed including a
concrete pad, a drum-rinsing operation, a drum crusher, and a sump to drain
liquids to the Southwest Wastewater Pond. All drums that had been stored
were reportedly cleaned, crushed and disposed of. File correspondence
indicates the shipment of some pesticide drums containing caustic wash to a
drum reconditioner in Oakland, California. The drum-rinsing and decon-
tamination operations at Oxy-Lathrop continued until sometime in 1977 and
some drum crushing still exists.
• There have been three Ag Chem fires in the past, at least one of
which resulted in large losses of pesticide products. The first fire
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occurred in January 1966 at the DBCP plant; the second in July 1975 in the
emulsifiable concentrate area; and the third on January 17, 1976 when the
pesticide warehouse burned down. During the January 17, 1976 fire, large
amounts of SSS tributyl phosphorotrithioate (DEF), methyl parathion and
malathion were lost. Firefighting efforts resulted in large volumes of
water being discharged to the Southwest Wastewater Pond.
• A non-fire related event which may have resulted in loss of
product to the environment occurred in 1979. A leak was detected in a
pipeline carrying ethylene dibromide (EDB). Some soil was excavated and
sent to a Class 1 site. The line was reportedly rinsed, drained and its
use discontinued. In the p?st, this line had carried DBCP.
Solid Wastes
• Solids generated in fertilizer and Ag Chem operations are cur-
rently divided into hazardous and non-hazardous wastes. The hazardous
wastes are collected and transported to hazardous waste dumpsters in the Ag
Chem area for subsequent off site disposal by a contractor at a Class 1
site. Non-hazardous wastes are collected, centralized and hauled by
private contractor to offsite disposal in Lodi, California.
• Some hazardous waste drums are currently hauled to a Class 1 site
for disposal; others are sent to a drum reconditioner in Montbello, Cali-
fornia.
• Information regarding past solid waste disposal practices is
limited. Hazardous waste dumpsters have been in use since at least
August 1974. Prior to and including part of 1970, some hazardous wastes
were disposed of in a burning pit and disposal trench onsite in the
"Boneyard Disposal Area." In 1970 an incinerator was constructed onsite to
burn, among other things, hazardous solid wastes. This incinerator was
disassembled in 1974.
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• Past DBCP operations provided additional sources of solid wastes.
The process included a dryer containing calcium chloride and a filter.
Both the calcium chloride and filter material had to be replaced—every 2
to 3 batches in the instance of the calcium chloride. Both of these
operations included direct contact with DBCP. Disposal practices for these
materials prior to the advent of hazardous waste dumpsters were not as-
certai ned.
PRODUCTION RECORDS REVIEW
Ferti1izer Material Balances
• Based on a review of Oxy-Lathrop records from 1971 to 1978, daily
losses of ammonia (NH3) and phosphates (P205) ranged from 9.4 to 13.8 (10.4
to 15.2) and 3.0 to 7.9 m. tons (3.3 to 8.7 tons)/day, respectively. Daily
losses of potassium (k20) from 1976 to 1978 averaged .09 to 1.2 m. tons
(0.1 to 1.3 tons)/day. These losses included percolation to groundwaters
and atmospheric discharges.
• Data collected by Oxy-Lathrop in 1966 and 1978 indicated fluoride
losses to percolation at 2.59 and 3.15 m. tons (2.85 and 3.47 tons)/day,
respectively. Losses of fluorine to the atmosphere ranged from 18 to 33 kg
(40 to 72 lb)/day or 0.33 to 0.86 lb fluorine per ton of P205.
• Data collected by Oxy-Lathrop from 1978 to 1979 indicated S02
losses ranging from 2.8 to 22.7 m. tons (3.1 to 25.0 tons)/day. On
November 24, 1976 annual losses of S02 were estimated to be 3,600 m. tons
(4,000 tons)/yr or 10 m. tons (11 tons)/day. Although all losses were
assumed to be to the atmosphere, the procedures could not provide for
distinguishing between percolation and atmospheric discharge.
Ag Chem Material Balances
• Two production record types were reviewed: inventory cards that
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listed raw materials and batch sheets that documented formulation of
products. Records were generally available from only 1973 to date, with
some incomplete records for 1971 to 1972.
• At least 84 active ingredients and solvents and 179 other in-
gredients were used from 1971 to 1979.
• Ten materials were used in excess of 454,000 kg (1,000,000 lbs).
Over 1,400,000 kg (3,000,000 lbs) of DBCP were handled from 1971 to 1979.
A computer summary of DBCP production from 1968 to 1977 showed 7,660,949 kg
(16,874,339 lbs); however, the origin of this document could not be ac-
curately described and it .may represent DBCP formulations and/or manu-
facturi ng.
• At least 41 raw materials and products suffered damage or loss
during storage and handling from 1971 to 1979, primarily resulting from the
January 17, 1976 fire which destroyed the Ag Chem warehouse.
• Average finished product losses were 0.79 and 0.70% in 1973 and
1978, respectively. Although these losses are smyll in terms of
percentages, if real, they represent large quantities when considering that
millions of pounds of pesticides were formulated/manufactured.
• An interoffice Oxy-Lathrop memorandum of June 25, 1976 estimated
pesticide losses to the ground at 5 tons/year. During the audit, the
writer of the memo, Mr. Robert Edson, discounted the accuracy of the memo.
However, he could not explain why specific numbers were included for
pesticide concentrations and mass losses which would have presumed the
availability of analytical data to make such an evaluation.
HISTORICAL GROUNDWATER AND SOIL DATA EVALUATION
• Past environmental data collected at or near the Oxy-Lathrop
facilities have documented environmental contamination attributable to
Oxy-Lathrop.
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• Beginning in late 1962 and continuing to present, sulfate con-
centrations in the vicinity of Oxy-Lathrop have exceeded the California's
Central Valley Regional Water Quality Control Board Resolution limit of 100
mg/1. Concentrations of sulfates in one of Oxy's wells, the "Best South"
well, now exceed 2,000 mg/1. These high sulfate concentrations are a
result of Oxy's wet phosphoric acid operation which generates large
quantities of sulfate-laden gypsum wastes.
• At least 27 organic compounds have been detected near the Oxy-
Lathrop facilities in soil, shallow groundwater, and process, irrigation
and potable wells. All these compounds are known to have been handled at
the Oxy-Lathrop plant. Twelve of the compounds are known animal carcinogens,
and one is a suspected animal carcinogen. DBCP is a suspected human carcino-
gen. The adverse health effects inferences of these statements are conserva-
tive since numerous other non-carcinogenic health effects are also known for
the compounds.
• Samples collected by the State of California in the vicinity of
the Oxy-Lathrop facilities have indicated the phosphoric acid operation and
attendant gypsum ponds to be the source of introduction of radioisotopes
into the groundwater. No gross alpha or beta activity was detected to the
east of the plant upgradient of the assumed direction of regional ground-
water movement. Measureable gross alpha and beta activity was found in
wells to the south, west and north of the plant. The majority of the
radioactivity in these samples was attributable to uranium.
AERIAL OVERFLIGHT OF OXY-LATHROP FACILITIES
On September 26, 1979, the Oxy-Lathrop facilities were overflown with
multi-band photography including false color infrared imagery. Certain
areas of land leading westward from the previously used Boneyard Disposal
Area and Southwest Wastewater Pond appeared dark or discolored, and veg-
etation appeared to be degraded. This pattern could have been caused by
leachate leaving the disposal areas.
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III. AUDIT FINDINGS
COMPANY HISTORY
The evolution of the" present Occidental Chemical Company operations
has followed a corporate maze of acquisitions/transfers. In 1953 the Best
Company opened a plant in Lathrop, California which manufactured fertilizer
products under the trade name Best Fertilizers. In 1957, the formulation
of pesticides was incorporated into their burgeoning line of fertilizer
products. The addition of pesticide products resulted in the 1962 con-
struction of a separate Ag Chem production area at the plant site.
In 1963, Best Company was purchased by the Occidental Petroleum
Corporation, which subsequently also acquired the Hooker Chemical Cor-
poration in 1968. The Occidental Chemical Company was formed in 1968
within Occidental Petroleum, absorbing the Best Company. In 1974, Oc-
cidental Chemical Company became a subsidiary of Hooker Chemical Cor-
poration.
Hooker Chemical Corporation purchased Zoecon Corporation, a Palo Alto,
California based company, in June of 1977. Subsequently, in February 1978,
the garden and lawn division of Occidental Chemical's Lathrop operations
was transferred by Hooker to Zoecon. These facilities are located ap-
proximately 1 mile east of the main Occidental Chemical production fa-
cilities in Lathrop. In conjunction with the transfer, Zoecon retained the
Best Products trade name.
PRODUCTION FACILITIES
Production facilities at Oxy-Lathrop are divided into fertilizer and
Ag Chem (pesticide) operations. The fertilizer operation produces sulfuric
acid, phosphoric acid, ammonium sulfate, and a pelletized ammonium
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phosphate-sulfate product. Gypsum and fluorosilicic acid are byproducts
from the production of phosphoric acid. In the past, ammonia*, normal
superphosphate and vanadium pentoxide catalyst were also produced at this
facility. Anhydrous ammonia and the vanadium pentoxide are now purchased
and normal superphosphate operations were terminated in 1972.
The Ag Chem facilities blend and package concentrated pesticides into
formulated, dilute pesticide products for agricultural, home and garden
use. The only pesticide manufactured at this site was l,2-dibromo-3-
chloropropane (DBCP). This was done during the years 1963 to 1971 and 1974
to 1976. DBCP was formulated from 1957 until July 1977.
The following sections describe the individual processes and facil-
ities included in the fertilizer and Ag Chem operations. Detailed flow
charts for each process are available in the NEIC files.
Fertilizer Operations
Table 1 summarizes the past and present fertilizer operations at the
Lathrop facility, including startup and shutdown dates. Those plants with
no shutdown dates are still in operation and include the sulfuric acid,
phosphoric acid, pellet and ammonium sulfate plants. The interrelationship
of the various plants is shown in Figure 1.
Sulfuric Acid Plant
The sulfuric acid (H2S04) plant consists of three single-contact
trains: the first began operation in 1956 and has a production capacity of
113 m. tons (125 tons)/day, the second began operation in 1960 with a
capacity of 204 m. tons (225 tons)/day and the third began operation in
* Ammonia was produced at the California Ammonia Company (Calamco)
adjacent to the Oxy facility which is a co-op with 48% Oxy ownership.
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Table 1
FERTILIZER OPERATIONS
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Plant Startup Rebuilt Shutdown
Phosphoric Acid 1953
Pellet Plant 1954 1972
Sulfuric Acid
No. 1 1956
No. 2 1960
No. 3 1964
Ammonium Sulfate 1958
Ammonia Plant 1958 1979
Normal Super- Prior to 1964 1966 1972
phosphate
Phosphate Ore 1963 1972
Crushing Plant
Vanadium Pentoxide 1965 1968
Plant
Fluorosilicic Acid
No. 1 Concentrator 1974
No. 2 Concentrator 1976
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(38.000
T/Y
'SALES t
85,000 T/Y
2.000 T/Y
SALES
NET SALES
o
o
PURCHASED
SULFURIC
ACID
39,000 T/Y
29,000 T/Y
51,000 T/Y H2S04
PURCHASED FEED
MATERIAL
20,000 T/Y
19,000 T/Y
TYPICAL BALANCE BUT
DOFSN'T NECESSARILY
REFLECT CURRENT PRODUCTION
LEVELS
PURCHASED
MATERIALS
20,000
T/Y
33,000 T/Y
25,000 T/Y
PRODUCT LOSS
135,000 T/Y
105.000 T/Y
SALES
45 000 T/Y
PACKAGED PRODUCTS
SALES
135,000 T/Y
SALES
Figure 1
SULFURIC
ACID
STORAGE
AMM0NIA
STORAGE
100,000 T/Y
NH, IMPORTED
BAGGING AND
WAREHOUSING
FACILITIES
ZOECON PRODUCTS
PACKAGING
PLANT
PHOSPHORIC
ACID PLANT
29,000 T/Y
P2O5
SULFURIC
ACID PLANTS
H2SO4
200,000 T/Y
AMMONIUM
SULFATE PLANT
128,000 T/Y
(NH4)2S04
PELLET PLANT
160,000 T/Y
INTERRELATIONSHIP OF VARIOUS FERTILIZER OPERATIONS* _
OCCIDENTAL CHEMICAL COMPANY ui
Lathrop, California
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1964 with a capacity of 295 m. tons (325 tons)/day. Although design
capacity is about 227,000 m. tons (250,000 tons)/yr, normal production has
been between 181,000 and 200,000 m. tons (200,000 and 220,000 tons)/yr.
Oxy can purchase up to 41,000 m. tons (45,000 tons)/yr from San Francisco
Bay Area sources and has historically been a net purchaser of H2S04 (10 to
15% of that required is purchased). All three plants operate seven
days/week, twenty-four hours/day producing acid that is sold as product or
used in the production of phosphoric acid, ammonium sulfate and in the
Pellet Plant.
The following general process description applies to all three trains.
Molten sulfur (S) is purchased from a Bay Area refinery, trucked to the
Lathrop facility, and stored in heated insulated tanks for processing as
molten sulfur. Piping connects these tanks to an underground pit from
which the sulfur is pumped to a furnace and oxidized with dry air to sulfur
dioxide (S02) vapors. The hot gases pass through a waste heat boiler and
are sent to the single pass converter. In the converter, the S02 is
oxidized further to sulfur trioxide (S03) by contacting oxygen while
passing through three vanadium pentoxide (V205) catalyst beds. The hot
gases pass through a second waste heat boiler, located between the first
two catalyst beds, and a third heat boiler, located after the last catalyst
bed. The S03 vapors are then hydrolyzed to H2S04 in an absorbing tower
where S03 gas flows upward through ceramic packing and countercurrent to
sulfuric acid. S03 is readily hydrolyzed to H2S04 by the water in the
acid. Hydrolysis releases heat, increasing the temperature of the acid.
By sending the acid to an acid pump tank and then through acid coolers, the
temperature increase is offset. From the acid pump tank, the 98.8% acid
product is drawn off, recycled through the absorbing tower, stored, or sent
through a drying tower.
The drying tower produces the dry air required to oxidize the sulfur
in the initial step of the process. Steam and air are mixed in an air
blower to produce moist air that enters the drying tower and travels
concurrently to a 98.8% acid solution. The acid absorbs excess moisture
and is recycled to the acid pump tank. The dried air is sent to the sulfur
furnace.
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Presently, the vanadium pentoxide (V205) catalyst is purchased from
outside sources. However, V205 pellets were produced at Oxy-Lathrop
between 1965 and 1968. In this process, V205 flakes were reduced in size
by a Pulva-Sizer Mill and mixed with dilute (20%) H2S04, water, potassium
hydroxide, sodium hydroxide, and molybdic acid in a stainless steel reactor
tank. This liquid mixture was then combined with dry materials (dicalite
No. 145, sulfur, sulfate of potash, and aqua ammonia) in a Sigma Blade
Mixer. The slurry was sent to an extruder where a feed screw forced the
catalyst into pellets and the pellets fell onto a belt dryer where the
material was dried and conveyed to a rotary kiln. The natural-gas fueled
kiln baked the pellets and dropped them into a squirrel cage cooling screw
and screen. Fines that were screened out were returned to the Pulva-Sizer
Mill and Sigma Blade Mixer and the finished product was stored for bagging.
Phosphoric Acid Plant
Phosphoric acid (H3P04) is produced at the Lathrop facility by the wet
process method in which phosphate rock is reacted with sulfuric acid. The
phosphoric acid plant began operation in 1953 and has a capacity of
41,000 m. tons (45,000 tons)/yr. Since 1963, phosphate rock from Oxy mines
in White Springs, Florida has been shipped to the Port of Stockton and
trucked to the plant. Prior to this time, the ore was purchased from the
Idaho/Wyoming/Utah area. Proximate analysis of phosphate rock from Florida
is shown below:
TYPICAL ANALYSIS3
FLORIDA PHOSPHATE ROCK
Percent
Moisture
P205 (dry basis)
Iron Oxide
Aluminum^Oxide
Fluoride
2.9
32.04
1.0
1.02
3.65
a Certificate of analysis 7/23/79.
b Lab analysis 11/20/78.
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18
No data were available on the radiochemical content of the phosphate rock
processed at this facility.
A phosphate rock crusher was employed from 1963 to 1972 but is no
longer used. Currently, the phosphate rock is loaded from one of the three
storage silos into a rock hopper and fed directly to the reaction tank. The
following overall process reaction occurs in the tank when H2S04 is added:
3 Ca10 (P04 )g F2 + 30 H2S04 + Si02 + 58 H20 -»
30 CaS04 • 2 H20 + ±8 H3P04 + H2SiF6
Gypsum Phosphoric Fluorosi1icic
Acid Acid
The fluorosilicic acid decomposes to SiF4 and HF, but is recovered
later in the water scrubbers after the concentrators. Agitation in the
tank is provided by turbines.
The gypsum/phosphoric acid slurry is pumped to e filter feed tank and
separated by two vacuum filters. The acid is of a 22 to 26% concentration
and is increased to 52% in one of two concentrators.
The filters are backwashed three times using washwaters retained from
previous washes. The third wash is recycled back into the system at the
reaction tank. Fresh water and gypsum pond decant supply the make-up water
needed for the initial backwash. The gypsum cake remaining on the filter
is repulped, ponded, dried, and sold as a soil conditioner/fertilizer
product to local farmers.
The concentrated acid goes through a series of intermediate storage
tanks and a Lamella separator (inclined screen and rake) to remove the
solids. These solids are combined with solids from the concentrators and
sent to the Gypsum Ponding area. The acid is either used in the Pellet
Plant or sold as a product.
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19
Fluorosi1icic acid (H2SiF6) is recovered from the concentrators by
scrubbing the waste gases. This practice began at the first concentrator
in 1974 and at the second in 1976. Prior to this, the fluorine in the
waste gas stream was released to the atmosphere.
As noted previously, normal superphosphate was produced at the Lathrop
facility until 1972; however, no process flow information was available to
the auditors for review.
Ammonia Plant
The ammonia (NH3) plant began operation in 1958 as a cooperative
venture between a farmers' co-op (52% ownership) and Best Fertilizers
(48%). When Occidental Petroleum purchased Best Fertilizers, they also
acquired 48% of the California Ammonia Company (Calamco). The plant has
not been in operation since April 1979, reportedly a result of the high
costs of energy and natural gas. The plant is being maintained, but will
be shutdown for an indeterminate length of time. At the time of the audit,
anhydrous ammonia was being purchased on the open markst and from the
Soviet Union.
Ammonium Sulfate Plant
The ammonium sulfate ((NH4)2S04) plant, which began operation in 1958,
consists of two saturators and four centrifuges serving common equipment.
This plant runs 24 hours/day, seven days/week producing (NH4)2S04 crystals
for sale and for use in the Pellet Plant. A product of 21% nitrogen is
guaranteed from this process. The capacity of the plant is about 116,000
m. tons (128,000 tons)/yr, but normally only 91,000 m. tons (100,000
tons)/yr are produced.
H2S04 and NH3 vapor react in a saturator forming crystals in a
supersaturated solution. Diammonium phosphate is added to control crystal
shape. The solution is centrifuged, separating the crystals from the
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20
liquid. The liquid returns to the saturator while the crystals are cooled,
dried, and screened, using a Tyler Hummer screen. The screen separates the
fine and oversize from the usable crystals. The fine and over-sized ma-
terials are either recycled through the mother liquor tank or stored and
used in the Pellet Plant. The mother liquor tank serves to recycle ma-
terials through the saturators including scrubbing water, fine and over-
sized crystals, sump water, sulfuric acid, ammonia liquid, dust-laden steam
from the dryer and cooling tower blowdown. Vapors from the saturator and
mother liquor tank pass through a scrubber and condenser to remove the
ammonia vapors and the resulting liquid is returned to the mother liquor
tank.
Pellet Plant
The Pellet Plant, which began operation in 1954, produces various
grades of fertilizers. Current production level is about 163,000 m. tons
(180,000 tons)/yr. Sulfuric and phosphoric acids are initially ammoniated,
making slurries which overflow to a mix tank. Phosphoric acid, sulfuric
acid, and ammonia are added in various proportions, depending on the
product desired. The slurry passes to a blunger where ammonium sulfate
crystals are added. The blunger spills the mixture to a gas fired dryer.
The dried product passes through a lump breaker and is then elevated to one
of three screens where a hammermill breaks up the oversized pieces. These
are combined with the fines on the recycle conveyor, where potash (KC1,
KS04), micronutrients (ZnO, FeS, gypsum), and dry bulk are added, returned
to the fines elevator and passed to the blunger. The saleable product
travels by conveyor to one of four warehouses for storage.
Vapors from the mix tank are passed through a Heil Scrubber which uses
process water and this liquid is recycled to the mix tank. Fumes from the
scrubber are passed to a condenser. The condensate is ponded and remaining
vapors are released to the atmosphere. Air from the dryer goes to a
baghouse and then to a condenser. Condensate is piped to a lined pond.
Vapors from the condenser pass through a wet electrostatic precipitator and
the recovered liquid is also ponded. Dust-laden air from the conveyor
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21
and elevator pass through one of two cyclones and then to a baghouse.
Vapors are released to the atmosphere and fines are recycled into the
system via the recycle conveyor.
Ag Chem Operations
Ag chem operations at the Lathrop facility including the approximate
dates of startup and shutdown for each plant are summarized below:
AG CHEM OPERATIONS
Plant
Startup
Rebuilt
Shutdown
Dust Plants
No. 1
No. 2
No. 3
1962
1964
1974
Emulsifiable
Concentrate Plant
1962a
1971b
Granular Plant
1967
DBCP Formulations
1957
Aug. 1977
DBCP Mfg.
1963
1974
1971
1976
Flowable Plant
1969
a Located where No. 3 dust plant is now located,
b Relocated to present location.
Although numerous pesticides are formulated at Oxy-Lathrop, no pesticides
currently are manufactured at this site.
The Ag Chem facility consists of seven plants: three dry plants, a
granular plant, an emulsifiable concentrate plant, a flowable pesticide
plant, a standby reactor capable of producing DBCP, and a facility for
processing spray oils. The operation of these plants is seasonal in
nature; during most of the year there is one shift operating per day, but
this increases to three per day in the winter.
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22
The following sections discuss each of these facilities and the type
of products produced.
Dust Plants
The first dust plant began operation in 1962. It has a capacity
ranging from 454 to 1,814 kg (1000 to 4000 lbs)/batch and is used primarily
for the blending of dusts and pest control agents. The second dust plant
began production in 1964 and has a capacity equal to approximately half the
first dust plant [227 to 907 kg (500 to 2,000 lbs)/batch]. It is used
primarily for processing foliar nutrients. The third dust plant was built
in 1974 and has approximately half the capacity of the second dust plant
[113 to 454 kg (250 to 1,000 lbs)/batch]. It is used in the processing of
wettable powders. One batch of dry product can serve several customers.
Sampling is performed at intervals of 1/3 and 2/3 of the way through each
batch for quality control purposes.
Dry blending begins with the addition of materials at a cut-in hopper.
The material is screw fed to a drag elevator and brought to a ribbon
blender at the top. Liquids can be introduced there through a spray
system. After blending, the product goes to a bagging hopper or to a
pulverizer. The pulverizer reduces particle size and mixes the product
more thoroughly. Usually dusts are packaged in 10, 20, 30, and 50 lb bags.
The No. 2 dust plant combines materials by the same process but has no
elevator or pulverizer. Material is elevated with a forklift to the
blender.
The No. 3 dust plant includes a cut-in hopper, elevator, one mixer, a
microblender, and a small packaging facility capable of packing products in
4 to 12 lb bags. There is no pulverizer.
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23
Granular Plant
The granular plant began operation in 1967 and is used to impregnate
clay materials and fertilizers with pesticides. In most cases a liquid is
applied onto a dry ingredient. Like the dust plants, this is a batch
process with a capacity of 454 to 1,814 kg (1,000 to 4,000 lbs)/batch. The
granular market is a deteriorating one. In the past, this plant made
approximately four or five times as much product as it now does.
In this process, 55-gal barrels of pesticides are either mixed with an
adhesive (oils or molasses) or used directly, if in a liquid state. This
material is either pumped to a batch tank where liquids can be sprayed and
then delivered to a "Munson" mixer or mixed directly. The mixer is the
largest piece of equipment and functions comparably to a cement mixer. A
cut-in hopper spills the clay or fertilizer (granules are between 24 and 48
mesh) to the mixer. An elevator carries the product from the mixer to a
baghouse hopper where it is packaged, usually in 25 to 50 lb bags. Farm
fertilizer is packaged exclusively in 80 lb bags.
Emu!sifiable Concentrece Plant
The emulsifiable concentrate (EC) plant began operation in 1962. Here
liquid products, accountable for the greatest proportion of Ag Chem sales,
are mixed. This plant consists of two batch tanks of 5,300 and 3,785
liters (1,400 and 1,000 gal) capacities, and holding tanks of corresponding
sizes. Batches must be a minimum of 1,320 to 1,510 liters (350 to 400 gal)
and can serve several customers. Products are bottled in plastic, glass
and metal one-gallon containers.
Ingredients are added to a batch tank and mixed through agitation.
Solvents can be pumped directly from 55-gal containers. If the solvents
are viscous, the 55-gal drums can be placed in a hot tank to reduce
viscosity. Active ingredients (i.e., pesticides) are usually added as a
last step. The batch tanks have a recirculating ability. Retention time
ranges between 1 to 4 hours depending on the number of ingredients mixed.
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24
Flowable Pesticide Plant
The flowable pesticide plant began operation in 1969 and mixes high
viscosity products, generally a liquid and a solid, which usually have
short shelf lives. Water and powders are typically used, but oil can be
used instead of water or two liquids, such as water and an organic liquid,
can also be mixed. This plant is idle most of the time due to a decreasing
market -for this type of product.
Two 2,270 liters (600-gal) tanks are available for mixing. Chelated
and complexed metals are added in powder form. Buffers are also added to
control the pH of the mixture. A Cowles Dissolver, the major piece of
equipment which disperses the powder in the liquid, can mix only one tank
at a time. A batch takes 2 to 4 hours to produce.
The product then goes to a drum filler and is packaged in 1 to 5 or
30-gal containers. The 1 to 5 gal containers are more popular now than in
the past and are usually used for foliar nutrients. The 30-gal drums are
used for dormant oils. These were more popular when oil was more commonly
used.
DBCP Plant
DBCP is a compound prepared by bromination of allyl chloride at
ambient temperature. Either alone or in formulations, DBCP was widely used
as a soil fumigant for the control of nematodes and root-knot disease.
Application was made by direct injection into the soil or addition to
irrigation water.
DBCP formulation began in 1957 and continued until July of 1977 when
it was banned by the State of California. Manufacturing of DBCP began in
1963 and continued until 1971, resumed in 1974 and continued until 1976.
It was produced under a license from Dow Chemical Company which owned the
patents for manufacturing of DBCP.
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25
When the DBCP manufacturing plant was operating, the reaction took
place in a glass-lined Pfaudler reactor, which was on weigh-scales and had
a capacity of 13,600 kg (30,000 lbs)/batch. The operation was continuous
(24 hrs)/day until a batch was completed. Two to three batches could be
produced in a week.
The reaction of bromine with allyl chloride is exothermic with
temperature control by bromine addition. Bromine is forced into the
reactor operating at atmospheric pressure using pressurized nitrogen.
Vapors pass through freshwater reflux condensers operating between 38 and
44°C (100 and 112°F) and are returned to the system. After the reaction is
completed, the material is nrutralized using soda ash and dried in a
calcium chloride column. The DBCP is then filtered and stored; filters are
replaced rather than backwashed every few batches. Five tanks were
available for storage but have been cleaned since the ban in 1977 and put
to other uses. After the ban, Oxy recalled the unsold and unused DBCP
products which amounted to 56,247 kg (124,003 lbs) of mixtures of varying
strength. Bulk stocks were returned to Dow Chemical in April and May of
1978. At the time of the audit, some stocks of DBCP were still stored at
the Lathrop site awaiting disposal.
Spray Oils
Spray oils are the largest single liquid pack-out in the Ag Chem
plant. Various spray stocks are stored in tanks located in the Ag Chem
tank farm. These tanks are equipped with recirculating spargers and can be
used for storage of spray stock, blending, or bulk storage or product. The
major products from the blending are contact weed killers. The spray oils
are shipped out through the bulk storage facilities in 19,000 to 26,000
liters (5,000 to 7,000 gal) tank trailers and trucks. Some of the spray
oils are canned out through the EC plant.
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26
MASTER LIST OF OXY LATHROP CHEMICALS
During the September 18 to 28, 1979 process audit of ,the Oxy-Lathrop
facilities, NEIC was provided a series of lists containing the names of all
chemicals thought to have been used or produced by the Company. The lists
contained the names of raw materials, active ingredients, products, in-
organics and organics. The Company lists were evaluated "and summarized.
Separate lists for Ag-Chem active ingredients, solvents and oils, inorganic
chemicals and miscellaneous products and chemicals were prepared (Tables 2
to 5). These lists identified 113 active ingredients, 8 solvents and oils,
45 inorganics, and 18 miscellaneous products. Table 6 contains an addi-
tional 5 compounds which were reportedly purchased for resale but not used
in production.
During the audit, the review of Ag Chem production records showed many
of the chemicals in Tables 2 to 5. In addition, 162 materials were en-
countered that were not previously listed. Table 7 lists these materials.
The nomenclature for active ingredients was readily cross-referenced.
However, because unique production codes were not always available, some
oils and solvents may be listed twice.
WASTE SOURCES AND CONTROL/DISPOSAL
Air Emissions
The air contaminants associated with the Oxy-Lathrop fertilizer and Ag
Chem (pesticide) operations include particulate matter, sulfur dioxide,
acid mist, fluorine compounds, volatile organics, and pesticide compounds.
The potential sources of these emissions and related control equipment are
discussed below.
Fertilizer Operations
Sulfuric Acid Plant - Sulfur dioxide (S02) and acid mist are the
major pollutants emitted into the atmosphere from the three sulfuric acid
-------
Table 2
AG-CHEM ACTIVE INGREDIENTS FROM OXY-LATHROP MASTER LISTS
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
COMPOUND OTHER NAME(S)
Aldnn
Ametryn
Aramite
Azinphos-methyl
Bacillus Thunngiensis
Benefin
Bensulide
BHC
BTB
Cacodylic Acid
Captan
Carbaryl
Carbophenthion
Chlordane
Chlorpyrifus
Chlorthaloni1
Cryol1te
Cube Resins
Dalapan
DBCP
DCPA
DD
DDT
DEF
Destun
Diazinon
Dicamba
Dichlone
Dichloran
Dicofol
Dieldrip
Dimethoate
Dimethrin
Dinocap
Dinoseb
Dioxathion
Dipheramid
Disulfoton
Dithane M-45
Dodine
Dyrene
Endosulfan
Endrin
Epichlorohydrin
EPN
Erbon
Ethion
Ethofumescate
ETDB
Fensulfothion
Fenthion
Ferbam
Folpet
Gibberellic acid
Glyodin
Glytac
Heptachlor
Lindane
Malathion
Maleic Anhydride
Maneb
MCPA
MCPP
Metaldehyde
Metarn-Sodium
Methiocarb
Guthion
Thiuricide, Bakthane
Balan, Benefine
Betasan, Prefar
Sevin
Trithion
Dursban
Dacthal
Dowpan
dibromochloropropane
Telone
Banvel D
Botran
Kelthane
Cygon
Karathane
DNBP
Delnav
Di syston
Cyprex
Anilazine
Thiodan
Norton
EDB, ethylene dibromide
Dasimt
Baytex
Phatton
gamma-BHC
Cythion
MH
Mecoprop
Vapan
Mesurol
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28
Table 2 (Cont )
AG-CHEM ACTIVE INGREDIENTS FROM OXY-LATHROP MASTER LISTS
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
COMPOUND OTHER NAME(S)
Methoxychlor
Methylparathion
Mevinphos
Mexacarbate
Mol1nate
Monocrotophos
Monuron
Nabam
Naled
n-octylbicycloheptene-
dicarboxunide
OVEX
Oxydemeton
Parathion
Parinol
PCNB
PCP
Pentac
Perthane
Phosphamidon
Piperonyl Butoxide
Polyram
Prometone
Propham
Propargite
Propoxur
Pyrethrum
Rotenone
Ryanodine
Sabudi11a
Si 1 vex
Sodium Cacodylate
2,4,5-T
TDE
Temephos
EPP
Terbutol
Terrazole
Tetrachlorvinphos
Thimet
Thiram
TOK
Toxaphene
Tricalcium Arsenate
Trichlorofon
Trif1uralin
Zi neb
Zi ram
Phosdrin
Zectram
Ordram
Azodrin
Dibrom
MGK-264
Chlorfenson
Meta-systox R
Ethyl parathion
Pentachlorom trobenzene
Pentachlorophenol
IPC
Omite
Baygon
2,4,5-TP
DDD
Acephate, Abate
Azak
Garbona, Raban, Stirofus
Phorate
Nitrofen
Dipterex, Dylox
Treflan
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Table 3
SOLVENTS AND OILS FROM OXY-LATHROP MASTER LISTS
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Nitration Grade Xylene
Isopropyl Alcohol
Cyclohexanone
PGSO 2 Oil
99 S Oil
Weed Oil (aromatic oil 54)
Chevron base C oil
Chevron thinner 339
Table 4
INORGANIC CHEMICAL USED AND PRODUCED FROM OXY-LATHROP MASTER LISTS
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Ammoni a
Ammonium Nitrate
Ammonium Phosphate
Ammonium Sulfate
Antimony Oxide
Argon
Bone Acid
Bromine
Calcium Carbonate
Calcium Nitrate
Carbon Dioxide
Clay
Copper Hydroxide
Copper Sulfate
Ferrous Sulfate
Fluosilicic Acid
Gypsum (calcium sulfate)
Iron Sulfur (sulfides and polysulfides)
Lime
Magnesium Oxide
Magnesium Sulfate
Manganese Carbonate
Manganese Sulfate
Molybdic Acid
Phosphate Rock (calcium phosphate)
Phosphoric Acid
Polymers (water treatment)
Potassium Chloride
Potassium Nitrate
Potassium Phosphate
Potassium Sulfate
Si 1ica
Sodium Chloride (de-ionizers)
Sodium Hydroxide
Sodium Chromate (water treatment)
Sulfur
Sulfuric Acid
Superphosphate (dicalcium phosphate type)
Superphosphate (monocalcium phosphate)
Urea
Vanadium Oxide
Water Treatement Chemicals
Zinc Oxide
Zinc Oxysulfate
Zinc Sulfate
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30
Table 5
MISCELLANEOUS PRODUCTS AND MATERIALS
FROM OXY-LATHROP MASTER LIST
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Cop-o-zinc
Adhere
Adjust
Ad-wet
Cocoamine Acetate
Comp-Ad
Dimine 4
Herb Ad
Nutrawet
Double D Oil
Oxy K Foliar Spray
Oxy P Foliar Spray
See White Spray Act.
Sprint 38
Tennacco 500-100
ZNK Spray A
Zinc Chelate 6%
Neutral Zn 52
Table 6
PRODUCTS PURCHASED FOR RESALE BY AG-CHEM
OXY-LATHROP BUT NOT USED IN PRODUCTION
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
TECHNICAL NAME EPA AND COMMON NAME
Atrazine Aatrex
2,4-D and its derivatives
Diuron
DSMA
Simazine Princep
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Table 7
MISCELLANEOUS MATERIALS - 0XY"LATHR0Pa
Lathrop, California
Acetic Acid
Allyl Chloride
Any! Acetate
Citrjs Oi I
Diesel Oil
Ethyl Hexanol
Moiphol1re
Solvent Thinner 347
Excel
Reax 88E
Supersul 50 (thiovet)
Calcium Chloride
Acetic Anhydride
Adsee 775
Aerosil 200 (Cab-o-sil)
Aerosol 0TB
Agrimul J-l
Aqueous Formaldehyde
Aquaflat
Antifoam A
Antifoam H-10
Arquad 20-75
Armeen CD
Atlox 804
Atlox 3403F
Atlox 3409F
Atlox 3431
Atlox 3453F
Atlox 3454F
Atlox 3455F
Atlox 3403F
Atlox 3404F
Attaclay
Calco oil blue liquid
Calcozine green mix, liquid
Calcozine Auramine 00
Calsoft T-60
Casein
Cela torn MP-78
CeI a torn MP
Celite 209'
Kaolin Type 41 Clay
K-nite
Lignosite 458
Lignosite 854
Lorsban 4E
M-4 Clay
Measurol Tech
Metani 1 Yel low Dye
Microcel E
Microcel T-26
Multifllm Defoamer
Nephthalene-Acetic Acid
Nekal WT-27
Nekal BX-78
Neutrallzer M-33
Ninate 401
Nopco 80-50
Nufilm p
Nutra Sol
Nutrawet-Folospray
Naphthol Greer Oye
Cotton Seed Oil
60 Pale Oil
Pine Oil
Spray Stock L
PGS0 1 oil
Pctro Ag
Powdered Bluestone
Propylene Glycol
PVP K30
Sellogen HR
Sellogen W
Semimo I
Sequesterine 30A
Sequesterine 330 Fe
Sequesterine Zn 14%
Shelsol
Sorbitol 70 Solution
Sponto EMC0L HJPZ
Sponto N142B
Sponto 102 0
Sponto N164
Chevron Agent 236-64A
Cottonseed Oi1
Copper-Traco 50%
Dicofol
Qiethylene Glycol
Dipel
Dimethrin
Oioctyl Phthalate
Diphos Premix
Dolomite Ag
Dorflo, Oil
Dowfax 2A1
Dowfax 21
Dow Anol EM
Dowcil 100
Duot Diluent, Chevron
Emgard 2063
Emgard 2066
ES0 (epoxidwed soybean oil)
Ferrif loc
Flo Sul
Folpet (phaltan 50W)
GAFAC-729
GAFAC-Re-610
Geopan-GA-1
Gil sonite
Glycerol 96
Groco 2 Red (oleic acid)
Hampene 6 5% Zn Chelate
Hampene 14% Zn Chelate
Hisi1 233
Hexylene Glycol
Hydrated Lime
Igepal Co 530
Igepal Co 430
Igepal Co 630
Igepal Co 710
Igepal DM-530
Igepal TN-74
Sponto A-69-40
Sponto 139-B
Sponto N-140B
Sponto AK-16-95N
Spray Stock L
Sprint 38
Sudan Blue
Sudan Orange
Sudan Red 0
Sudan Yellow Dye
Sugar
Sulfur
Supersul (thiolux)
Sulframin SXS 40% Liquid
Sulframin LX Flake 85%
Supersul 50 (thioret)
Tamd SH
Tamol TN
Tamol N Micro
Techroangan Nutra-spray
Techmangan (Mn SO,)
Terton K120
T-mulz 121N
T-mulz J39
T-mulz A-02
Thy late
Titanox - RGHT-X (titanium pigment)
Tribasic Copper 53%
Triple 12
Triton X-15
Triton AG 120
Trusorb 30-60 Granules
Tween 80
Versene 100
Versenol 120
Vitamin B-l
VLR-Diluent Clay
Xylene Milling Greer B Oye
a Miscellaneous materials identified during records audit at Oxy-Lathrop which
were not included in Company's master Iists - included are emulsifiers, diluents
antifoam agents and dyes.
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32
plants. Nearly all of the S02 and acid mist emissions are found in the
exit gases from the absorbing towers. In addition to the exit gases, small
quantities of sulfur oxides are emitted from storage tank vents and tank
truck vents during loading and unloading operations and from process
equipment leaks. However, very little data were available on emissions
from these sources.
The exit gases from the three absorbers are vented to the atmosphere
through a common stack with an inside diameter of 162 cm (64 in) and a
stack height of 42.7 m (140 ft). Each absorbing tower is equipped with a
vertical panel York type-S mist eliminator for acid mist control. These
mist eliminators were installed in September 1974 to reduce the acid mist
emission and to bring the plant into compliance with the visible emission
regulation (San Joaquin APCD Rule 401). The measured and allowable S02 and
acid mist emissions are summarized in Table 8.
The acid mist regulation was adopted on May 29, 1979, by the San
Joaquin Air Pollution Control District (APCD) and affected facilities had
until February 1980 to comply. Compliance testing was conducted by the
California Air Resources Board (CARB) in August 1979, '
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Table 8
SULFURIC ACID PLANT EMISSIONS3
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
c
Production S02 h Acid Mist Emissions
Date Rate, T/D Emissions, ppm lb/ton lb/hr
2/24/72
5/19/76 600
Combined
(stack)
4/7/77 No. 1 plant - 150
No. 2 plant - 235
No. 3 plant - 294
4/13/78 630
Combi ned
(stack)
6/30/78 No. 1 plant - 182
No. 2 plant - 190
No. 3 plant - 294
2,095 0.57
1,580 2.92 73
2,050 3.48 22
1,950 4.06 40
2,010 3.03 37
0.267 7
0.316 2.4
0.385 3.1
0.386 3.7
a Based on stack test results,
b Allowable emission 2,000 ppm.
c Allowable emission 0.3 lb/ton of 100% H2S04 adopted 5/29/79.
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34
Phosphoric Acid Plant - The major air pollutants emitted by the
phosphoric acid plant are sub-micron particulates, acid mists, silicon
tetrafluoride (SiF4), and hydrogen fluoride (HF). Fumes and vapors are
generated at the reaction tank, filters, product holding tanks, and the
concentrators.
The fumes and entrained particulates generated at the reaction tank
are collected by an overhead duct, scrubbed in a 2-stage scrubbing system,
and vented through the phosphoric acid fume stack. The 2-stage scrubbing
system, consisting of a prescrubber and packed tower, was designed and
installed by Oxy-Lathrop in 1972. The prescrubber is a horizontal duct
with water sprays and is located over the reaction tanks. The fumes from
the reaction tanks are collected in the duct, quenched with water sprays,
and then sent through the packed tower. The tower is packed with high
density polyethylene spheres 4 cm (1 5/8 in) in diameter to provide greater
turbulence and better gas-liquid contact. Most of the entrained par-
ticulates and acid mist are removed in the prescrubber and the gaseous
fluorine compounds are removed in the second stage of the system. Emission
data from this stack are limited to data contained in the monthly air
pollution reports for November 1975 through August 1^79. These reports
summarize opacity readings for the plant stacks and results of any stack
tests performed during the reporting period. The stack test results are
reported in Table 9. Data to verify the reported results were not provided
during the audit. The allowable emissions from this stack are 20% opacity
and 15 kg (33.8 lb)/hr. Emission data from this process prior to in-
stallation of the fume scrubbing system in 1972 were not available during
the audit.
The San Joaquin County Air Pollution Control District adopted fluorine
emission standards on January 29, 1979 and required sources to submit a
final control plan by February 20, 1979. Oxy requested and was granted an
extension to May 18, 1979. The emission standard is 0.02 lb fluorine/ton
of P205 input. Stack test data collected by the State in 1977 (0.045 lb
F/ton P205) and by Oxy in 1979 (0.03 lb F/ton P205) showed that Oxy did not
meet the standard. The final control plan calls for the phosphoric acid
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35
Table 9
SUMMARY OF STACK TEST DATA3
PHOSPHORIC ACID PLANT FUME STACK
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Date
Opacity
%
Particulates
F1uorine
Gas
Flowrate
kg/hr (lb/hr)
kg/hr
(lb/hr)
m3/mi n
(ft3/min)
2/25/76
5
1.7
(3.7)
0.02
(0.04)
824
(29,106)
4/30/76
10
1.5
(3.3)
0.06
(0.13)
550
(19,430)
5/25/76
10
2.7
(5.0)
0.05
(0.1)
1,008
(35,615)
2/16/79
10
0.4
(0.91)
0.09
(0.19)
812
(28,690)
a Oxy-Lathrop monthly air pollution reports - 11/75 - 8/79.
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36
plant tipping pan filters and the evaporator product tanks to be enclosed
and collected vapors to be routed to the existing scrubber. To prevent the
buildup of fluorosi1icic acid in the scrubber water and to maintain flu-
orine removal, the scrubber blowdown will be routed to fluorosi1icic acid
production facilities. Mist eliminators will also be added to the con-
centrators and the fluorosi1icic scrubbing system. Completion of this
project was reportedly scheduled for the Spring of 1980.
Pellet Plant - The major air pollutants emitted from the Pellet Plant
are particulate matter, ammonia, acid mists, and fluorine compounds. These
pollutants are emitted from the mix tank, blunger (in which fertilizer
pellets are formed), dryer, screens, and conveyors.
Fumes and vapors generated at the mix tank are collected and sent to a
Heil scrubber, followed by a fume condenser, and then vented to the Pellet
Plant fume stack which is 10 cm (4 in) in diameter and 30 m (100 ft) high.
The emissions data taken from the Company's monthly air pollution
reports are summarized in Table 10. The opacity and particulate emissions
complied with the regulations, but the fluorine emission-, from this stack
exceeded the standards (0.02 lb F/ton of P205) recently adopted by the
APCD. Stack test data taken by the State in 1977 (0.52 lb F/ton P205) and
Oxy data reported in an internal March 14, 1979 memo from John Baures to
Bob Edson (0.3 lb F/ton P205) showed that Oxy did not meet the standard.
The control plan calls for emissions from the Pellet Plant mix tank to be
routed through the Pellet Plant dryer burner as secondary air and through
the existing control equipment. This project was reportedly scheduled to
be completed in the Spring of 1980.
The primary sources of particulate emissions from the Pellet Plant are
the blunger, and the pellet dryer. The emissions from the dryer have been
a source of frequent opacity violations and the subject of a number of
variances and compliance plans to meet the opacity rule which was changed
from 40 to 20% opacity in 1974. A history of air pollution control
equipment associated with the Pellet Plant dryer is outlined in Table 11.
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37
Table 10
SUMMARY OF STACK TEST DATAa
PELLET PLANT FUME STACK
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Date
Gas
Flowrate
Opacity
Particulate
Fluorine
NH
'a .
m3/min
(fta/min)
%
kg/hr (lb/hr)
kg/hr
(lb/hr) kg/hr
(lb/hr)
4/29/76
314
(11,081)
20
3.4 (7.6)
0.7
(1.5)
5/27/76
357
(12,603)
15
4.2 (9.3)
13.7
(30.3)
3.4
(7.4)
7/16/77
300
(10,570)
-
6.2 (13.6)
0.8
(1.8)
0.6
(1.4)
12/9/77
306
(10,800)
~
4.0 (8.9)
1.5
(3.2)
2.5
(5.9)
a Note: Scrubber efficiency tests done in 6/9/72 reported the following
efficiencies - particulate - 76%; NH3 - 53%.
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38
Table 11
HISTORY OF AIR POLLUTION PROJECTS ON
PELLET PLANT DRYER AND BLUNGER
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Date Description
1971 High energy scrubbing system was installed
1974 Condenser cooling water system was modified to reduce NH3
loss. Ammonia and ammonium chloride particulates were
causing opacity excursions.
1976 A wet electrostatic precipitator (Electro-Dynactor Model EDY
48-3) was added to the existing scrubbing system which con-
sisted of three-cyclone separators, a venturi scrubber, and
a Polycon entrainment separator. This was added to remove
ammonium chloride and other sub-micron particles that caused
opacity violations.
1978 A sealed blunger feed tank was constructed to recycle air
through the dryer.
1978-79
A 50,000 SCFM pulse jet self-cleaning baghouse was ordered
to replace cyclones and venturi scrubber. Installation was
completed June 30, 1979.
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39
The present control system consists of routing the blunger air to the dryer
and the dryer off-gases through a baghouse, the Polycon condenser (spray
system), wet electrostatic precipitator (Dynactor), and finally to the
atmosphere. This project was completed in June 1979 and appeared to be
functioning properly at the time of the audit.
Additional sources of particulate emissions are the screens and
conveyors. Presently the bucket elevator after the dryer, the screens and
the recycle conveyor are vented to a baghouse to collect the product fines.
The collected fines are recycled to the blunger for pelletizing. Rather
than going to the atmosphere, the baghouse discharge was rerouted in 1976
to provide secondary air for the dryer burners.
Ammonium Sulfate Plant - The major air pollutants associated with the
ammonium sulfate plant are particulates and ammonia (NH3) vapors. These
pollutants are emitted from the dryer, mother liquor tank, and the sat-
urators (crystallizers).
The mother liquor tank is an enclosed vessel, under a slight vacuum,
where the raw materials are mixed and reacted to form ammonium sulfate.
Recycle streams, fines, and dust-laden steam from the dryer are also mixed
in this tank. The mother liquor tank and the saturators are vented to a
packed scrubber and condenser (spray chamber) to remove the particulates
(ammonium sulfate), fines and NH3. This system was installed in 1972 and
originally was vented through the Pellet Plant stack. Presently, this
system is vented through its own stack, but data such as physical dimen-
sions and installation date were not provided during the audit. The
scrubber water comes from the mother liquor tank and is returned to the
tank by a gravity line. The spray chamber water comes from the ammonium
sulfate cooling towers and the effluent is returned to the cooling tower
sump.
Limited information was available on actual emissions, but a stack
test performed in July 1977 indicated particulate emissions of 0.0041
grains/SCF or 0.1 kg (0.3 lb)/hr which was in compliance with the par-
ticulate emission regulation. The opacity readings from this stack were
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40
about 10%, according to the monthly air pollution reports. However, in the
past, high production rates of ammonium sulfate have caused stack emissions
to exceed 20% opacity. If this is true for the present operation, ad-
ditional control equipment or operation at a reduced rate may be needed to
maintain compliance. The ammonium sulfate plant was down for its annual
turnaround at the time of the audit and the emissions from the stack were
not observed.
Miscellaneous Sources
Warehouses - On July 1, 1979, Oxy filed a plan with the APCD to
control fugitive dust emissions from warehouses 1, 4, 5, 6 and 9. The
fugitive dust emissions from the loadout stations often exceeded the
visible emission limitation of 20% opacity during loading operations. The
control plan was intended to bring these emissions into compliance with the
regulations. The plan calls for the loadout stations at warehouses 1 and 4
to be equipped with retractable loading and filling spouts. The units will
be connected to an exhaust fan and the dust will be collected in a bag-
house. Warehouse 9 loadout Station 5, will be completely enclosed and an
exhaust fan will collect the dust which will be routed to an existing dust
collecting system. Warehouses 1, 4 and 6 will be equipped with an ex-
tendable flexible duct that will reduce the amount of product free-fall
during loading to reduce the dust emissions. This abatement plan is
scheduled to be completed in 1980. As an interim control measure, the
products are to be coated with wax to minimize dusting.
Incinerator - A multiple chambered incinerator was operated between
February 1970 and 1974. This incinerator was natural gas-fired with a
maximum waste burn rate of 500 kg (1,200 lb)/hr and a normal burn rate of
270 kg (600 lb)/hr. Oxy personnel interviewed during the audit thought
dry waste materials, including pesticides, were burned in the incinerator
but were not sure if liquid wastes were also burned. However, an Oxy memo
dated January 29, 1979 from Lloyd Thomas to Gregory J. Vervais indicated
that, "all toxic waste, garbage, wood, paper and other small size com-
bustible materials were destroyed in the incinerator." Data on emissions
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41
from this incinerator were not provided during the audit. The incinerator
was taken out of service in 1974 because it could not comply with the more
stringent air pollution regulations adopted during that year.
Ag Chem Operations
Because this facility handles and blends toxic materials, it is
important that work areas are hooded and ventilated to air pollution
control equipment to minimize worker exposure to these materials. Adequate
ventilation of work areas, control of spills, and control of organic vapor
emissions are the major areas of air pollution control associated with this
facility. Each of the plants in the Ag Chem area has its own ventilation
system which, prior to 1978, discharged directly to the atmosphere. In
1978, an old scrubber was converted to a collection chamber and stack for
all plant discharges. Presently all ventilation systems in the Ag Chem
area are vented to the atmosphere through this stack. The following
sections will'describe the existing ventilation system1; in each area of the
facility. Table 12 provides a brief chronology of units installed in the
Ag Chem area since 1962.
The Nos. 1 and 2 dust plants are vented to a common Pangborn baghouse
that previously discharged to the atmosphere, but presently discharges
through the new stack. The following equipment are hooded and vented to
the baghouse (1,190 m3/min): No. 1 dust plant - loader, mixer and bagger
and No. 2 dust plant - loader and bagger.
The granular plant is vented to a baghouse which was installed in
1969. The following points are hooded and vented: batch tank, cut-in
hopper, Munson mixer, bagging hopper, and bagger. Installation of local
ventilation on the flowable plant occurred about the same time as the
granular plant. The mix tanks, and drum filler stations in the flowable
plant are hooded and vented to a 60 m3/min dust collector.
The No. 3 dust plant (wettable powder plant) was constructed in 1974
and included its own baghouse and local ventilation system (2,460 m3/min).
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42
Table 12
CHRONOLOGY OF UNITS IN THE AG CHEM AREA
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Date Description
1962 No. 1 dust plant — started construction
1962 EC liquid line -- built where No. 3 dust plant is now located
1963 Dow DBCP Plant -- started construction late 1963, started
operation under license to Dow.
1964 No. 2 dust plant — start up
1966 Toxaphene storage tank installed
1967 Granular plant constructed and start-up soon after
1969 Local ventilation s/stem installed on granular plant (assume
it included baghouse)
1970 Some waste disposal bins are placed in use
1971 EC plant relocated and enlarged to present location (area
9 on plot plan)
1973 Waste disposal bins and procedures are modified to meet
State regs (regs were not specified)
1974 Relocate offices and install showers
1974 No. 3 dust plant constructed including local ventilation and
baghouse
1974 Small package line which was attached to No. 1 plant was added
to No. 3 plant
1975 Relocated electrical switchgear in EC plant to blockhouse;
remote from package area
1975 Installed rinse system in EC plant equipment
1975 Installed new package and filter system for EC plant
1975 Purchased power sweeper with vacuum collection system
1976 Installed hazardous tank farm away from EC plant area. West
wastewater tank is put into service
1976 Boundary of Ag Chem moves to the South 105 ft.
1977 Installed hot tank for heating technical grade materials and
emulsifiers in EC plant
1978 Local ventilation system placed in service in EC plant
1978 Ag Chem stack with monitoring station installed
1979 Added loading dock to handle hazardous materials more safely
1979 Install activated carbon-solvent recovery system. Awaiting
local APCD approval to operate for a test period.
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43
The following in the No. 3 dust plant areas are hooded and vented: bagging
area, batch mixer, dust hopper and elevator. Following startup and oper-
ation, a study by Oxy indicated that toxic fumes were being emitted from
the wettable powder plant baghouse. As a result, a private consulting
firm, hired to evaluate these findings, calculated that the emission levels
were higher than OSHA standards. Since the fumes discharged at worker
level, a tall stack was recommended to comply with the OSHA standards.
The major sources of fugitive dust from the dry plants are the bagging
areas. Spills, broken bags, overfilling, etc., all contribute to the
problem of fugitive dust. A mobile vacuum sweeper was purchased in 1976 to
sweep dust from the paved areas, thereby minimizing dust and reducing the
possibility of contaminated-rainfall runoff.
As a result of a 1976 Ag Chem fire, the Factory Mutual Company pre-
pared an insurance report and made a recommendation that an exhaust ven-
tilation system be added in the emulsifiable concentrate (EC) building to
remove flammable toxic fumes. A fume collection system in the EC area was
installed in 1977. The following pieces of equipment are hooded and vented
to the fume control system: the mix tanks (2), ba+.ch blending tanks (2),
and the liquid fill stations (2). This system was routed to the old
scrubber and vented to the atmosphere. Tests conducted by Oxy showed that
under certain operating conditions, the organic emissions from the Ag Chem
stack (old scrubber) exceeded the 18 kg (40 lbs)/day limit established by
the APCD. Table 13 summarizes the stack test conducted in 1978 on the Ag
Chem stack. It was determined that the EC plant could not be operated in
compliance with the APCD regulations until a control system was put into
use. The control system chosen was a VIC carbon adsorption system. The
present fume control system collects fumes and vapors from the EC area and
routes them through a VIC carbon adsorption system and discharges them
through the old scrubber. At the time of the audit Oxy was awaiting local
APCD approval of the system in order to operate it for a test period.
DBCP Plant - As noted previously, manufacturing of OBCP began in 1963
and continued until 1971, resumed in 1974 and continued until 1976. The
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44
Table 13
SUMMARY OF STACK TESTS ON THE AGRICULTURAL CHEMICAL STACK
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Date
Organic Emissions
kg/hr (lb/hr)
Process Data
3/31/78
4/20/78
11
3
(24)
(7)
No. 2 dust plant down
No. 2 dust plant down
EC No. 2 line-down
5/17/78
(3)
No. 2 dust plant-down
granular plant-down
Note: Allowable organic emission is 18 kg (40 lb)/day.
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45
exothermic reaction took place in a glass-lined reactor which was equipped
with two freshwater condensers that return the condensate to the reactor.
Bromine, allyl chloride, and DBCP vapors could escape from this system,
especially during an upset condition. The extent of these emissions could
not be determined from data gathered during the audit.
Storage Tanks - Ag Chem facility has 29 storage tanks ranging in
size from 9 to 600 m3 (2,500 to 159,000 gal). These tanks are all fixed
roof tanks and store solvents, technical grade materials and products, etc.
A listing of the storage tanks and data on each tank including material
stored is contained in Appendix A. True vapor pressure data for all of the
materials were not provided and, therefore, a compliance determination with
regulation 410 (Storage of Organic Liquids) could not be made.
In 1976, an estimate of solvent emissions was made by Oxy and reported
to the APCD. These estimates and the transmittal letter are also contained
in Appendix A.
Liquid Wastes
Fertilizer Operations
Present Practices - Considerable water reuse is practiced within the
fertilizer operations at Oxy-Lathrop, as evidenced by Figure 2 which is an
Oxy blueprint dated July 18, 1979 entitled "General Plant-Water Balance
Flow Sheet". The only major fresh water uses included are those in flu-
orosilicic acid production, boilers and cooling tower makeup at the
ammonia, H2S04 and ammonium sulfate plants. Although historically the
major use was in the ammonia plant (Calamco) cooling tower, the termination
of those operations left the H2S04 cooling water as the major freshwater
use.
Currently, process wastewaters go to one of three water cycles: the
Gypsum (gyp) Ponds, the Pellet Plant Pond or the Concentrator Pond
[Figure 3].
-------
WELL
40GPM 6UKCMt(l)
to 6PW set nQTfc(t)
VAPOR
u:
ocainac
'"1
CO»l"tKTRATOP COOLING POUD
cLlUT PL Ml PQKID
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CONFIDENTIAL
motes
(I) ALL
Of- EACH S*C£AM
(2} ISTI MATtO, iJOT CONPi^WttO
(3) POSSIBLE AlTEOMATE FOUTE
(4) LIMIS SHOWN
general plant
RATtS REPRtStNT THE WATER PORTION
WATER
BALANCE FLOW SHEET
are closed loops
FIGURE 2. PLANT FLOW DIAGRAM - 7/18/79
Occidental Chemical Company
Lathrop, California
-to
cr»
-------
—
Q
O
CC
<
o
-N-
CONCENTRATOR
POND
RAINWATER
POND
COOLING POND
OVERFLOW DITCH
PRODUCTION
AREA
AGRICULTURAL
CHEMICAL
PRODUCTION
AREA
PELLET
PLANT
POND
BONEYARD
CENTRAL
STORAGE AREA
AG CHEM SUMP
SOUTH-
WEST
WASTE-
WATER
POND
Figure 3
PLANT AND DISPOSAL SITE SCHEMATIC
OCCIDENTAL CHEMICAL COMPANY
Lathrup, California
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48
Gypsum, resulting from the wet phosphoric acid operation, is slurried with
water to the unlined ponds south of the plant. On a wet weight basis,
approximately 5 lbs of gypsum is generated per lb of P205 produced (4.6
lbs/lbs on dry weight basis). Water is decanted from the gyp with moveable
weirs into a ditch followed by collection in sumps and returned to the gyp
water-holding tank for reuse. Water not decanted from the gyp is lost to
the environment through a combination of percolation and evaporation.
During the process audit, Mr. Robert Edson, Technical Services Manager,
estimated these losses to be approximately 100 gpm based on meter mea-
surements, of which 5 to 10 gpm was thought to be a result of evaporation.
Dried gyp, once windrowed and disked, is hauled away for sale to local
farmers as a soil conditioner.
Pellet Plant wastewaters are discharged to a pond system located on
the east side of the plant for cooling prior to recycle to the pellet plant
for reuse in cooling and product [Figure 2]. The Pellet Pond is approx-
imately 2 ha (5 acres) in size and 1.5 m (5 ft) deep, underlain with a 7.6
cm (3 in) thick hydraulic asphalt liner. Design specifications for the
. s
asphalt liner called for a permeability of less than 10 cm/sec. Testing
by Oxy has reportedly indicated the permeability to be approximately three
_6
times better (i.e., 0.3 x 10 ) than this design criterion. According to
Mr. Edson, percolation losses are estimated to be 3 gpm.
Wastewaters entering the unlined Concentrator Pond immediately
northwest of the plant primarily originate at the phosphoric acid plant
barometric condensers (referred to as "concentrators"). These waters are
cooled by thermal evaporation and returned for reuse in the condensers.
Percolation losses, according to Mr. Edson, are approximately 100 gpm based
on past measurements.
All in-plant liquid spills and rainfall within the fertilizer man-
ufacturing areas are handled in the following manner:
1. Phosphoric Acid Plant - The manufacturing area is on a concrete
slab with curbing which carries liquid drainage to a sump for
return to in-plant use.
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49
2. Ammonium Sulfate Plant - Liquid drainage is caught within curbing
and drained to a sump and returned to in-pi ant use.
3. Pellet Plant - Liquid drainage is collected and discharged to the
previously described Pellet Plant Pond for return to in-plant
use.
4. H2S04 Plant - Although this area is not curbed, drainage is
carried to the so-called "Rock Sump" and then discharged to the
Concentrator Pond for return for in-plant use.
5. "Ammoni.-" Plant - When this plant is operating, a portion of the
drainage goes to the Rainwater Pond located east of the plant and
a portion goes to the Concentrator Pond for return to in-plant
use.
Most rainfall runoff from non-manufacturing areas is discharged to the
Concentrator Pond for return for in-plant use. However, the runoff from
the plant parking lot and the north end of the warehousing area drains to
sumps from which it is pumped to the unli jed Rainwater Pond on the north-
east side of the plant for percolation and evaporation.
Past Practices - Although wastewaters within the fertilizer plant
areas are now for the most part segregated and returned to the respective
plants for reuse, historical water uses were largely once-through, as
evidenced by Figure 4 which is an Oxy blueprint dated May 9, 1967 entitled
"General Plant Flow Diagram - Process Wastes (Existing Flows)". Virtually
all wastewaters not returned directly, such as waters from the H2S04 and
ammonia plant cooling towers (ammonium sulfate cooling tower not brought on
line until approximately 1972), made their way to an unlined 4.4 acre pond
hereinafter referred to as the "Southwest Wastewater Pond" [Figure 3]
Wastewaters entering the Southwest Wastewater Pond either percolated or
evaporated since there was no return to in-plant use. Based on interviews
with plant personnel and a review of internal records available to the
audit team, the following was ascertained. Gyp ponds have existed at the
-------
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Occidental Chemical Company
Lathrop, California
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-------
51
facility since the startup of the phosphoric acid operations in 1953;
however, originally they were located farther to the north than at present,
partially under what is now a warehousing area near the current Concen-
trator Pond. Construction of ponds in their present locations began in
1974 or 1975. Waters decanted from the gyp ponds were syphoned to the
Southwest Wastewater Pond for percolation and evaporation. This continued
until 1975 when the Pellet Plant Pond was completed. At that time gyp
decant waters were collected and discharged to this new pond for reuse in
the Pellet Plant. The gyp decant waters were finally segregated out of the
Pellet Plant Pond in late 1978 for reuse in the phosphoric acid plant water
cycle.
Pellet Plant wastewaters, as well as those generated in the ammonium
sulfate, phosphoric acid, and sulfuric acid plants were collected in a
series of sumps and discharged to the Southwest Wastewater Pond for per-
colation and evaporation. As noted previously, the Pellet Plant Pond was
completed in 1975 affording reuse of the Pellet Plant and gyp decant
wastewaters. Wastewater discharges from the ammonium sulfate plant were
essentially eliminated in 1972 with the construction of the aforementioned
cooling tower.
In 1964, the first unlined Concentrator Pond was constructed to allow
reuse of waters back into the phosphoric acid plant concentrators. This
pond system was expanded again in approximately 1974. Any excess waters
generated in these pond systems overflowed to the south to the Concentrator
Pond Overflow Ditch [Figure 3] which drained waters to the Southwest
Wastewater Pond either by gravity or via an alternate sump and pump located
adjacent to the Southwest Wastewater Pond. According to Mr. Robert Edson,
the Concentrator Pond also has overflowed at times onto the adjacent Libby
Owens Ford property.
Piping for wastewaters generated in the sulfuric acid plants was
rerouted to the Concentrator Pond system in approximately 1975; however,
even as recently as late 1978, some drainage could instead go directly to
the Southwest Wastewater Pond.
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52
Wastewaters generated in the ammonia plant were probably discharged to
the Southwest Wastewater Pond. Oxy personnel interviewed were not certain
if they might have gone to the old firepond instead but this would seem to
have generated excess water which would have had to go to the Southwest
Wastewater Pond anyway. After completion of the Concentrator Pond system
in 1964, these wastewaters were rerouted to it for either reuse in the
phosphoric acid concentrators or overflow to the Southwest Wastewater Pond
via the Concentrator Pond Overflow Ditch. A portion of the ammonia plant
wastewaters were diverted to the Nash tank for in-plant reuse at some point
in time which could not be ascertained during the audit, but even then
there were excess waters which went to the Concentrator Pond system.
During at least a portion of the time the ammonia plant operated, an
onsite C02 plant not owned by Oxy also contributed wastewaters to the
Concentrator Pond system. This plant processed off-gases from the ammonia
plant. Oxy personnel interviewed during the audit were not certain as to
whether or not this C02 plant contributed wastewaters directly to the
Southwest Wastewater Pond prior to the advent of the Concentrator Pond
system in 1964.
According to Oxy personnel interviewed during the audit, throughout
the history of the plant a Rainwater Runoff Pond has probably existed to
the east of the plant [Figure 3]. Runoff which didn't drain to this pond
or percolate directly would have drained to the Southwest Wastewater Pond
for percolation and evaporation.
Aq Chem Operations
Historical information relating to Ag Chem operations had to be pieced
together from a number of sources, including internal memoranda and re-
cords, and interviews with Oxy personnel during the audit. The Oxy-imposed
ground rule for interviewing employees was that no one would answer
questions regarding periods of time when they were not a supervisory
management employee. This meant, for example, that despite the fact that
Mr. David Crockett has been at the plant since 1960, working in the Ag Chem
-------
53
area since the early 1960s, questions regarding times prior to "late August
1974" would not be answered since that was when he became the Ag Chem
manager. Past managers, with the exception of Mr. Donald Mueller who only
served in the job briefly in 1966, were reported to be no longer working at
Oxy-Lathrop. Despite this apparent lack of first-hand memory, significant
detail can be gleaned from the combination of sources of information.
Present Practices - Current liquid disposal practices within Ag Chem
operations result in essentially a no-discharge system. The primary source
of waste liquids within these operations are rinses of equipment between
batches. Since the products are either water soluble or contain a
petroleum-bised carrier, rinses are performed with water, a caustic (NaOH),
soda ash or commercial product) and water solution or a solvent. Ag Chem
production runs are scheduled monthly to maximize durations and minimize
the frequency of rinses. Four to 25 cleanups/month are performed in the
emulsifiable concentrate area. Cleanups in the so-called "dry plants" are
performed with approximately 300 to 500 lbs of an inert dust which is
generally flushed through the equipment four times. These dusts can be
reused and, as will be described later, once they are spent, they are
handled as a dry-hazardous waste. Tho only need for liquid rinses in these
dry plants is a water rinse if maintenance of equipment is scheduled to
follow a production run.
Volume of liquid rinses within the "wet" processes in Ag Chem is also
minimized through use of multi-directional spray nozzles first installed in
1975. Where possible, solvent rinses are collected and stored for sub-
sequent reuse in production runs. Similarly, solvent-based product spills
are recovered where possible for reuse.
Spills which cannot be recovered, water and caustic rinses and un-
recoverable off-spec liquid batches are discharged to one of three sump
systems. The first encompasses the dry blending, flowable pesticides and
DBCP processing areas which all drain to a sump adjacent to the DBCP
reactor. The second sump system drains the emulsifiable concentrate (EC)
-------
54
process area and a tank farm area to a sump adjacent to the EC plant. Both
of these sump systems are pumped to one of two @ 568,000 liters (150,000
gal) hazardous waste storage tanks located in the Ag Chem area. These
tanks are in a paved area surrounded by a dike with a volume of 774,000 liters
(204,479 gal) allowing 6 in. of freeboard. According to plant officials,
the current yearly volume of these process waste liquids is estimated to be
1,100,000 liters (300,000 gal). The first of the two hazardous waste tanks
was put into service on May 24, 1976; the second followed in 1977.
A third sump system collects rainfall runoff in the Ag Chem area, all
of which is asphalt lined. This runoff is also pumped to the hazardous
waste storage tanks and was estimated by Mr. Crockett to be approximately
3,400,000 liters (900,000 gal)/yr [190 to 230,000 liters. (50 to 60,000 gal)
of runoff per inch of rain].
Wastes collected in the two hazardous waste storage tanks are hauled
by truck to California-approved Class 1 sites for subsequent disposal.
According to Mr. Crockett, Oxy originally v/as contracting with Cal Tank
Company to haul to the West Contra Costa Class 1 site in Richmond, Cali-
fornia and then switched to use of the IT Class 1 site in Benicia,
California. Recently, Oxy began using both Cal Tank and McKay Trucking to
haul to the Environmental Disposal Service Class 1 site at Kettleman Hills.
Some concentrated liquid solutions are put into drums and hauled by truck
to the West Contra Costa and Coalinga, California sites. All these waste
liquids are reportedly manifested per State of California Department of
Health Services requirements.
A reportedly small volume of hazardous waste liquids are also brought
over from the nearby Zoecon Inc. plant for storage in Oxy's hazardous waste
tanks and subsequent disposal.
Pesticide workers' clothing is laundered onsite. The resulting
laundry water is treated with caustic and discharged to a septic tank
behind the Ag Chem offices. The overflow goes to a leach field and per-
colates.
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55
Past Practices - Although present liquid waste handling in Ag Chem
operations results in essentially a no-discharge system, this has not been
the situation for long. According to information provided during the
audit, Ag Chem plant construction began in 1962 and was completed in 1963.
On the face of it, this would mean wastewaters were generated beginning in
approximately 1963. However, other information provided indicated DBCP was
formulated from 1957 to July 1977 and manufactured onsite from 1963 to 1971
and 1974 to 1976. Hence some pesticide-contaminated waste liquids would
have been generated from 1957 on. Information was not available as to
whether or not other pesticides were formulated prior to 1962 to 1963.
Written records regarding Ag Chem liquid waste handling practices
prior to 1965 were not available. On February 11, 1965 a State inspector
for the California Regional Water Quality Control Board, Mr. P. E.
Jepperson, visited the plant and noted that certain pesticide packaging
building wastewaters were being discharged to percolation ponds (presumably
the Southwest Wastewater Pond) following treatment with caustic soda. An
Oxy blueprint dated May 9, 1967 entitled "General Plant Flow Diagram-
Process Wastes (Existing Flows)" [Figure 2] shows DBCP plant washdown
waters and "Dump Solvent" and washdown v iters from the Ag Chem warehouse
areas being pumped to the Southwest Wastewater Pond. No other written
information appear to exist until an exchange of letters in 1970 between
the State of California Regional Water Quality Control Board and Oxy.
These letters primarily concerned themselves with the so-called "Boneyard
Disposal Area", which will be discussed under the "Solid Wastes" section of
this report, and proposed future disposal methods. There was discussion of
incineration of certain liquid wastes; however, these are indications that
this practice of incinerating liquids could have been no more than six
months duration following startup of the incinerator in 1970. The 1970
correspondence related to, among other things, the construction of a
concrete pad near the incinerator to store empty drums. This was located
just west of the present instrument and electrical building. There are
indications that in 1970 there were perhaps as many as 8,000 empty and
partially filled drums standing in the boneyard area. In a January 29,
1979 internal Oxy memo from Lloyd Thomas to Gregory J. Vervais, Mr. Thomas
stated, "A drum crusher was built in early 1970 and all drums stored in the
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56
boneyard were cleaned, crushed and disposed of by the superintendent of Ag
Chem." According to Mr. Crockett, at least some drums have been crushed
on a routine basis up to and including the present. A concrete sump was
also present, presumably to carry contents of drained drums to the South-
west Wastewater Pond. The file correspondence from 1970 also indicates the
shipment of some drums containing spent caustic wash from pesticide de-
contamination to Meyer Drum Company in Oakland, California. Since 1974
some hazardous waste drums have been sent to a drum reconditioner (now S.
Rose Cooperage in Montbello, California). According to Mr. Crockett, Ag
Chem also had a drum rinsing and decontamination operation until sometime
in 1977.
Conversations with present Oxy employees who also were at the plant
during these periods in question would likely have shed considerable light
on past disposal practices. However, the previously mentioned ground rule
restricting interviews to supervisory management employees precluded this.
Consequently, the official Oxy recollection available to the government
auditors began in late August 1974 with Mr. David Crockett. According to
Mr. Crockett, all three Ag Chem wastewater sump systems previously de-
scribed were in place then. Two of the three have since been reworked and
the DBCP plant sump was about 3 m (10 ft) from where it currently is
located. In-plant efforts were made to collect unrecoverable bad batches
(i.e., ones that could not be reworked), equipment drainage and unrecov-
erable solvent rinses and send them to a Class 1 type site. It was ac-
knowledged though that some solvent rinses, as well as all water and
caustic rinses, went to the sump systems for onsite disposal. This dis-
posal included pumping of the sump's contents to the Concentrator Pond
Overflow Ditch via a pipe located just north of the present hazardous waste
tanks. Once in the Concentrator Pond Overflow Ditch, the liquids flowed
south several hundred feet to a sump area from which they could either be
gravity fed or pumped into the unlined Southwest Wastewater Pond [Figure 3].
Once in the pond, liquids either evaporated or percolated to underlying
groundwaters.
-------
57
Regarding volume of process liquid wastes generated in Ag Chem
operations, very little written information was available to the auditors.
In a December 6, 1976 internal Oxy memo from Mr. Robert Edson to Mr. J.
Lindley, yearly estimates were stated as 2,560,000 liters (676,000 gal).
These were made seven months after installation of the first hazardous
waste tank. In the memo, Mr. Edson indicated that discharges prior to the
installation of the tank may have been as much as three times as high as
this.
Interviews with plant personnel indicated there have been three Ag
Chem fires in the past, at least one of which resulted in large losses of
pesticide produrts. The first fire occurred in January of 1966 at the DBCP
plant as a result of a ruptured bromine line. Mr. Don Mueller, who was in
charge of Ag Chem operations briefly during this time, recalled the fire as
being a gas fire above the DBCP reactor. He did not think the reactor
ruptured but it had to be rebuilt. He could not remember whether or not
the contents of the reactor were ruined and, if so, whether or not the DBCP
was dumped to the sewer system which would then have carried it to the
Southwest Wastewater Pond. However, an internal memorandum of February 17,
1967 from Mr. Jack Horner to Dr. W. L. G .rman indicated there were losses
of product during the fire. Whether these were to the atmosphere and/or
the drainage system was not stated. During the audit interviews, Mr.
Crockett also recalled losses of product during this fire.
The second fire occurred in July 1975 in electrical switch gear in the
emulsifiable concentrate area. According to Mr. Crockett, some solvents
burned but loss of product was minimal.
The third fire, which definitely resulted in a large loss of product,
occurred on January 17, 1976. The pesticide warehouse burned down and in
the fire fighting efforts, large volumes of water were applied. This
resulted in runoff to the sewer system and subsequently to the Southwest
Wastewater Pond, as well as excess runoff to the storage area immediately
west of the Ag Chem area. According to Mr. Crockett, large quantities of
SSS tributyl phosphorotrithioate (DEF), methyl parathion and malathion were
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58
lost in the fire. An Oxy report was issued on March 16, 1976 and is
available in the NEIC files.
Another non-fire related event which may have resulted in loss of
product to the environment occurred in 1979. A leak was detected in a
pipeline carrying EDB which historically had carried DBCP. The pipe was
found to be corroded. Some materials were excavated and sent to a Class 1
site. The line was reportedly rinsed, drained and its use discontinued.
The point in time at which discharge of Ag Chem wastewaters to the
Southwest Wastewater Pond ceased could not be ascertained. In an inter-
office memo of April 12, 1977 from Dave Crockett to A1 Osborn, Mr. Crockett
indicated that the non-hazardous Ag Chem wastewaters (estimated by Crockett
to be 50% of total liquid wastes) were being pumped to the Southwest
Wastewater Pond. Another inter-office memo of April 28, 1977 from
Evangeline Boykin to A1 Osborn recommended the preparation of an AFE
(Authorization for Expenditures) to construct a second hazardous waste
tank. According to Ms. Boykin's memo, "After the tank is installed, there
will be no further discharges of Ag Chem wastewaters to the ground." This
tank was completed and put into s'-rvice in 1977. However, a May 12, 1977
inter-office memo from R. Edson to E. Boykin indicated that at least some
possibly contaminated rain runoff would continue to be allowed to drain to
the pond. On January 5, 1979 R. Edson, in another inter-office memo to
"Distribution" stated, "We do not have any flow in our waste disposal ditch
today. We should all get together and try not to start this flow again."
Whether or not this indicated there had been discharges recently, or if
they resumed, could not be ascertained.
Sol id Wastes
Fertilizer Operations
Present Practices - Solid wastes generated in the fertilizer oper-
ations are currently classified by Oxy as hazardous or non-hazardous. The
hazardous wastes include asbestos insulation, vanadium pentoxide catalyst
-------
59
screenings, sulfur spills, bags from air pollution control baghouses, and
miscellaneous spills, etc. All these wastes are collected and transported
to hazardous waste dumpsters in the Ag Chem area. These will be discussed
in more detail below under "Ag Chem Operations."
All wastes designated as non-hazardous are collected, centralized and
picked up by the A1 Fuller Waste Handling Company for offsite disposal at
the Harney Lane Disposal Site in Lodi, California.
Past Practices - Information regarding past solid waste disposal
practices is limited. The A1 Fuller Company has been picking up non-
hazardous wastes since 1970. Whether or not this included some hazardous
wastes as well could not be ascertained. According to Mr. Crockett,
hazardous waste dumpsters were in existence in late August 1974, which
presumably received hazardous wastes from fertilizer operations. Letters
between the State of California and Oxy in 1970, pictures in State files,
and conversations with former plant personnel indicated that prior to and
including 1970, there was a burning pit and disposal trench in the so-
called "Boneyard" area west of the plant [Figure 2]. On July 27, 1970, Oxy
notified the State in writirj that use of these pits/trenches was being
discontinued. The previously referenced incinerator which went into
service in February 1970 undoubtedly was used to incinerate some solid
waste from fertilizer operations until it was discontinued and disassembled
in 1974.
Ag Chem Operations
Present Practices - All solid wastes generated in Ag Chem operations,
with the exception of items such as empty bags of inert additives (e.g.,
clays), are considered hazardous by Oxy. The few exceptions are collected
and disposed of with non-hazardous fertilizer operations wastes. Hazardous
solid wastes include solids manually collected from the sumps described
under "Liquid Wastes", floor sweepings, dry blending residuals (both dry
cleaning materials and dry product), off-spec and unsalvageable product,
dust collection system residuals, dry product spills, empty bags and
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60
containers, and spent baghouse bags. These materials, except the metal
drums, are collected and hauled to onsite hazardous waste dumpsters which,
when full, are hauled by truck to a Class 1 site for disposal. Some con-
tainers, such as 5-gal pails, are crushed first onsite and then placed in
the hazardous waste dumpsters for subsequent disposal. Some drums are
hauled by flat bed trucks to a Class 1 site. Other drums are sent to a drum
reconditioner, S. Rose Cooperage, in Montbello, California, which is
reportedly licensed by the State to receive such drums.
Past Practices - As noted previously, some hazardous waste dumpsters
existed when Mr. Crockett assumed the Ag Chem manager's position in late
August 1974. Presumably, all these wastes were hauled to a Class 1 site.
To the best of Mr. Crockett's knowledge, no pesticide waste containers were
disposed onsite (e.g., by burial) after he assumed the position.
Information regarding the practices used prior to late August 1974 is
limited. The previously referenced State/Oxy correspondence in 1970 as
well as State file photos document the use of onsite disposal areas in the
Boneyard Area west of the plant. These disposal trenches were filled in
in 1970 and graded o>ar. Apparently one trench area was primarily used
as a burning pit and another was a disposal trench for at least some pesti-
cide waste containers.
Another potential source of hazardous wastes was in the DBCP oper-
ations. According to information provided by Mr. Crockett, finished DBCP
was sent through a dryer contacting calcium chloride and then filtered.
Spent calcium chloride was removed after every two to three DBCP batches.
Similarly filter media (type not ascertained) would also have had to be
removed periodically. Both of these spent materials would likely have
contained some DBCP. Disposal procedures for these materials prior to the
advent of hazardous waste dumpsters were not ascertained.
PRODUCTION RECORDS REVIEW
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61
Fertilizer Material Balances
Ammonia, Phosphates and Potassium Losses
Annual losses (1971 to 1978) of ammonia (NH3), phosphates (P205), and
potassium (K20) from the fertilizer operation are summarized in Table 14.
These annual losses were compiled from quarterly fertilizer material ac-
counting reports and estimates made by Oxy.
Prior to 1972, material accounting was geared to production and was
based on "factors" used to calculate production figures. These factors
reflected recovery efficiencies and were used to plan production and sales
schedules. Since 1972, detailed material accounting reports for NH3, P205
and K20 were prepared on a quarterly basis. These quarterly material
accounting reports were based on material balances and were prepared to get
a better handle on losses and to reduce these losses if possible. The
material balances were derived from purchase records, production data,
inventory and shipping data, and pond water inventories. Rather than using
"factors" to determine material in and out, the majority of the data were
derived from measurement and analysis of all solid and liquid material
onsite, including pond water inventories. Compiling data in this manner
provided a more accurate accounting of material. Losses were estimated by
a "forced" material balance (i.e., in-out = losses). Losses from over-
formulation, bag weight averages, and losses to the wastewater pond were
taken into account. The remainder of the losses were unaccounted for and
were assumed to be lost to pond percolation and atmospheric discharge.
Oxy-Lathrop1 s estimates of these losses are summarized in Table 15.
Average daily losses of NH3 ranged from 9.4 to 13.8 m. tons (10.4 to 15.2
tons)/day; losses of P205 ranged from 3.0 to 7.9 m. tons (3.3 to 8.7
tons)/day and losses of K20 ranged from 0.09 to 1.2 m. tons (0.1 to 1.3
tons)/day.
Fluoride Losses
The data on fluoride losses provided by Oxy during the audit are
-------
62
Table 14
ESTIMATES OF
ANNUAL NH3, P205 AND K20 LOSSES3
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
NHa
P,0R
K,0
annual loss-% of input
(daily loss, tons)
annual loss-% i
(daily loss,
of input
tons)
annual loss-% of input
(daily loss, tons)
1978
4525 - 3.74%
(12.4)
3642 - 7
(10.0)
.82%
937 - 7.81%
(2.6%)
1977
5251 - 4.9%
(14.4)
2745 - 6
(7.5)
.65%
482 - 4.73%
(1.3)
1976
5951 - 5.5%
(16.3)
3471 - 9
(9.5)
.7%
1134 - 0.8%
(3.1)
1975
4836
(13.2)
4689
(12.8)
-
1974
7082
(19.4)
7281
(19.9)
-
1973
4437
(12.2)
4635
(12.7)
-
1972
4171
(11.4)
4271
(11.7)
-
1971
4165
(11.4)
4844
(13.3)
-
a Quarterly Fertilizer material accounting reports provided by Oxy for
1976 through 1978. 1971 through 1975 data based on Oxy memo dated
1/11/77 summarizing annual losses.
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63
Table 15
ESTIMATES OF
POND PERCOLATION AND
ATMOSPHERIC DISCHARGE LOSSES
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
NH^ Pg0s M.
annual losses
(daily), tons
annual losses
(daily), tons
annual losses
(daily), tons
1978 4346 (11.9)
3160 (8.7)
311 (0.9)
1977 4987 (13.7)
2100 (5.8)
43 (0.1)
1976 5554 (15.2)
2817 (7.7)
476 (1.3)
1975 3799 (10.4)
1217 (3.3)
1974 thru
1972
3799 (10.4)a
3799 (10.4)a
1217 (3.3)a
1971b
1683 (4.6)
a Data based on 1975 figures,
b Material balance for P205 only.
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64
summarized in Tables 16 and 17. The results of material balances done in
1966 and 1978 are given in Table 16 and include estimates of fluoride lost
through pond percolation. The atmospheric losses are summarized in Table
17 and include estimates from Company personnel and results of State tests.
The material balances calculated by Oxy-Lathrop personnel were per-
formed for a 10-month period in 1966 and a 6-month period in 1978. The
material balances were based on production and shipping records and on
analysis of material samples. As shown in Table 16, the estimated loss of
fluoride to pond percolation (including concentrator ponds) was 2.59 m.
tons (2.85 tons)/day in 1966, and 3.15 m. tons (3.47 tons)/day in 1978.
The estimated losses of fluorine to the atmosphere [Table 17] were
compiled from the previously mentioned material balances, Company esti-
mates, and State tests. The Company estimates and State test results were
ascertained from correspondence relating to fluoride emissions. Background
data, such as.a copy of State test report, were obtained from sources other
than the audit. The data reported in Table 17 are reported in two forms to
give a common basis for comparing the estimates. The losses of fluorine to
the atmosphere range from 18 to 33 kg (40 to 72 lb)/day or 0.33 tf> 0.86 lb
fluorine/ton of P205. These emissions are substantially higher than the
emission standard of 0.02 lb fluorine/ton of P205 recently adopted by the
San Joaquin County Air Pollution Control District. At the time of the
audit, Oxy was implementing a compliance schedule to meet this standard.
Sulfur Losses
Sulfur losses for 1978 and 1979 were taken from material balance data
provided by Oxy during the audit. Material balance data for previous
periods were not available for review. The sulfur dioxide (S02) losses as
estimated from the material balances are summarized in Table 18. The S02
losses to the atmosphere ranged from 2.8 to 22.7 m. tons (3.1 to 25.0
tons)/day, with an average daily loss of 13.6 m. tons (15 tons)/day for the
1978 to 1979 period. An internal memo dated November 24, 1976, from Sy
Bensky to Distribution indicated annual losses of S02 at 3,600 m. tons
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65
Table 16
FLUORIDE LOSSES FROM MATERIAL BALANCE DATA
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Time Period and Net Loss to Losses to Pond Losses to Unaccounted
Source of Data Concentrator Percolation and Atmosphere Losses
Ponds Evaporation
(Total Tons Lost/Avg Daily Tons Lost)
1/6 - 11/1/663 694/2.3 168/0.55 11/0.036 46/0.15
material balance
dated 11/18/66
(304 days)
12/26/77 - 6/25/78b 480/2.6 157.5/0.87 6.5/0.036
material balance
dated 11/20/78
(182 days)
a Based on 3.8% Fluoride in phosphate rock,
b Based on 3.65% Fluoride in phosphate rock.
-------
Table 17
SUMMARY OF FLUORIDE LOSSES TO THE ATMOSPHERE
OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Source of Data
Estimated Fluoride Losses to Atmosphere
lb/ton P205
Tons/Day
Comments
1966 material balance
0.86
0.036
Based on P205
input of 84 T/D
from material
balance
1978 material balance
0.60
0.036
Based on P205 input
of 118 T/D from
material balance
Summer 1977
ARB stack test
0.565
0.033
T/D estimated using
1978 P205 input of
118 T/D
3/14/79 memo
0.33
0.02
T/D estimated using
1978 P205 input of
118 "7D
a Abbreviation for State of California Air Resources Board.
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67
Table 18
SULFUR LOSSES FROM MATERIAL BALANCE DATA
• OCCIDENTAL CHEMICAL COMPANY
Lathrop, California
Time Period and
Source of Data
Stack Loss to Atmosphere Calculated
as S02 Overall Efficiency
(Total tons lost/Avg Daily Tons Lost) (%)
1/1 - 6/25/78 (176 days) 2422/13.8
8/1/78 material balar.ce
6/26 - 9/25/78 (92 days) 1106/12.0
10/10/78 material balance
9/26 - 12/31/78 (97 days) 2422/25.0
1/18/79 material balance
1/1 - 3/25/79 (84 days) 260/3.1
4/10/79 material balance
3/26 - 6/25/79 (93 days) 1994/21.4
8/17/79 material balance
97.3
97.4
94.1
99.4
93.5
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68
(4,000 tons)/yr or 10 m. tons (11 tons)/day. The amount of sulfur lost to
pond percolation was not delineated in the material balances since the
material balances were only based on shipments of sulfur and products in
and out of the facility. Analysis of wastewaters and pond inventories were
not included in the balances. All losses were assumed to be to the at-
mosphere.
Ag Chem Material Balances
Two production record types from the Ag Chem plant were reviewed
during the September 18 to 28, 1979 process audit of the Oxy-Lathrop
facilities: inventory cards that listed raw materials and batch sheets
that showed formulation of products. These records were only available for
1973 to date. The records were often difficult to read because of poor
copies. Also, in some cases records were incomplete and consistent in-
formation was unavailable. Some records were available for time periods
starting in 1971, but these were incomplete.
First, copies of the inventory cards were reviewed. The quantities of
active ingredients and solvent chemicals iiandled were summarized by year.
Many materials listed in the inventory were inactive ingredients such as
emulsifiers, diluents, dispersants and dyes and were not summarized by
quantity. Because it was impractical to accurately balance materials
moving in and out of the inventory system, totals were based on the ma-
terials handled. "Materials handled" are defined as all materials charged
out to production batches.
Table 19 summarizes the active ingredients handled at Oxy-Lathrop from
1971 to 1979. As noted above, the records were incomplete from 1971 to
1973; consequently, the figures listed represent only the available data.
Table 20 lists the solvent chemicals handled. Tables 21 and 22 rank these
materials by the total amounts handled. DBCP (l,2-dibromo-3-chloropropane)
and EDB (ethylenedibromide) rank one and two of the active ingredients
handled. Solvent Thinner 347 ranked first among the solvents. Eighty-four
materials were summarized.
-------
Table 19
SUMMARY OF ACTIVE INGREDIENTS HANDLED AT OXY-LATHROP FROM 1971 - 1979 YEARLY TOTALS
Raw Data were Incomplete for 1971 and 1972
Material
Code (lame
1971
210040
?
211070
213600
215090
215500
214350
216762
216110
800500
0S007 5
220090
221402
¦>
221725
221740
290900
227000
225503
225400
226100
226125
223070
2 2ti090
228482
224280
228660
220670
Abate (Tech) 528
Allyl chloride
Aldnn 2424
Azak. 80 W
Baytex 93 cone 2
Betasan tech 93%
BHC tech
Botran 90 dust base
BT6 2SU 1565
Cap tan 80 U
Chlorothalonil (Oacthal) -
Contact weed l.i ller
Cube root (powdered)
Cygon tech
Cyprex 65 !J 11
Cythion (lialathion)
tech 93%
DBCP-tech
Dibrom tech
Diazinon 4 EC
Ciazinon premix
Diazinon I1G-8 (tech)
Diazinon 40 W
Dieldrin tech
Dieldrin 50 dust base
Dimethoate 94-
Dimethyl T-75 (Dacthal)
Disyston tech 38530
Oisyston 1 & 2
24437
3173
100
Pounds
of Material
Handled
1972
1973
1974
1975
1976
1977
1978
_.19£>
2313
2942
2696
433
1982
_
170
155
_
-
56375
109800
-
-
-
-
5440
3495
7150
-
-
-
-
¦
2950
8641
20481
-
-
~
—
2
12
13760
2970
4148
59-52
5140
0
300
-
704
18673
8240
4639
127
-
-
-
-
-
-
-
-
1931
3284
2207
-
2170
-
386
99
375
-
-
-
~
—
_
_
.
13465
"
750
-
-
-
-
_
43079
333421
266719
413066
243361
374395
_
816
3489
3183
2994
1398
1970
_
_
_
37500
-
-
-
15
8
73
15
8
78
675
-
41027
104343
64161
63088
52090
50829
3039313 *
102724
_
_
-
-
21603
31071
49974
25577
-
3392
5126
-
_
_
-
-
25318
-
-
_
_
134850
14707
-
-
-
2462
44685
152298
113824
107432
18465
140381
261451
-
-
1551
214
1018
5637
6503
6537
661
-
-
-
"
I
_
36586
132632
136835
427308
_
-
-
1552
-
-
-
37000
38590
23855
-
-
-
-
-
_
-
-
-
460
304
-
-TotaL
11 ,219
166.175
13,509
32,072
31,936
33,056
127
9, 5C2
2,425
13,465
750
1 ,574,011
13,350
37,500
883
375,538
3,142,037
161,130
25,318
149,557
840,993
2,813
22,511
100
733,361
1,552
137 ,975
764
'22791 - hjndlrd on
ur,} rc. n date
k year* of pi eduction
u n nc..T
VO
-------
Table 19 (cont'd)
SUMMARY OF ACTIVE INGREDIENTS HANDLED AT OXY-LATHROP FROM 1971 - 1979 YEARLY TOTALS
Raw Data were Incomplete for 1971 and 1972
pounds of Material Handled
Material
Code
Name
1971
1972
1973
1974
1975
1976
1977
1978
1979
Total
228650
Disyston 63".
785
5618
4560
9346
2020
3963
1924
1278
_
29 ,494
230160
Dursban prennx
-
-
-
11422
13622
6370
5352
11306
10271
53,313
230205
Dursban 6-61 5 (cone)
-
-
-
3749
9343
5852
3911
5068
2409
30,332
230220
Dursban 52 5'i
132
273
2344
2316
786
-
565
-
-
6,416
050125
Dyrone SO"!, (tech)
-
-
-
-
-
2006
1254
3008
1790
8,058
290320
EDB (tech)
_
_
_
45490
3210
185175
144001
758778
U48980
2,585,634
232600
Endnn
-
-
-
-
900
-
-
-
-
9C0
232720
Epichlorohydrin
-
-
-
3292
1 5396
2939
1123
-
-
22,750
233330
Ethion tech
-
-
-
8030
-
200
-
6500
-
14 ,730
249520
Ethyl parathion
-
-
31930
158093
101527
90114
104700
53020
21450
560,834
233790
Feibam
10158
2121
82
-
-
-
-
-
-
12,361
210900
Lindane
_
_
_
_
3130
1777
6608
770
12,285
244SOO
iiethyl parathion (tech)
-
27245
151229
125361
131272
162520
130879
96859
84090
909,955
2-44570
Metlioxy chlor (tech)
11905
27955
10050
18956
11885
16241
8643
11618
400
117,653
253330
nevinp'nos 10 3 (tech)
_
-
-
8035
12352
32750
32200
3531 1
33600
154,243
245420
t'.orphol ine
-
-
-
-
-
2922
3t90
2003
3914
12,329
248680
Ordram 3E
_
_
_
102
25535
34056
8650
9079
-
77,422
7
Oimte (tech)
-
-
-
-
-
-
-
-
638508
633,503
800500
Paravet 25'.1 (methyl
_
-
244562
100142
-
-
-
800
-
345,504
parathion)
14112
100,343
253020
Perthane (tech)
1870
10272
14503
30431
8950
17205
-
-
253330
Phosdrin (tech)
13240
18448
8952
2990
4037
-
-
-
-
47,667
255780
Phosphamidon (tech)
4440
6377
-
-
-
-
-
-
-
11 ,317
650250
Pyrethi um
-
-
-
648
2810
2527
1982
3964
1504
13,435
?
Progibb (Gibberellic
-
-
-
-
-
-
-
-
63
kg 63
acid)
050275
Ryama powder 0.232
_
-
8013
7800
6000
3250
39S5
29,043
253440
Ryanicide 100 (Rynotox)* -
-
-
-
-
-
-
-
-
0
259429
Sevimol (bulk)
-
-
-
-
10060
7959
1220
-
19,239
~Material inventoried but none used
o
-------
Table 19 (cont'd)
SUMMARY OF ACTIVE INGREDIENTS HANDLEj AT OXY-LATHROP FROM 1971 - 1979 YEARLY TOTALS ¦
Raw Data were Incomplete for 1971 and 1972
Material
Pounds of Material Handled
!i?P5 J ,97.1 i 97.?..,,..
1973
1974
1215—
Ton!
260600
Sevin 80 DB
10205
59845
80216
1492
15639
47660
27777
78690
321,524
2606S0
Sevin 80 Spi ay
-
-
-
-
-
-
-
75
-
75
259550
Sevin (tech)
350
-
-
9742
-
-
-
-
-
10,0'j?
266930
Terrachlor
1045
1542
_
_
_
4586
_
_
2035
9,808
268 "CO
Terrazol
1860
-
-
-
-
-
-
-
-
1 ,360
269090
Thioda.i 50 U
14050
17786
592
-
-
-
-
-
-
32,123
271271
Thuricide HP-1,
-
5375*
-
-
-
-
11940
3264
-
20,579
5-B-DB
269010
Tlnosu 1 fjn (tlnodan)
52820
93020
57601
18255
1 7240
87052
139276
53743
67132
536,139
27<,6C0
Trithion tech (90»)
34376
33846
34431
-
-
13015
-
8920
13200
133,238
2723^0
Toxaphene 904 (tech)
337157
224259
303416
93400
103772
143609
126034
115952
41782
1 ,4S9,3in
272300
Toxaphene 10 DB
3125
382
-
-
-
-
-
-
-
3,507
191210
Urea (prilled)
_
_
18924
58902
23418
9552
9761
30763
12993
164,313
275260
Llrea-LoBi - (f inos)
-
-
9946
62503
126824
150011
108504
111503
569,296
2 7 99*5 3
Zn am 76 VI
_
58647*
_
_
16468
2418
_
_
_
77,533
279970
Zirain 95% (tech)
3240
64017
68741
-
-
19320
66210
316262
545778
1 ,083 ,5C3
279851
Zineb 75 UP
-
9122*
-
-
8390
5551
2330
7816
-
33 ,209
>sar unavail-
able
abl e
?.ir unava 11 -
-------
Table 20
SUMMARY OF SOLVENTS HANDLED AT OXY-LATHROP FROM 1971 - 1979 YEARLY TOTALS
Raw Data were Incomplete for 1971 - 1972
Pounds
of Material
Handled
Name
1971
1972
1973
1974
1975
1976
1977
1978
1979
Tucnl
Solvent thinner 347
-
-
-
1973859
1950195
2419762
1750559
1003156
1740450
10,837,981
Xylene
-
271377
724039
261295
58970
-
-
-
-
1 ,315,t81
Xylene-nitration graae
-
-
-
-
-
8610
50806
1139133
-
1 ,198,518
Isopropanol
39032
127778
131662
38720
89678
188105
191548
199896
159176
1 ,165,595
Dow General (bulk oil)
-
-
-
100368
106792
140087
185460
126355
163629
G22,o31
Cyclohexanone
-
-
-
-
-
11817
63151
350640
54239
! 7 9, d 17
Chevron base oil
-
-
-
-
-
18648
17748
23537
29156
89 3S9
Citrus oil
7000
10841
11553
6212
-
-
-
-
-
35,506
(gal)
Ethyl hexanol
-
-
-
-
-
-
-
400
427
£27
Amyl acetate
-
-
572
-
-
-
-
133
15
825
Acetic acid
-
-
-
7???R
9W
-
121
184
230
535
81 ,1:80
ro
-------
73
Table 21
SUMMARY OF ACTIVE INGREDIENTS HANDLED AT OXY-LATHROP
FROM 1971 to 1979 RANKED BY POUNDS HANDLED
Raw Oata Were Incomplete From 1971 and 1972
Material
Total Pounds
DBCP-Tech
EDB-tech
Contact Weed Killer
Toxaphene 90% (tech)
Ziram 95% (tech)
Methyl parathion (tech)
Diazinon MG-8 (tech)
Dimethoate 94%
Omite (tech)
Thiosulfan (thiodan)
Urea-LoBi-(fines)
Ethyl parathion
Cythion (malathion) tech 93%
Parawet 25W (methyl parathion)
SEVIN 80 DB
Allyl chloride
Urea (prilled)
Dibrom tech
Mevinphos 10 3 (tech)
Diazinon Premix
Trithion tech (90%)
Disyston tech
Methoxychlor (tech)
Perthane (tech)
Ziram 76W
Ordram 8E
Dursban Premix
Phosdrin (tech)
Cygon tech
Zineb 75WP
Betasan tech 93%
Thiodan 50W
AZAK 80W
BAYTEX 93 cone
Dursban 6-61 5 (cone)
Disyston 68%
Ryania Powder 0 23%
Diazinon 4EC
Epichlorohydrin
Dieldrin tech
Thuricide HP-1.5-B-DB
Sevimol (Bulk)
Aldrin
Ethion tech
Captan 80W
Pyrethrum
Cube Root (powdered)
Ferbam
Morpholine
Lindane
Phosphamidon (tech)
ABATE (tech)
SEVIN (tech)
Terrachlor
Botran 90 dust base
Dyrene 80% (tech)
Dursban 52 5%
Toxaphene 40 DB
Diazinon 40W
BTB 25W
Terrazol
Dimethyl T-75 (Dacthal)
Endrin
Cyprex 65W
Disyston 14 2
Chlnrothalom1 (Dacthal)
BHC lech
Dieldrin 50 dust base
SEVIN 80 spray
Progibb (Gibberellic Acid)
Ryanicide
3,142,037
2,585
634
1,674
041
1,489
391
1,083
568
909
955
840
998
733
361
638
508
586
139
569
296
560
884
375
538
345
504
321
524
166
175
164
318
161
180
154
248
149
557
138
2'.8
137
975
117
653
100
343
77
533
77
422
58
343
47
667
37
500
33
269
33
056
32
428
32
072
31
986
30
332
29
494
29
048
25
318
22
750
22
511
20
579
19
239 gal
18
509
14
730
13
465
13
435
13
350
12
361
12
329
12
285
11
317
11
219
10
092
9
808
9
592
8
058
6
416
3
507
2
813
2
425
1
860
1
552
900
883
764
750
127
100
75
63 Kg
0
-------
74
Table 22
SUMMARY OF SOLVENTS HANDLED AT OXY-LATHROP FROM 1971-1979
RANKED BY POUNDS HANDLED
Raw Data were Imcomplete for 1971 and 1972
Material Total Pounds
Solvent Thinner 347
10,837,981
Xylene
1,315,681
Xylene nitration grade
1,198,548
Isopropanol
1,165,595
Dow General (bulk oi1)
822,631
Cyclohexanone
479,847
Chevron base oil
89,389
Diesel oil
81,680
Citrus oil
35,606 gal
Ethyl hexanol
827
Amyl aretate
825
Acetic acid
535
-------
75
In addition, Table 23 lists the names of other raw materials handled,
and includes emulsifiers, diluents, dispersants and dyes. One hundred
seventy-nine (179) other ingredients are listed in Table 23. The quan-
tities of these materials handled varied from almost zero to over 41,000 kg
(90,000 lbs). Their use, however, generally was less than many active
ingredients.
During the interviewing of plant personnel it was noted that there was
a damage reporting system to record losses of product, unrecoverable bad
batches, etc. Subsequently, during the inventory card review, some records
of damaged, destroyed or lost materials were noted. Table 24 summarizes
these losses. Most losses were due to the January 17, 1976 fire described
previously.
Second, all batch formulation sheets were reviewed and summarized for
the 1973 and 1978 production years. The summaries were performed as
follows: Consider the target formulation amount (or raw materials total)
as the amount prepared. Calculate the actual amount formulated from bag
weights and counts, container volumes and counts orany other applicable
information recorded on the batch sheets. The difference of these two
amounts divided by target formulation amount yields the fraction over or
under formulation (or loss). Table 25 summarizes the percent product
losses as percentages of the target formulation. The calculations did not
include bulk quantity production because typically, there was no indication
of the actual amount packaged, only the target amount.
Table 25 shows overall average product losses of 0.79 and 0.70% for
1973 and 1978, respectively. The losses were further broken down by major
production plant type to liquids, dusts and granulars. The largest losses
occurred for dusts and wettable powders - 1.2 and 0.86% for 1973 and 1978,
respectively. In 1978, granulars actually showed an increase of 0.23% of
product produced over the target formulation. Although the losses noted
above are small in terms of percentages, if real they represent large
quantities when considering that millions of pounds of pesticides were
formulated/manufactured.
-------
Table 23
LIST OF MATERIALS HANDLED AT OXY-LATHROP FROM
1971 - 1972 NOT INCLUDED IN TABLES 19 AND 20
Raw Data were Incomplete from 1971 and 1972
Many are Emulsifiers, Diluents and Antifoam Agents
and Handled in Small Quantities (Generally less than 10,000 pounds)
Acetic anhydride
Ad see
Aerosil 200 (CAB-O-SIL)
Aersol 0TB
Agrimul J-l
Aqueous formaldehyde
Aquaflat
Antifoam A
Antifoam H-10
Arquad 20-75
Armeen CD
Atlox 804
Atlox 3403F
Atlox 3409F
Atlox 3431
Atlox 3453F
Atlox 3454F
Atlox 3455F
Atlox 3403F
Atlox 3404F
Attaclay
Calco oil blue liquid
Calcozine green mx, liquid
Calcozine auramine 00
Calsoft T-60
Casein
Celatom MP-78
Celatom MP
Celite 209
Chevron Agent 236-64A
Cotton seed oil
Copper-Traco 50%
Diammonium phosphate
Dicofol
Diethyleneglycol
Di pel
Dimethrin
Dioctyl phthalate
Diphos premix
Dipotassium phosphate
Dolomite Ag.
Dorflo, oil
Dowfax 2A1
Dowfax 21
Dow AN0L EM
Dowcil 100
Dust diluent, Chevron
Emgard 2063
Emgard 2066
ES0 (Epoxidized soybean oil)
Ferrifluc
Ferrous sulfate
Flosul
Folpet (phaltan sow)
GAFAC-729
GAFAC-Re-610
Geopan-GA-1
Gilsonite
Glycerol 96
Groco 2 red (oleic acid)
Hampene 6.5% Zn chelate
Hampene 14% Zn chelate
Hisil 233
Hexylene glycol
Hydrated lime
Igepal Co 530
Igepal Co 430
Igepal Co 630
Igepal Co 710
Igepal DM-530
Igepon TN-74
Kaolin Type 41 Clay
K-nite
Lignosite 458
Lignosite 854
Lorsban 4E
M-4 clay
Manganese oxide
Magnesium sulfate
Manganese carbonate
Mono ammonium phosphate
Measurol Tech
Metanil yellow dye
Microcel E
Microcel T-26
Mono potassium phosphate
Multifilm defoamer
Naphthalene-acetic acid
Nekal WF-27
Nekal BX-73
Neutralizer M-33
Ninate 401
-------
Table 23 (cont'd)
LIST OF MATERIALS HANDLED AT OXY-LATHROP FROM
1971 - 1972 NOT INCLUDED IN TABLES 19 AND 20
Raw Data were Incomplete from 1971 and 1972
Many are Emulsifiers, Diluents and Antifoam Agents
and Handled in Small Quantities (Generally less than 10,000 pounds)
Nopco 80-50
Supersul 50 (thioret)
Nufilm p
Tamol SN
Nutrasol
Tamol TN
Nutrawet-Folospray
Tamol N micro
Naphthol green dye
Techmangan Nutra-Spray
Cotton seed oil
Techmangan (Mn SO.)
60 pale oil
Tennco 500 - 100
Pine oil
Terton KT 20
Spray stock L
T-mulz 121 N
99 S oil
T-mulz 339
PGS0 1 oil
T-mulz A-02 '
PGS0 2 oil
Thylate
Petro Ag
Titanox-RGHT-X (titanium pigment)
Phosphate rock
Tribasiz copper 53%
Phosphoric acid
Triple 12
Potassium nitrate
Triton X-15
Potassium sulfate
Triton Ag 120
Powdered bluestone
Treble super phosphate
Propylene glycol
Trusorb 30-60 granules
PVP K30
Tween 80
Sellogen HR
Versene 100
Seelogen W
Versenol 120
Semimo1
Vitamin B-l
Sequesterine 30A
VLR-Diluent Icay
Sequesterine 330 Fe
Xylene milling green B dye
Sequesterine Zn 14%
Zinc chelate
Shelsol
Zinc oxide
Sorbitol 70 solution
Zinc sulfate
Sponto EMC0L HJPZ
Zinc sulfate (basic)
Sponto N142B
Sponto 108D
Sponto N164
Sponto A-69-40
Sponto 139-B
Sponto N-140B
Sponto AK-16-95N
Spray Stock L
Sprint 38
Sudam Blue
Sudan Orange
Sudan Red 0
Sudan yellow dye
Sugar
Sulfur
Sulfuric acid
Supersul (thiolux)
Sulframin SXS 40% liquid
Sulframin LX flake 85%
-------
78
Table 24
SUMMARY OF LOST RAW MATERIALS AT OXY-LATHROP
Based on Inventory Review from 1973 to 1979
Material Date Amount Reason
Abate (tech)
4/25/76
Anti Foam H-10
1/17/76
Arquad 20-75
1/16/?
Armeen CD
1/16/76
Betasan (tech 95%)
10/26/74
Calcozine green mix liq.
1/17/76
Calco oil blue liq.
1/17/76
Calsoft T-60
1/19/76
Celalom MP 78
8/2/76
Chevron base oil C (spray oil
C) 1/16/76
Contact weed killer
4/28/79
Dioctyl phthalate
1/16/76
Endrin 75DB
4/6/75
Erid green
1/17/76
Excel 24/48 granules
1/16/76
Excel 15/40 granules
4/25/76
GAFAC Bl-729 ,
1/16/79
Glycerol 96
1/16/76
Groco 2 Red
1/16/76
Hamphene zinc chelate
3/25/76
Hexylene glycol
1/16/76
Igepal C0-430
1/16/76
Igepal C0-630
1/16/76
Igepal DM-530
1/16/76
Isopropyl alcohol
3/26/77
Methyl parathion
1/19/76
Monowet SNO-35
6/24/78
Morpholine
1/16/76
Multifilm defoamer
1/18/76
NEKAI tfT-27
1/16/76
Napthol green dye
1/16/76
60 pale oil
1/16/76
60 pine oil
1/17/76
Oil Red-B-Liquid dye
1/17/76
SIPEX BOS
1/19/76
SP0NT0 139-B
1/16/76
SP0NT0 (EMCOL N 140B)
1/16/76
Sudan yellow dye GRN
1/16/76
Sulframin SXS 40%
4/25/76
Zinc sulfate 36% (reg)
6/20/77
Zineb 7SWP
8/17/76
200#
water contaminated
200#
destroyed (fire?)
428#
destroyed
in
fire
66#
destroyed
in
fire
800#
dumped
37,176 ml
destroyed
in
fire
10,638 ml
destroyed
i n
fire
480#
destroyed
i n
f i re
1000#
damage-lost
1200#
destroyed
in
fire
275 gal
loss
814#
destroyed
i n
fire
900#
dumped
100#
destroyed
in
fire
9100#
destroyed
in
fire
1200#
destroyed
in
fire
920#
destroyed
in
fire
570#
destroyed
in
fire
293#
destroyed
in
fire
413#
destroyed
i n
fire
420#
destroyed
in
fire
510#
destroyed
in
fire
643#
destroyed
in
fire
1700#
destroyed
in
fire
13,257 gal
product loss
1984#
destroyed
in
fire
860#
damaged material
427#
destroyed
in
fire
24(?)
destroyed
in
fire
1000#
destroyed
in
fire
2721.6 grams
destroyed
i n
fire
400#
destroyed
in
fire
20079 ml
destroyed
in
fire
20079 ml
destroyed
in
fire
2700#
destroyed
in
fi re
1458#
destroyed
in
fire
1923#
destroyed
in
fire
2706.52 grams
destroyed
in
fire
1825#
destroyed
in
fire
200#
to the dump
50#
? damage
-------
Table 25
AG-CHEM PRODUCTION MATERIALS BALANCES AT OXY-LATHROP
IN 1973 AND 1978
Negative Values Represent Losses
Percentage of Formulation
1973
1978
Overal1
-0.79
-0.70
Liquids
-0.20
-0.76
Dusts and wettable
powders
-1.2
-0.86
Granulars
-0.67
0.23
-------
80
The only internal Oxy memo available to the audit team which purports
to quantify pesticide losses from Ag Chem operations is one from Mr. Robert
Edson to A. Osborn on June 25, 1976. Included in this memo is a statement
that "To date we have been discharging more than 500 parts per million or
about 5 tons of pesticide per year to the ground." When interviewed during
the audit, Mr. Edson discounted the accuracy of this memo saying that it
was based on estimates or best information available. Mr. Edson could not
explain why specific numbers were included for pesticide concentrations and
mass losses which would have presumed data had been collected.
DBCP Production Records Review Summary
As shown in Table 19, over 1,400,000 kg (3,000,000 lbs) of tech-DBCP
was handled from 1971 to 1979 at Oxy-Lathrop. Much of this material was
manufactured at Oxy-Lathrop. Exact batch sheets and production records for
technical DBCP prior to 1971 were not available. Table 26, however,
summarizes 100 batches produced during the period from 1971 to 1976.
Because tech-DBCP was produced in bulk, measurement of the exact yield
of the reaction was virtually impossible. Sources of potential loss
included product wash cycles, evaporative losses, spillage and spent dryer
and filter material. At least one Company memo of February 17, 1967 from
Jack Horner to Dr. W. L. Garman mentions significant losses but no specific
reason(s) or amounts were given. Formulation of DBCP products in 1973 were
summarized and an average of 0.928% over formulation for six products was
determined. Generally, many of the formulations were for bulk products and
the accuracy of finished product measurement was very limited.
A computerized summary of DBCP production from 1968 to 1977 showed
7,660,000 kg (16,874,339 lbs). The origin of this document could not be
accurately described by Oxy and it may represent DBCP formulations and/or
DBCP manufacturing. Table 27 is a copy of the Oxy-Lathrop DBCP summary.
Prior to 1968 little information was available. Two Oxy-Lathrop inter-
office production summaries, however, showed production of 72,656 kg
(160,035 lbs) of tech-DBCP during April and May 1967.
-------
81
Table 26
TECH DBCP MANUFACTURING AT OXY-LATHROP
Record Summary 1971-1976
Year
No. Bottles
Pounds Used
Allylchloride Br2
1971
52
556,100 1,086,280
1972
2
>7,200 >14,150a
1973
None'3
1974
6
56,325 110,250
1975
27
287,479 575,370
1976
13
134,550 272,715
a Batch 339 (2/16/72) data unclear; only one
other batch reported.
b Available records showed no production in
1973.
-------
Table 27
OXY-LATHROP DBCP PRC-RUCTION SUMMARY OF 1968 - 1977
Supplied to EPA by Oxy During Process Audit
' oar
Jan
Feb
Mar
Total
Aor
Pounds Produced in Each
May June
Month
Jul V
Ann
Sent
Oct
Nov
Dpc
19o3
0
0
0
0
0
0
0
8520
50979
142407
87953
97160
1969
51805
8520
443124
498784
178828
49942
6238
11996
118682
75567
48184
39100
1970
61771
205640
220665
177655
186052
78264
188346
13366
11086
86334
68484
180457
1971
1 2251
179445
226905
226165
42273
87540
20618
68112
50135
107392
142309
66099
1972
4B694
186360
194701
135790
59829
46271
81043
41508
283595
282504
131509
1 4467
1973
170745
73023
152142
204502
198020
62458
49859
70760
72592
243889
405718
182607
i <>74
133252
201354
208067
248288
202136
228022
200516
22593
199759
664221
247081
248522
1975
325777
205581
321524
366657
105291
130104
129374
321363
103038
116728
162129
224673
1976
175158
216644
228984
195743
110912
139068
116521
422377
422686
23999
106784
133552
1977
222580
103503
402702
154099
G2192
126050
255401
0
0
0
0
0
Total s
1202034
1460082
2398814
2207183
907315
947719
1047916
980595
1312552
1743041
1400151
1186637
oo
r\>,
-------
83
HISTORICAL GROUNDWATER AND SOIL DATA EVALUATION
Past environmental data collected at or near the Oxy-Lathrop facil-
ities have documented environmental contamination attributable to Oxy. A
summary of selected data as it reflects (1) inorganics in groundwater, (2)
organics in soil and groundwater, and (3) radioactivity in groundwater
follows:
Inorganics Data - Groundwater
Groundwater monitoring data have been collected by Occidental Chemical
Company and its predecessor, Best. Fertilizer, at Lathrop, California since
at least 1960. This sampling commenced in conjunction with California
Central Valley Regional Water Quality Board Resolution No. 60-6. Although
data presented in Table 28 represent only selected wells and parametric
coverage, they are important in that they represent "usable" groundwater as
it relates to- the Resolution, depict the dramatic decline in groundwater
quality over time, and document effects directly attributable to Oxy's
operations.
In 1963, sulfate (S04) concentrations in the "Best West" well began to
exceed the California Resolution limit of 100 mg/1. At that time, the Best
West well was Oxy's principal process and domestic water source. As the
years went by, S04 concentrations continued to increase, reaching 1817 mg/1
in 1974 when the well was finally abandoned. The "Best South" well and
Libby Owens Ford (LOF) wells also demonstrate the same trend [Table 28].
S04 concentrations in the Best South well exceeded the limitation of
100 mg/1 in 1966 and rose steadily to 2,100 mg/1 on May 4, 1979. This well
is now used for process water only. S04 concentrations in the LOF well,
which actually reflects various wells sampled over time, first exceeded the
100 mg/1 limitation in late 1962.
The presence of S04 in these wells is directly attributable to Oxy's
operations at Lathrop. As described previously, large amounts of calcium
sulfate (gypsum) are generated in the manufacture of phosphoric acid which
-------
84
Table 28
Oxy-Lathrop Groundwater Monitoring Data - S04
Best West Well1 Best South Well2 Well3 East Well4
Date S04 (ppm) Date S04 (ppm) Date S04 (ppm) Date S04 (ppm)
8/20/60
28
28
1/61
23
26
1/62
69
26
2/15/62
64
h
h
75
2/27/62
63
(63)
27 (26)
4/7/62
73
54
75
5/30/62
66
U
49 b
95
7/27/62
85
(84)°
29 (44)
7/7/62
91
9/7/62
47
33
52
11/27/62
87
22
123
3/20/63
116
46
78
5/24/63
130
37
134
8/23/63
149
28
307
11/23/63
154
27
174
11/6/64
200
39
30
3/4/65
223
57
39
5/5/65
229
64
38
8/11/65
237
82
66
11/2/65
228
90
25
2/28/66
252
93
47
5/28/66
244
78
5/26/66
49
8/26/66
250
84
79
11/4/66
270
153
76
3/23/67
317
237
57
5/17/67
11
10/25/67
428
161
10
2/1/68
365
133
7
8/15/68
419
186
193 (10 g)
12
5/22/69
567
225
0
3/11/71
1396
392
1279 (Irr.)
6
5/2/73
112
5/3/73
682
5/1/73
641 (10 d)
5/1/73
0
5/16/74
1817
5/8/74
413
5/9/74
679 (10 d)
5/8/74
13
5/1/75
1717
5/1/75
1042 (10 a)
5/1/75
28
5/7/76
1001
5/8/76
29 (Comp)
5/7/76
22
5/7/77
1317
5/7/77
59 (Comp)
5/7/77
30
5/9/78
1699
5/9/78
66 (Comp)
5/4/79
2100
5/4/79
1270 (Comp)
5/4/79
37
a Unless otherwise specified, date listed is date from far left column,
b Concentrations in parentheses are from concurrent sampling by California
Water Board.
c Apparently began to sample another LOF well, listed as No. 10 from 11/6/64-3/23/67.
-------
85
Table 28 (Cont.)
Oxy-Lathrop Groundwater Monitoring Data - SO4
*BEST WEST WELL
Oxy's May 1974 well water analysis survey report describes their well as
"Located on west side of road on west side of NH3 plant next to C02 plant."
and describes the depth as 145 ft. An 8/21/62 memo to Colonel J. S.
Gurlinski, California Water Board, from G. E. Schmidt describes well as
"171' cased depth, 14" casing, 111' to 171' perforation interval (Use:
Domestic, Fire Reservoir, Process Water)." File information indicates
well was abandoned in 1974.
2BEST SOUTH WELL
Oxy's May 1979 well water analysis survey report describes their well as
"next to gypsum ponds south end of Occidental Chemical Company Property."
and describes depth as 130 ft. The G. E. Schmidt memo referenced above
describes well as "14" casing, 260' cased depth, 125 to 135' perforation
interval; (use: Process Water)".
3L.Q.F. WELL
Data reported historically represents sampling of a series of wells on
the Libby Owens Ford glass plant property just to the west of the Oxy
plant. At least one of the wells was listed in file information as being
204 ft deep. Recent years' data (1976 to 1979) indicate a composite sample
of various L.O.F. wells.
4BEST EAST WELL
Oxy's May 1979 well water analysis survey report describes well as "East
of Occidental Chemical Company Plant and just west of McKinley Avenue."
and describes depth as 250 ft. File information indicates this well was
brought into use in 1966 and became Oxy's principal potable water quality
wel 1.
-------
86
are slurried to onsite Gypsum Ponds for dewatering by percolation and
evaporation. The water which percolates is laden with sulfate ions which
have then been drawn into the cone of depression of the wells and con-
taminated them.
Groundwater monitoring data from these and other wells in the area
were submitted to the State of California until 1967 when the State in-
formed the Company in writing that they could terminate groundwater mon-
itoring in lieu of initiation of wastewater pond monitoring. The Company
did, however, continue to collect groundwater data for its own use and in
early 1979, at the request of the State, turned this data over to the
State.
The "Best East" well, installed in 1966 following the decline of water
quality in the Best West well, graphically depicts background S04 con-
centrations in the area as well as a recent trend toward deteriorating
quality [Table 28]. Concentrations from 1967 to 1974 were <13 mg/1. On
May 4, 1979 this concentration had risen to 37 mg/1, perhaps a harbinger of
migrating sulfate ions from the Gypsum Ponds into this well's cone of
depression.
Organics Data - Soils/Groundwater
To date, no data have systematically been collected and reported to indi-
cate the areal and vertical extent of organic contamination attributable to
Oxy-Lathrop. It has been demonstrated, however, that compounds attributable to
Oxy-Lathrop are in the soils in the vicinity of the plant and have migrated
to usable groundwaters serving industrial, agricultural and potable uses.
The first organics data known to have been collected, which indicated
the presence of organic compounds in soils on the Oxy property was col-
lected by Oxy in 1970.* These data were collected in conjunction with a
* See Appendix B for listing of organics data. Data is identified by
compound, date of collection, concentration, source of data, and lo-
cation of sample.
-------
87
State of California directive to define any contamination associated with
the "boneyard" disposal area. No groundwater sampling detecting specific
organic compounds is known to have been conducted until May 1978, when Oxy,
following discovery in 1977 of sterilization of pesticide plant workers,
found 1.1 ppb of lindane in the Mendes irrigation well. Since these dis-
coveries, a number of soil, shallow groundwater, and process irrigation,
and potable well samples have been collected which indicated the presence
of organic compounds. Disregarding the volatile organic compounds ident-
ified in Table 29, all the other compounds are known to have been handled
at the Oxy-Lathrop plant. It can be assumed that Oxy-Lathrop is the pri-
mary source of these compounds in the area. As indicated in Table 29, twelve
of the compounds rre known animal carcinogens, and ODD is a suspected animal
carcinogen. DBCP is also suspected of being a human carcinogen. The adverse
health effects inferences of these statements are conservative since numerous
other non-carcinogenic health effects are also known for the compounds.
Radioactivity Data - Groundwater
Phosphate rock used in phosphoric acid operations such as at Oxy-Lathrop
is known to contain naturally-occurring radioisotopes. Since improper dispo-
sal/treatment of the resulting wastewaters could result in contamination of
groundwaters, samples were collected of representative wells in the Lathrop
area on four separate occasions from October to December 1979. All sampling
was conducted by personnel of the California Central Valley Regional Water
Quality Control Board. Three of the four sets of samples were analyzed by
the California Department of Health Services; the fourth representing the
greatest number of wells and widest radiochemical parameter coverage, was
analyzed by the USEPA Office of Radiation Programs in Las Vegas, Nevada.
This last set of data confirmed and refined earlier findings. Specific
findings of the EPA analyses included documentation of:
(1) No gross alpha or beta activity to the east of the Oxy plant
-------
Table 29
ORGANIC COMPOUNDS FOUND IN VICINITY OF OXY-LATHROP FACILITIES
88
Media Where Compounds Found and
Maximum Concentration^
Compound
Soil/Sediment
Groundwater Drinking Hater
Aldrin
Total BHC Isomers
.b
a
BHCL
3 BHC°
Y BHC (Lindane)1
A BHC
Chlordaneb
DBCPb
DDD
DDEb
DDTb
DEF
Diazinon
Dibrom
Dieldrirf1
Dimethoate b
Disulfoton
(Disyston)
DNBP
Dursban
(Chlorpyri fos)
EDB (ETDB)b
x (6.7)
x (1-10 ppm)
x (6.3)
x (40 ppm)
x (2600)
x (1-10 ppm)
x (1-10 ppm)
x (20 ppm)
x (4000 ppm)
x (39)°
x (5000)
x (32)
x (1.0)c
x (80 ppm)
x (200)
x (200 ppm)
x (6700)
x (2.0)
x (6.1)
x (0.59)
x (22.1)
x (3.8)
x (95)
x (3.2)c
(0.5)
x (11.0)
x (9.9)
x (3.5)
x (18.0)
x (44)
x (0.9)
x (9.8)
x (0.4)
x (1.8)(
-------
Table 29 (Cont.) 89
ORGANIC COMPOUNDS FOUND IN VICINITY OF OXY-LATHROP FACILITIES
Compound Soi1/Sediment Groundwater Drinking Water
Endosulfan I,II. x (400 ppm)
Ethion x (12 ppm)
£
Ethyl Parathion x (1700 ppm) x (7.5) x (3.9)
Heptachlorb x (27)
Malathion x (5000) x (1.6)
Methoxychlor x (80 ppm)
Methyl Parathion (2.0 ppm) x (0.8)
PCNBb x (6-3)
Volatile Organicsd
Chloroform x (2-0) x (1.3)
1,1-Dichloroethane x (4.0)
1.1-Dichloroethylene x (1.0)
1.2-Dichloroethane x (0.18)
trans-1,2-Di- x (0.3)
chloroethylene
1,1,1-Trichloroethane x (0.5)
1,2-Dichloropropane x (0.6) x (3.3)
Tetrachloroethylene x (1.5)
a All concentrations in parts per billion unless otherwise specified,
b Animal carcinogen.
c Not a positive identification according to Oxy. Highest positive
identification is directly underneath this value, if available,
d No health effects computer search conducted on these compounds.
-------
90
upgradient of the direction of regional groundwater movement
which has been assumed to be to the west or northwest.
(2) Measureable gross alpha and beta activity in wells to the south,
west and north of the Oxy plant. Gross alpha and beta levels
were as high as 120 + 38 and 36+8.6 pci/1, respectively. The
Lathrop County wells currently used as drinking water (Nos. 1, 4,
5) showed non-detectable to low (i.e., gross alpha and beta of
3.4 + 2.9 and 4.2 + 1.9, respectively) gross alpha or beta
activity. The Lathrop County standby well (No. 3) had gross
alpha and beta activities of 27 + 19 and 10 + 2.2 pci/1, re-
spectively.
(3) The majority of the radioactivity in these samples was attrib-
utable to uranium, not isotopic thorium, radium-226 or polonium-
210.
These data, like the inorganics, are also indicative of the effects of
Oxy's activities in the Lathrop area.
AERIAL OVERFLIGHT OF 0XY-LATHR0P FACILITIES
The Oxy-Lathrop facilities were overflown on September 26, 1979 from
10:40 to 11:59 AM (PDT). The aerial reconnaissance was conducted in a
Cessna 172 Aircraft using a Hasselblad 70 mm hand-held camera. Multiband
photography was used which consisted of two spectral bands or segments of
the optical spectrum from the ultraviolet through the near infrared (300 to
950 nanometers). This enabled the detection of soil discoloration, pre-
sence of liquid, and vegetation damage.
The pertinent results of the photo-interpretation of the aerial imagery
are depicted in Figure 5, a location map. Indications are sketched on all
four sides of the Occidental facility. Of particular interest are general
areas found in the fields to the west of the Occidental waste disposal
areas [Figure 5].
-------
PONOS WHM
CHARCOAL COLORED
LIQUID
SPARSE
;GE TAT ION
DUG OUT A EA
STAINS IN WHITE SLI
LEADS TQ ROAD
YOSEMI T£L
7 0 1 MILE
1000 0 1000 2000 3000 4000 5000 6000 7000 FEET
~
1 KILOMETER
Figure 5 location Map - Occidental Chemical Company, Lathrop, California
-------
92
The false color infrared aerial imagery, exposed from yellow through
red into the near infrared segments of the optical spectrum, showed nu-
merous areas of dark or discolored soil and areas with apparently degraded
vegetation. This is sketched in Figure 6, a false color infrared photo-
graph. There appeared to be a continuous pattern of dark or discolored
soil leading westward from the western edge of the Occidental facility,
adjacent to the "boneyard" disposal area and pesticide wastewater pond
(Southwest Wastewater Pond) as shown by arrows in Figure 6. This pattern
could have been caused by the presence and movement of surface/near surface
liquid containing a substance toxic to the vegetation in these indicated
areas. The isocontour lines on the chart (Figure 5) do not indicate that
this effect was due to ponding of a waste liquid or water, especially in
the fields, if the land contour has not been significantly altered since
the printing of the chart in 1976. The aerial photographs do not reveal
any significant change in land contour.
-------
Fig ure 6. Fall• Color Infrared Aerial Photograpi.
Occidental Chemical Company, Lathrop, California
-------
APPENDIX A
ORGANIC SOLVENT EMISSIONS DATA
AND INVENTORY OF AG CHEM STORAGE TANKS
-------
OCCIDENTAL CHEMICAL COMPAMY
"1B~777 S Howland Ave POBoxISB Lachrop, California 95330 12OS)B50 25TI
July 29, 1976
San Joaquin County
' Air Pollution Control District
Box 2009
Stockton, CA 95201
Dear Sirs:
Attached per your request is a data sheet containing emissions data
for the organic solvents used in the pesticides formulated at our
Lathrop Plant.'
If you have any further questions, please contact Sy Bensky at
extension 335.
Very truly yours,
J. H. Lindley
Vice President
JHL:am
cc: A. Osborn
R. Edson
D. Crockett
D. Lery ( Houston )
FILE 414
vis ij s li lis £ y ij
-------
Reactivity
SOLVENT Rule
409 k ARQ
Isopropanol S III
Std-347 Solvent 6 II
Tenneco - 500 k2 III
Cyclohexanone S II
Ethylene Glycol Methyl
Ether S- III
Glycerol S III
Dioctyl Phthalate k2 III
Weed Oil k2 III
pgso2 S I
Diethylene Glycol S III
Hexylene Glycol S III
TOTALS
o
cLa. i
ter; • ""
l> *2
't
V"'
r ,
2ir>
Thruput
GPY
% OF TOTAL
EMISSIONS
Daily Yearly
lbs. lbs.
25,000 8.5 0.35 87.5
25,000 8.5 0.35 87.5
25.000 8,5 0.35 87.5
1,400 .5 0.02 5.0
500 .2 0.01 2.5
2,000 .7 0.03 7.5
500 .2 0.01 2.5
9,000 3.1 0.12 30.0
202,000 69.0 2.85 712.
2,100 .7 0.03 7.5
260 .1 0.01 2.5
292,760 100.0 4.13 1032.0
-------
SEPTEMBER 25, 1979
THE ATTACHED LIST IS THE MOST CURRENT INFORMATION
AVAILABLE AND SHOULD BE USED TO REVISE THE INFORMATION
ON DRAWING 541-D10-35, DATED 3/30/76.
NOTE: ALL AG CHEM STORAGE TANKS HAVE A BREATHER
OPENING AT THE TOP
-------
A-4
AG CHEM STORAGE TANKS
A-4
Tank
Matenal Stored
Tank
Capacity
Vapor Pressure
in nun Hg
at Temp. Given
1978
Storaqe
A.
TK-101
Spray Stock L
9,979
Gal
Not Available
21,389
Gal
B.
TK-102
Nitration Grade Xylene
15,060
Gal
10 at 80°F
163,488
Gal
C.
TK-103
Super 94 Oil
11,280
Gal
^0.1 at 100°f
86,305
Gal
D.
TK-104
Weed Oil
19,350
Gal
< .5 at 100°F
21,561
Gal
E.
TK-107
Cyclohexanone
4,390
Gal
2 at 20°C
43,387
Gal
F.
TK-108
Sponto N-500B
4 , 390
Gal
Not Available
1,189
Gal
G.
TK-105
Chevron 339 Thinner
10,176
Ga 1
Not Available
23,828
Gal
II.
TK-106
Super 94 Oil
11,740
Gal
<0.1 at 100°F
96,942
Gal
I
TK-113
Dow General
11,280
Gal
<90 at 2 0°C
13,809
Gal
J.
TK-114
Cythion Tech.
12,000
Gal
<.1 at 20°C
5,081
Gal
K.
TK-115
Sprint 38
4,390
Gal
Not Available
3,004
Gal
L.
TK-109
Double-D Oil
11,740
Gal
Not Available
75,668
Gal
M.
TK-116
Contact Weed Killer
11,280
Gal
<20 at 20°C
30,630
Gal
N.
TK-131
Liquid Zinc 9%
16,376
Gal
Not Available
13,003
Gal
P.
TK-127
Waste Water 158,64 0
Gal
Not Available
220,000
Gal
Q.
TK-128
Waste Water 158,640
Gal
Not Available
150,500
Gal
R.
TK-129
Shell 99 S Oil
93,240
Gal
<0.1 at 100°F
279,115
Gal
S.
TK-130
Tenneco 500-100
70,500
Gal
10 at 68°F
67,454
Ga 1
T.
TK-132
Waste Oil
2,000
Gal
Not Available
-0-
U.
TK-126
Xsopropanol
11,900
Gal
34 at 20°C
3,445
Gal
V.
TK-135
Phosphoric Acid
4,390
Gal
5 at 78°F
1,173
Gal
w.
TK-
DBCP Tech.(Empty/Rinsed)
8, 300
Gal
.8 at 68°F
-0-
X.
TK-
DBCP Tech.(Empty/Rinsed)
12,085
Gal
.8 at 68°F
-0-
Y.
TK-
EDB 85
11,800
Gal
12 at 25°C
25,349
Gal
Z.
TK-
EDB 85
11,800
Gal
12 at 25°C
25,349
Cal
AA
TK-
Toxaphene Tech.
11,500
Gal
O at 30°C
-0-
DB
TK-
Allyl Chloride
17,100
Gal
Not Available
W "°-
CC
TK-
DBCP Tech. (Empty/Rinsed) 4,480
Gal
.8 at 68°F
-0-
DD
TK-
Holding Tank - DBCP Tech 2,500
Gal
.8 at 68°f/V." ' ~
J J J
V'
•<» ii J J J L~i
-------
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-------
OCCIDENTAL CHEMICAL COMPANY
D^Y, po Box 198, Lalhrop, California 95330
INTER - OFFICE MEMO
TO:
FROM:
SUBJECT:
DATE:
Sn rwiK t"
I "7 D TcrW
hit/7&J C;'h>v 2JP/>"^cn°1
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-------
OCCIDENTAL CHEMICAL COMPANY
~XY« PO Box 198, Lathrop, California 95330
INTER - OFFICE MEMO
i TO:
FROM:
SUBJECT: \ <£j\
-p
DATE. ^
1 L ^ l\) ^
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-------
APPENDIX B
SUMMARY OF ORGANICS DATA COLLECTED AT OR IN
THE VICINITY OF OXY-LATHROP FACILITY
-------
1 .
B-l
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53. BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
to James Bunting 0ATE February 8, 1980
EPA Legal Coordinator, Oxy-Lathrop
Enforcement Division (EN-338)
from Thomas 0. Da hi (j U ( ')¦
EPA Technical Coordinator, Oxy-Lathrop
subject Summary of Organics Data Collected at or in the Vicinity of Oxy-Lathrop
Facility
Attached please find the subject data. To the best of my knowledge, this
represents a complete summary of organics data collected by Occidental
Chemical Company and their consultant(s) as well as the State of California.
Primary sources of data included:
1) State of California Central Valley Regional Water Quality Control
Board files up to January 9, 1980;
2) State of California, Department of Health Services files;
3) The SEC documents available to NEIC;
4) The report entitled, "Groundwater Quality in the Vicinity of Occidental
Chemical Company, Lathrop, California -- Supplemental Report on
Organic Compoundsof October 1979 by David Keith Todd acting as a
consultant to Occidental Chemical; and
5) An October 2, 1979 submittal by William A. Falik of Landels, Ripley and
Diamond to Harold L. Eisenberg of the California Attorney General's
Office on behalf of Occidental Chemical ComDany, Lathrop, California.
This October 2 submittal purported to include, among other things,
"Organic analysis and data of groundwater or soil done prior to June,
1979, by or for Occidental Chemical Company at or around the Lathrop
facility."
Regarding the attached data, the following should be noted:
1) The date listed is the sampling date unless otherwise noted in the left
margin.
2) Concentrations are in parts per billion (ppb) unless otherwise desig-
nated.
3) All samples are water samples unless noted otherwise, such as "sludge ,
"sediment", or "soil core samples" in the "location" column.
-------
B-2
4) Some duplication of data exists since data were reported by several
sources.
5) Maximum concentrations in soi1/sediment, groundwater and drinking water
have been marked with an asterisk. When maximum concentrations were
noted as "Not a positive identification," the highest confirmed concen-
tration was also noted, when available, with two asterisks.
If there are any questions regarding this summary, please call me.
Enclosures
cc: C. Wills, NEIC
M. Sterns, DOJ
R. Wyatt, EPA Region IX
H. Hatayama, California Health Services
R. Van De Pol, California Water Quality Control Board
H. Eisenberg, Asst. Attorney General, California
-------
COMPOUND ALDRIN
DATE
CONCENTRATION
SOURCE
1/24/79
6.7
OXY
1/24/79
1/24/79
1/25/79
5.8
2.8
3.2
OXY
OXY
OXY
5/13/79
2.6
OXY
3/13/79
3/13/79
1.3
1.3
OXY
OXY
LOCATION
SOIL CORE - 2' DEEP, 50' FROM WEST PROPERTY FENCE,
SOUTH OF CENTER.
SAME - 10' DEEP.
SAME - 30' DEEP.
SOIL CORE - 20' DEEP, 40' FROM PROPERTY FENCE, NEAR
SOUTHWEST CORNER.
SOIL CORE - 5' DEEP, NEAR DISCHARGE DITCH, SOUTH OF
CONCENTRATOR POND.
SAME - 20' DEEP.
SOIL CORF - 20' DEEP, NEAR NORTHEAST CORNER OF CON-
CENTRATOR POND.
00
I
CO
-------
03
I
-e»
COMPOUND TOTAL BHC ISOMERS
DATE
CONCENTRATION
SOURCE
LOCATION
Listed as "about;
1 Hp/L"
Listed as "about:
2 uj;/L"
LisLed as "about
0.1-0.5 Pg/L".
9/25/79
3/25/79
9/25/79
0/3/79
8/3/79
1.0"
2.0
0.1 - 0.5
1-10 PPM"
1-10 PPM
STATE
STATE
STATE
STATE
STATE
LOF 1) A. (NO BETA ISOMER WAS FOUND).
MENDES IRRIGATION WELL.
LOF 10 F.
SEDIMENT-DITCH ADJACENT TO CONCENTRATOR POND.
SEDIMENT-DITCH 100' SOUTH OF CONCENTRATOR POND.
-------
COMPOUND
DATE
CONCENTRATION
SOURCE
Date submitted to lab. 2/7S9/79
0. 024
STATE
7/18-19/79
0.31
TODD REPORT
7/18-19/79
0.06
TODD REPORT
7/18-19/79
0.47
TODD REPORT
7/18-19/79
0.39
TODD REpORT
7/18-19/79
6.1 ::
TODD REPORT
7/18-19/79
0.08
TODD REPORT
7/18-19/79
0.07
TODD REPORT
8/1/79
1.5
TODD REPORT
8/1/79
0.37
TODD REPORT
8/1/79
0.28
TODD REPORT
8/1/79
3.1
TODD REPORT
i
LOCATION
LOF 10 A.
TEST WELL 5.
TEST WELL 6.
TEST WELL 7.
TEST WELL 8.
TEST WELL 9.
TEST WELL 10.
TEST WELL 12.
TEST WELL 5.
TEST WELL 7.
TEST WELL 8.
TEST WELL 9.
-------
COMPOUND B BHC
DATE
CONCENTRATION
SOURCE
7/18-19/79
7/18-19/79
7/18-19/79
8/1/79
8/1/79
8/1/79
0.13
0.28
0.59:
0.42
0. 17
0.35
TODD REPORT
TODD REPORT
TODD REPORT
TODD REPORT
TODD REPORT
TODD REPORT
TEST V/ELL 5.
TEST WELL 7.
TEST WELL 9.
TEST WELL 5.
TEST WELL 7.
TEST WELL 9.
LOCATION
-------
1/2
COMPOUND Y BHC (LINDANE)
D\TE
CONCENTRATION
SOURCE
LOCATI ON
Date rec'd by Stoner lab. 5/24/78
1/25/79
Date submitted to lab,
2/7S9/79
2/28/79
2/28/79
2/28/79
2/28/79
2/28/79
2/28/79
2/28/79
2/28/79
2/28/79
3/8/79
3/9/79
3/9/79
3/9/79
3/9/79
3/13/79
3/13/79
3/13/79
1.1
4.4
0.053
0.3
0.4
0.9 "
0.7
0.4
1.9
0.6
0.7
0.5
2.3
0.4
2.0
0.2
0.2
6.3 "
4.1
2.4 •
OXY
OXY
STATE
OXY
OXY
OXY
OXY
OXY
OXY
OXY
OXY
OXY
OXY
OXY
OXY
OXY
OXY
OXY
• OXY
OXY
MENDES IRRIGATION WELL.
SOIL CORE - 20' DEEP, 40" FROM SOUTH PROPERTY FENCE
NEAR SOUTHWEST CORNER.
LOF 10 A.
PERRY IRRIGATION WELL.
OLSEN IRRIGATION WELL.
MENDES DOMESTIC WELL.
OXY SOUTH WELL.
LOF 10 A.
LOF 10 D.
OXY SOUTHEAST WELL.
OXY EAST WELL.
OLSEN DOMESTIC.
LOF 10 A.
REICHLIN IRRIGATION WELL.
MENDES IRRIGATION WELL.
LATHROP DISTRICT WELL NO. 1.
OXY SOUTH WELL.
SOIL CORE - 10' DEEP, NEAR WASTEWATER DISCHARGE DITCH
AND ROADWAY.
SAME - 15' DEEP.
ro
I
SOIL CORE - 10' DEEP, NEAR WASTEWATER DISCHARGE DITCH,
r» a i iti i r^r~ * rv
-------
2/2
COMPOUND Y BHC (LINDANE)
I'ATE
CONCENTRATION
SOURCE
LOCATION
3/13/79
4.8
OXY
SOIL CORE - 5' DEEP, NEAR DISCHARCiE DITCH, SOUTH OF
CONCENTRATION POND.
3/13/79
1.7
OXY
SAME - 10' DEEP.
3/13/79
3.0
OXY
SOIL CORE - 30' DEEP, NEAR NORTHEAST CORNER OF
CONCENTRATION POND.
3/13/79
4.8
OXY
SOIL CORE - 30' DEEP, NEAR SOUTHWEST CORNER OF
PROPERTY LINE.
7/18-19/79
0.51
TODD REPORT
TEST WELL 5.
7/18-19/79
0.08
TODD REPORT
TEST WELL 6.
7/18-19/79
5.1
TODD REPORT
TEST WELL 7.
7/18-19/79
22.1::
TODD REPORT
TEST WELL 9.
7/18-19/79
0.15
TODD REPORT
TEST WELL 10.
7/18-19/79
0.27
TODD REPORT
TEST WELL 12.
8/1/79
1.53
TODD REPORT
TEST WELL 5.
8/1/79
0.05
TODD REPORT
TEST WELL 6.
8/1/79
2.0
TODD REPORT
TEST WELL 7.
8/1/79
5.7
TODD REPORT
TEST WELL 9.
Listed as "about 9/25/79
0.5 pg/L"
0.5
STATE
MENDES BACK-UP WELL, NORTH OF HOUSE TRAILER.
Listed as "about 9/25/79
0J -'L"
0.1
STAT E
MENDES DOMESTIC, NORTHEAST OF CATTLE CORRAL.
-------
COMPOUND A BHC
DATE
CONCENTRATION
SOURCE
LOCATION
7/18-19/79
0.35
TODD REPORT
TEST WELL 7.
7/18-19/79
3.8"
TODD REPORT
TEST WELL 9.
8/1/79
0.61
TODD REPORT
TEST WELL 5.
8/1/79
0.25
TODD REPORT
TEST WELL 7.
8/1/79
3.5
TODD REPORT
TEST WELL 9.
03
I
UD
-------
COMPOUND CHLORDANE
DATE
CONCENTRATION
SOURCE
1/24/79
260
OXY
1/24/79
225
OXY
1/24/79
386
OXY
1/25/79
98
OXY
1/25/79
115
OXY
1/25/79
280
OXY
3/13/79
520
OXY
j/13/79
365
OXY
j! 13/79
320
OXY
3/13/79
249
OXY
3/13/79
191
OXY
3/13/79
126
OXY
3/13/79
71
OXY
3/13/79
169
OXY
3/13/79
101
OXY
3/13/79
250
CXY
1/2
¦CO
I
LOCATION
SOIL CORE - 2' DEEP, 50' FROM WEST PROPERTY FENCE,
SOUTH OF CENTER.
SAKE - 10' DEEP.
SANE - 30' DEEP.
SOIL CORE - 21 DEEP, 40' FROM SOUTH PROPERTY FENCE,
NEAR SOUTHWEST CORNER.
SAME - 10' DEEP.
SAME - 20' DEEP.
SOIL CORE - 10' DEEP, NEAR WASTEWATER DISCHARGE
DITCH AND ROADWAY.
SAME - 15' DEEP.
SOIL CORE - 10' DEEP, NEAR WASTEWATER DISCHARGE
DITCH, 200' SOUTH OF ROADWAY.
SOIL CORE - 5' DEEP NEAR DISCHARGE DITCH, SOUTH
OF CONCENTRATOR POND.
SAME - 10' DEEP.
SAME - 20' DEEP.
SAME - 30' DEEP.
SOIL CORE - 101 DEEP, NEAR NORTHEAST CORNER OF
CONCENTRATOR POND.
SAME - 20' DEEP.
SAME - 30' DEEP.
-------
i.1 c
O>P0UND CHLORDANE
DATE
CONCENTRATION
SOURCE
LOCATI ON
3/13/79
5.3
OXY
SOIL CORE - 30' DEEP, AT SOUTHWEST CORNER OF
PROPERTY LINE.
3/14/79
5000
TODD REPORT
SEDIMENT-POND 810.
3/14/79
5000
OXY
SED1 MENT-WASTEWATER POND.
3/14/79
40 PPM »
STATE
SEDIMENT-WASTEWATER POND.
3/15/79
5000
TODD REPORT
SEDIMENT-COOLING POND DITCH.
3/15/79
5000
OXY
SEDIMENT-DISCHARGE DITCH.
3/15/79
4000
OXY
SEDIMENT-DISCHARGE DITCH.
of meiro jn "hich 3/22/79
\>ere included.
7/11/79
4000
10
OXY
STATE
SLUDGE - 4-6" BELOW WASTE POND BOTTOM.
OVERFLOW DITCH.
7/11/79
100
STATE
SEDIMENT- 40 YARDS FROM CONCENTRATOR POND IN
OVERFLOW DITCH.
8/3/79
1-10 PPM
STATE
SEDIMENT-DITCH ADJACENT TO CONCENTRATOR POND.
8/3/79
1-10 PPM
STATE
SEDIMENT-DITCH 100' SOUTH OF CONCENTRATOR POND.
-------
COMPOUND
DATE
CONCENTRATION
9/25/79
9/25/79
9/25/79
9/25/79
9/25/79
10/22/79
10/30/79
0.5
2.0-
0.2
0.3
0.2
0.5
1.3"
CHLOROFORM
CD
I
SOURCE
LOCATION
STATE
STATE
STATE
STATE
STATE
STATE
STATE
LCWD 81.
FULLER IRRIGATION WELL.
LOF 10 A.
MENDES BACK-UP WELL, NORTH OF TRAILER HOUSE,
MENDES IRRIGATION WELL.
FULLER IRRIGATION WELL.
LCWD #1.
-------
1/6
COMPOUND DBCP
DATE
CONCENTRATION
SOURCE
LOCATION
Date o£ memo in 3/16/78
which data were included.
0.3
OXY
SOIL CORE - 2' DEEP, 40' FROM SOUTH FENCE.
Dale of memo in 3/16/78
which daLa were; included.
0.3
0XY
SAME - 10' DEEP.
Date of merro in 3/16/78
\luch data were included.
0.6
OXY
SAME - 20' DEEP.
1/24/79
12.9
OXY
SOIL CORE - 2' DEEP, 50' FROM WEST PROPERTY FENCE,
SOUTH OF CENTER.
1/24/79
3.5
OXY
SAME - 10' DEEP.
1/24/79
0.5
OXY
S/WE - 30' DEEP.
1/25/79
0.6
OXY
SOIL CORE - 20' DEEP, 40' FROM SOUTH PROPERTY FENCE,
NEAR SOUTHWEST CORNER.
2/5/79
00
STATE
MENDES DOMESTIC WELL.
2/8/79
13.0
STATE
LOF 10 A.
2/27/79
00
oc
STATE
LOF 10 A.
2/27/79
4.3
STATE
MENDES DOMESTIC WELL.
2/27/79
1.0
STATE
CONCENTRATOR POND OVERFLOW.
2/27/79
220
STATE
SEDIMENT-CONCENTRATOR POND OVERFLOW DITCH.
2/27/79
1.6
TODD REPORT
SEDIMENT-COOLING POND DITCH.
-------
2/6
COMPOUND DBCP
DATE
CONCENTRATION
SOURCE
LOCATION
2/27/79
1.9
STATE
WASTEWATER POND.
Date s.nup os vara sub-
mitted to ub.
0.1 as lIk detect.on
level.
2/28/79
2/28/79
1.9
0.1
STATE
OXY
BEST STORM WATER POND.
^LSE'.s IRRIGATION WELL.
2/28/79
6.2
OXY
MENDES DOMESTIC WELL.
2/28/79
8.2
OXY
LOF 10 A.
2/28/79
6.6
OXY
LOF 10 A.
1/28
AND 3/1/79
7.4
OXY
LOF 10 A.
2/23
AMD 3/1/79
5.3
OXY
MENDES DOMESTIC WELL.
Annlyzed 1:3:112 n
V-2-» 1 (G1 C- CCD)
3/8/79
111
TODD REPORT
SEDIMENT-COOLING POND DITCH.
Analyzed 'isxng a
CC-LCD .
3/8/79
990
TODD REPORT
SEDIMENT-COOLING POND DITCH.
3/8/79
5.3
OXY
LOF 10 A.
3/8/79
6.5
OXY
LOF 10 A.
Analyzed jsmg a
V-2-A1 (G'.C-ECD)
3/8/79
111
OXY
SEDIMENT-DISCHARGE DITCH.
Analyzed "'ung a
GC-ECD .
3/8/79
990
OXY
SEDIMENT-DISCHARGE DITCH.
3/9/79
3.9
OXY
REICHLIN IRRIGATION WELL.
3/9/79
57
OXY
MENDES IRRIGATION WELL.
3/9/79
3.4
"OXY
MENDES IRRIGATION WELL.
-------
COMPOUND
DBCP
DATE
CONCENTRATION
SOURCE
3/13/79
3/13/79
3/13/79
3/13/79
3/13/79
3/13/79
3/14/79
3/14/79
3/14/79
3/14/79
3/14/79
3/14/79
3/14/79
3/14/79
3/14/79
3/14/79
3/15/79
78
900
38
285
1.5
11.0
2.0
100
65
100
2.0
2.0
13.0
41.0
68.0
30.0
2600"
OXY
OXY
OXY
OXY
OXY
OXY
TODD REPORT
TODD REPORT
OXY
OXY
OXY
STATE
STATE
STATE
STATE
STATE
TODD REPORT
LOCATION
SOIL CORE - 5' DEEP NEAR WASTEWATER DISCHARGE DITCH
AND ROADWAY.
SAME - 10' DEEP.
SAME - 15' DEEP.
SOIL CORE - 10' DEEP, NEAR WASTEWATER DISCHARGE DITCH
200' SOUTH OF ROADWAY.
SOIL CORE - 5' DEEP, NEAR DISCHARGE DITCH, SOUTH OF
CONCENTRATION POND.
SOIL CORF - 30' DEEP, AT SOUTHWEST CORNER OF PROPERTY
LINE.
pond no.
SEDIMENT-POND S10.
MENDES IRRIGATION WELL.
SEDIMENT-WASTEWATER POND.
WASTEWATER POND.
WASTEWATER POND.
LOF 10 B.
LOF 10 F.
MENDES IRRIGATION WELL.
SEDIMENT-WASTEWATER POND. ro
SEDIMENT-COOLING POND DITCH.
-------
4/6
CO
COMPOUND DBCP
CT>
DATE
CONCENTRATION
SOURCE
LOCATION
3/15/79
2600
OXY
SEDIMENT-WASTEWATER DISCHARGE DITCH.
5/15/79
12.0 PPM
OXY
WATER FROM WEST TOXIC WASTEWATER TAJIK.
3/16/79
9.8::
STATE
MENDES DOMESTIC WELL.
4/9/7'-!
17
STATE
MENDES IRRIGATION WELL.
5/1/79
5.0
TODD REPORT
TEST WELL 7.
5/ 17-18//9
0.2
TODD REPORT
TEST WELL 1.
5/17-18/79
0.3
TODD REPORT
TEST WELL 2.
5/17/18-79
1.3
• TODD REPORT
TEST WELL 3.
5/17-18//9
2.7
TODD REPORT
TEST WELL k.
5/17-18 /"''9
0.8
TODD REPORT
TEST WELL 5.
5/17-18/79
0.6
TODD REPORT
TEST WELL 6.
5/17-18/79
2.0
TODD REPORT
TEST WELL 7.
5/17/18/79
0.6
TODD REPORT
TEST WELL 8.
6/1/79
0.1
TODD REPORT
TEST WELL 1.
6/1/79
0.2
TODD REPORT
TEST WELL 2.
6/1/79
0.1
TODD REPORT
TEST WELL 3.
6/1/79
0.2
TODD REPORT
TEST WELL 4.
6/1/79
3.8
TODD REPORT
TEST WELL 5.
6/1/79
1.0
TODD REPORT
TEST WELL 6.
-------
COMPOUND DBCP
DATE
CONCENTRATION
SOURCE
6/1/79
6/1/79
7/11/79
7/18-19/79
7/18-19/79
7/18-19/79
7/18-19/79
7/18-19/79
8/1/79
8/1/79
8/1/79
8/1/79
8/3/79
9/25/79
9/25/79
9/25/79
9/25/79
9/25/79
3.9
0.05
6.0
1.0
1.0
90
39
30
1. 1
95::
23
22
0.36
15
0.3
19
0.8
59
TODD REPORT
TODD REPORT
STATE
TODD REPORT
TODD REPORT
TODD REPORT
TODD REPORT
TODD REPORT
TODD REPORT
TODD REPORT
TODD REPORT
TODD REPORT
STATE
STATE
STATE
STATE
STATE
STATE
6
LOCATI ON
TEST WELL 7.
TEST WELL 8.
SEDIMENT-OVERFLOW DITCH, 40 YARDS FROM CONCENTRATOR
POND.
TEST WELL 5.
TEST WELL 6.
TEST WELL 7.
TEST WELL 9.
TEST WELL 12.
TEST WELL 5.
TEST WELL 7.
TEST WELL 9.
TEST WELL 12.
OVERFLOW DITCH, 100' SOUTH.
LOF 10 A.
LOF 10 B.
LOF 10 F.
SULLIVAN WELL.
MENDES BACK-UP WELL, NORTH OF TRAILER HOUSE.
-------
6/6
COMPOUND DBCP
DATE
CONCENTRATION
SOURCE
LOCATION
9/25/79
2.0
STATE
MENDES DOMESTIC WELL, NORTHEAST OF CATTLE CORRAL.
9/25/79
38
STATE
MENDES IRRIGATION WELL.
10/22/79
0. 7U
STATE
SULLIVAN WELL.
10/30/79
0.12
STATE
SULLIVAN WELL.
11/13/79
0.5
STATE
SULLIVAN WELL.
12/5/79
0.9
STATE
SULLIVAN WELL.
12/5/79
0.1
STATE
LCWD £1.
12/5/79
0. 1
STATE
LCWD S3.
-------
COMPOUND DDD
DATE CONCENTRATION SOURCE
7/11/79 1.0 STATE
8/3/79 1-10 PPM" STATE
8/3/79 1-10 PPM STATE
LOCATION
DITCH AT CONCENTRATOR POND.
SEDIMENT-DITCH ADJACENT TO CONCENTRATOR POND.
SEDTMENT-DITCH 100' SOUT.H OF CONCENTRATOR POND.
-------
COMPOUND
DDE
DATE
CONCENTRATION
SOURCE
7/11/79
7/11/79
7/11/79
10
10
1000
STATE
STATE
STATE
3/3/79
3/3/79
1-10 PPM::
1-10 PPM
STATE
STATE
C3
I
ro
o
LOCATION
DITCH AT CONCENTRATOR POND.
OVERFLOW DITCH.
SEDIMENT-OVERFLOW DITCH, 40 YARDS FROM CONCENTRATOR
POND.
SEDIMENT-DITCH ADJACENT TO CONCENTRATOR POND.
SEDIMENT-DITCH 100' SOUTH OF CONCENTRATOR POND.
-------
COMPOUND
DDT
DATE
CONCENTRATION
SOURCE
5/1^/79
3/1^/79
7/11/79
7/11/79
7/11/79
8/3/79
8/3/79
20 PPM "
20 PPM
1.0
10
1000
1-10 PPM
1-10 PPM
TODD REPORT
OXY
STATE
STATE
STATE
STATE
STATE
LOCATION
SEDIMENT - POND II10.
SEDIMENT - WASTEWATER POND.
DITCH AT CONCENTRATOR POND.
OVERFLOW DITCH WATER.
SEDIMENT - OVERFLOW DITCH, 40 YARDS FROM CONCEN-
TRATOR POND.
SEDIMENT - DITCH ADJACENT TO CONCENTRATOR POND.
SEDIMENT - DITCH 100' SOUTH OF CONCENTRATOR POND.
-------
COMPOUND DEF
DATE
CONCENTRATION
SOURCE
Idemtif ica t loii
not positive.
1/2 £f/7 9
9.4
OXY
Identificalion
not positive.
1/24/79
60
OXY
Identlfica t ion
not positive.
1/25/79
21
OXY
Ident ification
not pos iti\e
1/25/79
2.5
OXY
Idcntif Lea t ion
not pos i t i^'e .
1/25/79
1.3
OXY
1 don ciCica t j on
not positive.
2/27/79
22
OXY
Idcnllfica tion
not. positive.
2/27/79
3.3
OXY
Idcnlificat ion
roi positive.
3/8/79
3.2 "
OXY
Identificat:on
not positive.
3/8/79
0.3
OXY
Identification
not pos Ltive.
3/9/79
0.2
OXY
Identification
not positive.
3/9/79
O
CO
OXY
Identification
not positive.
3/9/79
0.4 "
OXY
1/3
CO
I
rv>
ro
LOCATION
SOIL CORE - 10' DEEP, 50' FROM WEST PROPERTY FENCE,
SOUTH OF CENTER.
SAME - 30' DEEP.
SOIL CORE - 2' DEEP, 40' FROM SOUTH PROPERTY FENCE,
NEAR SOUTHWEST CORNER.
SAME - 10' DEEP.
SAME - 20' DEEP.
WASTE POND WATER.
WATER FROM DISCHARGE DITCH TO WASTE POND.
LOF WELL 10 A.
RAINWATER POND.
REICHLIN IRRIGATION WELL.
MENDES IRRIGATION WELL.
LATHROP DISTRICT WELL NO. 1.
-------
COMPOUND
DEF
DATE
CONCENTRATION
SOURCE
Idem l fication
not. positive.
Identification
not positx^-e.
Idcntiflc^tion
not positive.
IdontiCicati .m
not positive.
Iduntific?tJ on
not positive.
Id(_nt j f icat j r.n
not positive.
DaLe of r"Cno in
wh:ch data rerc
included.
3/9/79
3/9/79
3/13/79
3/13/79
3/13/79
3/13/79
3/14/79
3/14/79
3/14/79
3/14/79
3/14/79
5/14/79
3/15/79
3/15/79
3/22/79
0.2
0.2
102
108
11.2
18.5
30
2000 PPM
0.5 ::
2000 PPM
30
3000 PPM
1100 PPM
1100 PPM
4000 PPM
OXY
0XY
OXY
OXY
OXY
OXY
TODD REPORT
TODD REPORT
OXY
OXY
OXY
STATE
TODD REPORT
OXY
OXY
2/3
LOCATION
OXY SOUTH WELL.
AIR PRODUCTS WELL.
SOIL CORE - 5' DEEP, NEAR WASTEWATER DISCHARGE
DITCH AND ROADWAY.
SAME - 10' DEEP.
SAME - 15' DEEP.
SOIL CORE - 10' DEEP, NEAR WASTEWATER DISCHARGE
DITCH, 200' SOUTH OF ROADWAY.
POND 310.
SEDIMENT - POND H10.
OXY SOUTH WELL.
SEDIMENT - WASTEWATER POND.
WASTEWATER POND.
SEDIMENT - WASTEWATER POND.
SEDIMENT-COOLING POND DITCH.
SEDIMENT-WASTEWATER DISCHARGE DITCH.
SLUDGE - 4-6" BELOW WASTE POND BOTTOM.
i
ro
-------
COMPOUND DEF
DATE
CONCENTRATION
SOURCE
Date of iiomo in vhich
data rcio included.
Date of i'>e^o j n vhich
data uci'c included.
3/15/79
3/22/79
5/22/79
5/1/79
7/11/79
7/11/79
7/11/79
8/3/79
8/3/79
1200 PPM
0.4
10
0.2
10
10
1000
4000
1000
OXY
OXY
OXY
TODD REPORT
STATE
STATE
STATE
STATE
STATE
I
3/3
LOCATION
SEDIMENT - DISCHARGE DITCH.
BEST SOUTH WELL.
WASTE POND.
TEST WELL 7.
DITCH AT CONCENTRATOR POND.
OVERFLOW DITCH.
SEDIMENT OVERFLOW DITCH, 40 YARDS FROM CONCENTRATOR
POND.
SEDIMENT DITCH ADJACENT TO CONCENTRATOR POND.
SEDIMENT DITCH, 100' SOUTH OF CONCENTRATOR POND.
-------
1/3
COMPOUND DIAZINON
DATE
CONCENTRATION
SOURCE
LOCATION
1/20/76
5000
OXY
WASTE POND
- CENTER WEST SIDE.
1/20/76
40 PPM
OXY
BONEYARD POOL.
2/26/76
2300
OXY
WASTE POND
3/4/76
1000
OXY
WASTE POND
Not a positive
ident 1 f ic it 1011.
1/24/79
4.8
OXY
SOIL CORE - 2 ' DEEP, 50' FROM WEST PROPERTY FENCE,
SOUTH OF CENTER.
Mot a positive
identif icaiion.
1/24/79
3.1
OXY
SAME - 10'
DEEP.
Not a p'ositive
- dent 1fica tion
1/24/79
3.6
OXY
SAME - 30'
DEEP.
Not a positive
identifica tion.
1/25/79
2.3
OXY
SOIL CORE - 2' DEEP, 40' FROM SOUTH PROPERTY FENCE,
NEAR SOUTHWEST CORNER.
!>ot a positive
identification.
1/25/79
1.4
OXY
SAME - 10'
DEEP.
Not a positive
identification.
1/25/79
6.5
OXY
SAME - 20'
DEEP.
Not a positive
ident1fica tion.
3/13/79
7.4
OXY
SOIL CORE - 5' DEEP, NEAR WASTEWATER DISCHARGE
DITCH AND ROADWAY.
Not a positive
identification.
3/13/79
4.4
OXY
SAME - 10'
DEEP.
Not a positive
identlfica13 on.
3/13/79
10.6
OXY
SAME - 15'
DEEP.
c
1
Not a positive
identlfication.
3/13/79
3.5
OXY
SOIL CORE -
200' SOUTH
r\
- 10' DEEP, NEAR WASTEWATER DISCHARGE DITlH°
OF ROADWAY.
-------
2/3
03
COMPOUND DIAZINON £
DYTE
CONCENTRATION
SOURCE
LOCATION
Not a positive
identification.
3/13/79
00
o
OXY
SOIL CORE - 5' DEEP, NEAR DISCHARGE DITCH, SOUTH OF
CONCENTRATOR POND.
Not a positive
ident:fication.
3/13/79
0.7
OXY
SAME - 10' DEEP.
Not a positive
ideniificntion.
3/13/79
0.5
OXY
SAME - 20" DEEP.
Not d positive
identification.
3/13/79
6.6
OXY
SAME - 30' DEEP.
Not d positive
idem if ication.
3/13/79
11
OXY
SOIL CORE - 10' DEEP, NEAR NORTHEAST CORNER OF
CONCENTRATOR POND.
Hot d positive
l den11fica 11on.
3/13/79
39 "
OXY
SAME - 20' DEEP.
Nol a positive
ldentification.
3/13/79
6.3
OXY
SAME - 30' DEEP.
\'ot a posLtivc
identiflen tion .
3/13/79
1.7
OXY
SOIL CORE - 30' DEEP, AT SOUTHV.'EST CORNER OF
PROPERTY LINE.
3/14/79
120
TODD REPORT
POND «10.
3/14/79
120
OXY
WASTEWATFR POND.
3/15/79
200 PPM
OXY
TOXIC WASTEWATER TANK.
Date of rremo in
uhich these data
were included.
3/22/79
20 PPM
OXY
TOXIC WASTEWATER TANK.
5/1/79
1.8
TODD REPORT
TEST WELL 3.
5/1/79
11.0 ::
TODD REPORT
TEST WELL 4.
-------
5
COMPOUND DIAZINON
DATE
CONCENTRATION
SOURCE
LOCATION
5/1/79
4.9
TODD REPORT
TEST WELL 5.
5/1/79
1.8
TODD REPORT
TEST WELL 6.
5/1/79
1.7
TODD REPORT
TEST WELL 7.
5/1/79
0.85
TODD REPORT
TEST WELL 8.
5/17-18/79
0.3
TODD REPORT
TEST WELL 1.
5/17-18/79
h. 1
TODD REPORT
TEST WELL 5.
6/1/79
0.2
TODD REPORT
TEST WELL 2.
CO
no
-
-------
COMPOUND DIBROM
DATE
CONCENTRATION
SOURCE
3/15/79
5000 "
TODD REPORT
3/15/79
5000
OXY
CO
I
ro
CD
LOCATION
SEDIMENT-COOLING POND DITCH.
SEDIMENT-WASTEWATER DISCHARGE DITCH.
-------
COMPOUND 1,1-DICHLOROETHANE
D'vTE
CONCENTRATION
SOURCE
LOCATIOti
9/25/79
O
STATE
FULLER IRRIGATION WELL.
10/22/79
k.Q ••
STATE
FULLER IRRIGATION WELL.
10/30/79
1.3
STATE
FULLER IRRIGATION WELL. «
-------
COMPOUND 1,2-DICHLOROETHANE w
CO
o
DATE
CONCENTRATION
SOURCE
LOCATION
11/13/79
0. 18 *
STATE
LCWD ti3.
-------
COMPOUND
DATE
CONCENTRATION
9/25/79
9/25/79
9/25/79
0.2
0.2
1.0 "
1,1-' DICHLOROETHYLENE
SOURCE LOCATION
STATE LOF 10 A.
STATE MENDES BACK-UP WELL, NORTH OF TRAILER HOUSE.
STATE MENDES IRRIGATION WELL.*
DO
I
U>
-------
COMPOUND TRANS -1,2-DICHLOROETHYLENE co
ro
DME
CONCENTRATION
SOURCE
LOCATION
11/13/79
0.3 *
STATE
FULLER IRRIGATION WELL.
-------
COMPOUND 1,2-DTCHLOROPROPANE
DATE
CONCENTRATION
SOURCE
LOCATI ON
9/25/79
0.5
STATE
LCWD n 3.
9/25/79
1.3
STATE
FULLER DOMESTIC.
10/22/79
1.0
STATE
LCWD 513.
10/22/79
3.3 ::
STATE
FULLER DOMESTIC.
10/50/79
0.3
STATE
LCWD S3.
10/30/79
0.2
STATE
SULLIVAN.
10/30/79
0.6 ::
STATE
FULLER IRRIGATION.
10/30/79
2.0
STATE
FULLER DOMESTIC
11/13/79
0.k2
STATE
LCWD 83.
11/13/79
0.5
STATE
FULLER IRRIGATION.
11/13/79
l.k
STATE
FULLER DOMESTIC.
12/5/79
0.42
STATE
LCWD S3.
CO
CO
OJ
-------
CO
I
COMPOUND DIELDRIN
DATE
CONCENTRATION
SOURCE
LOCATION
1/24/79
32 ::
OXY
SOIL CORE - 2' DEEP, 50' FROM WEST PROPERTY FENCE,
SOUTH OF CENTER.
3/13/79
3.3
OXY
SOIL CORE - 5' DEEP, NEAR DISCHARGE DITCH, SOUTH
OF CONCENTRATOR POND.
-------
CONFOUND DIMETHOATE
DATE
CONCENTRATION
SOURCE
LOCATION
4/24/78
100
OXY
WASTEWATER POND NEAR ENTRANCE.
Not a positive 2/27/79
1.2
OXY
OXY SOUTH WELL.
identification.
not a positive 2/28/79
<4.2
OXY
LOF 10 A.
identification.
Not j positive 2/28/79
5.0
OXY
LOF 10 D.
identification.
Not a positive 2/28/79
1.8 ::
OXY
OXY EAST WELL.
identification.
N'ot a positive 3/13/79
1.0 "
OXY
SOIL CORE - 30' DEEP, AT SOUTHWEST CORNER OF
identlfication.
PROPERTY LINE.
8/1/79
2.1
TODD REPORT
TEST WELL 5.
8/1/79
9.9 ::
TODD REPORT
TEST WELL 7.
CO
CO
<_n
-------
COMPOUND PISULFOTQN (DISYSTON)
DATE
CONCENTRATION
SOURCE
LOCATION
Not a positive
identification.
2/27/79
0.4
OXY
DISCHARGE DITCH TO WASTE POND.
Not a positive
identification.
3/9/79
2.2
OXY
MENDES IRRIGATION WELL.
Not a positive
ident11ication.
3/13/79
1.1
OXY
SOIL CORE - 5' DEEP NEAR WASTEWATER DISCHARGE
DITCH AND ROADWAY.
Kot n positive
id entif 1ca tion.
3/13/79
4.3
OXY
SAME - 15' DEEP.
3/15/79
40 PPM
TODD REPORT
SEDIMENT - COOLING POND DITCH.
3/15/79
40 PPM
OXY
SEDIMENT - WASTEWATER DISCHARGE DITCH.
3/15/79
80 PPM ::
OXY
SEDIMENT - DISCHARGE DITCH.
5/1/79
3.5 ::
TODD REPORT
TEST WELL 7.
7/11/79
10
STATE
OVERFLOW DITCH.
7/11/79
100
STATE
SEDIMENT - 40 YARDS FROM CONCENTRATOR POND.
8/3/79
1000
STATE
SEDIMENT - DITCH ADJACENT TO CONCENTRATOR POND.
-------
COMPOUND DNBP
DaTE
CONCENTRATION
SOURCE
2/27/79
7/18-19/79
7/18-19/79
8/1/79
200 ::
18 =
1.5
17.5
STATE
TODD REPORT
TODD REPORT
TODD REPORT
LOCATION
SEDIMENT - CONCENTRATOR POilD OVERFLOW DITCH.
TEST WELL 7.
TEST WELL 10
TEST WELL 7.
-------
CO
t
CONFOUND DURSBAN CCHLORPYRIFOS) oo
DATE
CONCENTRATION
SOURCE
LOCATIO! 1
of ncro m \'hxch
wore included.
3/14/79
3/14/79
3/14/79
3/15/79
3/15/79
3/22/79
7/11/79
4000
4000
4000
200 PPM ::
200 PPM
4000
100
TODD REPORT
OXY
STATE
TODD REPORT
OXY
OXY
STATE
SEDIMENT- POND 810.
SEDIMENT - WASTEWATER POND.
SEDIMENT - WASTEWATER POND.
SEDIMENT - COOLING POND DITCH.
SEDIMENT - WASTEWATER DISCHARGE DITCH.
SLUDGE - 4-6" BELOW WASTE POND BOTTOM.
SEDIMENT - 40 YARDS FROM CONCENTRATOR POND IN
OVERFLOW DITCH.
-------
COMPOUND EDB (ETDB, 1,2-DIBROMOETHANE)
DATE
CONCENTRATION
SOURCE
LOCATION
3/14/79
44 ::
OXY
MENDES IRRIGATION WELL.
3/15/79
6700 "
TODD REPORT
SEDIMENT-COOLING POND DITCH.
t
3/15/79
6700
OXY
SEDIMENT-WASTEWATER DISCHARGE DITCH.
3/15/79
800 PPM
OXY
TOXIC WASTEWATER TANK.
7/13-19/79
35
TODD REPORT
TEST WELL 7.
8/1/79
34
TODD REPORT
TEST WELL 7.
9/25/79
3.0
STATE
LOF 10 A.
9/25/79
2.0
STATE
LOF 10 F.
9/25/79
2.5
STATE
MENDES BACKUP WELL.
9/25/79
2.5
STATE
MENDES IRRIGATION WELL.
00
oo
U3
-------
1/2
UD
I
COMPOUND ENDOSULFAN I. II
DUE
CONCENTRATION
SOURCE
LOCATION
4/22/77
250 PPM
OXY
AG CHEM DITCH WATER.
4/19/78
17
OXY
WASTEWATER POND NEAR ENTRANCE.
4/19/78
0.2
OXY
POND - MIDWAY WESTS IDE. '
4/24/78
2.1
OXY
POND NEAR ENTRANCE.
4/26/78
0.1
OXY
POND NEAR ENTRANCE.
2/27/79
4.0
OXY
WASTE POND.
2/27/79
10 PPM
STATE
SEDIMENT-CONCENTRATOR POND OVERFLOW DITCH.
:d a:>
it 0 1 ppb" 2/28/79
0.1
STATE
CONCENTRATOR POND OVERFLOW.
3/14/79
4.0
TODD REPORT
POND it 10.
3/14/79
40 PPM
TODD REPORT
SEDIMENT POND B10.
3/14/79
40 PPM
OXY
SEDIMENT-WASTEWATER POND.
3/14/79
4.0
OXY
WASTEWATER POND.
3/14/79
40 PPM
STATE
SEDIMENT-WASTEWATER POND.
3/15/79
20 PPM
TODD REPORT
SEDIMENT-COOLING POND DITCH.
3/15/79
20 PPM
OXY
SEDIMENT-WASTEWATER DISCHARGE DITCH.
3/15/79
4 PPM
OXY
TOXIC WASTEWATER TANK.
3/15/79
400 PPM ::
OXY
SEDIMENT-DISCHARGE DITCH.
of memo xn i-hich 3/22/79
40 PPM
OXY
SLUDGE - 4-6" BELOW BOTTOM OF WASTE POND.
were included.
-------
COMPOUND
D'ME
CONCENTP.AT I ON
IVto of nc.ro in
wiu ch data '.ere
llll_ 1 uclcJ .
3/22/79
8/3/79
8/3/79
2000
1-10 PPM
1-10 PPM
ENDOSULFAN I, I I
SOURCE LOCATION
OXY TOXIC WASTEWATER TANK.
STATE SEDIMENT-DITCH ADJACENT TO CONCENTRATOR POND.
f
STATE SEDIMENT-DITCH 100 1 SOUTH OF CONCENTRATOR POND.
CD
I
-------
COMPOUND ETHION
DATE
CONCENTRATION
3/15/79
3/15/79
3/15/79
//11/79
8/3/79
8/3/79
10 PPM
10 PPM
12 PPM ::
100
500
1000
SOURCE
TODD REPORT
OXY
OXY
STATE
STATE
STATE
CD
I
-&>
rv)
LOCATION
SEDIMENT-COOLING POND DITCH.
SEDIMENT-WASTEWATER DISCHARGE DITCH.
SEDIMENT-DISCHARGE DITCH.
SEDIMENT-DISCHARGE DITCH 40 YARDS FROM CONCENTRATOR
POND.
SEDIMENT-DITCH ADJACENT TO CONCENTRATOR POND.
SEDIMENT-DITCH 100' SOUTH OF CONCENTRATOR POND.
-------
COMPOUND
DVTE
CONCENTRATION
Da Le of - c.i n • a i.. li
L , J \ Ll\ 1 'It. J ikIocI
ccg .utaclicd P.J) Ldl"
i nc,1 L ion-;
S r c js .i I a
S;'~ic at. abt
cf- c s Oi i_:.
S i. io <• s nhi''^l; .
S.t c .t- c in 'O .
Sarro .->b Ii(. .. c .
Sane as ,'bove.
Seme a~ p'jo e.
Sane a: above.
Same as .lbovc.
Sana as alovc.
Same as ..buve.
Sane ns al.o-,e.
Sane as above.
Same as above.
Sane as above.
1/19/76
5/4/76
7/19/76
7/19/76
7/19/76
7/19/76
7/19/76
//19/76
7/19/76
7/19/76
7/19/76
7/19/76
7/19/76
7/19/76
7/19/76
7/19/76
7/19/76
7/19/76
7/19/76
5000
1000
1000
1000
500
100
100
1000
100
230 PPM
150 PPM
400 PPM
40 PPM
150 PPM
1700 PPM "
50 PPM
125 PPM
50 PPM
50 PPM
ETHYL PARATHION
LOCATION
WASTEWATER POND - CENTER WEST SIDE
WASTE POND.
SITE B - 2' DEEP.
SITE B -
SITE B -
SITE C -
SITE C -
SITE C -
SITE C -
SITE D -
SITE D -
SITE E -
SITE E -
10' DEEP.
20' DEEP.
2* DEEP.
10' DEEP.
20' DEEP.
30' DEEP.
SURFACE.
1' DEEP.
SURFACE.
1' DEEP.
SITE G
SITE H
SITE H
SITE J
SITE J
SITE J
- 1' DEEP.
- 6" DEEP.
- 1' DEEP.
- 1* DEEP.
- 2* DEEP.
- V DEEP.
-------
2/4
00
1
COPOUND ETHYL PARATHION £
DATE
CONCENTRATION
SOURCE
LOCATION
4/19/78
500
OXY
WASTEWATER POND NEAR ENTRANCE.
4/24/78
300
OXY
WASTEWATER POND NEAR ENTRANCE.
"lot a
id an t 1
positi ve
flea tion.
1/24/79
3.6
OXY
SOIL CORE - 2' DEEP, 50'. FROM WEST PROPERTY FENCE,
SOUTH OF CENTER.
2/27/79
4000
STATE
SEDIMENT-CONCENTRATOR POND OVERFLOW DITCH.
Iv>t ci
positlve
2/27/79
10.9
OXY
WASTE POND.
ulcnti L" Lcation .
Not n
posi t Lve
ID.
2/28/79
0.8
OXY
PERRY IRRIGATION WELL.
Nut j
posiLive
7 1).
2/28/79
0.4
OXY
OXY SOUTH WELL.
Not j
positive
ID.
2/28/79
1.3
OXY
LOF 10 D.
Ko t a
positlve
ID.
2/28/79
3.9 ::
OXY
OXY SOUTHEAST WELL.
Not a
positlve
ID.
2/28/79
1.5
OXY
OXY EAST WELL.
Not n
positive
ID
2/28/79
1. 1
OXY
OLSEN DOMESTIC.
Mot a
posltlve
ID.
2/28/79
0.2
OXY
FORT DOMESTIC.
Not a
positivc
ID.
2/28/79
0.7
OXY
MOSSDALE RECREATIONAL AREA WELL.
Mot a
positlve
ID.
3/13/79
123
OXY
SOIL CORE - 5' DEEP, NEAR WASTEWATER DISCHARGE
DITCH AND ROADWAY.
Not a
positive
ID.
3/13/79
9.7
OXY
SAME - 10' DEEP.
Not a
posit ive
ID.
3/13/79
1.0
OXY
SOIL CORE - 10' DEEP, NEAR WASTEWATER DISCHARGE
DITCH, 200 FT SOUTH OF ROADWAY
3/14/79
20
TODD REPORT
POND it 10.
-------
COMPOUND ETHYL PARATHION
DX1E
CONCENTRATION
SOURCE
LOCATION
3/1^/79
4000
TODD REPORT
SEDIMENT-POND illO.
3/14/79
4000
OXY
SEDIMENT-WASTEWATER POND.
3/14/79
20
OXY
WASTEWATER POND.
3/14/79
4000
STATE
SEDIMENT-WASTEWATER POND.
3/15/79
60 PPM
TODD REPORT
SEDIMENT-COOLING POND DITCH.
3/15/79
60 PPM
OXY
SEDIMENT-WASTEWATER DISCHARGE DITCH.
3/15/79
10 PPM
OXY
TOXIC WASTEWATER TANK.
3/15/79
80 PPM
OXY
SEDIMENT-DISCHARGE DITCH.
f ner.io m which data 3/22/79
neJLudcd.
f men'o in \'liLch data 3/22/79
,cl„dod. 5/1/79
8000
12 PPM
0.2
OXY
OXY
TODD REPORT
SLUDGE - 4-6" BELOW WASTE POND BOTTOM.
TOXIC WASTEWATER TANK.
TEST WELL 4.
5/1/79
0.6
TODD REPORT
TEST WELL 5.
5/1/79
7.5 "
TODD REPORT
TEST WELL 7.
5/17-18/79
3.1
TODD REPORT
TEST WELL 7.
6/1/79
2.2
TODD REPORT
TEST WELL 7.
7/11/79
10
STATE
END OF DITCH.
7/11/79
10
STATE
OVERFLOW DITCH.
7/11/79
100
STATE
SEDIMENT - 40 YARDS FROM CONCENTRATOR POND IN
OVERFLOW DITCH.
-------
4/4
DO
I
COMPOUND ETHYL PARATHION
DATE
7/IS-19/79
8/1/79
8/1/79
8/3/79
8/3/79
CONCENTRATION
't. 6
1.3
3.6
1000
300
TODD REPORT
TODD REPORT
TODD REPORT
STATE
STATE
SOURCE
LOCATION
TEST WELL 7.
TEST WELL 3.
TEST WELL 7.
SEDIMENT-DITCH ADJACENT TO CONCENTRATOR POND.
SEDIMENT-DITCH 100' SOUTH OF CONCENTRATOR POND.
-------
dy
P
.c»»c: en or.
j.PMrovto ov.
•r _Ti"5.: K>.
A-/T/? OV r>J fZ-Kt i - i lj-\' L- /> q. f> t~iu ) q /_/
B-47
sne'A' 5\TP/c/
[ ' : ]
L 3"?f'T)
30* FROM WtST FEMCE
A-1 2FT 5=L0VJ ^rACC
A-2 lOPT
A-3 2t>rr
A"4- oOFT
^'~rrL vr ' ('v/ATG^ (? 'O f7)
V.'£S7 SiCE.CiljnCRCr fc:jd
C-l e FT o0^r;-ci
C-Z IOPT
C-3 20TT
C-4 2"3 F"7
C-5 3ori
S]"TE sfi' (fv.'A TG G P T)
4oF7 FRCM 20DT^ RlxJCS ¦
E>-1 2FT EtLOW SORFACC
B-i lOPT
5-3 ?o FT
si~£ xn
MGR.TH V/£3T COPJJCR.
D -1 S'JRtacE
O-Z 1 FT
SIT-
SOUTH CAST CCPvjE.
E-l SURFACC
E-a in*
i
snr vc
CE»3TcR. £A57 01
r--i p. face.
^ \pt
__S\Tr.\)^
CcLll-''v, CAM 51 Cd
J-i j-}
J • i i r r j - «v
an
o f T
V-.'
i:c\ir! v/^7 c:r,..C3
G-l
:ac;
I -7
S1T1 N V-)'
.;:^T s'.oi.ccotc? c;
H-l
»i- 2
H- 3
n....
5'jrr.\cG
l n
c FT
-------
COMPOUND
DM E
i/2/,/79
1/24/79
1/24/79
3/13/79
3/13/79
CONCENTRATION
27 ::
19
7.9
3.0
1.7
CO
I
HEPTACHLOR »
SOURCE
LOCATION
OXY
SOIL CORE - 2' DEEP, 50' FROM WEST PROPERTY FENCE,
SOUTH OF CENTER.
SAME - 10' DEEP.
SAME - 30' DEEP.
SOIL CORE - 10' DEEP, NEAR WASTEWATER DITCH
200' SOUTH OF ROAD.
OXY
SAME - 20' DEEP.
-------
COMPOUND
MALATHION
DME
Nol a positive
ldentiflcat:on.
Mot: a posita je
iden tificaC3 on.
Not a positive
ldcnc1fica Lion.
Kot a positive
ident 1 £ ica c: tin .
2/27/79
3/8/79
3/13/79
3/13/79
3/14/79
3/14/79
3/13/79
3/15/79
3/13/79
COi !CEN TRAT I ON
11.8
1.6 "
71
4.9
10
10
5000 ::
5000
10 PPM
SOURCE
OXY
OXY
OXY
OXY
TODD REPORT
OXY
TODD REPORT
OXY
OXY
LOCAT1011
WASTEWATER POND.
LOF 10 A.
SOIL CORE - 5' DEEP, NEAR WASTEWATER DISCHARGE
DITCH AND ROADWAY.
SAME - 10' DEEP.
POND 810.
WASTEWATER POND.
SEDIMENT-COOLING POND DITCH.
SEDIMENT-WASTEWATER DISCHARGE DITCH.
TOXIC WASTEWATER TANK.
CO
I
¦fc
Io
-------
OT
CONFOUND METHOXYCHLOR °
DXTE
CONCENTRATION
SOURCE
LOCATION
3/1^/79
80 PPM ::
TODD REPORT
SEDIMENT- POND iilO.
3/1^/79
80 PPM
OXY
SEDIMENT-WASTEWATER POND.
f
3/15/79
35 PPM
TODD REPORT
SEDIMENT-COOLING POND DITCH.
3/15/79
35 PPM
OXY
SEDIMENT-WASTEWATER DISCHARGE DITCH.
3/15/79
40 PPM
OXY
SEDIMENT-DISCHARGE DITCH.
3/22/79
80 PPM
OXY
SLUDGE-WASTE POND BOTTOM, 4-6" BELOW BOTTOM.
7/11/79
1
STATE
OVERFLOW DITCH.
7/11/79
100
STATE
SEDIMENT - 40 YARDS FROM CONCENTRATOR POND.
-------
COMPOUND
DATE
\ot a pnbUi'/e identifi-
cation .
1/19/76
1 / 2 0 / 7 (¦>
1/70/76
2/2/76
3/^/76
4/22/77
2/27/79
2/28/79
CONCENTRATION
10 PPM
10 PnM
30 PPM
3500
2000
2535
2000 ::
0.8-
METHYL PARATHION
SOURCE
OXY
OXY
OXY
OXY
OXY
OXY
STATE
OXY
LOCATION
WASTE POND-CENTER WEST SIDE.
WASTE POND-CENTER WEST SIDE.
BONEYARD POOL.
WASTE POND.
WASTE POND.
AG CHEM DITCH.
SEDIMENT-CONCENTRATOR POND OVERFLOW DITCH.
MENDES DOMESTIC WELL.
-------
COMPOUND PCNB
DATE
CONCENTRATION
SOURCE
5/17-18/79
6.3 ::
TODD REPORT
CD
I
en
ro
LOCATION
TEST WELL 7.
-------
COMPOUND TETRACHLOROETHYLENE
DYiE
COi !C El IT RATI ON
SOURCE
LOCA1 I or^j
9/25/79
1.5 "
STATE
LOF 10 13.
-------
CO
I
------- |